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HomeMy WebLinkAboutDSHW-2008-004542 - 0901a06880156c08PUBLIC PARTICIPATION DOCUMENT For the ATK Launch Systems Inc. - Promontory SEP 3 0 UTAH DIVISION 0^ „,c Part B Hazardous Waste Storage Permit SOLID & HAZARDOUS ^ASl UTD009081357 2W9' P^'^' September 30, 2008 Prepared by: UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF SOLID AND HAZARDOUS WASTE Hazardous Waste Facilities Section TABLE OF CONTENTS Introduction Fact Sheet Public Notice Hearing Statement Public Comments Response to Comments Construction of Module V Table Introduction In accordance with R315-4-10 ofthe Utah Administrative Code (UAC) the Executive Secretary ofthe Utah Solid and Hazardous Waste Control Board (the Board) has prepared this Public Participation Document which is part ofthe Administrative Record for the Hazardous Waste Storage Pennit issued to ATK Launch Systems Incorporated for the Promontory Facility. Included in this document is a copy ofthe Fact Sheet for the draft Permit, the public notice announcing the public comment period and the public hearing, the hearing statement, a copy of the comments received during the public comment period and the response to comments. The Administrative Record for this Permit also includes the Permit Application, draft Pennit and all other supporting documents referenced in the response to comments. The additional documents can be found in the Division of Solid and Hazardous Waste (the Division) public file or referenced location. The Executive Secretary ofthe Board conducted a 45-day public comment period and hearing. The comment period began on August 1, 2008 when a legal notice was published in the Salt Lake Tribune, Deseret Moming News and Ogden Standard Examiner, and ended on September 15, 2008. In conjunction with the notice that started the public comment period the Executive Secretary used the notice to announce that a public hearing would be held at the Brigham City Public Library on the evening of September 9, 2008. Utah Department of Environmental Quality Division of Solid and Hazardous Waste Fact Sheet July 2008 Draft Hazardous Waste Storage Permit for the ATK Launch Systems - Promontory (ATK) Facility WHERE IS THE ATK FACILITY? The ATK - Promontory facility is located in Box Elder County, approximately 30 miles northwest of Brigham City, Utah. The 20,000 acre plant site is situated in Blue Creek Valley, north ofthe Great Salt Lake, along State Highway 83. WHAT ACTIVITIES OCCUR AT THE ATK FACILITY? Since operations began in 1956, ATK and its predecessors have been primarily involved in the production and testing of rocket motor propellants. Currently, ATK's primary activities consist of motor production for the Space Shuttle, development work for the next generation of space shuttles including the Crew Launch Vehicle and Heavy Launch Vehicle, restoration of Minuteman ICBMs, and the production and testing of various types of military flares. WHAT IS THE PURPOSE OF THE ATK HAZARDOUS WASTE STORAGE PERMIT? ATK generates a variety of chemical and reactive hazardous wastes and conducts hazardous waste management activities at the site that are regulated by R315 ofthe Utah Administrative Code (UAC). The site was formeriy owned and operated by the Thiokol Corporation. A Hazardous Waste Storage Permit was originally issued to the Thiokol Corporation by the Executive Secretary ofthe Utah Solid and Hazardous Waste Control Board (Executive Secretary) on September 15, 1992. The Executive Secretary is proposing to reissue the Hazardous Waste Storage Pennit (the Permit) to ATK. The Pennit will reauthorize the operation of six hazardous waste storage units in accordance with the UAC. The six storage units that will be regulated by the permit are: M-186, E-501, M-705S, M-136, M-47 and M-603. WHERE CAN I REVIEW THE DRAFT PERMIT? A copy ofthe draft Permit is available for review by the public during normal business hours at the Brigham City Library, 26 East Forest Street, Brigham City, Utah. A copy ofthe draft Permit and complete administrative record are available for review by the public at the Division of Solid and Hazardous Waste (the Division) office on the 4th floor ofthe Martha Hughes Cannon Health Building, 288 North 1460 West, Salt Lake City, Monday through Thursday between the hours of 7:00 am and 6:00 pm or other hours with prior arrangement. The public may also review this fact sheet and an unofficial copy ofthe draft Permit on-line at the Division's web site: (http://www.hazarciouswaste.utah.gov/) To access the on-line infonnation, go to the Division's web site identified above, select the "Public Viewing Area" and click on the "Public Hearings & Comment Periods" menu item. Then select the ATK - Promontory draft Permit to access all on-line information. HOW MAY I COMMENT ON THE DRAFT PERMIT? A 45-day public comment period will begin on August 1, 2008 and will end on September 15, 2008. A public hearing will be held on September 9, 2008 from 6:00 to 7:00 pm at the Brigham City Public Library, 26 East Forest Street, Brigham City, Utah. Public comments will be collected at the hearing. Written comments may also be submitted to: Mr. Dennis R. Downs, Executive Secretary Utah Solid and Hazardous Waste Control Board P.O. Box 144880 Salt Lake City, Utah 84114-4880 Comments may be sent via electronic mail to swpubiic(g),utah.eov. and should be identified in the subject line by putting the following information "Comments on the ATK - Promontory Draft Hazardous Waste Storage Permit." All documents included in the comments should be submitted as ASCII (text) files or in PDF fonnat. All comments must be received no later than 6:00 p.m. on September 15, 2008. Public comments will be considered in the Executive Secretary's final decision on the draft permit. For additional information regarding the draft Permit, please contact: JeffVandel Environmental Scientist Division of Solid and Hazardous Waste DEQ/DSHW P.O. Box 144880 288 North 1460 West SaltLakeCity,UT 84114-4880 Telephone: (801)538-6170 Email: ivandel(a)utah.gov Additional on-line information is available on the Division's web site: hHp://vvv\'w.hazardouswaste. utah.gov/ In compliance with the Americans with Disabilities Act, individuals with special needs (including auxiliary communicative aids and services) should contact: Brooke Baker DEQ Office of Human Resources Telephone: (801) 536-4413 TDD#: (801)536-4414 Public Notice The Executive Secretary ofthe Utah Solid and Hazardous Waste Control Board (the Board) is proposing to reissue a Hazardous Waste Storage Permit (the Permit) to the ATK Launch Systems - Promontory (ATK-Promontory) facility located approximately 30 miles northwest of Brigham City, Utah. The site, formerly owned and operated by the Thiokol Corporation, has been in operation since 1956. Since operations began, ATK and its predecessors have been primarily involved in the production and testing of rocket motor propellants. The original Pennit was issued by the Executive Secretary ofthe Utah Solid and Hazardous Waste Control Board to the Thiokol Corporation on September 15, 1992. The reissued Permit will continue the authorization for the storage of hazardous waste at six hazardous waste storage units in accordance with R315 ofthe Utah Administrative Code. The six storage units that will be regulated by this Permit are: M-186, E-501, M-705S, M-136, M-47 and M-603. A copy ofthe draft Permit is available for review by the public during normal business hours at the Brigham City Library, 26 East Forest Street, Brigham City, Utah. A copy ofthe draft Permit and complete administrative record are available for review by the public at the Division of Solid and Hazardous Waste (the Division) office located in the Martha Hughes Cannon Health Building, 288 North 1460 West, Salt Lake City, Utah, Monday through Thursday between the hours of 7:00 am and 6:00 pm or other hours with prior arrangement. The public may also review the fact sheet for this Permit and an unofficial copy ofthe draft Permit on-line at the Division's web site: {http://www. hazardouswaste. utah.gov/Public/PuhlicHearingsandCommentPeriods. htm) A 45-day public comment period will begin on August 1, 2008 when this notice is published in the Salt Lake Tribune, Deseret News and the Ogden Standard Examiner and will expire at 6:00 pm on September 15, 2008. A public hearing will be held on September 9, 2008 from 6:00 to 7:00 pm at the Brigham City Library, 26 East Forest Street, Brigham City, Utah. Public comment will be collected during the hearing. Written comments should be addressed to Dennis R. Downs, Executive Secretary, Utah Solid and Hazardous Waste Control Board, P.O. Box 144880, Sah Lake City, Utah 84114-4880, and submitted before the comment period closes on September 15, 2008. All public comments will be considered in the Executive Secretary's final decision on this draft Permit. Comments may be sent via electronic mail to swpublic(a),utah.gov. and should be identified in the subject line by putting the following information "Comments on the ATK - Promontory Draft Hazardous Waste Storage Permit." All documents included in the comments should be submitted as ASCII (text) files or in PDF format. For additional informafion regarding this draft Permit, contact JeffVandel at (801)538-6170. In compliance with the Americans with Disabilities Act, individuals with special needs (including auxiliary communicative aids and services) should contact Brooke Baker at the DEQ Office of Human Resources at 801-536-4413 (TDD 801-536-4414). STATEMENT OF HEARING OFFICER FOR PUBLIC HEARING ATK Launch Systems - Promontory Public Hearing to Accept Comments on the Draft Storage Permit for the Promontory Facility September 9, 2008 Brigham City Library 6:00 P.M. Hearing Officer: JeffVandel Ladies and Gentlemen, I call this hearing to order. This is a hearing to receive public comment on the draft Storage Permit that has been prepared for the ATK Promontory facility. The Executive Secretary ofthe Utah Solid and Hazardous Waste Control Board is proposing to reissue the Permit. The reissued Permit will continue the authorization for the storage of hazardous waste at six hazardous waste storage units in accordance with R315 ofthe Utah Administrative Code. The six storage units that will be regulated by this Permit are: M-186, E-501, M-705S, M-136, M-47 and M-603. The reissued Permit will also continue the authorization of treatment of hazardous waste which consists ofthe disassembly of waste rocket motors at Building M-603 and waste hydrazine dilufion at Building T-29B. This hearing is being held under the authority of Title 19, Chapter 6, Section 104 ofthe Utah Code Annotated, 1953 as amended. My name is JeffVandel. I represent the Utah Solid and Hazardous Waste Control Board and have been appointed by the Executive Secretary ofthe Board as the hearing officer. The public nofice for this request was published in the August 1, 2008 edition ofthe Salt Lake Tribune. Deseret Moming News, and the Ogden Standard Examiner. The public comment period for this issue began on August 1, 2008 and will conclude on September 15, 2008. Copies ofthe Draft Storage Permit have been and are available for examination and public review at the Brigham City Public Library, 26 East Forest Street, and at the office ofthe Division of Solid and Hazardous Waste, 288 North 1460 West, Salt Lake City, Utah. Opportunity will be provided to any person desiring to participate in this hearing. Written comments conceming this Draft Storage Permit shall be received and accepted for the record, no later than 6:00 p.m., on September 15, 2008. If anyone desires to make an oral comment at this hearing, please indicate so on the attendance list. These proceedings are being recorded and a transcript of these proceedings will be available for public inspecfion at the Division of Solid and Hazardous Waste, 4th Floor ofthe Martha Hughes Cannon Health Building. This is an administrative hearing and as such there will be no cross examination of any participants. Those who have questions or comments to make should state their names and direct their questions or comments to me. 1 ask that you confine your remarks to this draft Permit and related issues. Comments that are not pertinent may be mled out of order. It is the policy ofthe Department of Environmental Quality that this hearing remain in session for at least one hour. If, during that hour, there comes a time when there is no one desiring to make a comment or ask a question, the hearing may be recessed. At the end ofthe hour or when there is an indication that someone would like to make a comment or ask a question, the hearing will be reconvened and the record reopened. This hearing will then be concluded after all those who desire to make a comment have done so. RECESS: 6: pm COMMENTS RECONVENE: 6: pm If there are no additional comments, this hearing will be considered closed. Any additional written comments will be accepted until 6:00 p.m., on September 15, 2008. Written comments may be submitted in person to the Division of Solid and Hazardous Waste, Fourth Floor ofthe Cannon Health Building or they may be mailed to Dennis R. Downs, Executive Secretary, Utah Solid and Hazardous Waste Control Board, P.O. Box 144880, Sah Lake City, Utah 84114-4880. Adjoumed at 7: pm, September 9, 2008 ATK LAUNCH SYSTEMS INC. - PROMONTORY DRAFT STORAGE PERMIT RESPONSE TO COMMENTS The Division of Solid and Hazardous Waste (the Division) conducted a 45-day public comment period from August I, 2008 until September 15, 2008 to allow the public the opportunity to comment on the Draft Storage Permit. In conjunction with this public comment period, the Division held a public hearing at the Brigham City Public Library on September 9, 2008. The Division did not receive any comments from the public before the close ofthe comment period or during the public hearing. The permittee did submit one comment on the Draft Storage Permit. The Division's response to this comment is shown below. In addition, upon further review ofthe draft document, the Division made a small number of changes to it. The Division considers these changes to be non-substantive, but necessary in order to improve the accuracy and clarity of the Permit. A second public comment period will not be held. RESPONSE TO COMMENT SUBMITTED BY PERMITTEE The following comment is dated September 15, 2008 and was received by the Division on September 17, 2008. Module I - Standard Permit Conditions The state has included language regarding perchlorate and perchlorate salts within the text ofthe permit, specifically, but not inclusively, in paragraphs I.K.I. and I.T.3. Perchlorate and perchlorate salts are neither a hazardous waste nor a hazardous constituent. A review ofthe public record pertaining to the facility failed to show any documented decision by the Executive Secretary or supporting technical or risk-based information or determinations justifying the inclusion of perchlorate and perchlorate salts in this permit. Therefore, in the absence of a technically justified decision and to be consistent with EPA guidance on the topic (OSWER No. 9488.1989(01) (February 27, 1989) this language and all references to perchlorate and perchlorate salts should be removed. Response to Comment: The inclusion of perchlorate and perchlorate salts in this permit is within the rights ofthe Execufive Secretary's authority under R315-3-3.3(b)(2) ofthe Utah Administrative Code (UAC). This provision ofthe UAC allows the Executive Secretary to incorporate conditions into the permit that are necessary to protect human health and the environment. The Executive Secretary considered a number of issues before deciding to develop and incorporate permit conditions that are specific to perchlorate and perchlorate salts. The inclusion ofthe condifions that specifically address perchlorate and perchlorate salts in this Permit is based on a number of issues that are present at the Promontory facility. The following conditions exist at the Promontory facility: 1) Ammonium perchlorate is a primary ingredient in the formulafion of solid propellants manufactured by ATK (the Permittee) at the Promontory facility; 2) Past disposal pracfices have resulted in the release of perchlorate to the environment. This release is documented by the Permittee's groundwater monitoring program. Perchlorate is one ofthe constituents that comprise the Groundwater Protection Standard in ATK's Post-Closure Permit. 3) The operations at the Permittee's facility periodically release perchlorate and perchlorate salts to the environment; and 4) The hazardous waste management rules do not adequately address the risks to human health or the environment associated with perchlorate and perchlorate salts. While writing this Permit the Executive Secretary developed two permit conditions specific to perchlorate and perchlorate salts to protect human health and the environment, and minimize the further release of perchlorate to the environment. These conditions are I.K.I., and I.T.3. Condifion l.K.l. requires the Permittee to take all reasonable steps to minimize releases of solid and hazardous wastes, hazardous waste constituents, and perchlorate salts to the environment and to carry out such measures as are reasonable to prevent significant adverse impacts on human health or the environment. All hazardous waste permits issued by the Executive Secretary include a condition similar to this one. Perchlorate salts were included to minimize the potential introduction of additional perchlorate to the environment. The Executive Secretary believes that this is an appropriate permit condition given the risks associated with perchlorate and the operational history ofthe Promontory facility. In Condition I.T.3., the Executive Secretary defines when the Permittee needs to report a spill or release that contains perchlorate. This condition was developed to complement Condition l.K.l. The reporting standard is based on the toxicity of perchlorate and the fact that perchlorate is not an acute toxin. The commenter states that perchlorate and perchlorate salts are neither a hazardous waste nor a hazardous constituent. The cunent rules do not define perchlorate or perchlorate salts as a hazardous waste constituent. However, while it is tme that perchlorate and perchlorate salts are not a listed hazardous waste, they can be a characteristic hazardous waste for ignitability (DOOl) and reactivity (D003). It should also be noted that the conditions in this permit, which address perchlorate and/or perchlorate salts, have not defined perchlorate or perchlorate salts as a listed hazardous waste. The commenter stated that a review ofthe public record pertaining to the facility failed to show any documented decision by the Executive Secretary or supporting technical or risk-based information or determinafions justifying the inclusion of perchlorate and perchlorate salts in this permit. While there is no so-called "specific decision document" on perchlorate in the facility files, there are a number of documents that identify the Executive Secretary's concems with respect to the perchlorate contamination and the desire to rriinimize the possibility of creating additional perchlorate source areas. The facility file for the Promontory facility includes the following informafion: groundwater monitoring data; groundwater modeling reports; risk assessment reports; corrective action reports and pilot test reports. The facility files document that the Permittee has reported releases of perchlorate at SWMUs at the Promontory facility. Perchlorate has been identified as a reactive waste that is present as a contaminant at the facility in the RFI Phase 1 Workplan (April, 1993) and the RFI Phase I Report (August, 2000). In addition, ATK is cunently conducting a pilot test at the Promontory facility to evaluate a method for treating soil contaminated with perchlorate. The groundwater monitoring program has been assessing the magnitude and extent ofthe groundwater contamination at the Promontory facility for many years. ATK has been analyzing groundwater samples for perchlorate since 1987. -In addition, groundwater flow and contaminant transport models have been developed for the Promontory facility which are cunently being used to predict the migration of perchlorate contamination in the groundwater. The Executive Secretary has also developed a fact sheet for Perchlorate. This fact sheet was inidally authored in 1999 and updated in 2005. The fact sheet describes the perchlorate ion, the environmental fate and transport concems, the known human health effects, the perchlorate contaminated sites in the State of Utah, the regulatory status and remediafion guidance. The fact sheet can be found on the Department website and hard copies can be obtained at the offices ofthe Division of Solid and Hazardous Waste. The spill reporting limits for a perchlorate release identified in Condition l.T.3. were developed using the reference dose for perchlorate that is published in the US EPA IRIS database, and the knowledge that perchlorate is a non-acute toxin. In accordance with R315-9 ofthe UAC,when a non-acute material is released to the environment, the volume released must be greater that 100 kilograms to be a reportable quantity. Condition l.T.3 also requires that the perchlorate concentration ofthe spilled material must be greater than 26 ug/l. This concentration was established using the aforementioned reference dose for perchlorate which is 0.0007 mg/kg-day, USEPA default exposure parameters and human health risk exposure calculations. The exposure parameters used in this calculation were: Ingestion Rate of 2 liters/day; Exposure Frequency of 350 days/year; Exposure Duration of 30 yrs; Body Weight 70 kg; and an Averaging time of 10950 days. It should be noted that the 26 ug/l concentration identified above is protecfive for adults, children and a developing fetus. The Executive Secretary has considered this comment and determined that all requirements and references specific to perchlorate and perchlorate salts should be maintained in Permit Conditions l.K. 1 and l.T.3. CHANGES MADE TO THE DRAFT STORAGE PERMIT BY THE EXECUTIVE SECRETARY The language added to Permit conditions is underlined (except for section headings). The language removed from the Pennit is crossed out. Explanations for the changes are shown in italics. Module II - General Facility Conditions 1. II.J. 1. The Permittee shall follow the Preparedness and Prevention Plan, Attachment 40 8. 2. 1I.J.2. At a minimum, the Permittee shall equip and maintain in good operating condition at the facility the equipment set forth in Attachment 40 8, as required by UAC R315-8-3.3. Permit conditions II.J. I. and II.J. 2. had the wrong Attachment number for the Preparedness and Prevention Plan. It -was changed from " 10" to "8". 3. ll.J.7. The Permittee shall attempt to make arrangements (Coordination Agreements) with State and local authorities as required by UAC R315-8- 3.7. Copies ofthe Coordination Agreements shall be included in Attachnient 11 kept in the Operating Record. The attempts to make such agreements, any refusals and all final agreements shall be documented in the Operating Record. 77?^ Division determined that arrangements with local authorities should be kept in the Operating Record, not in the Permit itself. This seems to be more consistent with R315-8-3.7(h) as well. Module III - Storage in Containers To make the Permit requirements that apply to the treatment of hydrazine at Building T-29B easier to understand, the Division took components of Module III and Attachment 10 and created Module V- Treatment of Waste Hydrazine. The Division considers this change to non-substantive because the language included in Module V already appeared in the draft Permit that was available for public comment, in Module III and Attachment 10. A document showing where the Module V permit language was taken from is included at the end ofthis record. 4. III.B.4. Tho Permittee may treat hydrazine, EPA hazardous waste code U133, by dilufion, at Building T-29B, for the solo purpose of safely shipping the resultant waste to an off site disposal or treatment facility in accordance with Attachment 10. This condition regarding the treatment of hydrazine was removed from Module III and is now Condition V.A.I. 5. III.E.5. The Permittee shall store hazardous wastes in containers at M-705S, M-47, M-603 and M-136 so that the container or waste rocket motor ^ney may be readily inspected and hazardous waste labels are visible. The modification in language to this condition makes it more consistent with Conditions III B.I., III B. 2., III B. 3., and III B. 5. 6. 1I1.F.4. The bum trays at M-136 are only permitted for the storage of solid reactive wastes in containers received from off-site for no more than 14 days. However since some ofthe containers contain small amounts of desensitizing fluid (e.g. diesel, shingle oil, etc.), the containment requirements, as specified in Attachment 9, apply to the storage of wastes in the bum trays. Inspecfionof the bum trays shall be conducted in accordance with Attachment 2. The language was inserted to clarify the condition and make it consistent with Condition III B.5. 1. lll.l. 1. The Permittee shall inspect the hazardous waste storage and treatment facilities identified in Condition IIl.A.B. ofthis Permit as specified in the Inspection Schedules contained in Attachment 2. The purpose of this inspection shall be to detect leaking containers, standing liquids, deterioration of containers, and to detect deterioration of, or liquids in, the secondary containment system caused by corrosion and other factors as specified in R315-8-9.5. The changes above were made to make this condition more accurate. Module V - Treatment of Waste Hydrazine As stated above. Module Vwas added to the Permit in order to make the Permit requirements that apply to the treatment of hydrazine at Building T-29B easier to understand. The Division took components of Module III and Attachment 10 and created Module V- Treatment of Waste Hydrazine. The conditions of Module V are shown below. 8. V.A. APPLICABILITY V.A.I. The Permittee mav treat hydrazine, EPA hazardous waste code U133. bv dilution, at Building T-29B, for the sole purpose of safelv shipping the resultant waste to an off-site disposal facilitv in accordance with this Module and Attachment 10. V.A.2. The treatment process shall be conducted in a manner that will ensure protection of human health and the environment. V.A.3. After the waste hydrazine has been transfened to the treatment container, and the treatment process has been completed, the Permittee shall ship the diluted hydrazine directly to an approved hazardous waste management facilitv for disposal or transfer it to the M-186 Hazardous Waste Storage Facilitv. V.A.4. The Permittee shall comply with the requirements specified in the facility Contingency Plan (Attachment 4). when there has been a release at Building T-29B that threatens human health or the environment. V.A.5. The Permittee shall take precautions to prevent accidental ignition or reaction ofthe waste hydrazine and follow the procedures specified in UAC R315-8-2.8. V.A.6. The Permittee shall inspect Building T-29B in accordance with the inspection schedule contained in Attachment 2. V.B. RECORD KEEPING AND REPORTING V.B.I. The Permittee shall record in the operating record the following: V.B.I.a. The date that waste hydrazine is received at T-29B; V.B.l.b. The quantity of waste hydrazine received; V.B.I .c. The date the waste hydrazine is treated by the dilution process; V.B.I .d. The quantity of diluted hydrazine after the dilufion process is complete; and V.B. 1 .e. The date the diluted hydrazine is shipped off-site or to the M-l 86 storage facility. VC. CLOSURE V.C. 1. The Permittee shall close Building T-29B in accordance with R315-8-7, R315-8-9.9, Permit Condifion ll.N. and the designated Closure Plan in Attachment 5 ofthis Permit. Attachment 2 - Inspection Schedules and Procedures 9. II.A. Purpose and Scope The inspection schedule used by ATK for the hazardous waste management areas has been designed to meet the requirements of R315-8.2.6. The design ofthe schedule promotes the detection of malfunctions, deterioration, discharges, and other situations which may be causing or leading to a release of hazardous waste constituents into the environment or pose a threat to human health. Eight areas are designated for inspection: the container storage area at E-501, M-705S, M-186, the buming grounds at M-136 (including the LTTAs, bum trays and Bum Station 14), M-225, T-29B hydrazine dilution and the solid propellant/motor storage buildings, M-47 and M-603. The "B " was added to building T-29B, as shown above. It was inadvertently left off before. Attachment 5 - Closure Plan 10. 1.3 Maximum Waste Inventory and Disposal Method [40 CFR 264.112(b)(3) and UAC R315-8-7] The maximum inventory of hazardous waste onsite at any one time during the life ofthe facilities is based on permit limitations for inert facilities, and Quantity/Distance(QD) limitations for live materials, based on Department of Defense Explosive Safety Standard 4145.26M or a lesser designated amount. If storage capacities change, the Permit will be modified. These quantity limitations are listed below: M-186 (inert) 400 ea. 55 gallon drum equivalent M-705S (inert) 32 ea. 55 gallon dmm equivalent E-501 (inert) — 160 ea. 55 gallon dmm equivalent M-136 (live) 1006,000 lbs 1.3 / 20,000 lbs 1.1 M-225 (live) — 50,000 lbs 1.3 / 1,500 lbs 1.1 T-29B (inert) ~ — 1 ea. 55 gallon drum (pure) equivalent M-47 (live) —- —- 840,000 lbs 1.3 / 21,000 lbs 1.1 M-603 (live) 240,000 lbs 1.3 / 65,000 lbs 1.1 The correct number for the storage capacity at M-136 is 106,000 lbs, not 100,000 lbs as appeared in the draft Permit. 11. 1.4 Schedule for Closure [40 CFR 264.112(b)(6) and UAC R315-8-7] Tables 1 - 3 ofthis plan provide an estimated closure schedule for all activities associated with implementation ofthis closure plan. If the final ZOEC sampling determines sample resuhs indicate the need for additional investigafion or a CMS, this plan the schedule will be modified to accommodate the changes. Final closure will be certified by an independent professional engineer licensed in Utah. The change above was made to clarify that the sampling that will be conducted at closure is not the same as ZOEC sampling. ZOEC sampling is normally conducted during the operation of the facility. "The schedule " was 'inserted also to clarify the text. 12. 1.5.1 Soil and Ground Water Sampling Groundwater sampling is not covered under this plan, but a groundwater monitoring program is currently in place as discussed above. Soil sampling should not be required for any ofthe permitted facilities, except for the two bum ground areas (M-136, M225). In preparation for closure, an additional round of ZOEC sampling will be perfomied to confirm the results of previous sampling performed throughout tho life of these two facilities soil samples will be collected at the bum ground areas to supplement the ZOEC soil sample data that has been collected at these HWMUs. Same comment as above. Attachment 7 - Security 13. 07.01.4 Signs All hazardous waste management areas (i.e., E-501, M-136, M-186, M-225, M-705S, M-47, M-603 and T29B) have waming signs placed at the access approaches. All signs are legible from a distance of at least 25 feet. All signs have a legend which reads "Danger - Unauthorized Personnel Keep Out." The legend is in English and Spanish except at M-705S, M-47 and M-603 which is only in English. The "S" was added to building M-705S, as shown above. It was inadvertently left off before. Attachment 8 - Preparedness and Prevention 14. 8-1-4 Prevention of Water Supply Contamination The materials in the trays at the buming grounds are normally destroyed on a biweekly basis, except those materials too sensitive to store which are bumed the same day. The bum trays are inspected weekly and prior to loading to look for cracks or holes. Minimizing free liquids and controlHng run-on and mn-off prevent water supply contamination. It is not anticipated that groundwater or surface water will become contaminated from the storage operations. The hazardous wastes are typically open-burned on a biweekly basis - not weekly. This correction was needed as shown above. 15. 8-1-7 Emergency Equipment ATK maintains a spill response vehicle trailer which is used to respond to spills that are medium to large. The vehicle trailer contains safety and spill response equipment. This vehicle trailer is maintained by the fire department and is inspected weekly or after use to ensure that an adequate supply of material is on hand. For accuracy, "vehicle" was replaced with "trailer. " 16. 8-1-10 Storage and Containment System If a leaking or deteriorating dmm is identified during the inspecfion, the contents or the entire container must be immediately transferred into a new container. The new container must be numbered and labeled with exactly the same number and label as the old container. The date and time of any transfer action must be noted in the inspection log and the Environmental Waste Disposal technical staff must be notified. The transfer ofthe leaking or deteriorating drum can be handled in two ways: the contents ofthe container can be transferred by pump to a new dmm, or the dmm can be placed in an 85-gallon over-pack dmm with the space between the two dmms filled with an absorbent to control any possible leaks. ATK has changed how this scenario is managed. The language that was removed was from the original permit; it should have been removed previously. 17. 8-1-11 Buming Ground Area Buming of explosives and reactive wastes occurs normally on a biweekly basis, but can occur more often if conditions necessitate the increased frequency. Inspections ofthe area, equipment, and bum trays, are conducted weekly or as specified in Attachment 2. Items inspected under this category are subject to general wear or weathering. Reactive hazardous wastes are typically open- burned biweekly, not weekly. The correction shown above was needed for this purpose. 18. 8-1-15 Inspecfion Log All inspections are recorded. These forms are put into one of three inspection logs. Each log contains the most recent three years of records and is available for review. Envirormiental Monitoring Services keeps the inspection logs of the results of all inspections on the security equipment, emergency equipment, general area, safety equipment, storage and containment system, buming grounds, and general facility categories. The Fire department keeps a log ofthe Fire department categories and Maintenance Control keeps a log for the heavy equipment category. The environmental group is now referred to as "Environmental Services, " not "Environmental Monitoring. " The language that was removed was from the original permit; it should have been removed previously. 19. 8-4-2 Precautions for Open Buming of Explosives and Propellants Safety procedures for handling energetic and sensitive materials are found in ATK's Hazardous Operafions Standard Manual (AHOPS) and the Reactive Waste Disposal Instmcfions(RWDI) which is available at the facility for inspection. The change above was made to make this section ofthe Preparedness and Prevention Plan more accurate. 20. 10-3-1 Prevention of Releases to Ground Water or Subsurface Environment Several parameters have been considered in determining the prevention of a release to ground water or subsurface environments. It is important to note that there will only be a limited amount of pure hydrazine, generally no more than 55 gallons, to dilute at any one fime and that this process is all done within a containment system as shown. The containment system is shown in the facility drawing contained in Attachment 6 (Figure H-l). Because ofthe secondary containment, there should be minimal potential for deposition or migration of waste constituents into the subsurface or groundwater. The changes above were made to clarify the text. 21. 10-3-2 Prevention of Releases to Surface Water. Wefiands, or Soil Surface The dilution area has secondary containment to ensure collection of any spill. A 7,500-gallon, emergency-use-only sump has been designed to contain any spill. A detailed drawing ofthis concrete sump can be found in Attachment 6. It The sump is only used if a spill occurs; it is not used on a routine basis. The sump is designed to collect any large spill and has more than sufficient capacity to hold any spill during the dilution process. The change above was made to clarify redundant text. 22. 10-5 Record Keeping and Reporting ATK will record in the operafing record the following: 1. The date that waste hydrazine is received at T-29B; 2. The quantity of waste hydrazine received; 3. The date the shipment of waste hydrazine is treated by the dilution process; The change above was made to clarify confusing text. ATK Launch Systems - Promontory Draft Storage Permit- Construction of Module V From Draft Permit out for public comment: Proposed Module V Condition: Module 111 III.B.4. The Permittee may treat hydrazine, EPA hazardous waste code U133, by dilution, at Building T-29B, for the sole purpose of safely shipping the resultant waste to an off-site disposal or treatment facility in accordance with Attachment 10. Attachment 10-Section 10-4 ATK will conduct the dilution process in a manner that will ensure protection of . human health and the environment. Attachment 10 - Section 10-2, pp 3 After the material transfer has been completed, the material is shipped off plant for disposal or sent to the M-l 86 Hazardous Waste Storage Facility. Attachment 10 - Section 10-4, pp2 ATK will comply with the requirements specified in the facility Contingency Plan (Attachment 4), when there has been a release at Building T-29B that threatens human health or the environment. Module V V.A. 1. The Permittee may treat hydrazine, . EPA hazardous waste co de U13 3, by dilution, at Building T-29B, for the sole purpose of safely shipping the resultant waste to an off-site disposal facility in accordance with this Module and Attachment 10. Module V V.A.2. The treatment process shall be conducted in a manner that will ensure protection of human health and the environment. Module V V.A.3. After the waste hydrazine has been transferred to the treatment container, and the treatment process has been completed, the Permittee shall ship the diluted hydrazine directly to an approved hazardous waste management facility for disposal or transfer it to the M-186 Hazardous Waste Storage Facility. Module V V.A.4. The Permittee shall comply with the requirements specified in the facility Contingency Plan (Attachment 4), when there has been a release at Building T-29B that threatens human health or the environment. Attachment 10 - Secfion 10-4, pp3 ATK will comply with the ignitable and reactive waste regulations as required by UAC R315-8-2.8. Attachment 10 - Section 10-4, pp4 ATK will inspect Building T-29B in accordance with the inspection schedule contained in Attachment 2. Attachment 10 - Secfion 10-5 ATK will record in the operating record the following: 1. The date that waste hydrazine is received at T-29B; 2. The quantity of waste hydrazine received; 3. The date the waste hydrazine is treated by the dilution process; 4. The quantity of diluted hydrazine after the dilution process is complete; and 5. The date the diluted hydrazine is shipped off-site or to the M-186 storage facility. Attachment 10 - Secfion 10-6 ATK will close Building T-29B in accordance with R315-8-7, R315-8-9.9, Permit Condition II.N. and the designated Closure Plan in Attachment 5 ofthis Pemiit. Module V V.A.5. The Permittee shall take precautions to prevent accidental ignition or reacfion ofthe waste hydrazine and follow the procedures specified in UAC R315-8-2.8. Module V V.A.6. The Permittee shall inspect Building T-29B in accordance with the inspection schedule contained in Attachment 2. Module V V.B. 1. The Permittee shall record in the operating record the following: V.B. 1 .a. The date that waste hydrazine is received at T-29B; V.B. 1 .b. The quantity of waste hydrazine received; V.B.I.c. The date the waste hydrazine is treated by the dilution process; V.B.I .d. The quantity of diluted hydrazine after the dilution process is complete; and V.B.I .e. The date the diluted hydrazine is shipped off-site or to the M-186 storage facility. Module V V.C. 1. The Permittee shall close Building T-29B in accordance with R315-8- 7, R315-8-9.9, Pennit Condifion II.N. and the designated Closure Plan in Attachment 5 ofthis Pemiit.