DSHW-2008-004842 - 0901a068801589e1

Hazardous Waste Storage Permit
September 2008
Prepared by:
The Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
Hazardous Waste Facilities Section
STATE OF UTAH
HAZARDOUS WASTE STORAGE PERMIT
September 30, 2008
PERMITTEE:
ATK Launch Systems Inc.
Promontory Facility
Brigham City, Utah
EPA Identification Number UTD009081357
Pursuant to the Utah Solid and Hazardous Waste Act, 19-6-101, et. seq., Utah Code Annotated
1953, as amended, and the regulations promulgated by the Utah Solid and Hazardous Waste
Control Board, codified in the Utah Administrative Code R315, and pursuant to the Solid Waste
Disposal Act, 42 U.S.C. 3251 et. seq., as amended by the Resource Conservation and Recovery
Act of 1976, 42 U.S.C. 6901 et. seq., and the Hazardous and Solid Waste Amendments of 1984
(HSWA), a permit is issued to the ATK Launch Systems Inc. - Promontory facility (herein after
called the "Permittee"). The facility is located in Box Elder County, Utah at 41 degrees, 39
minutes, 33 seconds north latitude and 112 degrees, 26 minutes, 17 seconds west longitude. The
U.S. Environmental Protection Agency (U.S. EPA) has authorized the Executive Secretary ofthe
Utah Solid and Hazardous Waste Control Board to issue such a permit under Section 3006(b) of
the Resource Conservation and Recovery Act (RCRA).
The Permittee shall comply with all the terms and conditions ofthis permit. The permit consists
of Modules I through V and Attachments 1 through 10. The Permittee shall also comply with all
applicable State rules, including R3I5-1 through R315-102. Applicable rules are those which
are in effect on the date of issuance ofthis permit and any self-implementing provisions and
related rules that, according to the requirements of HSWA, are automatically applicable to the .
Permittee's hazardous waste management activities, notwithstanding the conditions ofthis
permit.
This permit is based on the premise that the information submitted in the original permit
application, as modified by subsequent amendments, permit modification requests received
throughout the term ofthe original permit, and the permit renewal application, as modified by
subsequent amendments, is accurate. The Permittee's failure in the application or during the
permit issuance process to disclose fully all relevant facts, or the Permittee's misrepresentation
of any relevant facts at any time, may be cause for the termination or modification ofthis permit,
the initiation of enforcement action, including criminal proceedings, or any combination of these
remedies. The Permittee shall inform the Executive Secretary ofthe Utah Solid and Hazardous
Waste Control Board of any deviation from or changes to the information on which the
application was based which would affect the Permittee's ability to comply with the terms and
conditions of this permit.
HAZARDOUS WASTE STORAGE PERMIT
ATK LAUNCH SYSTEMS INC. - PROMONTORY
EPA ID# UTD009081357
Issued By:
Utah Solid and Hazardous Waste Control Board
September 29,2008
TABLE OF CONTENTS
MODULE I - STANDARD PERMIT CONDITIONS
l.A. EFFECT OF PERMIT
I.B. ENFORCEABILITY
I.C. OTHER AUTHORITY
I.D. PERMIT ACTIONS
I.E. SEVERABILITY
I.F. DUTIES TO COMPLY
I.G. DUTY TO REAPPLY
I.H. PERMIT EXPIRATION
LI. CONTINUATION OF EXPIRING PERMIT
LJ. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE
I.K. DUTY TO MITIGATE
I.L. PROPER OPERATION AND MAINTENANCE
I.M. DUTY TO PROVIDE INFORMATION
I.N. INSPECTION AND ENTRY
I.O. MONITORING AND RECORDS
LP. REPORTING PLANNED CHANGES
LQ. REPORTING ANTICIPATED NONCOMPLIANCE
LR. CERTIFICATION OF CONSTRUCTION OR MODIFICATION
LS. TRANSFER OF PERMIT
LT. TWENTY-FOUR HOUR REPORTING
I.U. MONITORING REPORTS
I.V COMPLIANCE SCHEDULES
LW. MANIFEST DISCREPANCY REPORT
I.X. UNMANIFESTED WASTE REPORT
I.Y. BIENNIAL REPORT
LZ. OTHER NONCOMPLIANCE
LAA. OTHER INFORMATION
I.BB. SIGNATORY REOUIREMENT
LCC. CONFIDENTIAL INFORMATION
LDD. REPORTS. NOTIFICATIONS. AND SUBMISSIONS
LEE. DOCUMENTS TO BE MAINTAINED AT THE FACILITY SITE
I.FF. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
MODULE II - GENERAL FACILITY CONDITIONS
ILA. APPLICABILITY
II.B. DESIGN AND OPERATION OF FACILITY
II.C. REOUIRED NOTICE
II.D. WASTE ANALYSIS PLAN
ILE SECURITY
II.F. GENERAL INSPECTION REOUIREMENTS
II.G. PERSONNEL TRAINING
ILH. GENERAL REOUIREMENTS FOR IGNITABLE. REACTIVE. OR
INCOMPATIBLE WASTE
II.I. LOCATION STANDARDS
II.J. PREPAREDNESS AND PREVENTION
ILK. CONTINGENCY PLAN
ILL. MANIFEST SYSTEM
II.M. RECORDKEEPING AND REPORTING
II.N. CLOSURE/POST-CLOSURE
ILO. COST ESTIMATES FOR HWMU CLOSURE
II.P. FINANCIAL ASSURANCE FOR FACILITY CLOSURE
II.Q. LIABILITY REOUIREMENTS
II.R. INCAPACITY OF OWNER OR OPERATORS. GUARANTORS. OR
FINANCIAL INSTITUTIONS
MODULE III - STORAGE IN CONTAINERS
III.A. APPLICABILITY
III.B. WASTE IDENTIFICATION
IILC. CONDITION OF CONTAINERS
III.D. COMPATIBILITY OF WASTE WITH CONTAINERS
III.E. MANAGEMENT OF CONTAINERS
III.F. CONTAINMENT SYSTEMS
III.G. SPECIAL REOUIREMENTS FOR IGNITABLE OR REACTIVE
WASTE
III.H. SPECIAL REOUIREMENTS FOR INCOMPATIBLE WASTE
IILL INSPECTION SCHEDULES AND PROCEDURES
IILL CLOSURE/POST-CLOSURE
MODULE IV - MISCELLANEOUS UNITS
IV.A. APPLICABILITY
IV.B. ALLOWABLE WASTE STREAM
IV.C. OPERATING REOUIREMENTS
IV.D. INCOMPATIBLE WASTES
IV.E. IGNITABLE OR REACTIVE WASTES
IV.F. INSPECTION REOUIREMENTS
IV.G. RECORD KEEPING AND REPORTING
IV.H. CLOSURE
MODULE V - TREATMENT OF WASTE HYDRAZINE
V.A. APPLICABILITY
V.B. RECORD KEEPING AND REPORTING
V.C. CLOSURE
ATTACHMENTS
Attachment 1 - Waste Analysis Plan
Attachment 2 - Inspection Schedules and Procedures
Attachment 3 - Personnel Training
Attachment 4 - Contingency Plan
Attachment 5 - Closure Plans and Closure Plan Figures
Attachment 6 - Facility Aerial Photographs and Drawings
Attachment 7 - Security Plan
Attachment 8 - Preparedness and Prevention Plan
Attachment 9 - Container Management Procedures
Attachment 10- T-29B Hydrazine Dilution Procedures
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MODULE I - STANDARD PERMIT CONDITIONS
I.A. EFFECT OF PERMIT
LA. 1. The Permittee is allowed to store hazardous waste in containers and to treat hydrazine,
by dilution, in containers at the ATK Launch Systems-Promontory (ATK) Facility, Box
Elder County, Utah in accordance with the conditions ofthis Permit. In addition, the
Permittee is allowed to store and disassemble waste rocket motors at the facility in
accordance with the conditions ofthis Permit. Any treatment, storage, or disposal of
hazardous waste not authorized in this Permit, is prohibited.
l.A.2. Compliance with this Permit, during its term, constitutes compliance for purposes of
enforcement with applicable sections of Utah Administrative Code (UAC) R315 only
for those management practices specifically authorized by this Permit.
I. A.3. Issuance ofthis Permit does not convey property rights of any sort or any exclusive
privilege; nor does it authorize any injury to persons or property, any invasion of other
private rights, or any infringement of State or local law or regulations.
I. A.4. This Permit has been developed in accordance with the applicable requirements of UAC
R315-1 through 101 ofthe Utah Hazardous Waste Management Rules. All conditions
within this Permit will supercede conflicting statements, requirements, or procedures
found vwthin UAC R315-1 through 101 or attachments to this Permit.
LB. ENFORCEABILITY
I.B. 1 Violations documented through the enforcement process pursuant to Utah Code
Annotated (UCA) 19-6-112 may result in penalties assessed in accordance with UAC
R315-102, the Penalty Policy.
I.C. OTHER AUTHORITY
I.C. 1. The Executive Secretary expressly reserves any right ofentry provided by law and any
authority to order or perform emergency or other response activities as authorized by
law.
LD. PERMIT ACTIONS
I.D.I. This Permit may be modified, revoked and reissued, or terminated for cause, as
specified in UAC R315-3-4. If the Executive Secretary determines that cause exists to
modify, revoke, and reissue, or terminate this Permit, the action will proceed in
accordance with UAC R315-4-1.5. The filing of a request for a permit modification,
revocation, reissuance, termination, or the notification of plarmed changes or anticipated
noncompliance on the part of the Permittee does not stay the applicability or
enforceability of any permit condition.
I.D.2. The Executive Secretary may modify this Permit, in accordance with UAC R315-3-4.2,
when the standards or regulations on which the Permit was based have been changed by
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statute, through promulgation of new or amended standards or regulations, or by
judicial decision after the effective date ofthis Permit.
I. D.3. The Permit may be modified at the request ofthe Permittee according to the procedures
ofUACR315-3-4.3.
I.D.4. All Permit conditions supersede conflicting statements, requirements or procedures
found in the Attachments to the Permit.
I.D.5 If a conflict exists between conditions in this Permit, the most stringent condition, as
determined by the Executive Secretary, shall be met.
I.D.6. In accordance with the Utah Solid and Hazardous Waste Act, UCA, 19-6-108(13), this
Permit shall be reviewed no later than five (5) years from the date of issuance or
renewal and subsequently modified, if necessary.
I.E. SEVERABILITY
I.E. 1. The provisions ofthis Permit are severable and if any provision ofthis Permit, or the
application of any provision ofthis Permit to any circumstance, is held invalid, the
application of such provision to other circumstances and the remainder ofthis Permit
shall not be affected thereby. Invalidation of any State or federal statutory or regulatory
provision which forms the basis for any condition of this Permit does not affect the
validity of any other state or federal statutory or regulatory basis for said condition.
LF. DUTIES TO COMPLY
l.F.l. The Permittee shall comply with all conditions of this Permit, except to the extent and
for the duration such noncompliance is authorized by an Emergency Permit issued in
accordance with UAC R315-3-6.2. Any permit noncompliance, other than
noncompliance authorized by an Emergency Permit, constitutes a violation ofthe Utah
Solid and Hazardous Waste Act, and is grounds for enforcement action; for Permit
termination, revocation and reissuance, or modification; or for denial of a Permit
renewal application; or a combination of enforcement action and any ofthe other listed
remedies.
I.F.2. Compliance with the terms ofthis Permit does not constitute a defense to any order
issued or any acfion brought under Sections 3007, 3008, 3013, or 7003 of RCRA (42
U.S.C. Sections 6927, 6928, 6934 and 6973), Section 106(a), 104, or 107 ofthe
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42
U.S.C. 9606(a), 9604, and 9607, commonly known as CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), or any other State or
federal law providing for protection of human health or the environment from any
imminent and substantial endangerment.
LG. DUTY TO REAPPLY
I.G. 1. If the Permittee wishes, or is required by the Executive Secretarty, to continue an
activity allowed by this Permit after the expiration date ofthis Permit, the Permittee
shall submit a complete application for a new permit, in accordance with UAC R315-3-
2.1g and UAC R315-3-3.1(b), at least 180 days before this Permit expires.
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I.H. PERMIT EXPIRATION
LH. 1. This Permit shall be effective for ten years from the date it is issued.
LI. CONTINUATION OF EXPIRING PERMIT
LL I. This Permit and all conditions herein shall continue in force until the effective date of a
new permit, if the Permittee has submitted a timely and complete application, in
accordance with applicable requirements of UAC R315-3 and R315-4, and through no
fault ofthe Permittee, the Executive Secretary has neither issued nor denied a new
permit under UAC R315-3-5.2 on or before the expiration date ofthis permit.
LJ. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE
I.J. 1. It shall not be a defense for the Permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the conditions ofthis Permit.
I.K. DUTY TO MITIGATE
I.K. 1. In the event of noncompliance with the Permit, the Permittee shall take all reasonable
steps to minimize releases ofhazardous waste, hazardous waste constituents, and
perchlorate salts to the environment resulting from the noncompliance, and shall carry
out such measures as are reasonable to prevent significant adverse impacts on human
health or the environment.
I.L. PROPER OPERATION AND MAINTENANCE
I.L. 1. The Permittee shall, at all times, properly operate and maintain all facilities and systems
of treatment and control (and related appurtenances) which are installed or used by the
Permittee to achieve compliance with the conditions ofthis Permit. Proper operation
and maintenance includes effective performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary equipment or similar systems only when necessary to achieve
compliance with the conditions ofthis Permit.
I.M. DUTY TO PROVIDE INFORMATION
I.M. 1. The Permittee shall fumish to the Executive Secretary, within a reasonable time, any
relevant information which the Executive Secretary may request to determine whether
cause exists for modifying, revoking and reissuing, or terminating this Permit, or to
determine compliance with this Permit. The Permittee shall also fumish to the
Executive Secretary upon request, copies of records required to be kept by this Permit.
I.N. INSPECTION AND ENTRY
I.N.I. Pursuant to the UCA 19-6-109, the Permittee shall allow the Executive Secretary, or an
authorized representative, upon the presentation of credentials and other documents, as
may be required by law, to:
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I.N. 1 .a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or
activity is located or conducted, or where records are kept as required by the conditions
ofthis Permit;
I.N. 1 .b. Have access to and copy, at reasonable times, any records that are kept as required by
the conditions of this Permit;
I.N.I .c. Inspect at reasonable times any portion of the Facility, equipment (including monitoring
and control equipment), practices, or operations regulated or required under this Permit;
I.N. 1 .d. Sample or monitor, at reasonable times, for the purposes of assuring permit compliance
or as otherwise authorized by the Utah Solid and Hazardous Waste Act, any substances
or parameters at any location; and
I.N, 1 .e. Make record of inspection by photographic, electronic, videotape, or any other
reasonable medium. No audio recording devices shall be used without notice to all
individuals in recording range prior to activation ofthe recording device. Photographic
and video recording shall comply with the safety and security requirements ofthe
Permittee.
I.O. MONITORING AND RECORDS
LO.l. The Permittee shall retain records of all monitoring information, including all
calibration and maintenance records and, where applicable, all original strip chart
recordings (or equivalent recordings) for continuous monitoring instrumentation, copies
of all reports and records required by this Permit, the waste minimization certification
required by UAC R315-8-5.3. (40 CFR § 264.73(b)(9) incorporated by reference), and
records of all data used to comply with the conditions ofthis Permit, including any and
all data to support human health and ecological risk assessments for cleanup and closure
activities. All ofthe above referenced material shall be retained for a period of at least
three years from the date ofthe sample, measurement, report, certification, or recording
unless a longer retention period for certain information is required by other conditions
ofthis Permit. The three-year period may be extended by the Executive Secretary at
any time by written notification to the Permittee. The retention times are automatically
extended during the course of any unresolved enforcement action regarding the facility
to three years beyond the conclusion ofthe enforcement action. Recordkeeping may be
accomplished using original documents, xerographic copies, document replicas, electronic
facsimiles, electronic disk, CD-ROM computer drive files, microfilm, microfiche, photograph,
magnetic tape or any other reasonable medium or similar recordkeeping technique. Any
recordkeeping system shallbe capable of reproducing complete, accurate and legible records.
i.0.2. Pursuant to UAC R315-3-3.1(j)(3), records of monitoring information shall specify at a
minimum:
1.0.2.a. The date(s), exact place, and times of sampling or measurements;
I.0.2.b. The name(s), title(s), and affiliation of individual(s) who performed the sampling or
measurements;
I.O.2.C. The date(s) analyses were performed;
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I.0.2.d. The individual(s) who performed the analyses;
I.0.2.e. The analytical techniques or methods used; and
I.0.2.f The results of such analyses.
1.0.3. Samples and measurements taken for the purpose of monitoring shall be representative
ofthe monitored activity. The method used to obtain a representative sample ofthe
waste to be analyzed shall be the appropriate method from UAC R315-50-6 or as
specified or modified by this Permit.. Laboratory methods shall be those specified in
"Test Methods for Evaluating Solid Waste; Physical/Chemical Methods SW-846 {Third
Edition, November 1986)" or most currently promulgated edition, "Standard Methods
for Examination of Water and Wastewater (17th Edition, 1989) " or most currently
promulgated edition; or an equivalent method as approved by the Executive Secretary.
The analysis of all samples shall be conducted by laboratories certified by the State of
Utah.
1.0.4. When requesting substitute or additional analytical methods, the Permittee shall submit
to the Executive Secretary a request for substitution ofanalytical methods which are
equivalent to the methods specifically approved for use in this permit, in accordance
with UAC R315-3-4.3. The request shall provide information demonstrating that the
proposed methods are equivalent or superior in terms of sensitivity, accuracy, and
precision (i.e. reproducibility).
LP. REPORTING PLANNED CHANGES
I.P. 1. The Permittee shall give written notice to the Executive Secretary 60 days prior to any
planned physical alterations or additions to any Hazardous Waste Management Unit
(HWMU) or system being permitted or previously permitted in accordance with UAC
R315-3-3.1(1) and R315-3-4.3. Plarmed physical alterations or additions shall include
all changes in any hazardous and solid waste activities, and to any non-waste
underground storage tanks regulated under UAC R315-202 (40 CFR 280).
Constmction or operation of new or modified HWMUs shall not begin unless the
provisions of UAC R315-4-1.5 are met.
I.Q. REPORTING ANTICIPATED NONCOMPLIANCE
l.Q.l. The Permittee shall give written notice to the Executive Secretary 30 days prior to any
planned changes in the permitted Facility or activity which may result in noncompliance
with requirements ofthis Permit. Advance notice shall not constitute a defense for any
noncompliance.
I.R. CERTIFICATION OF CONSTRUCTION OR MODIFICATION
I.R.I. The Permittee shall not commence storage, treatment, or disposal ofhazardous waste in
a new hazardous waste management unit or in a modified portion of an existing
permitted hazardous waste management unit, except as provided in UAC R315-3-4.3,
until:
I.R. 1 .a. The Permittee has submitted to the Executive Secretary by certified mail, express mail
or hand delivery:
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I.R. 1 .a.i. A letter signed by the Permittee and an independent, Utah registered professional
engineer qualified by experience and education in the appropriate engineering field
certifying that the unit has been constmcted or modified in accordance with the
approved modification request and this Permit; and
I.R. 1 .a.ii. As-built engineering drawings and specifications as appropriate.
I.R. I .b.. The Executive Secretary or designated representative has reviewed and inspected the
modified or newly constmcted unit and has notified the Permittee in writing that the
unit was found in compliance with the conditions ofthis Permit.
LR.2. If within fifteen (15) calendar days ofthe date of receipt ofthe letter required by Permit
Condition I.R.l.a.i., the Permittee has not received notice from the Executive Secretary,
ofthe intent to inspect, prior inspection is waived and the Permittee may commence
treatment, storage, or disposal ofhazardous waste in the permitted unit, if certified in
accordance with Condition I.R. 1 .a.i.
LS. TRANSFER OF PERMIT
I.S. 1. This Permit may be transferred to a new owner or operator only if it is modified or
revoked and reissued pursuant to UAC R315-3-4.1 and R315-3-4.2(b)(2). Prior to
transferring ownership or operation ofthe Facility during its operating life, the
Permittee shall notify the new owner or operator, in writing, ofthe applicable
requirements of UAC R315-1 through R315-101, and this Permit. Failure by the
Permittee to notify the new owner or operator of these requirements and this Permit in
no way relieves the new owner or operator of his obligation to comply with all
applicable requirements ofthe Rules and this Permit.
I.T. TWENTY-FOUR HOUR REPORTING
I.T.I. In accordance with UAC R315-3-3.l(l)(6)(i), the Permittee shall orally report to the
Executive Secretary any noncompliance with this Permit which may endanger human
health or the environment. Any such information shall be reported as soon as possible,
but not later than twenty-four (24) hours from the time the Permittee becomes aware of
the noncompliance.
I.T.2. In accordance with UAC R315-9-1 (b), the Permittee shall immediately report to the
Executive Secretary any spill of any hazardous waste or material which, when spilled
becomes a hazardous waste, if the spilled quantity exceeds 100 kilograms or a lesser
amount if there is a potential for endangerment to human health or the environment, or
exceeds 1 kilogram if the material is an acute hazardous waste as defined by UAC
R315-9-1 (b)(2).
I.T.3. The Permittee shall immediately report to the Executive Secretary any spill that
contains perchlorate, if the spilled quantity exceeds 100 kilograms and the perchlorate
concentration ofthe spilled material is greater than 26 ug/L. Any such information
shall be reported as soon as possible, but not later than 24 hours from the spill
occurrence.
I.T.4. The non-compliance and spill reports shall include, but not be limited to, the following:
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I.T.4.a. Information conceming the release of any hazardous waste which may endanger public
drinking water supplies; and
I.T.4.b. Any information of a release or discharge ofhazardous waste, or of a fire, or explosion
at the Facility, which could threaten human health or the environment.
I.T.4.C. A description ofthe occurrence and its cause;
LT.4.d. The name, title, and telephone number ofthe individual reporting;
I.T.4.e. The name, address, and telephone number ofthe owner or operator;
I.T.4.f The name, address, and telephone number ofthe Facility;
I.T.4.g. The date, time, and type of the incident;
I.T.4.h. The location and cause ofthe incident;
I.T.4.i. The name and quantity of materials involved;
I.T.4.J. The extent of injuries, if any;
LT.4.k. An assessment of actual or potential hazard to the environment and human health,
where this is applicable;
I.T.4.1. A description of any emergency action taken to minimize threat to human health and the
environment;
I.T.4.m. An estimated quantity and disposition ofthe recovered material that resulted from the
incident; and
I.T.4.n. Any other information necessary to fully evaluate the situation and to develop an
appropriate course of action.
I.T.5. Within 15 days ofthe time the Permittee is required to provide the reports specified in
Conditions I.T.I. through I.T.4., the Permittee shall submit to the Executive Secretary a
written report.
I.T.6. The written report shall include, but not be limited to the following:
I.T.6.a. The name, title, address, and telephone number ofthe individual reporting;
l.T.6.b. A description including the date, time, location and nature ofthe reported incident;
I.T.6.C. The extent of injuries, ifany;
I.T.6.C. The name and quantity of material(s) involved in the spill;
LT.6.d. An estimated quantity and disposition ofthe recovered material;
I.T.6.e. An assessment of actual or potential hazards to human health and the environment,
where this is applicable. The report shail aiso include whether or not the results ofthe
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incident remain a threat to human health and the environment (whether the
noncompliance has been corrected and the release has been adequately cleaned up); and
I.T.6.f If the release or noncompliance has not been adequately corrected or cleaned up, the
anticipated time that the noncompliance or remediation is expected to continue; the
steps taken or planned to reduce, eliminate, and prevent recurrence of the '
noncompliance; and/or the steps taken or planned to adequately remediate the release.
I.U. MONITORING REPORTS
I.U.I. Monitoring information shall be recorded and maintained as specified in Condition I.O.
I.V COMPLIANCE SCHEDULES
I.V. 1. Reports of compliance or noncompliance with, or any progress reports on, interim and
final requirements contained in any compliance schedule of this Permit shall be
submitted no later than 14 days following each scheduled date.
LW. MANIFEST DISCREPANCY REPORT
I.W.I. Manifest discrepancies shall be defined as differences between the quantity or type of
hazardous waste designated on the manifest or shipping paper, and the quantity or type
ofhazardous waste the permittee actually receives. Significant discrepancies in
quantity are: (1) for batch waste, any variation in piece count, such as a discrepancy of
one dmm in a tmckload, and (2) for bulk waste, variations greater than 10 percent in
weight. Significant discrepancies in type are obvious differences which can be
discovered by inspection or waste analysis, such as waste solvent substituted for waste
acid, or toxic constituents not reported on the manifest or shipping paper. Ifa
significant discrepancy is discovered in a manifest, the Permittee shall attempt to
reconcile the discrepancy. If not resolved within 15 days, the Permittee shall submit a
written report, including a copy ofthe manifest and efforts to reconcile the discrepancy,
to the Executive Secretary in accordance with UAC R315-8-5.4.
I.X. UNMANIFESTED WASTE REPORT
I.X. 1. The Permittee shall submit to the Executive Secretary an Unmanifested Waste Report
within 15 days of receipt of unmanifested waste in accordance with UAC R315-8-5.7.
I.Y. BIENNIAL REPORT
I. Y. 1. The Permittee shall submit to the Executive Secretary a Biennial Report covering
facility activities during odd numbered calendar years. This report shall be submitted
by March 1 ofthe following even numbered year in accordance with UAC R315-8-5.6.
LZ. OTHER NONCOMPLIANCE
LZ. I. The Permittee shall report all other instances of noncompliance with this Permit not
otherwise required to be reported in accordance with Condition I.T., within seven days
of discovering the noncompliance. The reports shall contain the information listed in
Condition I.T. ofthis Permit. Reporting shall not constitute a defense for any
noncompliance.
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LAA. OTHER INFORMATION
LAA. 1. Whenever the Permittee becomes aware that it failed to submit any relevant facts in a
permit application, or submitted incorrect information in a permit modification, or in
any report submitted to the Executive Secretary, the Permittee shall submit such facts or
corrected information within seven working days.
I.BB. SIGNATORY REOUIREMENT
I.BB. 1. All reports, notifications, submissions or other information required by this Permit,
requested by or submitted to the Executive Secretary, shall be signed and certified in
accordance with UAC R315-3-2.2.
I.CC. CONFIDENTIAL INFORMATION
I.CC. 1. The Permittee may claim confidential any infonnation required to be submitted by this
Pemiit in accordance with Utah Code Annotated 63-2-101 et seq. and Utah Code
Annotated 19-1-306.
LDD. REPORTS. NOTIFICATIONS. AND SUBMISSIONS
I.DD. 1. All reports, notifications, or other submissions vvhich are required by this Permit to be
transmitted to the Executive Secretary should be sent by certified mail or other means of
proof of delivery to:
Executive Secretary
Utah Solid and Hazardous Waste Control Board
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Phone [phone]
Normal business hours are 7 am to 6 pm, Monday through Thursday, except Utah State
holidays. Required oral notifications shall be given only to the Executive Secretary or
an authorized representative of the Executive Secretary. Notifications made at other
times shall be made to the 24-hour answering service at [phone]. Notifications
made to the 24-hour answering service shall include all applicable information required
by this Permit. The Permittee shall give oral notification to the Executive Secretary or
an authorized representative ofthe Executive Secretary on the first business day
following notification to the 24-hour answering service.
LEE. DOCUMENTS TO BE MAINTAINED AT THE FACILITY SITE
I.EE. 1. The Permittee shall maintain at the facility, for the periods specified, current copies of
the following documents and amendments, revisions and modifications to these
documents;
I.EE. 1 .a. A copy ofthe Permit until closure is certified in accordance with Condition II.N.;
I.EE.I.b. Waste Analysis Plans (Attachment 1), and all associated analytical data, as required by
UAC R315-8-2.4. and this Permit until closure is certified in accordance with Condition
ILN.;
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I.EE. 1 .c. Inspection schedules and logs (Attachment 2), as required by UAC R315-8-2.6(b) and
this Permit for a period of three years in accordance with UAC R315-8.2.6(d);
I.EE. 1 d. Personnel training documents (Attachment 3), and records, as required by UAC R315-
8-2.7(d) and this Permit until closure for current employees, or for a period of three
years for former employees in accordance with UAC R315-8.2.7(e);
I.EE. 1 .e. Contingency Plan (Attachment 4), as required by UAC R315-8-4 and this Permit until
closure is certified in accordance with Condition II.N;
I.EE. 1 .f. Operating record, as required by UAC R315-8-5.3, and this permit until closure is
certified in accordance with Condition II.N;
I.EE. 1 .g. Closure Plans (Attachment 5), as required by UAC R315-8-7 and this permit, until
closure is certified in accordance with Condition II.N;
I.EE.l .h. Cost estimates (Attachment 5) for the closure and post-closure ofthe Hazardous Waste
Management Units covered by this Permit, in accordance with UAC R315-8-8 and
Condition ILO. of this Permit;
I.EE.I .i. Manifest copies, as required by UAC R315-8-5 and this Permit for at least three years
from the date the waste shipment was accepted at the facility or shipped off-site to an
approved hazardous waste management facility; and
I.EE. 1 .j. A copy of the Permittee's waste minimization statement until closure is certified in
accordance with Condition II.N.
LFF. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
I.FF.l. Pursuant to Section 3005(C)(3) of RCRA (Section 212 of HSWA) and UAC R315-3-
3.3(b)(2) [40 CFR 270.32(b)(2)], this Permit contains those terms and conditions
determined necessary to protect human health and the environment.
10
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MODULE II - GENERAL FACILITY CONDITIONS
ILA. APPLICABILITY
II.A. 1. The requirements ofthis permit module pertain to all Hazardous Waste Management
Units (HWMUs) identified within Modules I, II and III.
II.B. DESIGN AND OPERATION OF FACILITY
II.B. I. The Permittee shall design, constmct, maintain and operate all ofthe HWMUs and
surrounding areas to minimize the possibility ofa fire, explosion, or any sudden or non-
sudden release ofhazardous waste or hazardous waste constituents to the air, soil,
groundwater or surface water which could threaten human health or the environment.
II.B.2. Any constmction changes associated with a permitted HWMU at the facility shall be
documented by as-built drawings and certified by a registered professional engineer in
accordance with Condition I.R.I, and UAC R315-3-3.l(l)(2)(i).
II.B.3. After review ofthe as-built drawings and field verification ofthe facility's HWMUs, the
Executive Secretary will notify the Permittee in writing of any change which he
concludes does not satisfy the operating requirements specified in this permit.
H.C. REOUIRED NOTICE
II.C.l. As required by UAC R315-8-2.3(a)(l), the Permittee shall notify the Executive
Secretary in writing at least four weeks in advance ofthe date the Permittee expects to
receive hazardous waste from a foreign source. Notice of subsequent shipments ofthe
same waste from the same foreign source in the same calendar year is not required.
II.C.2. When the Permittee arranges to receive hazardous waste from an off-site source (except
where the Permittee is also the generator), the Permittee shall inform the generator in
writing that he has the appropriate permit(s) for, and will accept, the waste the generator
is shipping. The Permittee shall keep a copy ofthis written notice as part ofthe
operating record as required by UAC R315-8-2.3(b).
ILD. WASTE ANALYSIS PLAN
II.D. 1. The Permittee shall follow the procedures of the Waste Analysis Plan included as
Attachment 1 ofthis Permit. In addition, the Permittee shall comply with any other
conditions involving waste analysis in Modules I, II, III and IV.
II.D.2. The Permittee shall use the test methods described in the Waste Analysis Plan
(Attachment 1) or an equivalent procedure that satisfies Condition 1.0.3. Changes in a
test method described in the Waste Analysis Plan, as a result of an improvement or
refinement of that method, may be adopted by the Permittee and incorporated into this
Permit, in accordance with UAC R315-4-1.5 and Condition I.D.
II.D.3. The Permittee shall characterize, using analytical techniques if necessary, all waste
streams generated on or off-site in accordance with UAC R315-8-2.4 and Attachment 1.
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The waste characterization profiles shall be kept in the operating record.
II.D.4. An annual evaluation of each waste stream shall be performed, as outlined in the waste
analysis plan, to verify that the waste characterization is still accurate. These
evaluations shall be kept in the operating record until the next annual evaluations are
completed. Characterization of waste streams shall also be done each time the process
generating the waste changes.
II.D.5. Any waste analysis used to evaluate off-site waste for acceptance by the Permittee shall
be accomplished using a laboratory that has been certified by the Utah State Division of
Laboratories.
II.D.6. At a minimum, the Permittee shall:
II.D.6.a. Maintain properly functioning sampling and analytical equipment;
II.D.6.b. Use approved sampling and analytical methods; and
II.D.6.c. Submit an updated list of parameters, analytical methods, and sample preparation
methods on an annual basis. The updated list shall be submitted to the Executive
Secretary on or before January 15 of each calendar year.
II.D.7. Whenever the Executive Secretary determines that the Permittee needs to update the
analytical methodologies or the version(s) of SW-846 that are being used by the
Permittee's analytical laboratory, the Executive Secretary will submit written
notification to the Permittee. The Permittee shall notify the Utah Department of Health,
Bureau of Laboratory Improvement ofthe requested update within 30 days of receipt of
the Executive Secretary's determination. The Permittee shall have 180 days from the
receipt ofthe Executive Secretary's written notification to complete the requested
update. If it is not possible to complete the update within the prescribed time, the
Permittee shall submit a written request for extension to the Executive Secretary for
approval.
II.D. 8. If the Permittee uses a contract laboratory to perform analyses, the laboratory must be
certified by the State of Utah to perform the contracted analyses. For parameters for
which certification is unavailable, the Permittee shall ensure that quality control/quality
assurance data provided by the laboratory is sufficient to assess the validity ofthe data.
The Permittee shall inform the laboratory in writing that it must operate under the
Waste Analysis Plan conditions set forth in this Permit.
ILE SECURITY
ILE. I. The Permittee shall comply with the security conditions and procedures contained in
Attachment 7 of this Permit.
II.F. GENERAL INSPECTION REOUIREMENTS
II.F. 1. The Permittee shall conduct inspections in accordance with UAC R315-8-2.6 and shall
follow the inspection schedule found in Attachment 2.
II.F.2. The Permittee shall remedy any deterioration or malfimction as required by UAC R315-
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8-2.6(c). If the remedy requires more than 72 hours to implement from the time that the
problem is detected, the Permittee shall submit to the Executive Secretary, before the
expiration ofthe 72 hour period, a proposed time schedule for correcting the problem.
II.F.3. Any problem which could endanger human health or the environment shall be corrected
as soon as possible after the problem is discovered. The Permittee shall make every
effort to eliminate the threat to human health or the environment within 24 hours.
II.F.4. If, upon determination by the Executive Secretary or the Permittee, continued operation
ofthe waste management unit involved in the inspection could endanger human health
or the environment, the Permittee shall cease operation ofthe unit until the problem has
been corrected. The Permittee shall be allowed to undertake those operations which are
part of corrective activities.
II.F.5. Records of inspections shall be kept as required by UAC R315-8-2.6(d).
ILG. PERSONNEL TRAINING
II.G. 1. The Permittee shall conduct personnel training as required by UAC R315-8-2.7. This
training program shall follow the outline found in Attachment 3. New personnel
working with or around hazardous waste shall complete the required personnel training
within six (6) months of their hire date, assignment to the facility or assignment to a
new position at the facility.
II.G.2. Facility persormel shall take part in an annual review of their initial training for
contingency and hazardous waste management procedures relevant to the positions in
which they are employed.
II.G.3. The Permittee shall maintain training documents and records as required by UAC R315-
8-2.7(d) and R315-8-2.7(e) [40 CFR 264.16(d) and 264.16(e)], in accordance with the
Training Plan in Attachment 3. These records shall indicate the type and amount of
training received.
II.G.4. The Permittee shall maintain a copy ofthe Training Plan at the Facility until it is fully
closed and closure is certified.
II.G.5. Employees working at the rocket motor disassembly and storage building (M-603) shall
receive task specific on-the-job-training in addition to the training outlined in
Attachment 3. This training shall be documented and maintained in the operating
record until the specific program is completed.
ILH. GENERAL REOUIREMENTS FOR IGNITABLE. REACTIVE. QR
INCOMPATIBLE WASTE
II.H.I. The Permittee shall comply with the requirements of UAC R315-8-2.8.
II.H.2. Inaddition to the requirements of UAC R315-8-2.8., the Permittee shall comply with
the Conditions III.G and III.H pertaining to ignitable, reactive, or incompatible waste.
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ILI. LOCATION STANDARDS
II.I. 1. The Permittee shall comply with the location standards specified by UAC R315-8-2.9.
ILJ. PREPAREDNESS AND PREVENTION
II.J. 1. The Permittee shall follow the Preparedness and Prevention Plan, Attachment 8.
II.J.2. At a minimum, the Permittee shall equip and maintain in good operating condition at
the facility the equipment set forth in Attachment 8, as required by UAC R315-8-3.3.
II.J.3. The Permittee shall test and maintain the equipment specified in Condition II.J.2 as
necessary to assure its proper operation in time of emergency.
II.J.4. The Permittee shall maintain records ofthe preventative maintenance and repair
activities specified in Condition II.J.3. and shall keep schedules, reflecting minimum
and planned frequency for the performance of preventative maintenance activities in the
Operating Record at the facility.
II.J.5. The Permittee shall maintain access to the communications or alarm system as required
by UAC R315-8-3.5.
II.J.6. At a minimum, the Permittee shall maintain 30 inches of aisle space between containers
or pallets ofcontainers at storage areas M-186 and E-501.
1I.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 kept in the Operating Record. The attempts to make such
agreements, any refusals and all final agreements shall be documented in the Operating
Record.
ILK. CONTINGENCY PLAN
II.K.l. The Permittee shall immediately carry out the provisions of Attachment 4, and follow
the emergency procedures described by UAC R315-8-4.7 whenever there is a fire,
explosion, or release ofhazardous waste or hazardous waste constituents which
threatens or could threaten human health or the environment. The Permittee shall
comply with Condition I.T. in reporting releases to the Executive Secretary.
II.K.2. The Permittee shall provide copies ofthe Contingency Plan to emergency agencies who
may be called in an emergency, shall maintain a copy ofthe Plan at the facility, and
shall provide a copy upon request in accordance with UAC R315-8-4.4.
II.K.3. The Permittee shall review the Contingency Plan, in accordance with UAC R315-8-4.5
and shall modify it in accordance with Condition I.D., if necessary.
II.K.4. A trained emergency coordinator shall be available at all times in case of an emergency,
in accordance with tjAC R315-8-4.6 and identified in Attachment 4.
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ILL. MANIFEST SYSTEM
ILL. 1. The Permittee shall comply with the manifest requirements of UAC R315-5-2 and UAC
R315-8-5. The manifest tracking number shall be recorded in the Operating Record
with each waste load that arrives or leaves the Permittee's facility.
ILM. RECORDKEEPING AND REPORTING
II.M. 1. The permittee shall maintain an accurate written Operating Record at the facility in
accordance with UAC R315-8-5.3 (40 CFR 264.73 incorporated by reference) and
R315-50-2 (Appendix I to Part 264 incorporated by reference).
II.M.2. The Permittee shall, by March 1 of each year, submit to the Executive Secretary a
certification pursuant to UAC R315-8-5.3 [40 CFR 264.73(b)(9).incoiporated by
reference], signed in accordance with UAC R315-3-2.2, that the Permittee has a
program in place to reduce the volume and toxicity ofhazardous waste that he generates
to the degree determined by the Permittee to be economically practicable; and that the
proposed method of treatment, storage, or disposal is the most practicable method
currently available to the Permittee which minimizes the present and fiiture threat to
human health or the environment.
II.M.3. The Permittee shall comply with the biennial report requirements of UAC R315-8-5.6,
by March 1 of each even-numbered reporting year. The report shall include wastes
generated, treated or stored at the Permittee's facility during the previous odd-numbered
year.
II.M.4. The Permittee shall submit additional reports to the Executive Secretary in accordance
with UAC R315-8-5.8.
II.M.5. All reports, notifications, applications, or other materials required to be submitted to the
Executive Secretary shall be submitted in accordance with Condition I.DD.
II.N. CLOSURE/POST-CLOSURE
II.N.L The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101
and Attachment 5.
II.N.2. For all HWMUs, minor deviations from the approved closure plan procedures,
necessary to accommodate proper closure, shall be described in narrative form with the
closure certification statements. The Permittee shall describe the rationale for
implementing minor changes as part ofthis narrative report. Within 60 days after
completion of closure of each HWMU, the Permittee shall submit the certification
statements and narrative reports to the Executive Secretary.
II.N.3. The Permittee shall amend the closure/post-closure plan in accordance with UAC R315-
8-7 and Condition I.D. whenever necessary, or when required to do so by the Executive
Secretary.
II.N.4. The Permittee shall notify the Executive Secretary in writing ofthe partial closure of
any portion ofthe facility in accordance with UAC R315-8-7. The Permittee shall
notify the Executive Secretary at least 180 days prior to the commencement of final
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facility closure. The closure plan contained in Attachment 5 will be reviewed before
commencing partial or final facility closure. If the closure plan requires modification,
the plan shall be modified and submitted to the Executive Secretary for approval in
accordance with Condition LD.
II.N.5. After receiving the final volume ofhazardous waste, the Permittee shall treat or remove
from the site all hazardous waste and complete closure activities in accordance with the
schedule specified in Attachment 5.
II.N.6. The Pennittee shall decontaminate or dispose of all facility equipment, stmctures, soil
and rinsate as required by UAC R315-8-7, R315-8-9 and Attachment 5. Facility
equipment, stmctures and soil which have not been decontaminated shall be disposed of
only at a permitted hazardous waste treatment, storage or disposal facility.
II.N.7. The Permittee shall certify that the facility has been closed in accordance with the
specifications in Attachment 5 as required by UAC R315-8-7, and shall provide a
certification by an independent, Utah registered professional engineer qualified by
experience and education in the appropriate engineering field.
II.N.8. In the event that any ofthe hazardous waste management units covered by this permit
cannot be clean closed by decontaminating or removing contaminated structures or soil,
or releases have occurred which have impacted soil or groundwater, the Permittee shall
modify the Closure/Post-Closure Plan for tha,t hazardous waste management unit in
accordance with Condition I.D. Within 30 days ofthe date that the Executive Secretary
approves the modification, the Permittee shall close the unit in accordance with the
applicable provision of UAC R315-8-7 and R315-101.
II.N.9. If a HWMU can not be clean closed, the Permittee shall submit a survey plat and
property description for the HWMU with the submission ofthe certification of closure
for the HWMU, in accordance with UAC R315-8-7 and R315-101.
ILO. COST ESTIMATES FOR HWMU CLOSURE
ILO. 1. The Permittee's closure cost estimate for each HWMU shall be prepared and maintained
at the facility in accordance with UAC R315-8-8 (40 CFR 264.142 incorporated by
reference) and Attachment 5.
II.0.2. On the one year anniversary date of Permit issuance, the Permittee shall submit to the
Executive Secretary for approval updated closure plans and detailed closure cost
estimates for each HWMU at the ATK facility. The closure cost estimates shall identify
the costs, in current dollars, ofthe steps necessary to perform final closure for each
HWMU in accordance with UAC R315-8-9.9 and UAC R315-8-8 (40 CFR 264.142
incorporated by reference).
ILO.3. On the five year anniversary date ofthe submittal ofthe closure cost estimates required
by Condition 11.0.2. above, the Permittee shall conduct a detailed evaluation ofthe
closure cost estimates for each HWMU and determine whether the annual adjustments
for inflation have been adequate to update the closure cost estimates. The Permittee
shall submit a report on this assessment and if necessary, a modification ofthe Permit in
accordance with Condition I.D. to the Executive Secretary 90 days after the report is
submitted.
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II.0.4. The Permittee shall revise the closure cost estimate within 30 days after the Executive
Secretary has approved the request to modify the affected closure plan(s).
ILO.5. For each new HWMU placed into operation, an updated closure cost estimate to the
facility must be prepared which includes the new unit, 60 days prior to waste being
placed on or into the new unit.
II.P. FINANCIAL ASSURANCE FOR FACILITY CLOSURE
II.P.l. The Permittee shall demonstrate continuous financial assurance compliance by
providing a third party financial assurance certification of at least the amount ofthe
closure/post-closure cost estimates established in Condition ILO. The Permittee may
substitute other instmments of financial assurance provided the method, funding and
wording requirements of UAC R315-8-8 are followed and approved by the Executive
Secretary.
II.P.2. The financial assurance document shall be updated within 60 days ofthe annual
adjustment for inflation or within 60 days ofthe approval of a revised closure/post-
closure cost estimate in accordance with UAC R315-8-8.
II.Q. LIABILITY REOUIREMENTS
II.Q. 1. The Permittee shall demonstrate continuous compliance with the liability requirements
of UAC R315-8-8 (40 CFR 264.147 incorporated by reference). The Permittee shall
have and maintain hazardous waste liability coverage for sudden accidental occurrences
in the amount of at least one $1 million U.S. dollars per occunence with an annual
aggregate of at least $2 million U.S. dollars, exclusive of legal defense costs. The
Permittee shall submit an approved certificate of hazardous waste liability insurance
worded as required by UAC R315-8-8.
II.Q.2. Changes in liability coverage mechanisms shall be approved by the Executive Secretary
60 days prior to such a change.
II.R. INCAPACITY OF OWNER OR OPERATORS. GUARANTORS. OR
FINANCIAL INSTITUTIONS
II.R. 1. The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (40 CFR 264.148 incorporated by reference).
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MODULE III - STORAGE IN CONTAINERS
III.A. APPLICABILITY
III.A. 1. The requirements ofthis permit Module pertain to the operation ofhazardous waste
container storage areas at the facility. The Permittee shall comply with R315-8-9 and
all conditions ofthis Module.
III.A.2. The designated hazardous waste storage areas are the bays of Buildings M-705S, E-501,
M-47, M-603, M-186, the bum trays at M-136 and Bum Station 14 at M-136.
Drawings of these storage areas are presented in Attachment 6.
HLB. WASTE IDENTIFICATION
III.B. 1. The Permittee shall, subject to the terms of this Permit, store only the following
hazardous wastes, as listed by EPA hazardous waste code, in containers at storage areas
M-186, M-705S and E-501:
DOOl, D002, D003, D004, D005, D006, D007, D008, D009, DOIO DOl 1, D016, D018,
D019, D021, D022, D023, D024, D026, D027,D028, D029, D035, D036, D038, D039,
D040, D042, D043, FOOl, F002, F003, F004, F005, F006, F007, F008, F009, K044,
P003, POI2, P022, P028, P029, P030, P047, P048, P064, P067, P077, P087, P092,
P093, P095, P098, P105, P106, Pl 12, Pl 16, Pl 19, UOOl, U002, U004,U006, U008,
U009, U019, U025, U028, U029, U031, U037, U041, U044, U048, U053, U056, U057,
U069, U070, U072, U077, U079, UOSO, U085, U088, U092, U093, U095, U098, UlOl,
U102, U103,U105, U108, U112, U113, U117, U118, U120, U121, U122, U123, U131,
U133, U134, U140, U147, U148, U149, U151, U154, U156, U159, U160, U161, U162,
U165, U168, U169, U170, U171, U185, U186, U188, U190, U196, U201, U209, U210,
U211, U218, U219, U220, U221, U223, U224, U225, U226, U228, U238, U239, U240,
U243, U244, U246, U253, U328, U353, U359, U404.
III.B.2. The Permittee may store waste solid rocket motors and waste solid propellant, EPA
hazardous waste code D003, in storage Building M-47 subject to the terms ofthis
Permit.
III.B.3. The Permittee may store and treat solid propellant/rocket motors, EPA hazardous waste
code D003, in Building M-603 in accordance with Module IV ofthis Permit.
III.B.4. The Permittee may store solid reactive waste, EPA hazardous waste code D003,
received from off-site in bum trays at M-136 for up to 14 days prior to thermal
treatment. Waste stored in bum trays shall be containerized only in covered dmms,
boxes, plastic bags, woven bags or other US Department of Transportation (DOT) or
United Nations (UN) approved shipping containers. Containers shall be labeled and
managed as specified in Attachment 9.
III.B.5. The Permittee may store waste rocket motors, EPA hazardous waste code D003,
received from off-site that contain solid propellant, one at a time on the ground at M-
136, Bum Station 14 for up to 14 days prior to thermal treatment. The waste rocket
motors shall be labeled and managed as specified in Attachment 9.
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III.B.6. The Permittee is prohibited from storing hazardous waste that is not identified in
Section III.B. ofthis Module. Any addition ofhazardous waste codes to Condition
III.B.l. requires modification ofthe permit in accordance with Condition I.D.3.
IILC. CONDITION OF CONTAINERS
IILC. 1. If a container holding hazardous waste is not in good condition (e.g., severe msting,
bulging, apparent stmctural defects) or it has begun to leak, the Permittee shall transfer
the hazardous waste, or the container itself, to a UN approved container in accordance
with Section 8-1-10 of Attachment 8. The transfer shall be completed as soon as
possible but not later than 24 hours from the time the problem was first discovered.
III.D. COMPATIBILITY OF WASTE WITH CONTAINERS
IILD.l. The Permittee shall assure that the waste is compatible with the containers as required
by R315-8-9.3. The Permittee shall follow the compatibility plan as indicated in
Section 9-2.1 and Table 9-2 of Attachment 9.
HLE. MANAGEMENT OF CONTAINERS
III.E. 1. The Permittee shall manage containers in accordance with this module of the Permit,
UAC R315-8-9.4 and the procedures identified in Attachment 9. A container holding
hazardous waste shall always be closed during storage except when the Permittee is
adding or removing waste from the container. The Permittee shall not open, handle, or
store containers in a manner which may cause the containers to leak.
III.E.2. The Permittee shall store liquid hazardous wastes in containers only at storage areas
M-186, E-501 and M-705S. Drawings ofthe container storage areas are shown in
Attachment 6. At capacity, the Permittee may store the following volumes of wastes:
III.E.2.a. E-501 - 8,800 gallons, which is 160 55-gallon containers or the equivalent;
III.E.2.b. M-l 86 - 22,000 gallons, which is 400 55-gallon containers or the equivalent; and
III.E.2.c. M-705S - 1,760 gallons, which is 32 55-gallon containers or the equivalent.
III.E.3. The Permittee shall store waste solid propellant in containers at storage areas M-47,
M-603 and M-136. Drawings ofthe storage areas are shown in Attachment 6. At
capacity, the Permittee may store the following amounts of wastes:
III.E.3.a. M-47 - 840,000 lbs 1.3 or 21,000 lbs 1.1 solid propellant;
III.E.3.b. M-603 - 120,000 lbs 1.3 on rail and 120,000 lbs 1.3 in the casting pit, not to exceed
240,000 lbs total 1.3 solid propellant or 8,000 lbs 1.1 on rail and 65,000 lbs 1.1 in the
casting pit not to exceed 65,000 lbs total 1.1 solid propellant; and
III.E.3.c. M-136 - 106,000 lbs of 1.3 solid propellant or 20,000 lbs of 1.1 solid propellant in bum
trays or in a rocket case placed on the ground.
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III.E.4. The Permittee shall maintain an aisle space of 30 inches minimum between containers
or pallets ofcontainers at storage areas M-186 and E-501.
III.E.5. The Permittee shall store hazardous wastes at M-705S, M-47, M-603 and M-136 so that
the container or waste rocket motor may be readily inspected and hazardous waste
labels are visible.
III.E.6. The Permittee may stack 55-gallon drums at a maximum of two high at storage areas
M-186 and E-501.
III.E.7. Hazardous waste containers shall not be stacked at storage areas M-705S, M-47,
M-603 and M-136.
III.E.8. The Permittee shall unload any transport vehicle hauling containers ofhazardous waste
for storage within 10 days following arrival at the site. Arrival for purposes ofthis
permit shall be the day the vehicle anives at the facility.
III.E.9. The Permittee shall provide storage for and maintain on-site, 85 gallon Overpack drums
at areas where liquid hazardous waste is stored.
III.F. CONTAINMENT SYSTEMS
III.F. 1. The Permittee shall maintain the containment systems in accordance with the attached
plans and specifications contained in Attachment 9 and as specified in UAC R315-8-
9.6.
III.F.2. Container management areas shall be inspected for the presence of free liquids in
accordance with Attachment 2. If free liquids are discovered in the sumps or other
containment areas, the Permittee shall identify the location in the inspection log. Any
liquids discovered shall be removed immediately, but in no case later than twenty-four
hours after the liquid is discovered and managed according to the spill contingency plan
specified in Section 9-4.3 of Attachment 9.
III.F.3. For purposes of inspections, all containers stored in the liquid hazardous waste storage
area shall be considered full to their respective capacities with liquid hazardous waste.
Gondolas/roll-offs that are used only for the storage of solid hazardous waste need not
be considered in the calculations for containment. The area for storing solid waste shall
be identified.
III.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. Inspection ofthe bum trays shall be conducted in accordance with
Attachment 2.
ATK Launch Systems Inc. - Promontory - September 2008
Module 111 - Storage in Containers UTD00908I357
III.G. SPECIAL REOUIREMENTS FOR IGNITABLE OR REACTIVE WASTE
III.G. 1. The Permittee shall not locate containers holding ignitable or reactive waste within 15
meters (50 feet) ofthe facility boundary.
IILG.2. The Permittee shall take precautions to prevent accidental ignition or reaction of
ignitable or reactive waste and follow the procedures specified in Attachment 8, UAC
R315-8-2.8 and UAC R315-8-9.7.
III.H. SPECIAL REOUIREMENTS FOR INGOMPATIBLE WASTE
III.H.l. The Permittee shall not place incompatible wastes, or incompatible wastes and
materials, in the same container, in accordance with UAC R315-8-2.8 and UAC R315-
8-9.8(a).
III.H.2. The Permittee shall not place hazardous waste or materials in an unwashed container
that previously held an incompatible waste or material in accordance with UAC R315-
8-2.8 and UAC R315-8-9.8(b).
III.H.3. A storage container holding a hazardous waste that is incompatible with any waste or
other materials stored nearby shall be separated from the other materials or protected
from them by means of a dike, berm, wall, or other device.
IILL INSPECTION SCHEDULES AND PROCEDURES
111.1.1. The Permittee shall inspect the hazardous waste storage and treatment facilities
identified in Condition III.B. ofthis Permit as specified in the Inspection Schedules
contained in Attachment 2. The purpose ofthis inspection shall be to detect leaking
containers, standing liquids, deterioration ofcontainers, and to detect deterioration of,
or liquids in, the secondary containment system caused by conosion and other factors as
specified in R315-8-9.5.
111.1.2. If problems are observed during the inspections, the Permittee shall correct the problem
in accordance with Module II, Section F.
III.J. CLOSURE/POST-CLOSURE
III.J. 1. The Permittee shall close the storage areas in accordance with UAC R315-8-7, UAC
R315-8-9.9, Condition II.N. and Attachment 5 ofthis Permit.
III.J.2. Closure plans for each individual hazardous waste management area shall be submitted
to the Executive Secretary for approval no less than 180 days prior to the
commencement of closure activities. No closure activities shall take place that have not
received prior approval from the Executive Secretary.
ATK Launch Systemslnc. - Promontory
Module IV-Miscellaneous Units
September 2008
UTD009081357
IV.A.
IV.A.l.
IV.A.2.
IV.B.
IV.B.l.
IV.B.2.
MODULE IV - MISCELLANEOUS UNITS
APPLICABILITY
The Permittee may treat (disassemble) and store solid rocket motors, in
accordance with the requirements ofthis Module, at Building M-603.
Disassembly includes those steps that are necessary to prepare the rocket motor
for treatment by open buming (or other appropriate treatment process).
ALLOWABLE WASTE STREAM
The Permittee may disassemble and store solid rocket motors that consist of class
1.1 or class 1.3 solid propellant. The quantity of solid propellant kept in Building
M-603 at any one time shall not exceed the amounts tabulated in IV.B.2. The
Permittee may not store liquid hazardous wastes at Building M-603.
Propellant Class
1.1
1.3
Quantity on Rail
8,000 lbs
120,000 lbs
Quantity in Casting Pit
65,000 lbs
120,000 lbs
Total Quantity
65,000 lbs
240,000 lbs
IV.C. OPERATING REOUIREMENTS
IV.C.l. The Permittee shall follow intemal procedures for solid rocket motor disassembly.
Detection or discovery of liquid NG shall be recorded in the Operating Record for
the building. A description and date ofthe action taken to clean up the liquid NG
shall also be recorded.
IV.C.2. The Permittee shall comply with the requirements specified in the facility
Contingency Plan, when there has been a release at Building M-603 that threatens
human health or the environment.
IV.C.3. The Permittee shall conduct disassembly operations in a manner that will ensure
protection of human health and the environment.
ATK Launch Systemslnc. - Promontory September 2008
Module IV- Miscellaneous Units UTD009081357
IV.D. INCOMPATIBLE WASTES
IV.D. 1. The Permittee shall not mix incompatible wastes in Building M-603.
IV.E. IGNITABLE OR REACTIVE WASTES
IV.E. 1. The Permittee shall document compliance with the ignitable and reactive waste
regulations as required by UAC R315-8-2.8, and place this documentation in the
facility Operating Record.
IV.F. INSPECTION REOUIREMENTS
IV.F. 1. The Permittee shall inspect Building M-603 in accordance with Attachment 2.
IV.G. RECORD KEEPING AND REPORTING
IV.G.l. The Permittee shall record in the operating record the following:
IV.G. 1 .a. The date the motor was received at M-603.
IV.G.l.b. The date the motor and components were removed from M-603.
IV.G. 1 .c. The components generated by the disassembly process at M-603 (gas
generators, charges, etc.) including quantities.
IV.G. I .d. The manifest number and the rocket motor type with each movement of
waste.
IV.G.l .e. The destination ofthe rocket motor stages and components removed from
M-603.
IV.G. 1 .f The detection or discovery of liquid NG in building or on rocket motor
components.
IV.G. 1 .g. Documents as required to demonstrate compliance with UAC R315-8-2.8
IV.H. CLOSURE
IV.H. 1. The Permittee shall close Building M-603 in accordance with R315-8-7, R315-8-
9.9, Condition ILN. and the designated Closure Plan in Attachment 5 ofthis
Permit.
ATK Launch Systems Inc. - Promontory September 2008
Module V - Treatment of Waste Hydrazine UTD009081357
MODULE V - TREATMENT OF WASTE HYDRAZINE
V.A. APPLICABILITY
V.A.I. 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 facility in accordance with this
Module and Attachment 10.
V.A.2. The treatment process shall be conducted in a marmer 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
facility for disposal or transfer it to the M-l 86 Hazardous Waste Storage
Facility.
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. 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. I .b. The quantity of waste hydrazine received;
V.B. 1 .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. 1 .e. The date the diluted hydrazine is shipped off-site or to the M-186 storage
facility.
ATK Launch Systems Inc. - Promontory September 2008
Module V - Treatment of Waste Hydrazine UTD009081357
V.C. CLOSURE
V.C. 1. The Permittee shall 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 Permit.
ATK Launch Systems Inc. - Promontory September 2008
Attachment I - Waste Analysis Plan UTD009081357
Attachment 1
WASTE ANALYSIS PLAN
ATK Launch Systems Inc. - Promontory
Attachment 1 - Waste Analysis Plan
September 2008
UTD00908I357
1.0 WASTE ANALYSIS PLAN
Ll INTRODUCTION
1.1.1
1.2
1.2.1
This Waste Analysis Plan (WAP) was prepared to support the Part B permit re-issuance
for the ATK-Promontoty facility (ATK). The plan is intended to provide guidance and
assistance in sampling and testing ofthe two general categories ofhazardous waste at
ATK. These two groups include "reactive waste", and "chemical waste". The term
"reactive waste" consists of propellant and explosive waste, as defined in R315-2-9(1).
The term "chemical waste" is the term used to describe all non-reactive RCRA hazardous
waste, or unknown potential RCRA hazardous waste. This category could include
drummed waste, lab packs, bulk wastes, waste from offsite ATK facilities, etc. The plan
outlines a process for making a hazardous waste determination for both of these general
waste categories. This plan will be on file with the Environmental Services and
Operations group.
The WAP was developed to ensure that all reactive waste will be properly characterized
prior to being stored and/or treated. The WAP also outlines how chemical wastes that are
being stored priorto shipment to an offsite disposal facility will be characterized.
Information on these waste chemicals is obtained from process knowledge, MSDSs, and
chemical analysis.
Site History
ATK-Promontory (ATK) has been manufacturing explosives at this site for over 50
years. The facility manufactures rocket motors, military flares and related items.
WASTE ACCEPTANCE PROTOCOL
Acceptance of On-Site Reactive Waste for Storage and Treatment
All reactive wastes must be characterized before they can be accepted for storage or
treatment. The characterization will be accomplished through a profiling process which
will identify the type of reactive waste as defmed in R315-2-9(1) and determine whether
the waste exhibits any additional hazardous waste characteristics, and if it is listed in
accordance with R315-2-9 and 10 UAC. The reactive waste profile is completed through
process/generator knowledge, MSDS and testing, if needed. These profiles must be
completed and approved before any waste is accepted at the bum grounds. Each profile
includes the following infonnation:
Reactive material family name and general formulation type
Chemical composition with percentage ranges
US DOT hazard classification or suspected classification for developmental
materials
EPA codes
Physical characteristics
Underlying hazardous constituents (ifany)
Reactivite waste category as defined in figure 3-5
Packaging type and other applicable information
The profile approval process includes approval by the Generator, Safety and
Environmental Services
ATK Launch Systems Inc. - Promontory September 2008
Attachment 1 - Waste Analysis Plan UTD009081357
Any new propellants or other reactive wastes will be characterized as described above
before they are accepted for storage or treatment. Any waste that does not fit an existing
profile, must be profiled before the waste can be accepted. In the event that a reactive
waste cannot be properly characterized with existing information, additional information
will be obtained, which may include laboratory analysis.
Laboratory wastes can be characterized using generator knowledge. Upon receipt ofthe
reactive waste at permitted storage facilities, all containers are inspected to verify proper
labeling, and packaging. The total quantity and type of propellant is then recorded in the
facility operating record.
1.2.2 Acceptance ofHazardous Chemical Waste for Storage and Offsite Disposal
Hazardous chemical waste generated at the facility, and other ATK facilities are accepted
for storage at M-186. Upon receipt of all hazardous waste at M-186, all containers are
visually inspected to verify proper labeling, packaging and paper work. Upon
acceptance, a unique container number is recorded in the chemical waste tracking system.
All wastes received from an off site source have been characterized in advance, and are
assigned a container number at the time of delivery. These shipments are visually
inspected to verify that the type and quantity ofthe waste matches the profile and
manifest. The manifest numbers for off-site generated hazardous waste are entered into
the chemical waste tracking system upon acceptance.
Most waste generated on-site is characterized before arrival at the permitted facility,
through generator/process knowledge. However, some waste may be received at the
TSDF without characterization. When this occurs, sampling and testing ofthe waste
stream is conducted to properly characterize the waste.
Whenever a waste is accepted, all ofthe pertinent information on the waste is entered into
the operating record. This information shall, at a minimum, include the waste profile
description, EPA codes, quantity, date of generation, date received, storage location and
date it was shipped offsite for disposal,. The chemical waste tracking system will also
include the manifest number(s) for all hazardous waste received firom an oflF-site source
and all off-site shipments of hazardous waste to a TSDF. At a minimum the following
resources are used to help characterize chemical waste:
• R315-2 ofthe UAC
• Generator process knowledge
• MSDS
• Laboratory analysis
• National Institute for Occupational Safety and Health: Pocket Guide to Chemical
Hazards
1.2.3 Acceptance of Off-site Generated Reactive Waste
ATK periodically receives reactive waste from off-site ATK Launch Systems and non-
ATK Launch Systems facilities. This waste is accepted by ATK for storage prior to on-
site treatment at the M-136 bum grounds. All off-site generated wastes must be
approved in advance through a waste acceptance and profiling process. The waste profile
for wastes received from off-site contains the same infonnation as profiles for wastes
generated on-site (described above).
ATK Launch Systems Inc. - Promontory September 2008
Attachment 1 - Waste Analysis Plan UTD009081357
Before the waste is accepted, ATK reviews the shipping papers and visually inspects the
container(s) to confirm that container(s) and shipping papers agree and that the waste
description meets the previously approved waste profile. Discrepancies will be resolved
with the generator before the waste is accepted. After the waste has been visually
inspected and accepted by ATK, it will be entered into the reactive waste tracking
system. Buildings/areas authorized to store reactive waste, and quantity limits are
specified in Module III.
3.3 TESTING CRITERIA
3.3.1 Parameters and Rationale for Testing Reactive Wastes
Reactive waste may carry several waste codes, but will always carry a D003 waste code
for reactivity and such wastes are generally classified as explosives. Due to the inherent
hazardous nature of reactive wastes, this material is not routinely sampled or analyzed as
part ofthis WAP. In addition to classifying and characterizing the reactive waste
managed at the ATK facility, in accordance with R315-2 ofthe UAC, ATK will assess
emission hazards associated with the open buming of these hazardous wastes as required
in 40 CFR 264.601, Environmental Performance Standards. Figure 3-2 the Reactive
Waste Treatment and Disposal Decision Matrix, diagrams the steps and decisions that are
addressed whenever reactive wastes are treated and subsequently disposed.
3.3.2 Parameters and Rationale for Testing Chemical Waste
ATK generates two general categories of solid waste that can be defined as hazardous in
accordance with R315-2 ofthe UAC: 1) off-specification commercial chemical products,
and 2) spent materials. These wastes may be disposed of individually or consolidated
with other hazardous waste streams. Figure 3-3 the Chemical Waste Characterization
and Disposal Decision Matrix, identifies how ATK will decide whether a waste is
hazardous as defined by R315-2 ofthe UAC.
Off-specification commercial chemical products are chemicals that have not been altered
from their original manufactured formulation but are discarded for some reason. The
most common reason for discarding these chemicals is because they are no longer needed
or the shelf life has been exceeded. Under this scenario, generator knowledge can be
used to characterize these wastes. Detailed information on commercial chemical
products is available on the MSDSs.
A spent material is any material that has been used and as a result of contamination can
no longer serve the purpose for which it was produced without being processed or
reclaimed. ATK has process knowledge for most ofits spent material waste streams.
Annual evaluation will be performed to verify chemica] composition and concentration
ranges. All new or modified spent material waste streams will be initially assessed at the
point of generation and annually thereafter to maintain proper characterization of all
waste streams.
3.4 TEST METHODS AND SAMPLING
3.4.1 Test Method [40 CFR 264.13(b)(2)]
ATK will make a hazardous waste determination for all waste streams generated, stored
or treated onsite. This waste stream evaluation will be made utilizing process knowledge
and/or analytical testing. All analytical testing will be completed at a Utah certified
laboratory. Only EPA approved test methods, selected from the most current version of
SW-846 list ("Test Methods for Evaluating Solid Waste, Physical and Chemical
ATK Launch Systems Inc. - Promontory
Attachment 1 - Waste Analysis Plan
September 2008
UTD009081357
Methods"), will be used. Test method selection will be made, based on the most
applicable method as described in Chapter Two ofthe SW-846 publication. New test
methods will be used only after they have been approved by the EPA. The laboratory
will certify new methods during the annual certification process. Specific methods which
may be used to characterize wastes are listed in Figure 3-4.
3.4.2 Sampling Methods [40 CFR 264.13(b)(3), 261 Appendix I and UAC R315-8-2.4]
Waste sampled at the ATK facility consists of new waste, unknown waste, waste from
changed processes, and waste sampled for annual re-verification analysis. Representative
samples will be collected and handled in accordance with the procedures and protocols
identified in Table 3-1. At a minimum the following safety precautions are used when
sampling waste materials:
• Chemical resistant gloves and safety glasses will be used while sampling all
waste. Based on the chemical hazards and splash potential, protective clothing
and a splash shield or respirator may also be utilized.
• Non-sparking tools will be used to sample any waste that presents a fire hazard.
• All necessary equipment and materials will be available prior to sampling
Table 3-1
Waste Matrix
Free Flowing
Liquids/Slurries
Sludges
Moist
Powder/Granules
Dry
Powder/Granules
Sand/Packed
Powder
Large Grained
Solids
Debris (i.e. Rags,
Gloves, Towels,
etc.)
Container/Containment Type
Drums, Totes
Coliwasa
Trier/Spoon
Trier/Spoon
Thiei7Spoon
Auger/Spoon
Large
Trier/Spoon
Rag'
Boxes, Bags,
Sacks
N/A
N/A
Trier/Spoon
Thief/Spoon
Auger/Spoon
Large
Trier/Spoon
Rag'
Storage
Tanks
Pump/Dipper
N/A
N/A
N/A
N/A
N/A
N/A
Ponds,
Lagoons,
Pits
Dipper
N/A
N/A
N/A
N/A
N/A
N/A
Tankers
Dipper
N/A
N/A
N/A
N/A
N/A
N/A
Roll-Off Bins
N/A
Trier/Bucket/Shovel
Trier/Shovel
Thief/Shovel
Auger/Shovel
Large Trier/Shovel
Rag'
' The rag technique is used for sampling solid material such as rags, gloves and paper towels. After a
conlainer has been selected, il is opened and a representative sample collected and placed in the sample
container. One or more ofthe varied materials (e.g. gloves, tongue depressors, rags, paper, plastic, etc.) is
sampled depending on the mix ofthe container.
A variety of sampling equipment and materials will be used to collect waste samples,
reusable equipment will be washed with a detergent solution and thoroughly rinsed
All
ATK Launch Systems Inc. - Promontory
Attachment 1 - Waste Analysis Plan
September 2008
UTD00908I357
before re-use. Disposable equipment may also be used. This equipment and specified
sampling methods are described in the SW-846 publication.
Drummed consolidation waste will be randomly sampled each year as outlined in the
table below. "Average Monthly Drum Number" will be based on the previous calendar
years average monthly drum inventory, for each waste stream. Samples will be obtained
in the first quarter of each calendar year.
Table 3.1
Average Monthly Drum Number
2 to 8
9 to 27
28 to 64
65 to 125
126 to 216
217 to 343
344 to 512
Aliquots Selected
2
3
4
5
6
7
8
The above table is based on a table found in ASTM D 140-70, "Standard Methods of
Sampling Bituminous Materials," ASTM D 140-70.
All sample containers used during a sampling event will be new, and certified clean from
a reliable source. Container selection will be based on the chemical/container
compatibility, physical state and sample volume. A label will be attached to each sample
container which will include the following minimum information:
Sample number
Samplers name
Date
Time
Location
3.5
3.5.1
In addition to the information included on the label, the chain ofcustody, which
accompanies all waste characterization samples, will also include the following:
• Composite or grab sample
• Number of containers
• Remarks section
• Relinquishment signature block
All samples will be preserved as specified in SW-846 while in storage at ATK and while
in transit to the testing laboratory.
FREQUENCY OF ANALYSIS
Frequency of Analysis for Reactive Waste [40 CFR 264.13(b)(4) and UAC R315-8-
2.4]
Reactive waste treated at the ATK bum grounds come from various ATK Launch
Systems facilities, Autoliv ASP and occasionally from other Department of Defense
facilities or contractors. These reactive wastes are derived from energetic materials that
have been manufactured to strict specifications. Therefore, the chemical composition of
ATK Launch Systems Inc. - Promontory
Attachment I - Waste Analysis Plan
September 2008
UTD009081357
each formulation is well known. As discussed above, ATK characterizes all reactive
waste streams using generator knowledge. While these energetic waste streams are not
analyzed prior to being treated, ATK does review the reactive waste profile on an annual
basis or any time the manufacturing process changes.
3.5.2 Frequency of Analysis for Chemical Waste
The industrial processes at ATK generate a number of routine waste streams. Figure 3-1
shows major waste streams and processes generating those wastes. These waste streams
will be evaluated annually to verify waste characterization is still accurate. The waste
characterization will also be re-evaluated whenever the process that generated the waste
changes to determine if the process change altered the characteristics ofthe waste stream.
Off specification commercial chemical products are well characterized by the information
on their MSDSs. These wastes are not analyzed on a routine basis.
ATK- Promontory Waste Generation
Figure 3-1
Case Prep/Finishing Facility/Vehicle Maint Lab Waste Ground Water Carbon/Carbon
Offspec Oil
None
Note; The EPA codes induded above are primary codes only; The above list includes major waste streams only.
ATK Launch Systems Inc. - Promontory
Attachment 1 - Waste Analysis Plan
September 2008
UTD00908I357
Reactive Waste Treatment and Disposal Decision Matrix
Figure 3-2
Reactive Waste and Contaminated Materials
Treatinent
by OB
Large/solid
Debris
Positive
Visual
-( Reactivity
Inspection
Yes
Ash Residue
& Debris
Positi\e
Visual
Reactivity
Inspection
Negative RCRA
Non Haz"
Negative
Derived-From/
TCLP/UHC
Testina if needed
Non-Haz Solid
Waste Disposal
Waste
Profiled
No Waste nol accepted
For open burning
RCRA
Hazardous
Orsubject to IIDR
Haz Waste
Disposal
ATK Launch Systems Inc. - Promontory
Atlachment 1 - Waste Analysis Plan
September 2008
UTD00908I357
Chemical Waste Disposal Decision Matrix
Figure 3-3
RCRA Solid W aste
Is this an Exempt
Solid W aste
N on-H azardous
D isposal
Based on Process
K now ledg e / M S D S ,
is the waste listed in
Part 26 1 subpart D ?
Based on process
knowledge / M SDS.
does the waste exhibit
my characteristics specified
in 26 1 subpart C ?
Based on
Lab analysis
Based on
Lab analysis
fs the waste listed
or characte ris tic
N o
Non-hazardous disposal
Hazardous waste management
and disposal
Y es
ATK Launch Systems Inc. - Promontory
Attachment 1 - Waste Analysis Plan
September 2008
UTD009081357
Figure 3-4
Parameter
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Analytical Methods for Metals
Analytical Method
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA7470A(W)&7471A(S)
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 60IOB
EPA 601 OB
EPA 60IOB
Preparation Method *
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA7470A(W)&7471A(S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
EPA 3005A (W) & 3050B (S)
Parameter
Volatle Organics
Semivolatile Organics
TPH
TOC
Oil & Grease
Analytical Methods for Organics
Analytical Method
EPA 8260B
EPA 8270C
EPA 80I5B
EPA 9060A (W only)
EPA 1664A(Wonly)
Preparation Method
EPA 5030B (W) & 5035 (S)
EPA3510C(W)&3550B(S)
EPA3510C(W)&3550B(S)
EPA 9060A (W only)
EPA 1664A(Wonly)
Miscellaneous Test Methods
Parameter
pH
Ignitability
Toxicity
Explosives
Perchlorate
Anions
TSS
TS
Analytical Method
EPA 9040C (W) & 9045D (S)
EPA I010A(W only)
EPA 601 OB/7470 A (Metals)
EPA 8260B (Volatile Organics)
EPA 8270C (Semivolatile Organics)
EPA 8330 .
EPA 314.0
EPA 9056A
SM2540D
SM2540B
Preparation Method
EPA 9040C (W) & 9045D (S)
EPA lOlOA(Wonly)
EPA I311/3010A
EPA131I/5030B
EPA131I/3510C
EPA 8330
EPA 314.0
EPA 9056A (W) & 5050 (S)
SM 2540D
SM 2540B
* The ' W indicates a water matrix. Samples that are water soluble liquids (or aqueous phase) fit into this
category. Non-aqueous liquids are usually treated as solids depending on the test method. In the case of an
oil matix that cannot be analyzed by the solid preparation method, a waste dilution is often performed. The
'S" indicates a solid matrix.
10
ATK Launch Syslems Inc. - Promontory
Attachment I - Waste Analysis Plan
September 2008
UTD00908I357
Figure 3-5
REACTIVE WASTE CATEGORY
Group
A
B
C
D
E
F
G
H
Description
Class 1.3 Composite Propellant without HMX, RDX or
CXM-3
Class 1.3 Composite Propellant with HMX, RDX or CXM-3
Class 1.1/1.3 Nitrate Ester Containing Material
High Explosive Material
Class 1.3 Pyrotechnic, Illuminants, Metal Powders, or
Autoliv ASP Products
Oxidizers (does not include high explosives such as HMX,
RDX or CXM-3)
Developmental Materials-R&D Lab Use Only(small
quantity)
Unique Waste (small quantity)
11
ATK Launch Systemslnc. - Promontory September 2008
Attachment 2-InspectionScheduIes and Procedures UTD009081357
ATTACHMENT 2
INSPECTION SCHEDULES AND PROCEDURE
ATK Launch Systemslnc. - Promontory September2008
Attachment 2- InspectionScheduIes and Procedures UTD009081357
INSPECTION SCHEDULES AND PROCEDURES
ILA. 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 of the
schedule promotes the detection of malfunctions, deterioration, discharges, and
other situations which may be causing or leading to a release ofhazardous waste
constituents into the enviroimient 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.
Inspections are conducted by personnel trained to identify potential problem areas
and to use the inspection schedule and the inspection log. The T-29B hydrazine
dilution process uses a UN dnmi in which treatment occurs. The hydrazine waste
collection tank is tested and certified annually.
The Permittee may discontinue inspections ofa storage facility during extended
periods of inactivity, as approved by the Executive Secretary. A facility must be
inspected, however, prior to receiving hazardous waste for storage or treatment if
inspections were discontinued during the period of inactivity. Ifany problems are
identified with the areas of concern that are listed in the inspection schedules
(contained in this attachment), they must be corrected before the facility is put
back into use.
II.B. Remedial Action or Maintenance
Repairs or corrective action for any deterioration or malfunction discovered by an
inspection shall be conducted as outlined in Module II, Section F. Repairs to
security equipment shall be completed as soon as practicable, but not later than 72
hours after the problem is discovered. As stated in R315-8-2.6(c), where a hazard
is imminent or has already occurred, remedial action shall be taken immediately.
II.C. Inspection Records
All records of inspections and remedial actions shall be retained in the Operating
Record, for a period of at least three years. At a minimum, inspection records
shall include the date and time ofthe inspection, the name ofthe inspector, a
notation ofthe observations made, and the date and nature of any repairs or
maintenance taken.
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD00908I357
II.D. Inspection Schedules
The inspection schedules appear in detail in Tables II-A through II-F. Each
inspection schedule is designed so that the items appearing on the schedule are
inspected frequently enough to avoid any deterioration of equipment and thus
reduce the probability of an environmental or human health incident between
inspection times. Each inspection schediile is divided into individual categories
and each category contains a specific list of items to be inspected. Inspections are
also required within 24 hours after a storm event as outlined in the schedules
below. A storm event is defined as precipitation in excess of 1.0 inch in a one-
hour period. It shall be documented in the inspection log that the inspection was
conducted in response to a storm event.
TABLE II-A
INSPECTION SCHEDULE FOR DRUM STORAGE AT JVH86
EOUIPMENT
1. Security Equipment
Fences
Signs
Gates
Lock
2. Area
Roadway
Loading/
Unloading Areas
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Weekly
Daily'
Daily'
Periphery Daily'
AREAS OF CONCERN
Visually inspect all fence lines and look for
broken or downed fence lines, loose wires
Readable signs, signs in place
Able to properly close gate, safety
flags in place
In working order, able to lock
Inspect road for spills,
soil discoloration
Inspect loading areas for
spills, soil discoloration
Inspect groimds for any spills, soil
discoloration or stressed vegetation
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
3. Safety Equipment
Eyewash/Shower Monthly Ensure in working order by
testing, check water supply
Telephone/Radio Monthly
4. Storage Containment
Containers Weekly
Pads Weekly^
Sumps/Pads
Drainage Area
Roof
5. Emergency Equipment
Fire
Extinguisher
Absorbent
Repack Drums
55-Gallon dmms
Generator
Pump
Daily'
Weekly^
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Working condition
Number ofcontainers, severe
corrosion (i.e., flaking, large rust buildup,
msty bungs), dented dmms, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums,
adequate aisle space (2.5 feet)
Chips, cracks,or irregularities in concrete,
general condition
Standing liquid on pad or in sumps
Spills, discolored soil
General condition including holes or defects
Fire extinguisher full, in working order
Adequate supply (minimum 25 lbs)
Two repack dmms with seals
Six empty 55-gallon dmms with bungs
in good condition, no dents, etc.
Routine oil check, fill with gas, test startup
Good working order, hoses intact, test
startup and pump
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
When in use
And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.
TABLE II-B
INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-136
AREAS OF CONCERN
Visually inspect all fence lines, look for
loose wires or broken lines
Readable signs, signs in place
Able to properly close gate
In working order, able to lock
Spills, discolored soil
Spills, discolored soil
Spills, discolored soil, stressed vegetation
1.
2.
3.
4.
EOUIPMENT
Security Equipment
Fences
Signs
Gates
Lock
Area
Roadway
Loading/
Unloading Areas
Periphery
Safety Equipment
Telephone/Radio
Bum Ground Area
Erosion
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Weekly
Daily'
Daily'
Daily'
Monthly
Weekly^
Check operating condition of equipment
Survey area and note severe erosion on
grounds
5. Storage/Containment
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD00908I357
Bum tray Weekly 2,3
Container Weekly
6. Emergency Equipment
Fire
Extinguisher Monthly
Tray is intact and liquid tight, accumulation
of liquids
Closed, labeled, signs of leaks or spills
Fire extinguisher full and in working order
1 When in use
2 Inspect upon arrival, then each calendar week
3 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.
TABLE II-C
INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-225
AREAS OF CONCERN EOUIPMENT
1. Security Equipment
Fences
Signs
Gates
Lock
2. Area
Roadway
Loading/Unloading
Areas
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Weekly
Daily'
Daily'
Visually inspect all fence lines, look for
loose wires or broken lines
Readable signs, signs in place
Able to properly close gate
In working order, able to lock
Spills, discolored soil
Spills, discolored soil
Periphery Daily' Spills, discolored soil, stressed
ATK Launch Systemslnc. - Promontory
Attachment 2-InspectionScheduIes and Procedures
3. Safety Equipment
Telephone/Radio
4. Bum Ground Area
Erosion Weekly
Bum Tray Weekly
5. Emergency Equipment
Fire Extinguisher Monthly
September 2008
UTD009081357
vegetation
Monthly Check operating condition of equipment
Survey area and note severe erosion on
grounds
Tray is intact and liquid tight, accumulation
of liquids
Fire extinguisher full and in working order
' When in use
"^ And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.
TABLE II-D
INSPECTION SCHEDULE FOR STORAGE AND CONSOLIDATION
ROOM AT M-705S
EOUIPMENT
MINIMUM
FREOUENCY
1. Security Equipment
Signs Weekly
2. Area
Roadway Daily'
Loading/Unloading Daily'
Areas
Periphery Daily'
AREAS OF CONCERN
Readable signs, signs in place
Spills, discolored soil
Spills, discolored soil
Spills, discolored soil, stressed
vegetation
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
3. Safety Equipment
Eyewash/Shower Monthly
Telephone/Radio Monthly
4. Storage containment
Containers Weekly
Pads, Sumps Weekly
Portable Secondary Daily
Roof Weekly
Sump, pads Daily'
5. Emergency Equipment
Fire Extinguisher Monthly
Absorbents Monthly
Repack Drums Monthly
55-Gallon Drums Monthly
Ensure in working order by testing,
check water supply
Check operating condition of equipment
Number ofcontainers, severe corrosion (i.e.
flaking, large mst buildup, msty bungs),
dented dmms, hazardous waste labels in
place, properly marked, readable, no open
bungs, no standing liquid on the dmms
Chips, cracks, or irregularities in the
concrete, general conditions
Cracks, liquid, containment integrity
General condition including holes or defects
Check for standing liquids in the sump and
containment system
Fire extinguisher full and in working order
Adequate supply (minimum 25 lbs.)
Two repack dmms with seals
Six empty 55-gallon dmms with bungs in
good condition, no dents, etc.
When in use
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
TABLE II-E
INSPECTION SCHEDULE FOR M-47, M-603
EOUIPMENT
1. Security Equipment
Signs
Bay Doors
Lock
2. Area
Roadway
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Daily'
Loading/Unloading Areas Daily
Periphery
3. Communications Equipment
Telephone
4. Storage Containers
Motors/bags, etc.
Building
Roof
Daily'
Monthly
Weekly
Weekly
Weekly
AREAS OF CONCERN
Readable signs, signs in place
Fimction properly
Function properly
Inspect road for spills, soil
discoloration
Inspect loading areas for spills, soil
discoloration
Inspect grounds for any spills, soil
discoloration or stressed vegetation
Working condition; place
call to verify operation
Verify condition of motors/bags,
properly marked and labeled, out of
place material and check for leakage,
or liquid discharge from waste solid
rocket motors and propellant.
Verify no damage done to exterior of
facility
General condition including holes or
defects
ATK Launch Systemslnc.-Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
5. Emergency Equipment
Fire Extinguisher Monthly In working order and full
When in use
TABLE II-F
INSPECTION SCHEDULE FOR DRUM STORAGE PAD AT E-501
EOUIPMENT
1. Security Equipment
Fences
Signs
Gates
Lock
2. Area
Roadway
Loading/
Unloading Areas
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Weekly
Daily'
Daily'
Periphery Daily'
3. Safety Equipment
Eyewash/Shower Monthly
AREAS OF CONCERN
Visually inspect all fence lines and look for
broken or downed fence lines, loose wires
Readable signs, signs in place
Able to properly close gate, safety
flags in place
In working order, able to lock
Inspect road for spills,
soil discoloration
Inspect loading areas for
spills, soil discoloration
Inspect grounds for any spills, soil
discoloration or stressed vegetation
Ensure in working order by
testing, check water supply
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
Telephone/Radio Monthly
4. Storage Containment
Containers Weekly
Pads
5. Emergency Equipraent
Weekly
Sumps/Pads
Drainage Area
Roof
Daily'
Weekly^
Weekly
Fire
Exfinguisher
Absorbent
Repack Dmms
55-Gallon dmms
Monthly
Monthly
Monthly
Monthly
Working condition
Number ofcontainers, severe
corrosion (i.e., flaking, large mst buildup,
msty bungs), dented dmms, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on dmms,
adequate aisle space (2.5 feet)
Chips, cracks,or irregularities in concrete,
general condition
Standing liquid on pad or in sumps
Spills, discolored soil
General condition including holes or defects
Fire extinguisher full, in working order
Adequate supply (minimum 25 lbs)
One repack dmm with seals
Three empty 55-gallon drums with bungs
in good condition, no dents, etc.
When in use
And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD00908I357
TABLE II-G
INSPECTION SCHEDULE FORT-29 Hydrazine Dilution Bay
EOUIPMENT
MINIMUM
FREOUENCY AREAS OF CONCERN
1. Security Equipment
Signs Weekly' Readable signs, signs in place
Door Locked
2. Area
Roadway
Periphery
Weekly'
Daily'
Loading/ Daily'
Unloading Areas
Daily'
3. Safety Equipment
Eyewash/Shower Monthly
In working order, locked
Inspect road for spills,
soil discoloration
Inspect loading areas for
spills, soil discoloration
Inspect grounds for any spills, soil
discoloration or stressed vegetation
Ensure in working order by
testing, check water supply
Telephone(cell)
4. Storage Containment
Containers
Floor
Monthly
Weekly'
Weekly'
Working condition
Number ofcontainers, severe
corrosion (i.e., flaking, large mst buildup,
rusty bungs), dented dmms, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on dmms
Chips, cracks,or irregularities in concrete,
general condition
ATK Launch Systemslnc. - Promontory
Attachment 2- InspectionScheduIes and Procedures
September 2008
UTD009081357
Roof
5. Emergency Equipment
Fire
Extinguisher
Absorbent
Collection tank
' When in use
Weekly'
Monthly
Monthly'
Annual
General condition including holes or defects
Fire exfinguisher full, in working order
Adequate supply (minimum 25 lbs)
Verify certificafion
ATTACHMENT 3
PERSONNEL TRAINING
ATK Launch Systemslnc. - Promontory September 2008
Attachment 3-Personnel Training UTD00908I357
Annual On-Going Up-Date Training
Outline
I. Introduction to Hazardous Waste
A. Major Laws
B. Govemment Publicafions (29, 40, 49 CFR)
C. EPA, DOT, OSHA Interface
II. Hazardous Waste Determination
A. 40 CFR 261
III. Hazardous Waste Accumulation Areas
A. 40 CFR 262.34
IV. Container Management
A. 40 CFR 265 Subpart I
V. DOT Shipping Criteria
A. 49 CFR 172.101
VI. Reportable Quantities
A. 49 CFR 172.101 Appendix
VII. Implementation ofthe Contingency Plan
Training is held throughout the year for all TSDF operators that handle or are expected to handle
hazardous waste.
ATK Launch Systemslnc. - Promontory September 2008
Attachment 3-Personnel Training UTD00908I357
OUTLINE FOR THE TRAINING OF PERSONNEL WHO
GENERATE, PICKUP/TRANSPORT/DISPOSE OF, AND MANAGE
HAZARDOUS WASTE
INTRODUCTION
This training will teach employees and contractors (if they work with hazardous waste) to
properly handle, pickup/transport/dispose of, and manage hazardous waste. It will enable
employees to safely handle hazardous waste and ensure that facility personnel are able to respond
effectively to emergencies in order to protect human health and the environment. It will also
ensure that the Company is in compliance with all applicable laws and regulations as they pertain
to training.
AUDIENCE
The audience is made up of three major groups. 1) Those individuals who generate hazardous
waste. 2) Personnel who pickup, transport, and dispose of hazardous waste. 3) The technical
people who manage hazardous waste operations at the Company.
ATK Launch Systemslnc, - Promontory September2008
Attachment 3- Personnel Training UTD009081357
CONTENT OF THE PROGRAM: REOUIRED FOR
(The employee will be able to:) GROUP^s)
1) Define hazardous waste terms 1,2,3
2) Understand the importance of and follow procedures 1,2,3
3) List characterisfics ofhazardous waste 1,2,3
4) List various hazardous waste materials 1,2,3
5) List examples of and consequences of improper disposal 1,2,3
6) Comply with Federal and State Laws 1,2,3
7) Comply with Company 1,2,3
8) List the major functions performed in their work area as 1,2,3
related to hazardous waste
9) List their job responsibilities as related to hazardous waste 1,2,3
10) Use resources and references related to hazardous waste 1,2,3
11) Operate various hazardous waste handhng equipment 1,2
12) Proper use of safety equipment 1,2,3
13) Avoid shortcuts when handling hazardous waste 1,2,3
14) Proper use of monitoring equipment 2,3
15) Identify hazardous waste 1,2,3
16) Segregate incompatible materials 1,2,3
17) Proper useof package materials 1,2,3
18) Label materials 1,2,3
19) Inspection requirements for TSDFs 2
20) Requirements for the pickup of hazardous waste 2,3
21) Requirements for the transport of hazardous waste 2,3
22) Dispose of hazardous waste in a timely manner 1,2
23) Respond properly under emergency conditions 1,2,3
24) Procedures to cleanup spills 1,2,3
25) Understand the importance of properly handling and 1,2,3
disposing ofhazardous waste to protect employees and the
environment
26) Understand the basis for these requirements 1,2,3
ATK Launch Systemslnc. - Promontory September 2008
Attachment 3-Personnel Training UTD00908I357
APPROACH
The training is divided into the following three categories:
1. Orientafion training. Items number 1, 2, 3,4, and 5 and parts of number 6, 7, 8, and 9
listed above will be covered in orientation training. These items will also be
reinforced on the j ob.
2. Formal. Stmctured on-the-iob-training. Parts of items 6, 7, 8, and 9 and items 10
through 26 will be covered on the job.
3. Specialtv training. This is classroom instruction indirectly related to hazardous waste
operations. Some of these courses are: Asbestos, Propellant Material Handling,
Environmental awareness and Hazardous Waste Disposal and Hazardous Waste for
Dock Coordinators. All training must be recorded.
Employees will not be allowed to handle hazardous waste unsupervised until they have
successfully completed the training program. Training will be completed within six months of
the employee's hire date. There will also be annual refresher training (similar to new hire
training) conducted for all employees affected by the program to assure they are always
adequately trained. This training will consist of, at a minimum, a review of their inifial training
in both contingency procedures and the hazardous waste management procedures relevant to the
posifions in which they are employed. All training will be evaluated to ensure compliance and
safety. Performance will be measured against specific standards set out at the beginning ofthe
program.
TRAINING DOCUMENTATION
The following documents and records will be maintained at the facility and made available for
review by DSHW upon request:
1. The job title for each position at the facility related to hazardous waste management,
and the name ofthe employee filling each job;
2. A written job description for each position listed under number one above. The
descripfion will include the requisite skill, education, or other qualificafions and
dufies ofthe employees assigned to each position;
3. A written description ofthe type and amount of both introductory and continuing
training that will be given to each person filling a posifion under number one above.
4. Records that document that the required training or job experience has been given to,
and completed by the appropriate personnel;
Records ofthe training will be kept until closure ofthe facility or for three years after the
employee leaves the Company.
ATK Launch Systemslnc. - Promontory September 2008
Attachment 3-Personnel Training UTD009081357
CONCLUSION
The training program presented in this outline is made up of a number of different components,
all ofwhich work together and supplement each other. All of these components are under the
guidance, supervision, and management ofa combinafion of professional trainers, line
supervision, and hazardous waste management professionals. The trainers are skilled in current
instructional technologies, have appropriate educational backgrounds, and the work experience to
qualify them for this assignment. Much ofthe training is already being done in one form or
another. Throughout its life, the program will continue to be evaluated and revised. This will
assure that it is continually improved, current, and in compliance. The program will meet the
needs ofthe employees, the environment, the law, and the Company.
HAZARDOUS WASTE MANAGEMENT
Contingency Plan and
Emergency Procedures
For Spills of
Hazardous Materials
July 2008
ATK Launch Svstems
Promontory Plant
P.O. Box 689 Brigham City UT 84302-0689
[phone]
ATK Launch Systems- Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
PREFACE
This document, HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES FOR SPILLS OF HAZARDOUS MATERIALS, (herein refeired to as Contingency Plan), provides
written instructions on how to take care of spills ofhazardous substances. It is intended to meet the requirements of
the Utah Hazardous Waste Rules and Subpart D of the EPA Resource Conservation and Recovery Act.
This CONTINGENCY PLAN does not replace, nor is it to be used instead of, the ATK Launch Systems -
Promontory EMERGENCY AND DISASTER RESPONSE PLAN, or any other plan which outlines procedures to
be followed during general emergencies, disasters, civil disturbances, riots, bomb threats, etc.
Most spills involving hazardous substances will not require use ofthe EMERGENCY AND DISASTER
RESPONSE PLAN. Spills that create an emergency situation involving possible injury to personnel or damage to
property will require use ofthe EMERGENCY AND DISASTER RESPONSE PLAN to take care ofthe emergency.
This CONTINGENCY PLAN applies to containment and cleanup of a hazardous waste spill.
Definitions in the HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES reflect EPA and State of Utah environmental language while those in the EMERGENCY AND
DISASTER RESPONSE PLAN reflect OSHA, UOSH, FEMA, and ATK Launch Systems language. The user must
be careful not to be confused by differences in language between these documents and must evaluate the
applicability of each document to the particular situation.
ATK Launch Systems- Promontory September 2UU8
Attachment 4 - Contingency Plan UTD009081357
TABLE OF CONTENTS
INTRODUCTION
A. PURPOSE...,
B. SCOPE
C. NOTIFICATION
D. POSTING
E. REVISIONS AND UPDATING
F. DEFINITIONS 2
G. PLANT LOCATIONS AND SITE INFORMATION 5
H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES 7
II. REPORTFNG PROCEDURES AND INCIDENT IDENTIFICATION 7
A. EVACUATION CRITERIA 7
B. IDENTIFICATION OF A HAZARDOUS WASTE FN A SPILL 7
C. REPORTING OF EMERGENCY INCIDENTS 8
D. PERSONNEL RESPONSIBILITIES 8
E. ALARM SYSTEMS 19
F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND
HOSPITALS 15
III. SPILL CONTAINMENT AND CLEANUP 16
A. CONTROL PROCEDURES 16
B. SPILL CONTAFNMENT AND CONTROL 16
C. SPILL CLEANUP 16
D. FOLLOWUP PROCEDURES 17
E. fNCOMPATIBLE WASTE 18
F. CLEANUP MATERIAL AND EQUIPMENT 18
G. DECONTAMfNATlON EQUIPMENT AND PROCEDURES 20
H. EQUIPMENT DECONTAMfNATlON AND REPLENISHMENT 20
IV. INSTALLATION RESPONSE TEAM TRAINING 21
A. TRAINING 21
B. SIMULATION 22
V. TRAINING PLAN 22
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN 22
B. REVIEW OF LEGAL REQUIREMENTS 22
C. LOCAL ATK CORPORATION REQUIREMENTS 22
D. CUSTOMER REQUIREMENTS 22
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER . 22
F. EMERGENCY COMMUNICATION SYSTEM 22
G. FIRE PLANS/FIRE DRILL 22
H. BOMB SEARCH TECHNIQUES 22
I. FIRE BARRICADE/CORDON AREAS 23
J. EMERGENCY MEDICAL TREATMENT 23
K. SECURITY OF SITE 23
L. INVESTIGATION 23
M. PUBLIC RELEASE OF INFORMATION 23
N. FACT-FINDING METHODS 23
O. SAFING THE AREA 24
P. CONTROL OF THE CURIOUS 24
ATK Launch Systems- Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
Q. HANDLING OF REMAINS 24
R. NOTIFICATION PROCEDURES 24
S. RESCUE EFFORTS 24
TABLES
TABLE I COMPATIBIUTY INFORMATION 25
TABLE II EMERGENCY COORDINATOR CALL LIST 26
FIGURES
FIGURE! DECONTAMINATION/SPILL SCENE : 27
FIGURE 2. DECONTAMINATION 28
APPENDIX I
NORTH PLANT SITE MAP 30
SOUTH PLANT SITE MAP 31
TEST AREA SITE MAP 32
PLANT 3 SITE MAP 33
M-136 BURNING GROUNDS FACILITY FUNCTION TABLE 34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE 34
M-136 SITE MAP AND EVACUATION PLAN 35
M-l 86 SITE MAP AND EVACUATION PLAN 36
E-501 STORAGE YARD FACILITY FUNCTION TABLE 37
E-501 SITE MAP AND EVACUATION PLAN 38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE 39
M-225 SITE MAP AND EVACUATION PLAN 40
T-29B SATELLITE ACCUMULATION AREA FUNCTION TABLE 41
T-29B SITE MAP AND EVACUATION PLAN 42
M-705 WASTEWATER TREATMENT FACILITY FUNCTION TABLE 43
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM 43
M-705 SITE MAP AND EVACUATION PLAN 44
M-47 PROPELLANT STORAGE FUNCTION TABLE 45
M-47 SITE MAP AND EVACUATION PLAN 46
M-603 PROPELLANT STORAGE FUNCTION TABLE 47
M-603 SITE MAP AND EVACUATION PLAN 48
ATK Launch Systems-Promontory September 2008
Attachment 4 - Contingency Plan . UTD009081357
APPENDIX II
A. BULK FLAMMABLE LIQUID STORAGE AREAS 50
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE 51
APPENDIX III
ARRANGEMENTS WITH LOCAL AUTHORITIES 52
ATK Launch Systems- Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
L INTRODUCTION
A. PURPOSE
This plan may be activated by requesting emergency response on phone number 2222 or 911.
The purpose ofthis Contingency Plan and Emergency Procedures is to set forth responsibilities,
establish organizational structure, and outline the procedures required to ensure effective waming,
response, and control to minimize hazards to human health or the environment from fires, explosions,
or any unplaimed sudden or non-sudden release ofhazardous waste or hazardous waste constituents to
air, soil, or surface water.
B. SCOPE
This organizational plan is intended to meet requirements ofthe Utah Hazardous Waste Management
Rules and Subpart D ofthe Resource Conservation and Recovery Act.
The provisions ofthis plan will be carried out immediately whenever there is a fire, explosion, or
release ofhazardous waste or hazardous waste constituents at one ofthe permitted facility that could
threaten human health or the envirorunent. This plan specifically addresses company actions to be
initiated in the event ofa spill or release ofhazardous materials.
C. NOTIFICATION
Incidents covered by this contuigency plan and which meet applicable State of Utah and U.S. EPA
reporting requirements will be reported to the appropriate agencies by Environmental ^ecialists. The
Environmental Specialist should confer with the Director or Manager of Environmental Services prior
to notification.
D. POSTING
Copies ofthe Contingency Plan and all revisions must be:
1. Maintained at the facility and the Fire Department's Spill Response vehicle.
2. Submitted to all local police departments, fire departments, hospitals, and State and local
emergency response teams that may be called upon to provide emergency services.
(Arrangements have been made between ATK Launch Systems- Promontory and the hospitals
located at Brigham City and Tremonton regarding emergency services that would be provided as
required. Letters of agreement are kept in the Envirotmiental Services Central Files.)
E. REVISIONS AND UPDATING
This contingency plan will be reviewed and amended whenever:
1. Applicable regulations are revised.
2. The plan fails in an emergency.
3. The facility changes its design, construction, operation^ maintenance, or other circumstances in
a way that materially increases the potential for fires, explosions, or release ofhazardous waste
or hazardous waste constituents, or changes the response necessary in an emergency.
ATK Launch Systems- Promontory September 2008
Attachment 4 - Contingency Pian UTD00908I357
4. The list of emergency coordinators change.
5. The list of emergency equipment changes.
F. DEFINITIONS
1. Disaster - An event in which loss of life, serious and/or multiple injuries, major property or
environmental damage, or major disrupfion of normal operaions has occurred. This includes
serious fires or major hazardous material spills, explosions, injuries to multiple people, and acts
of nature such as floods, violent storms, or earthquakes.
2. Discharge - The accidental or intentional spilling (see Spill), leaking, pumping, pouring,
emitting, emptying, or dumping ofhazardous waste on or into the air, land, or water.
3. Emergency - A situation which, if not quickly controlled, can lead to death, serious and/or
multiple injuries, major loss or damage to property, significant damage to the environment, or
disruption of normal operations.
4. Emergency Command Unit - The group of personnel selected by the emergency commander to
assist in the fiill scope administration ofthe emergency.
5. Emergency Commander - The General Manager or his designee, as head ofthe Command
Unit, is responsible forthe overall direction, coordination, and function of all units charged with
providing countermeasures to cope with conditions and/or events within the scope of ths plan.
The Command Unit will consist of any and all persons selected by the Emergency Commander.
NOTE
The Emergency Commander -will be the head ofthe Command
Unit for all civil disturbances, bomb threats, national
emergencies, and natural disasters.
The Command Unit will operate from a pre-designated Emergency Operations Center specified
by the Emergency Disaster Response Plan or the Emergency Commander.
6. Emergency Operations Center (E.O.C.) - The location of senior management where decisicns
and incident specific policies are made.
7. Environmental Specialist - The Environmental Specialist is the Spill Team Leader from
Environmental Services. He or his designated altemate will assist the Incident Commander in
the evaluation ofthe impact on the environment resulfing from any emergency, disaster, or
hazardous substance discharge.
NOTE
When required, notification of Federal, State, and/or local
environmental agencies shall be through the Environmenial
Specialist. Company policy requires that the event be discussed
with the Vice President ofthe applicable division and ATK
Corporate Environmental.
Fire Brigade - A group of employees, generally from maintenance, who have received
HAZWOPER training and are called on as needed to assist the full-time fire department in
emergency response.
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September 2008
UTD009081357
9. Fire Warden - A designated individual assigned in advance to assist the fire department in
evacuation procedures and give information on the building and surrounding area.
10. Hazardous Waste - Identified in 40 CFR 261 and in Utah Hazardous Waste Management Rules,
Section 2.1 on the basis of specific listed material and general characteristics. Specific listed
wastes are found in these documents. The EPA regulations provide detailed technical
specifications of four characteristics:
Ignitable (DOOl)-
Cortosive (D002) -
Reactive (D003) -
An ignitable compressed gas, an oxidizer, a liquid having a flashpoint <
140^F, or a non-liquid capable of causing fire, under standard temperature
and pressure, through friction, absorption, moisture, or spontaneous chemical
changes.
A solid waste that (1) is aqueous and has a pH < 2 or > 12.5; or (2) is a
liquid and has a corrosion rate > 0.25 inches/year on steel.
A solid waste that:
a. Is unstable and readily undergoes violent change without detonafing.
b. Reacts violently with water.
c. Forms potentially explosive mixtures with water.
d. Generates toxic gases, vapors or fiimes in a quantity sufficient to present
a danger to human health or the environment when mixed with water.
e. Is a cyanide or sulfide bearing waste which can generate toxic gases,
vapors, or fiimes in a quantity sufficient to present a danger to human
health or the envirotmient when exposed to pH conditions between 2 and
12.5.
TCLP Toxicity - (as determined by Toxicity Characteristic Leachate Procedures)- Presence of
certain listed toxic materials at levels greater than those specified in the
regulation.
11. Hazardous Communication Web (Haz Com Web)- a computer based system which contains
a scaimed image ofthe MSDS, plus additional safety and disposal information.
12. Hazardous Waste ProHle Data (HWPD) Sheet - An ATK document that lists all EPA, DOT,
and chemical information needed for marking, labeling, and identifying waste streams on plant.
13. Hazardous Waste Operations and Emergency Response (HAZWOPER) - Refers to specific
training requirement for handling hazardous materials and for emergency operations. These
requirements are found in 29 CFR 1910.120.
14. Human Resource Coordination - An intermediate between management and personnel who
deals with employee concems and interests.
15. Incident Commander/Emergency Coordinator - The Incident Commander will be the on-duty
Assistant Fire Chief/Incident Commander.
The Incident Commander will direct the activities of all Field Units from a designated control
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ATK Launch Systems - Promontory September 2008
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point at the scene ofthe emergency, disaster, or other event.
The Security Manager will be the Incident Commander for countermeasures in situafions caused
by hostile persons.
The Fire Prevenfion Captain will act as Incident Commander until relieved by an Assistant Fire
Chief
The following items are identified as principles for the Emergency Commander and Incident
Commander to apply to the unique circumstances ofthe emergency or disaster:
a. Assist the injured.
b. Stabilize situation and site.
c. Assure evidence is not destroyed, lost, or moved.
d. Record situation through text, photographs, videos, and/or mapping.
e. Notify State and local officials.
f Secure and admit only qualified essential personnel to the site,
g. Debrief participants.
16. Material Safety Data Sheet (MSDS) - Provides information on safe handling , proper PPE, and
disposal information for each chemical. This document is prepared by the chemical manufacture.
For additional information, contact your local Industrial Hygienerepresentative.
17. Non-sudden Release - The accidental discharging (see Discharge), spilling, leaking, pumping,
pouring, emitting, emptying, or dumping ofhazardous wastes or materials which, when spilled
become hazardous wastes, into or on any land or water over an extended period of time. This
also includes spills onto asphalt or concrete pads.
18. Post Emergency Remediation Team - A group of employees made up of environmental
professionals and technicians who have received appropriate training as stated in 29 CFR
1910.120 for hazardous waste operations and who respond to post emergency remediation
projects as needed.
19. Reportable Spill (Discharge) - A hazardous waste spill which must be reported to the Utah
Department ofEnvironmentai Response and Remediation, National Response Center and/or
other applicable Federal, State or local authorities. The Utah Hazardous Waste Management
Rules list reportable spill quantities as:
a. One kilogram (2.2 lb) of material in accordance with R315-9-1(b)(1). A spill ofa lesser
quantity must be reported if there is a potential threat to human health or the environment.
b. One-hundred kilograms (220 lb) ofhazardous waste or material which, when spilled,
becomes hazardous waste, in accordance with R315-9-1(b)(2). A spill ofa lesser quantity
must be reported if there is a potential threat to human health or the environment.
c. Subpart J of 40 CFR Part 265 ofthe Resource Conservation and Recovery Act sfipulates
that a spill of 1 lb fi-om a leaking hazardous waste sump is a reportable quantity.
ATK Launch Systems-Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
NOTE
For complete descriptions and listings, contact Environmental
Services or refer to R3I5-9 ofthe Utah Hazardous Waste
Management Rules.
The following is a partial list of materials used at ATK and the quanfities which, if spilled, would
require State or Federal notification:
EPA Utah
Material
Acetone
Methanol
Methylchloroform
Methylene Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Nitroglycerin
Propellants, reactive
materials (HMX)
oxidizers (AP)
Sodium Azide
Toluene
Xylene
Quantity
5000 lbs.
5000 lbs.
1000 lbs.
1000 lbs.
5000 lbs.
5000 lbs.
10 lbs.
100 lbs.
1000 lbs.
1000 lbs.
IOO Ibs.
Quantitv
220 lbs.
220 lbs.
220 lbs.
220 lbs.
220 lbs.
220 lbs.
2.2 lbs.
220 lbs.
2.2 lbs.
220 lbs.
220 lbs.
A more complete list of reportable quantities is found in GM3.1, Table IX.
20. Solid Waste - Any discarded material that is a solid, liquid, semi-solid or contained gaseous
material resulting from industrial, commercial, mining, or agricultural operations and is not
excluded under 40 CFR 261.4(a), 260.30, or 260.31.
21. Spill - The accidental discharging (see Discharge), spilling, leaking, pumping, pouring, emitting,
emptying, or dumping ofhazardous wastes or materials which, when spilled become hazardous
wastes, into or on any land or water. This also includes spills onto asphalt or concrete pads.
22. Environmental Services - A department with expertise in the areas ofhazardous waste, air and
water management, including envirorunental regulations in these areas.
PLANT LOCATIONS AND SITE INFORMATION
1. The ATK Launch Systems - Promontory (ATK) plant is located in Box Elder County
approximately 30 miles northwest of Brigham City. The 30-square mile plant site is
remote from any major population centers and is reasonably isolated from ranches
located at varying distances from the area boundaries. The plant site is composed of
four major areas in which manufacturing and testing activities take place: South Plant,
North Plant, Test Area, and Plant 3. There are approximately 675 buildings located on
the plant site, (See Appendix I for facility site maps).
ATK owns and operates these 4 areas. All of these areas are contiguous and waste
disposal is managed by one organization.
From the beginning of operations in 1956 to the present time, plant activities have
encompassed a wide range of programs requiring the production of solid rocket
propellants, rocket motor testing, and industrial support necessary to achieve each
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ATK Launch Systems- Promontory September 2008
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program's objectives. Solid rocket motors manufactured during this period vary from
motors containing 7-9 Ib of propellant to 1,100,000 Ib. Programs have included Space
Shuttle SRM, Peacekeeper, Trident, SRAM, HARM, Standard, Genie, Minuteman,
Poseidon and a variety of ground and air launched flares.
2. The plant site has eight hazardous waste treatment and storage facilities: Burning
Grounds at M-136, and M-225; Drum Storage areas at E-501 and M-186; the T-29B
Hydrazine Dilution Facility; the M-705 Wastewater Treatment Plant; the M-705S
Hazardous Waste Consolidation Room; the soiid propellant waste storage facilities at
M-47and building M-603 which will be used for storage and treatment of solid propellant,
rocket motors, and non-hazardous liquids. The site maps and evacuation plans for
these facilities are shown in Appendix I.
These nine facilities serve as waste management units for the entire facility. Reactive
wastes treated at the burning grounds include waste propellants, waste explosives,
oxidizers, or solid waste contaminated with propellants, explosives, or oxidizers. No
propellants or explosives are ever stored in the drum storage areas; hazardous wastes
that are flammable, toxic, or corrosive are stored in these units. The Hydrazine Dilution
Facility at T-29B dilutes waste hydrazine to between 5 to 50 percent by volume for
shipment to an off-plant disposal site. The M-705 Wastewater Treatment Facility treats
hazardous and industrial waters from building sumps. Hazardous wastes are
consolidated and lab packed at the M-705S Hazardous Waste Consolidation Room.
3. Approved hazardous waste accumulation areas are described in Table I.
4. Fire hydrants are located as follows: 101 hydrants in the Administrative and
Manufacturing area, 95 at North Plant, 47 in the Test Area, and 9 in Plant 3. Static and
dynamic pressure heads have been measured for each hydrant and the Fire
Department maintains this information. The fire protection system at the plant site
meets the NFPA codes for fire protection. ATK owns and operates two pumper fire
engines and two brush trucks which are used for emergency response.
The following water tanks are interconnected:
Location
X-1
X-2
M-131
M-132
M-133
M-587 (North Plant)
M-696
T-59 (Test)
Caoacitv (aal)
200,000
20,000
50,000
50,000
100,000
1,000,000
20,000
1,000,000
The M-203 (Propellant Development Area) water tank with a 100,000 gallon capacity is
not interconnected to the other tanks.
Fire hydrants throughout the plant are color coded according to capacity.
Color Code Flow Capacity (gpm)
Green Fire Hydrant 1,000 or more
Orange Fire Hydrant 500 -1,000
Red Fire Hydrant 500 or less
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5. Information depicting the capacity, location, and practical consequences of a
catastrophic failure of large hazardous material storage areas is found in Appendix II C,
p.67.
6. All buildings with 10 or more regular occupants have an evacuation plan posted at all
major exits of the building. (See Appendix I for the site maps and evacuation routes of
the hazardous waste treatment and storage facilities).
H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES
1. There are many steps that can be taken to prevent the recurrence and spread of fires,
explosions, or releases at the drum storage areas, burning grounds, and operating
buildings. These include limiting propellant quantities placed in the burning trays,
following safe handling procedures, personnel training, segregating incompatible and
reactive materials in the burning trays and in the drum storage areas, practicing good
housekeeping procedures, proper labeling, regular inspections, and separating the
burning trays by safe distances. These procedures are outlined in company operating
manuals.
2. Each fire, explosion, or release into the environment is unique. The Incident
Commander must be an experienced individual who will take all possible steps to
prevent a recurrence, to limit the extent ofthe damage, and to stop the discharge.
These steps may include:
a. Stopping processes and operations.
b. Collecting and containing released wastes.
c. Removing and isolating containers.
d. Preventing additional harm to the environment through knowledge of the potential
hazards associated with storage areas (found in Appendix II, A and B, pp. 65 and
66, their locations, capacities, and identification.
3. User organizations conduct regular inspections on items such as bulk storage
containers that store hazardous wastes or materials which, if released to the
environment, would become hazardous wastes. Audits are taken on volumes of stored
materials versus consumption to ensure that non-sudden releases are not occurring. If
a non-sudden release of materials is discovered, steps are taken immediately to
minimize the impact on the environment
II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION
A. EVACUATION CRITERIA
1. A fire that is a threat to human safety.
2. A spill that is a threat to human safety.
B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL
1. The building personnel working the operation identify the material.
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2. The Material Safety Data Sheet(MSDS) is referred to for chemical constituents, health
hazards and protective clothing.
3. The Hazardous Waste Profile Data sheet, Haz Com Web, GM 3.1 or MSDS is referred
to for proper disposal of the waste.
REPORTING OF EMERGENCY INCIDENTS
1. Spilled material is reported to Security.
2. Security contacts the Environmental Service's Spill Advisory Team and Safety for
technical support and advice.
3. Environmental Services contacts the State and EPA to report the incident (if required).
4. Environmental Services obtains the log from Security to prepare the written report to the
State.
5. Within 15 days, Environmental Services submits the written report to the State and
maintains a permanent copy in the Environmental Services' Central File as required.
PERSONNEL RESPONSIBILITIES
1. EMERGENCY MANAGER
a. At all times, there shall be at least one employee either present on the facility
premises or on call with the responsibility for coordinating all emergency response
measures.
b. The facility emergency coordinator is thoroughly familiar with all aspects of the
facility's contingency plan, all operations and activities at the facility, the location
and characteristics of waste handled, the location of manifests and all other
records within the facility, and the facility layout, or has immediate access to
persons with this information.
c. This person shall have the authority to commit the resources needed to carry out
the contingency plan.
d. Arranges for and directs a spill contingency plan simulation.
2. EMPLOYEES, FIRST LINE SUPERVISORS AND FIRE WARDENS
a. Report all fires or emergencies by activating the fire alarm or calling the emergency
number.
b. Report from a safe telephone location:
Your name and phone number
Type of incident (fire, explosion, injury, spill, etc.)
Location of incident
c. Stay on the line when possible until released by the emergency operator.
d. Do not attempt to fight fires involving live or possibly toxic hazardous materials.
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ATK Launch Systems - Promontory September 2008
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e. Do not attempt to contain spills that are beyond capability or training.
FIRST LINE SUPERVISORS
a. Ensure personnel evacuate buildings or areas to the assembly point indicated on
the Emergency/Evacuation Plan located in each building.
NOTE
Handicapped personnel must be provided priority and
assistance during evacuation and assembly.
b. Advise the Fire Captain and the Incident Commander of conditions at the scene.
c. Account for all employees that were in or assigned to the affected building or area.
d. Report any injured or missing personnel to the Incident Commander.
e. Remain at the assembly point until released by the Incident Commander,
f Notify appropriate Safety Department and fill out a Mishap Report.
INCIDENT COMMANDER
a. Initiate the first response actions.
b. Contact line supervision at the assembly point to determine the details of the
situation:
i. Nature of incident
ii. Number of personnel injured or not accounted for and the location of their last
known assignment.
iii. Location and type of hazardous materials that may be exposed to fire or
explosion (Quantity Distance Criteria).
c. Applicable Quantity Distance Criteria.
d. Assume control of emergency area.
e. Declare severity of event such as an emergency or disaster as appropriate.
f Establish emergency scene, coordinate road blocks, cordon the site, and control
entry/exit from the area.
g. Make an initial assessment of situation.
h. Notify the Security Radio Dispatcher as appropriate, close the switchboard, if
absolutely necessary. The Environmental Specialists must be included if a building
deluge system has been activated and the building sump has overflowed or
another known spill of hazardous material has taken place.
i. Identify safe response routes for follow-on units.
j. Coordinate activities with other emergency units.
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ATK Launch Systems- Promontory September 2008
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k. Commit rescue and first aid crews as necessary.
I. Obtain emergency rescue and ambulance as required.
m. Keep the Emergency Commander informed of the emergency situation.
n. Request outside assistance from the EOC as needed.
p. Check with building's supervision to identify propellant ingredients and hazardous
constituents in any building or building sump which must be pumped by Water
Operations personnel. Evaluate what hazards, if any, exist which may hinder safe
access to the building.
q. Perform actions in accordance with 29 CFR 1910.120 (HAZWOPER).
SECURITY
a. Set up road blocks as directed by the Incident Commander to preclude
unauthorized entry of personnel and provide clear traffic flow for emergency
vehicles.
b. Coordinate with Incident Commander to ensure orderly evacuation of personnel.
c. Provide protection for classified information, valuable records, and special
equipment.
d. Ensure protection of Company and Government property from theft or sabotage.
e. Provide proper disposition, storage, and protection of classified material in
accordance with the Department of Defense Industrial Security Manual.
f Establish perimeter boundary for emergency scene, set up road blocks, cordons,
etc.
g. Above actions must be consistent with HAZWOPER requirements.
SECURITY RADIO DISPATCHER
a. When directed by the Incident Commander, notify appropriate personnel in
accordance with the Emergency and Disaster Response Plan.
b. Monitor and record all emergency radio communications, and establish required
communications between radio units.
c. Upon direction ofthe Incident Commander, notifies appropriate ATK management.
TELEPHONE OPERATORS
a. When directed by the Incident Commander, refuse incoming and outgoing calls
unless directed otherwise by the Emergency Commander.
INDUSTRIAL HYGIENIST
a. Report to the Incident Commander at the assembly point or Field Command Post
b. Advise the Incident Commander on emergencies involving toxic chemical or
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ATK Launch Systems- Promontory September 2008
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radiation hazards.
c. Perform the following activities as necessary:
i. Sample air at the scene, including any sumps which have to be pumped, (if
determined to be necessary by the Industrial Hygienist (IH) on the scene)
ii. Monitor radioactivity at the scene, (if determined to be necessary by the IH on
the scene)
iii. Advise Emergency Response Team concerning proper decontamination
controls.
iv. Notify Medical Services of personnel exposure to toxic chemicals or
radioactive materials.
V. Advise the Incident Commander to notify public health authorities.
d. Performs these duties in accordance with HAZWOPER requirements.
9. MAINTENANCE CRAFTS PERSONNEL
a. Respond to all alarms when notified by the Security Police Radio Dispatcher and
report to the Incident Commander at the command post.
b. Control distribution of air, water, steam, and electrical power as directed by the
Incident Commander.
c. Provide equipment, barricading, and shoring as necessary per direction of Incident
Commander.
d. As Fire Brigade, assist when needed.
e. Provide construction type materials and services for containment of hazardous
material spills.
f Performs these duties per direction of Incident Commander.
10. ENVIRONMENTAL SERVICES PERSONNEL
NOTE
The propellant collection crews are not trained for
emergency response. Trained operators for HAZWOPER
emergency sump truck response are on plant to operate the
sump truck on day shift, Monday thru Friday. A
Remediation Team has been trained to respond to spill
clean-ups larger than building personnel are normally able
to handle, contact Gene Curtis at Ext 4479 for assistance.
Sump truck services are available on off-shifts at the
discretion of the remediation team leader If emergency
sump truck service is needed during off-shift hours, call the
waste management company contracted by ATK.
a. Report to the Incident Commander at the command post, when notified by Security
Police Radio Dispatch.
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b. Perform duties as directed by the Incident Commander after material to be
collected has been identified, any hazards associated with the material have been
identified, and safe procedures to handle the material have been established.
c. Perform these duties in accordance with HAZWOPER requirements.
d. Advise the Incident Commander on potential environmental hazards, safe handling,
and disposal options.
11. MEDICAL SERVICES PERSONNEL
a. Remain at or report to the Dispensary to receive and treat patients.
b. Report to the emergency area when requested by the Incident Commander.
c. Coordinate with surrounding community hospitals and doctors for the receipt and
treatment of injured.
d. Requisition supplemental medical supplies, equipment, and personnel as needed.
May request helicopter transportation in life or death situations.
e. Conduct and supervise treatment for injured personnel.
f Review MSDS and other relevant information, and transmit same to receiving
hospital.
12 TRANSPORTATION PERSONNEL (IN-PLANT TAXI SERVICE)
a. Coordinate with Incident Commander to ensure adequate transportation of plant
personnel.
13. EMERGENCY COMMANDER
a. Control and coordinate overall activities of the emergency situation. The
Emergency Commander will work from the Emergency Command Center, and will
assist and direct the On-Scene Incident Commander as needed.
b. Evaluate situation and determine need to convene the Emergency Command Unit.
c. Direct the Telephone Operators to open or close the switchboard according to the
nature of the emergency.
d. Open the Emergency Operations Center as necessary.
e. Identify the disaster potential posed by the emergency.
f Make the disaster declaration when necessary (disaster responsibilities are listed in
Section III).
14. PHOTOGRAPHER
a. Report to the Incident Commander at the Command Post.
b. Advise the Incident Commander on photo coverage.
c. Photograph the scene as directed.
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AlK Launch Systems-Fromonlory September/uu»
Attachment 4 - Contingency Plan UTD009081357
d. Expedite printing and delivery ofthe photographs.
e. Interpret the photographs as required.
15. HUMAN RESOURCES COORDINATOR
a. Provide food and assistance with personal needs for emergency team members
and those affected.
b. Notify next of kin of injured persons when advised by Emergency Commander.
(See Section IV, the Emergency and Disaster Response Plan for procedures).
16. ENVIRONMENTAL SPECIALIST
a. Assess possible environmental hazards resulting from the incident including
assessment of spills caused by the activation ofa building deluge system which in
turn caused the building sump to overflow.
b. Initiate reports required by the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) and Utah Solid and Hazardous Waste
Regulations.
c. In conjunction with trained personnel from the area involved, supervise the clean-
up activities (Remediation Team), taking control from the Fire Department as the
emergency is concluded.
d. Determine (along with the responding local emergency agency) whether the facility
has had a discharge, fire, or explosion which could threaten the environment
outside of the facility. Assure immediate implementation of emergency procedures.
e. Notify the State and Federal environmental agencies as required.
f The Environmental Specialist contacts either the government official designated as
the on-scene coordinator or the National Response Center, [phone], and
Utah Dept. of Environmental Response and Remediation (DERR) at (801) 536-
4123 to relaying the following information:
Name and telephone number of reporter.
i. Name and address of facility.
ii. Time and type of incident (such as discharge, fire, etc.).
V. Name and quantity of material(s) involved, to the extent known.
V. The extent of injuries, if any.
vi. The possible hazards to human health or to the environment outside the
facility.
g. Notify the Corporate Environmental Engineer if the spill is reportable.
David Shead
[phone]
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ATK Launch Systems- Promontory September 2008
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h. Utah Hazardous Waste Management Rules require that the Environmental
Specialist note in the operating record the time, date, and details of any incident
that requires implementing the contingency plan. Within 15 days after the incident,
he must submit a written report on the incident to the Executive Secretary of the
Solid and Hazardous Waste Control Board. The report must include:
i. Name, address, and telephone number of the owner or operator.
ii. Name, address, and telephone number of the facility.
iii. Date, time, and type of incident (such as fire, explosion, etc.).
iv. Name and quantity of material(s) involved.
v. The extent of injuries, if any.
vi. An assessment of actual or potential hazards to human health or the
environment where this is applicable.
vii. Estimated quantity and disposition of material recovered from the incident.
i. Notify the community emergency coordinator for the local emergency planning
committee in compliance with requirements outlined in 40 CFR 355.40, where
applicable.
j. Immediately after an emergency, the Environmental Specialist must provide
direction for treating, storing, or disposing of recovered waste, contaminated soil or
surface water, or any other material that results from a discharge, fire, or explosion
at the facility.
k. The Environmental Specialist and the Incident Commander must ensure that, in the
affected area(s) ofthe facility:
i. A determination is made who will do the spill remediation work (Building
Personnel, ATK Spill Remediation Team, or Off-Site Contractor).
ii. No waste that may be incompatible with the discharged material is stored or
disposed of until cleanup procedures are completed; and
iii. All emergency equipment listed in the contingency plan is cleaned and ready
for its intended use before normal operations are resumed.
17. CORPORATE PUBLIC AFFAIRS
a. Establish liaison with representatives of public information media.
b. Prepare drafts of general/public information press releases relating to the
emergency.
c. Release information as directed by the Emergency Commander, according to ATK
Policy.
18. RECORDER
a. Record incoming and outgoing communications at the EOC.
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ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
b. Record all significant events and actions.
c. Initiate and maintain record information in a time line log.
d. Assist in the preparation of interim and final reports.
ALARM SYSTEMS
1. Alarm systems are available at ATK for fires or building evacuations if an emergency or
disaster situation exists:
lype
Fire and Building
Evacuation
Hazardous Waste
Storage and
Thermal Treatment
People/Materials
People
People
Materials
Sound
Fire Alarm
Verbal Signal (or fire alarm, if
available)
Verbal Signal (fire alarm or air
horn, if available)
2. The hazardous waste storage facilities at M-186 and E-501 are located outdoors in open
areas, evacuation of personnel will be in any direction away from the problem. The assembly
area for E-501 is directly across the street (to the north) from the entrance gate. The
assembly point for M-186 is at the M-381 trailer.
3. The hazardous waste storage facility at the M-705 Consolidation Room is a single room
equipped with two exits, a single door on the west and a double door on the east. Both sets
of doors open directly to an open outdoor area where personnel are to evacuate to an area
near the intersection of the main in-plant road and the M-705 access road. The room is
equipped with a heat sensor alarm, a fire alarm and a carbon monoxide alarm on the
supplied air system.
4. M-47 is a storage building only, and is equipped with evacuation doors on the west side of
the building only. These exits are delineated in the evacuation plans in Appendix I.
5. M-603 is a storage and disassembly building with multiple exits as outlined in the evacuation
plan in appendix I.
6. Tables and maps showing the function of the various hazardous waste sites and area
evacuation plans are found in Appendix I, p. 40.
LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND HOSPITALS
1. Local law-enforcement agencies, fire departments, and hospitals have been contacted
to respond to or treat any ATK emergency. The most recent copy of this Contingency
Plan is sent to each agency in order to familiarize them with the layout, description of
hazardous wastes handled, and evacuation plan for the plant. Copies of the letters sent
to each agency are kept in the Operating Record.
2. All emergency response units from off-plant will be escorted from the gate to the
15
ATK Launch Systems - Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
fire/explosion/spill site by an ATK authorized agent. This will ensure the units reach the
location as quickly and efficiently as possible.
IIL SPILL CONTAINMENT AND CLEANUP
A. CONTROL PROCEDURES
1. Detailed emergency response procedures whenever there is a fire, explosion, or release
(spill) are found in the current Emergency and Disaster Response Plan.
2. Specific directives for cleaning up spills are given in the GM 3.1 and the Hazardous
Waste Profile Data (HWPD). There are over 1,000 chemical entries in the HPWD.
Approximately 800 of the chemicals in current use exhibit hazardous properties. The
MHSI documents are generated in-house to provide a standard format for easy use.
Each entry contains Material Safety Data Sheet (MSDS) information as well as other
information. There are approximately 100 sets of MHSI distributed throughout the
facility. In addition, a complete MHSI is accessible through over 1,000 computer
terminals at the facility.
3. The Wastewater Treatment Facility (M-705) is designed to treat wastewater containing
hazardous waste constituents. The responsible building foreman or supervisor should
report to the M-705 facility personnel any spill or accidental discharge to a sump
suspected of containing chemicals at concentrations above the levels normally
discharged. The report should include the incident location, name of person reporting,
chemical involved, and approximate quantity. The treatment facility personnel will then
be able to determine how best to handle the wastewater.
4. The propellant storage buildings will be inspected daily or weekly as required when in
use. While the propellants stored in these buildings are solid, occasionally a small
amount of nitro glycerin or similar material can ooze from the motor and drip to the floor.
These drips will be checked for during the inspections, and cleaned up using rags and
acetone within 24 hours of discovery or as soon as is practicable.
B. SPILL CONTAINMENT AND CONTROL
§265.56(e) of the Resource Conservation and Recovery Act (RCRA) states:
"During an emergency, the Emergency Commander must take ail reasonable
measures to ensure that fires, explosions and releases do not occur, recur, or
spread to other hazardous waste at the facility. These measures must include
where applicable, stopping processes and operations, collecting and containing
released waste and removing or isolating containers."
Confine hazardous material spills to the affected area with dams, Quicksorb, or other
approved means. Hazardous material properties may be determined by consulting the
Hazardous Waste Profile Data Sheet, MHSI, or the DOT Emergency Response
Guidebook. No attempt will be made to contain a spill until the hazardous properties are
known. Secondary containment is provided for most storage tanks. For those tanks
without secondary containment, consult Appendix II for spill containment considerations.
C. SPILL CLEANUP
1. Waste Management and Environmental Services will be responsible for the coordination
of spill cleanup activities. Building personnel will clean up smaller sized spills, incidental
to the work process, that are deemed within the skills and level of training possessed by
16
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
September 2008
UTD00908I357
available building personnel, where the spill occurred. All other spills will be cleaned up
by the Spill Remediation Team or a company contracted by ATK.
Proper procedures will be followed for every release of hazardous wastes. Because of
the extensive inventory of hazardous materials managed at ATK Corporation, each
release will require specific safety precautions, cleanup procedures, and/or disposal
methods. See Table II p. for chemical compatibility information.
WARNING
Do not attempt to contain or clean up any spill until hazards
associated with the material are known and proper safety
precautions are taken.
Response procedures to be used during container spills or leaks are as outlined:
a. Identify the material
From the hazardous waste label
From Waste Management and Environmental Services inventory records
Through laboratory analysis
From carrier manifest or placard DOT guide number
Protect personnel through the use of personal protective equipment specific to the
identified material (refer to MHSI or Material Safety Data Sheet, available from
Industrial Hygiene.)
c.
d.
Stops the spill or leak
Contain the material
Eliminate the source
Use Quicksorb, or other approved methods
e. Clean up the material
! Re-drum
! Wipe up, use absorbent material, excavate soil
f Dispose of the material (refer to Haz Com Web and Disposal Instructions for
Waste Materials, GM-3.1)
g. Decontaminate the site and clean the equipment
D. FOLLOWUP PROCEDURES
1. When the spill has been properly contained and stopped, appropriate equipment
will be used to remove the spilled material to a disposal site designated by the
Environmental Specialist.
2. Spills involving very large quantities of material caused by the failure of a large
storage tank should be dealt with as quickly as possible to minimize exposure to
the environment. The method of pickup generally will be pumping material into a
tank truck, the original tank after repairs, or into another tank. An alternative may
be to use the Environmental Waste Disposal sump truck to pump liquid hazardous
wastes and transfer them to a 5,000 gallon storage tank trailer at M-705. Contact
17
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
Waste Management and Environmental Services for use.
3. Proper steps will be taken to repair equipment and facilities and/or remove the
cause ofthe spill.
4. Operating procedures will be changed, if necessary, to prevent recurrence of a
spill.
5. Safety and Operational Training will be instigated, if required.
6. When possible, all reasonable effort will be made to salvage reusable material.
INCOMPATIBLE WASTE
The Environmental Coordinator and Incident Commander will ensure no waste is
incompatible with any material during the cleanup ofa discharge. Table II, p. lists the
information and its available location to the Environmental Coordinator and Incident
Commander to make decisions regarding compatibility. All of these matenals are available
for inspection at the plant site.
CLEANUP MATERIAL AND EQUIPMENT
The following is a partial list of safety equipment that may be used for cleanup as required
per Haz Com Web. All items can be obtained from Stores or from a call contract.
Item
Coveralls
Smocks
Tyvek Suit (m)
Tyvek Suit (I)
Tyvek Suit (xl)
Tyvek Sack Suit
Tyvek Hood
Polyethylene-
Tyvek Suit
Saranex Tyvek Suit
Booties (Yellow)
Booties (Clear)
Boots (Rubber)
Glasses, Safety
Monogoggles
Ear Plugs
Gloves, Rubber (s)
Gloves, Rubber (m)
Gloves, Rubber (1)
Gloves, Leather
Gloves, Cotton
Gloves
Gloves, NBR (s)
Gloves, NBR (m)
Gloves, NBR (I)
Respirator, Half Mask
Air f^urifying
Respirator,
Full-face Cart
Stock No. Use
Live Operations
Manufacturing Area
Asbestos & Dust
Asbestos & Dust
Asbestos & Dust
Asbestos & Chemical Spills
Asbestos & Chemical Spills
Asbestos & Chemical Spills
Chemical Spills
Asbestos & Chemical Spills
Asbestos & Chemical Spills
Chemical Spills
Spills-Less than 1 quart
Spills-Greater than 1 quart
Noise-Greater than 90 B(A)
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
General Use
General Use
Solvent Resistant
Methyl Chloroform
Methyl Chloroform
Methyl Chloroform
In O2 Sufficient Areas Only
In O2 Sufficient Areas Only
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ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
Respirator, Fresh Air
Respirator, No. 8710
Filter S (Gray)
Filter H (Purple)
Filter GMA (Black)
Filter GMC (Yellow)
Filter GMD (Green)
Filter (Purple/Black)
GMA-H
Filter (Purple/
Yellow) GMC-H
Filter (Black/Olive)
GMP
Acetone
Rumple cloth
Chemliner bag
Velostat bag
In O2 Deficient Areas Only
Dust, Single-use Only
Dusts, Mists, Fumes, Radon
Daughters, Asbestos
Dusts, Mists, Fumes, Radio-
nuclides, Asbestos
Organic Vapors
Organic Vapors, Acid Gases
Ammonia & Methylamine
Organic Vapors, Dusts, Mists,
Fumes, Radionuclides,
Asbestos
Organic Vapors, Acid Gases,
Dusts, Fumes, Mists,
Radionuclides, Asbestos
Pesticides
Propellant solvent
wipe
Contain solvent rags
Conductive bag to contain chemiliner
In addition, the following materials are available if required:
Item Location Ext Description
Lumber
Sawdust
Pipe
Quicksorb (27-200002)
Absorption Clay
Hydrated Lime (54-426006
Chemical Spill
Neutralizer
Acids (General)
Bases (General)
Flammable Solvents
Mercury Cleanup Kits
NG Spill and
Detector Kit
Bulldozer (Space/DLV)
Front-end Loader
Portable Lights and
Generator
Sump Tank
M-90
M-90
M-90
M-3 (Stores)
Landfill
M-3 (Stores)
J. T, Baker
M-53
M-53
M-53
M-53
M-585
M-55/M-321
M-55/M-321
M-6
M-136
Portable Diaphragm Pumps M-55/M-321
General Trucks
SCBA Respirators
Water Ops. Equip
Spill Response Truck
M-55/M-321
Fire Dept
M-705
Fire Dept
2680/2757
2680/2757
2680/2757
2757
2837
2757
2617
2617/7436
2617
2617
8446
2837/2455
2837/2455
3431
2520
2837/2455
2837/2455
2222
2222
2222
Plywood, Lumbers
Bulk
All dimensions
50 Ib Bag
Bulk
50 Ib Bag
3.2 kg
1.2 kg
(1.1 kg) (18 kg)
0.9 kg
5 liter bottle
D-8
r/4and 3 yd bucket
2 Mercury Lamps
3,000 gal
r/2-5Ton
30 Min. Tank
Sump Trucks, Etc.
Spill Response
and Rescue
19
ATK Launch Systems-Promontory September zuus
Attachment 4 - Contingency Plan UTD009081357.
G. DECONTAMINATION EQUIPMENT AND PROCEDURES
1. Equipment available for decontamination includes \wo disposable wading pools, a
wood-framed plastic pool carried on the spill truck for tool and spill team
decontamination, and fire trucks to supply wash down water. Decontamination
procedures outlined on Figures 1 and 2 will be followed to ensure spill containment and
to minimize the area of contamination.
2. The M-186 hazardous waste drum storage site is located near the burning pits: This
area is serviced by the E-522 Fire Station which is located 3-5 minutes away. The M-
705 Hazardous Waste consolidation room and the E-501 drum storage yard are also
serviced by the E-522 Fire Station which is located 1-2 minutes away. Both the E-522
and M-11 Fire Stations are outfitted with quick-response spill control equipment (See
maps. Appendix I). In addition, spill response kits are available at the M-53 and M-585
Laboratories.
H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT
1. The Incident Commander, or his designee, will ensure all equipment has been properly
decontaminated, cleaned, and replaced before normal operations are resumed. The
following guidelines are to be used for decontamination of equipment after a discharge
has occurred. These steps are also supplemented by the information found in the
sources listed in Paragraph F.
2. As much as possible, measures should be taken to prevent contamination of
equipment Any delicate instrument which cannot be decontaminated easily should be
protected while it is being used. It should be bagged and the bag taped and secured
around the instrument Openings can be made in the bag for sample intake.
a. Sampling Devices
Sampling devices require special cleaning. The instruction and care manuals
provide information on proper decontamination methods for each instrument used.
b. Tools and Equipment
Equipment and tools designated for spill response should be disposable; however,
some tools and equipment require decontamination.
Decontamination equipment, materials, and supplies are generally selected based
on availability. Soft-bristle scrub brushes or long-handle brushes are used to
remove contaminants. Water in buckets is used for rinsing. Large galvanized
wash tanks or stock tanks can hold wash and rinse solutions; children's wading
pools can also be used. Open top (55-gallon) drums or similar containers lined
with plastic bags can be used to store contaminated clothing and equipment.
Contaminated liquids can be stored temporarily in metal or plastic cans or drums.
Other supplies include paper or cloth towels for drying protective clothing and
equipment.
Personal protective equipment, sampling tools, and other equipment are usually
decontaminated by scrubbing with detergent-water using a soft-bristle brush
followed by rinsing with copious amounts of water. While this process may not be
fully effective in removing some contaminants, it is a relatively safe option
compared with using a chemical decontaminating solution. Occasionally, a
decontamination chemical is then needed to change the contaminant into a less
20
ATK Launch Systems-Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
harmful substance during decontamination. The Environmental Coordinator and
Incident Commander, or his designee, may consult the information sources in
Table I, p. 33, to determine the necessity of using a chemical decontamination
solution.
All materials and equipment used for decontamination must comply with proper
disposal. Clothing, tools, buckets, brushes, and all other equipment that are
contaminated must be secured in drums or other containers and labeled. Clothing
not completely decontaminated onsite should be secured in plastic bags before
being removed from the site.
Contaminated wash and rinse solutions should be contained to hold spent
solutions. The spent solutions are transferred to drums which are labeled and
properly disposed of The Environmental Specialist and Incident Commander, or
his designee, will ensure the disposal of these materials is done in an appropriate
manner.
c. Respirators
Certain parts of contaminated respirators, such as the harness assembly and
leather or cloth components, are difficult to decontaminate. If grossly
contaminated, they may have to be discarded with the other spill cleanup wastes.
Rubber components can be soaked in soap and water and scrubbed with a brush.
Regulators must be maintained according to manufacturer's recommendations.
Persons responsible for decontaminating respirators should be thoroughly trained
in respirator maintenance.
d. Heavy Equipment
Bulldozers, trucks, back-hoes, bulking chambers, and other heavy equipment are
difficult to decontaminate. The method generally used is to wash them with water
under high pressure and/or to scrub accessible parts with detergent/water solution
under pressure, if possible. Shovels, scoops, and lifts may be sandblasted or
steam cleaned. Particular care must be given to those components in direct
contact with contaminants such as tires and scoops. Wash water generated during
the decontamination process must be contained and disposed of in a proper
manner.
IV. INSTALLATION RESPONSE TEAM TRAINING
Building/area personnel responding to spills of hazardous materials incidental to the normal
processes within their building/area will not need training beyond that required by ATK's Hazard
Communication Program. Personnel responding to spills, who are not assigned to the building/area
where the spill occurred, are to be members ofthe Spill Remediation Team with the proper OSHA
training.
NOTE
Hazard Communication Plus Program is a combination of
the HAZ-COM Program required by OSHA 29 CFR
1910.1200 and HAZWOPER first awareness level required
by OSHA 29 CFR 1910.120.
A. TRAINING
All personnel involved in cleanup operations will be trained. This training will include an
21
ATK Launch Systems - Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
awareness of the locations of cleanup materials and equipment and the procedures for the
operation of such equipment
B. SIMULATION
The Spill Contingency Plan will be simulated annually under the direction ofthe Emergency
Commander.
V. TRAINING PLAN
One of the most important objectives of the Contingency Plan is to ensure that the emergency
responders are properly trained. Training should include teaching, exercise and critique phases. Re-
training and review should be completed at least annually. The following is an outline of training plan
elements:
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN
B. REVIEW OF LEGAL REQUIREMENTS
1. Authority
2. OSHA requirements
3. State requirements
4. EPA requirements
5. State Fire Marshall requirements
6. Law enforcement requirements
7. Medical Examiner/Coroner requirements
C. LOCAL ATK REQUIREMENTS
D. CUSTOMER REQUIREMENTS
Contract review
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER
F. EMERGENCY COMMUNICATION SYSTEM
1. Initial notification and follow-up
2. Verification of information
3. Radio discipline
4. Communication intercept
G. FIRE PLANS/FIRE DRILL
1. Use
2. Exercise
3. Evaluate
4. Evacuation
5. Assembly points
H. BOMB SEARCH TECHNIQUES
1. Outside to Inside
2. Left to right
3. Bottom to Top
22
ATK Launch Systems - Promontory ileptember 2008
Attachment 4 - Contingency Plan UTD009081357
4. Evacuation
5. Suspect items (Isolate; don't touch or disturb)
J.
K.
L.
M.
N.
FIRE BARRICADE/CORDON AREAS
1.
2.
Function
Initiate/release
EMERGENCY MEDICAL TREATMENT
1.
2.
EMT training, equipment
First response first aid
SECURITY OF SITE
1.
2.
3.
Purpose
Authority
Who authorizes access
INVESTIGATION
1.
2.
3.
4.
5.
6.
OSHA
EPA
Local Law enforcement
Medical Examiner/Coroner
Customer
ATK
PUBLIC RELEASE OF INFORMATION
1.
2.
3.
4.
5.
Who authorizes
Importance of controlling
Who releases
Who reviews
Next of kin
FACT-FINDING METHODS
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11,
12.
Initial interview
Follow-up interview
Recordings
Photo Coverage
Mapping damage
a. Who?
b. How?
c. Why?
Personnel security checks
Drug and alcohol tests
Weather conditions
Product status
Operational status
Equipment records and history
Facility, tooling, modification and history
23
ATK Launch Systems - Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
SAFING THE AREA
1. Electric Power
2. Water
3. Steam
4. Toxic chemicals
5. Falling hazards
6. Explosives
CONTROL OF THE CURIOUS
1. Outsider
2. Employees
3. Press
HANDLING OF REMAINS
1. Notification
2. Photo
3. Movement (after authorization by Medical Examiner)
4. Release (after authorization by Medical Examiner)
NOTIFICATION PROCEDURES
1. When?
2. Who?
3. How?
4. Verification
RESCUE EFFORTS
1. When?
2. When not to
3. How to determine
24
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
TABLE I
COMPATIBILITY INFORMATION
Source of Compatibility Information Location
1. Hazardous Waste Compatibility Chart
Table 9-2 of Attachment 9
Available at
Environmental Services offices
2. Material Health and Safety
Information (example of informa-
tion found in plan)
Available in hard copy form at
approximately 100 locations through-
the plant; also available on 1,000 computer
terminals throughout the plant*
3. Material Safety and Data Sheets
4. Work Experience
Located on the Haz Com Web
Knowledge of each member of the Response Team
when responding to a discharge
25
ATK Launch Systems-Promontory
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September 2008
UTD009081357
TABLE II
EMERGENCY COORDINATOR CALL LIST
Primary Coordinator
Steve Winn
Alternate Coordinator
Ray Stokes
Steve Batis
Work No.
722175
6600
6600
Home No.
801-699-2473
435-245-4627
435-257-7116
Home Address
8538 S. WIdoak Drive
West Jordan, UT 84088
161S. 200W.
Wellsville, UT 84339
196 S. 1000 W.
Tremonton, UT 84337
26
ATK Launch Systems- Promontory
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September 2008
UTD009081357
FIGURE 1. DECONTAMINATION/SPILL SCENE
Difficult Decontamination Situations
Some situations, such as a solvent spilled on tiles or large spills on unprotected ground require the
removal and disposal of the affected material. Other situations, such as contaminated equipment or
fixtures, require steam cleaning and the use of a detergent. Frequently, the rinse from steam cleaning is
best controlled with a wet/dry vacuum. Steam cleaners, detergents, and wet/dry vacuums can be
obtained from local rental companies. The rinse should be tested for the contaminant and managed
appropriately.
27
AlK Launch Systems-Promontory
Attachment 4 - Contingency Plan
oepieiiiDci zuuo
UTD009081357
The Spill Scene
While each spill is unique, every spill shares common features best referred to as the "Spill
Scene." This allows a conceptual illustration of the work area which emphasizes the relationship
of the various components.
Complete decontamination of workers, tools, and the spill site must be performed before the spill
response is completed.
It is prudent to establish an area for worker decontamination through which all SPILL TEAM
members must pass prior to leaving the site. In this TEAM DECONTAMINATION SITE (TDS)
protective clothing can be thoroughly washed with detergent and rinsed with water, if necessary.
The soles of ALL WORKERS SHOES MUST BE RINSED before they leave the area. Outer
coveralls (Tyvek, etc.) must be removed in this area. These steps are necessary to prevent
spreading the contamination or introducing toxic substances into workers homes.
Tools can be rinsed with detergent and water prior to removal from the spill scene. All
rinses from these decontamination procedures must be treated as hazardous waste.
Dry decontamination may be used when appropriate.
It is frequently necessary to test the site for completeness of decontamination prior to declaring
the emergency resolved. Spills which contaminate soil, asphalt, concrete, or other absorbent
materials will require that samples be obtained and analyzed. After all residual contamination is
removed, asphalt and concrete areas must receive a thorough wash-down with fresh water.
FIGURE 2. DECONTAMINATION
28
ATK Launch Systems - Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
APPENDIX I
FACILITY FUNCTION TABLES, SITE MAPS, & EVACUATION PLANS
NORTH PLANT SITE MAP 30
MANUFACTURING AREA SITE MAP 31
TEST AREA SITE MAP .....32
PLANT 3 SITE MAP 33
M-136 BURNING GROUNDS FACILITY FUNCTION TABLE 34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE 34
M-136 SITE MAP AND EVACUATION PLAN 35
M-186 SITE MAP AND EVACUATION PLAN 36
E-501 STORAGE YARD FACILITY FUNCTION TABLE 37
E-501 SITE MAP AND EVACUATION PLAN 38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE .: 39
M-225 SITE MAP AND EVACUATION PLAN 40
T-29B SATELLITE ACCUMULATION AREA FACILITY FUNCTION TABLE 41
T-29B SITE MAP AND EVACUATION PLAN 42
M-705 WASTEWATER TREATMENT FACILITY F UNCTION 43
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM 43
M-705 SITE MAP AND EVACUATION PLAN .44
M-47 PROPELLANT STORAGE FUNCTION TABLE 45
M-47 SITE MAP AND EVACUATION PLAN 46
M-603 PROPELLANT STORAGE FUNCTION TABLE 47
M-603 SITE MAP AND EVACUATION PLAN 48
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ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
i I * I w ' MMm i»
NORTH PLANT SITE MAP
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ATK Launch Systems- Promontory
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September 2008
UTD00908I357
MANUFACTURING AREA SITE MAP
(South Plant)
31
ATK Launch Systems - Promontory
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September 2008
UTD009081357
TEST AREA SITE MAP
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September 2008
UTD009081357
TBf * n^f F vxm
nORTHDW JTAH FACUTT
PEVUDPUWT MKA (PUHT i) •
WSm SJTE WP
33S
PLANT 3 SITE MAP
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ATK Launch Systems- Promontory
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September 2008
UTD00908I357
M-136 BURNING GROUNDS
FACILITY FUNCTION: Propellant, explosives, unstable and pyrotechnic waste disposal
Waste Products Into Area
Class 1.1 and 1.3 propellant
wastes, propellant con-
taminated wastes, and unstable
waste.
Method of
Disposal
Burning
Spill Cleanup/Handling
Flashing in waste propellant
disposal areas
M-186 HAZARDOUS WASTE AREA
FACILITY FUNCTION: Receive hazardous waste materials and store for shipment
Waste Products Into Area
Methyl Chloroform
Methyl Ethyl Ketone
Xylene
Toluene
Paint
Thinners
Oil
Lab Chemicals
Photographic Fixer Solution
Rags & debris
Method of
Disposal
Store for
off-plant
shipment
Store for
off-plant
shipment
Spill Cleanuo/Handlinq
Six UN Drums
Quicksorb, 100 Ib
Two shovels
One broom
One fire extinguisher
Emergency shower/eye wash
Two overpack drums
Saranex suit (level B)
34
ATK Launch Systems - Promontory
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September 2008
UTD009081357
EVACUATE AREA, THEN PROCEED TO ASSEMBLY POINT
200 FEET WEST ON APPROACH ROAD
f~
NEW
POND
TANK 2 D
TANK1
^ >
BURNING PIT 19
PIT 18
PIT 17
PIT 16
PIT 15
PIT 14
|-|
PIT 13
. L J
N
M-136
-X X X
DETONATION PITS
D D D D ^
NO. 11 NO. 10 NO.9 NO.S
PIT 7
PITS
PITS
PIT 4
PIT 3
• O
PIT 1 PIT 2
PROPELLANT BED
•>C^-'—1A% X-
LEGEND:
# FIRE EXTINGUISHER
IVI-136
AND BURNING PITS
35
ATK Launch Systems- Promontory
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September 2008
UTD009081357
EVACUATE, THEN PROCEED TO ASSEMBLY POINT,
SOUTHWEST AT M-381
STORAGE
SHED
^
LEGEND:
• FIRE EXTINGUISHER
HAZARDOUS WASTE TREATMENT,
STORAGE, DISPOSAL, AND FACILITIES
M-186
36
ATK Launch Systems-Promontory
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September 2008
UTD009081357
BUILDING E-501 STORAGE YARD
FACILITY FUNCTION: Hazardous Waste Storage Yard
Waste Products Into Area
Various
Other assorted materials
that may be recycled
Method of
Disposal
Shipment
off-plant
for disposal
N/A
Spill Cleanup/Handlinq
Two fire extinguishers
Absorbent
Two repack drums
Electrical pump
Telephone/radio
Eyewash/shower
Safety gates
Safety flags
Six UN 55-gal drums
(empty)
Saranex suit (level B)
37
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
isepiemoer zuue,
UTD009081357
EVACUATE AREA, THEN PROCEED TO ASSEMBLY
POINT ON 200 STREET, 200 FEET EAST
LEGEND:
• FIRE EXTINGUISHER
E-501
and
SALVAGE YARD
38
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
M-225 BURNING GROUNDS
FACILITY FUNCTION: Disposal of waste products from High Performance Propellant
Development Area and miscellaneous rocket motors, igniters, and
related materials
Waste Products Into Area
Composite propellant, uncured
from M-209
Composite propellant, cured Burn
from M-221
NG propellant, uncured from
M-208, M-241
NG propellant, cured from M-221
HMXfrom M-208, M-210
AP from M-210 (fine only)
Binder premix (NG or other
nitrate, etc.)
PEP contaminated waste (rags,
containers, etc.)
Miscellaneous (motor, igniters)
Method of
Disposal
Burn
Burn
Burn
Burn with
diesel
Burn with
propellant
Spill Cleanup/Handlinq
Dampened rags (wipes)
Pick up, soft brush or wet rags (wipes)
Solvent dampened rags followed by NG
detector to verify cleanliness
Pick up, soft brush and/or wet rags
Soft brush and/or water-damp rags.
If possible, wet HMX with water before handling
Sweep with soft brush. Wipe with
composite water-wet rag. Flush with water into
sump
Burn or Contain, absorb into sawdust or pulp,
detonate pick up with wipes, wet rags. Apply NG
depending detector to verify cleanliness
on materials
and/or condition
Burn with
respective
propellant
Burn or
detonate
depending
on materials
and/or con-
dition
Pick up, clean with method used for
respective propellant
or ingredient
Each case must be dealt with on an
individual basis
39
ATK Launch Systems- Promontory
AUachment 4 - Contingency Plan
September 2008
UTD009081357
EVACUATE AREA TO M-22eA BUNKER
M-225
40
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
T-29B SATELLITE ACCUMULATION AREA
BUILDING FUNCTION: Hydrazine Storage and Dilution Facility
Waste Product Method of disposal
From Buildinq
Pure hydrazine
Hydrazine-citric
acid solution
5-50% dilute
hydrazine
contaminated
waste
Disposal
Dilute with
water to 5-50%
solution by
volume. Waste
hydrazine is
shipped for
disposal/Treatment.
Contaminated
waste is also
shipped for
disposal/treatment
Spill Cleanup/Handlinq
All areas where normal operations are
performed have a drainage system which
culminates in a common sump. Spills
should be flushed thoroughly with large
amounts of water. The wash water is
then drummed and shipped for disposal
•
41
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD00908I357
N
EVACUATE BUILDING, THEN PROCEED TO
ASSEMBLY POINT 300 FEET NORTH OF BUILDING
I
I
I
© ^
T-29B
42
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
M-705 WASTEWATER TREATMENT FACILITY
BUILDING FUNCTION: Removal of reactive wastes from sump water
Waste Products From Area
Lime Sludge (Heavy Metals)
Potassium Perchlorate
Classifier Decanter Solids
Method of
Disposal
Shipment
to off-
plant
disposal
company
Burning
Burning
Spill Cleanup/Handlinq
Two shovels
One broom
Plastic gloves
One bin
Saranex suit (level B)
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM
BUILDING FUNCTION: Consolidation and lab packing of hazardous wastes
Waste Products From Area
Consolidated hazardous wastes
Lab packed hazardous wastes
Method of
Disposal
Shipment to
M-186 for
eventual
off-plant
disposal
Spill Cleanup/Handlinq
Two shovels
One broom
Plastic Gloves
One Fire Extinguisher
Emergency shower/eyewash
Quicksorb, 100 Ib
Two overpack drums
Six UN drums
Saranex suit (level B)
43
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
EVACUATE BUILDING 300 FEET, THEN PROCEED TO
ASSEMBLY POINT ON DR" AVENUE NEAR M-366
M-705
44
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
M-47 PROPELLANT STORAGE FACILITY
BUILDING FUNCTION: Storage of waste and non-waste propellant and motors
Waste and non-waste Products
1.3C Propellant and Motors
Method of
Disposal
Burning/slurried
recovery/neutralization
Spill Cleanup Materials
Obtain clean up material as needed
1.1C Propellant and Motors Burning/slurried
explosives/AP
recovery/neutralization
Obtain clean up material as needed
45
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
EVACUATE BUILDING, THEN PROCEED
TO ASSEMBLY POINT 500 FEET SOUTH ON 6TH AVENUE
• FIRE EXTINGUISHER
N
M-47
46
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
M-603 PROPELLANT STORAGE FACILITY
BUILDING FUNCTION: storage and Disassembly of waste and non-waste propellant and motors
Waste and non-waste Products
1.3C Propellant and Motors
1.1C Propellant and Motors
Method of
Disposal
Burning/slurried
explosives/AP
recovery/neutralization
Burning/slurried
explosives/AP
recovery neutralization
Spill Cleanup Materials
Obtain clean up material as needed
Obtain clean up material as needed
47
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
beptemoer iuv6
UTD009081357
EVACUATE BUILDING 500 FEET, THEN PROCEED
TO ASSEMBLY POINT AT BUILDING M-643
CALL HEADQUARTERS WITH HEADCOUNT N
"9-
J
TRUCK
BAY
El
IHl
E
E
(.
LEGEND:
FIRE EXTINGUISHER
MANUAL ALARM
ALARM RESET
EVACUATION HORN
A SYSTEM RISER
El HEAT DETECTOR
$ INSPECTORS TEST
o
0 m
M-603
48
ATK Launch Systems - Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
APPENDIX 11
BULK STORAGE AREAS INFORMATION
A. BULK FLAMMABLE LIQUID STORAGE AREAS 50
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE 51
APPENDIX III
ARRANGEMENTS WITH LOCAL AUTHORITIES 57
49
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
BULK FLAMMABLE LIQUID STORAGE AREAS
Location
M-4
M-53
M-55
M-66
1-10
M-585
M-711
E-510
E-512
E-517
Type of
Flammable Liquid
Butanol
Ethanol
Isopropanol
Methanol
Methyl Ethyl Ketone
Paint
Paint Thinner
Acetone
Ethanol
Heptane
Methanol
Methyl Ethyl Ketone
Gasoline
Assorted
Methanol
Methyl Ethyl Ketone
Acetone
Ethyl Acetate
Methanol
Toluene
Gasoline
Ethanol
Isopropanol
Methanol
Acetone
Isopropanol
Paint Thinner
Polyester Resin
Toluene
Xylene
Isopropanol
Kerosene
Methyl Ethyl Ketone
Capacity
(Gallons)
40
60
530
500 .
400
500
120
60
10
10
50
60
17,000
80
15
50
50
15
10
30
10,000
100
1,660
35
100
50
50
160
50
160
170
50
450
Above/Below
Ground
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Below
Above
Above
Above
Above
Above
Above
Above
Below
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
T-29B Hydrazine 100 Above
50
ATK Launch Systems- Promontory
Attachment 4 - Contingency Plan
September 2008
UTD009081357
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE
Building
Number
1-10
M-4"
M-8"
M-43B
M-53A
M-66
M-504
M-585
M-605
E-512
E-517
Location
Shed west of building
Building north of M-3
system
Two sheds west of
building
Shed south of building
Shed south of building
Shed southwest of
building
Shed south of building
Shed east of building
Waste dock north of
building
Shed west of building
Shed north of building
Direction of Flow*
Has self-containment concrete berm
Liquid would run west across asphalt into drain
Spill would drain down west hill
Self-contained storage building
Self-contained storage building
Spill would run into ditch (trench
or grading needed to keep surface runoff from
accumulating in containment area)
Spill would flow into ditch
Spill would drain into ditch
Spill would drain into ditch
Spill would drain into ditch
Spill would drain into ditch
All other storage areas have self-containment
Fire flows and/or spilled material from these buildings will flow into a gated spill
containment structure below M-2. The gates are hand operated.
51
ATK Launch Systems - Promontory September 2008
Attachment 4 - Contingency Plan UTD009081357
APPENDIX III
Arrangements with Local Authorities
ATK has a well trained and full time Fire Department and Security Department onsite. ATK's roads and
grounds and Water Operations departments maintains a fleet of trucks, tractors, vacuum trucks and
other equipment that could be used during an emergency response. The facility also has a nursing staff
during normal business hour, and a 24/7 ambulance service operated by ATK firemen with EMT
certifications.
Due to these capabilities, the need for outside assistance is greatly reduced. The most likely need for
outside assistance would be that of hospital service. Arrangement will be made with both the Bear River
Valley Hospital and the Brigham City Community Hospital to accept employees that may have been
injured due to an explosion, chemical exposure or other accident. This arrangement will include
information on the types of chemicals used at ATK Promontory as well as explosive hazards and other
mechanical hazards associated with work performed at ATK.
The most likely scenario that would require assistance from a police agency would be the need to control
traffic on Highway 83. Arrangements for assistance in this area will be made with the Box Elder County
Sheriffs Department and the Utah Highway Patrol. All on plant traffic control will be handled by
ATK's security department.
ATK has established contracts with three different emergency response/remediation contractors for use
as needed. While we do not anticipate the need for emergency service assistance, these companies are on
call to provide service if needed.
All emergency response at the plant will be handled by the ATK Fire Department, who will act as the
primary emergency authority. Arrangements will also be made with the Box Elder County Fire
Department and the Tremonton Fire Department. We do not anticipate any need for assistance from the
Utah Department ofEnvironmentai Response and Remediation, although notification of emergencies will
be made to this department as required. In addition to those agencies listed above, ATK will also provide
a copy ofthe contingency plan to the Box Elder County Emergency Planning Committee for review and
comment.
Below is a summary list of those agencies/service providers for which service arrangements will be
sought:
Bear River Valley Hospital
Brigham City Community Hospital
Box Elder County Sheriffs Department
Utah Highway Patrol
Box Elder County Fire Department
Tremonton Fire Department
The most recent copy ofthe Contingency Plan will be sent to each of these agencies in order to
familiarize them with the layout, description ofhazardous wastes handled, and evacuation plans for the
plant. All correspondence with these agencies, in regard to the Contingency Plan and service
arrangements will be kept in the Operating Record.
52
ATTACHMENT 5
CLOSURE PLANS
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
CLOSURE PLANS AND FINANCIAL REQUIREMENTS
This Closure Plan describes the steps that will be taken in order to close the hazardous waste
management units (HWMUs) at the ATK Launch Systems Inc. - Promontory (ATK) facility.
Estimates ofthe closure costs associated with these steps are also detailed in this Plan. Closure
Plans are included in this document for the following HWMUs: M-186; M-705S; E-501; M-136;
M-225; T-29B; M-47 and M-603.
The closure plans for each HWMU were developed in order to comply with R315-8-7 and R315-
8-9.9 ofthe Utah Administrative Code (UAC). UAC R315-8-7 incorporates by reference the
requirements of 40 CFR 264 Subpart G. The closure cost estimates were made in accordance
with UAC R315-8-8, which incorporates by reference the requirements of 40 CFR 264
Subpart H.
All facilities in current operation are being managed in a marmer that we believe will facilitate
clean closures. Historical sites, such as the LTTAs do require post closure care, and are covered
in our Post Closure Permit.
LO Closure Plans [40 CFR 270.14(b)(13), 270.23(a)(2), and 264.112(a)(1) &(2) and UAC
R315-3, R315-8]
This closure plan identifies all ofthe steps needed to close ATK's storage and treatment
facilities, as identified above, at the end of their operating life. Copies ofthis plan will be
maintained by ATK Environmental Services in central files at the Promontory site. The closure
plans will be followed as written, unless modification to the original plans have been submitted
and approved by the Utah Department ofEnvironmentai Quality, Division of Solid and
Hazardous Waste (DEQ). Upon update/revision approval, revised pages or complete documents
will be sent to all plan addressees.
1.1 Closure Performance Standards [40 CFR 264.111 and UAC R315-8-7|
Closure standards specified under RCRA are designed to be protective of human health and the
enviroimient. These goals can best be achieved by one ofthe following closure methods:
• Clean closure - this method refers to residential risk based levels. Cleanup to
residential risk based levels, as outlined in UAC R315-101, will be considered clean
closure. Clean closure is the most desirable approach, and includes removal of all
contaminants, or removal to the risk based level.
• Site Management - closure where waste remains in place and specific post- closure care
is required.
For the purposes of estimating closure costs, it is assumed that all ofthe HWMUs will be clean
closed. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(l). All closures will
assess real and potential impacts to human and ecological exposures.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Preliminary remediation goals can be established prior to implementing any ofthe closure plans.
ATK may use the screening levels published by USEPA Region III "Risk-Based Concentrations"
(RBC) and the USEPA Region IX "Preliminary Remediation Goals" (PRG), or they can
establish site-specific, risk-based clean closure goals in accordance with UAC R315-101-5.2.
If contamination in the form ofhazardous waste or constituents are discovered in the soil or
ground water above risk based goals, further investigation will be performed to determine the
extent ofthe contamination. Based on the results ofthis investigation, a Corrective Measure
Study (CMS) may be prepared for review and approval by the DEQ, prior to implementation.
If this investigation suggests that clean closure is not a practicable approach, ATK will prepare a
Site Management Plan for DEQ's approval. Upon approval, the unit will be closed by
implementing appropriate site management or post closure requirements. If this approach is
necessary, the Post Closure Permit may be modified to provide post closure care for the sites that
are not clean closed.
1.2 Partial Closure and Final Closure Activities [40 CFR 264.112(b)(1) through (b)(7)
and UAC R-315-8-7J
This plan is designed to accommodate both partial and final closure. The plan will include
separate steps to close 1) storage, consolidation & disassembly areas and 2) open buming and
open detonation areas. The maximum extent ofthe operations is shown in Closure Plan Figures
1 through 8 at the end ofthe Closure Plan. These figures also include the "area of influence"
associated with each facility. The area of influence includes loading and offloading areas
adjacent to the buildings, as well as areas around the bum grounds that may have been impacted
by smoke from the bum grounds, based on soil and vegetation samples already obtained and
tested by ATK. The area of influence figures are used for estimating closure costs only. The
extent of sampling and remediation around the HWMUs will be based on sample results.
ATK implemented annual soil monitoring ofthe M-136 and M-225 bum grounds in 1991. The
purpose ofthis monitoring is to determine if ATK bum ground activities are adversely impacting
the environment. The Zone of Engineering Control (ZOEC) Soil Sampling Plan used for this
monitoring was prepared and submitted in the original permit application in 1991 as appendix
13.H. WTiile some aspects ofthis plan are outdated, ATK believes the sample selection protocol
and total number of samples obtained each year are valid. Semiannual groundwater monitoring
is conducted, in accordance with ATK's Post-Closure Permit. ATK is currently investigating the
need for remediation of contaminated groundwater as described in the Post-Closure Permit. It is
not expected that the storage and treatment activities addressed in this Permit are impacting
groundwater.
1.3 Maximum Waste Inventory and Disposal Method [40 CFR 264.112(b)(3) and UAC
R315-8-7]
The maximum inventory ofhazardous 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
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
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-705 S (inert) 32 ea. 55 gallon drum equivalent
E-501 (inert) 160 ea. 55 gallon drum equivalent
M-136 (live) 106,000 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 dmm (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
ATK treats reactive hazardous wastes on-site at the M-136 and M-225 open buming grounds.
These two waste treatment units are currently operated vmder interim status. Wastewater is
loaded onto ATK ovmed vacuum tmcks and transported to two on-site UPDES permitted
treatment facilities. All other hazardous wastes are transported via a commercial carrier to fully
permitted disposal or recycling facilities.
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 sample results indicate the need for additional
investigation or a CMS, the schedule will be modified to accommodate the changes. Final
closure will be certified by an independent professional engineer licensed in Utah.
1.4.1 Time Allowance for Closure [40 CFR 264.113(a) and (b) and UAC R315-8-7]
Final closure is expected to be initiated within 30 days of receipt ofthe final volume of
hazardous waste. If more time is required, ATK will submit a request to the Executive
Secretary. All hazardous wastes will be removed or treated within 90 days of (1) plan approval,
.or (2) after receiving the fmal volume ofhazardous waste, whichever is later. Final closure
activities will be completed within 180 days of (1) plan approval, or (2) after receiving the final
volume ofhazardous waste, whichever is later.
1.4.2 Extensions for Closure time [40 CFR 264.113(a) and (b) and UAC R315-8-7]
If closure activities cannot be completed within the time designated in this closure plan, a permit
modification and request for additional time will be submitted to the DSHW. The request will
state the reason for needed additional time and the status of the closure underway. It will also
address any added measures that must be followed to minimize any threats to human health or
the environment during the extension period.
1.5 Closure Procedures [40 CFR 264.112 and 264.114 and UAC R315-8-7[
Past disposal practices have created many solid waste management units throughout the
Promontory plant. These sites have been, and are being investigated to determine the appropriate
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
actions needed to close these areas. This plan does not address these sites, but deals with our
permitted storage and treatment facilities.
All permitted treatment and storage facilities have been designed and managed to minimize
possible contamination. This includes chemical resistant concrete coatings, blind containment
sumps, regular inspections and maintenance, prompt clean up of any spilled materials, and
annual ZOEC sampling and testing of our bum grounds as mentioned above. These practices
should greatly reduce the need for significant remediation efforts upon closure.
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, soil samples will be collected at the bum ground areas to supplement the ZOEC soil
sample data that has been collected at these HWMUs.
Soil sampling will include samples taken within the top 12" ofthe surface. Soil samples will
first be collected at those locations that are most likely impacted by waste management practices
- as approved by DEQ personnel. 20 soil samples will be collected at M-136 and 12 soil
samples will be collected at M-225. These samples will be sent to a State of Utah certified
laboratory for analysis. Sample collection, preservation and handling methods will follow those
outlined in the Waste Analysis Plan ofthis permit, and will be in compliance with all applicable
SW-846 methods. Tables 4 & 5 include lists of potential contaminants based on a review of
profiles for materials treated at these facilities. These tables will serve as the analytical
constituent list for all soil samples obtained from the respective bum ground. While this list is
not 100% complete, it is a good indicator of potential contamination from the open buming
operation. Ifany of these constituents are found above the risk based level, an additional
sampling plan will be submitted to the State for approval.
1.5.1.1 Sampling Equipment Decontamination Procedures
All field sampling equipment will arrive on site pre-cleaned, and will be decontaminated
following standard protocol and the waste analysis plan in this permit. A mobile
decontamination station will be utilized to clean all sampling equipment that could come in
contact with soil samples.
1.5.1.2 Sampling Waste Management
All waste generated from field sampling and decontamination operations will be managed in
accordance with the current 40 CFR and UAC R315 mles. Water used in the decontamination
process will be sent to the M-705 wastewater treatment plant onsite and discharged in
accordance to its UPDES permit. Soils will be stored in UN dmms pending lab results. Any soil
determined to be hazardous waste, in accordance with 40 CFR 261.3, will be managed
appropriately. Soils exceeding the Universal Treatment Standard levels will also be managed as
a hazardous waste.
ATK Launch Systems inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
All non-aqueous hazardous waste generated by the sampling operation will be transported by a
third party contractor off site to a fully permitted TSDF for disposal. Any waste determined not
to be hazardous under EPA regulations will be sent via third party to a non-hazardous landfill for
disposal.
A field log will be maintained to track and identify all samples. This log will include sample
numbers, dates, times, sample depth, samplers name, weather conditions and test methods and
constituents for which to analyze.
1.5.1.3 Health and Safety Procedures
Soil and water sampling will be performed by trained and qualified personnel. A determination
of appropriate PPE to be utilized for this effort will be determined at the time of closure. PPE
selection will be based on potential hazards as determined at the time of closure, and in
consuhation with Industrial Hygiene.
Soil sampling should only be required at the bum grounds, because of well maintained secondary
containment and waste management practices during the entire life of all other permitted
facilities. Protective clothing appropriate for the task will be used during removal of waste and
during decontamination of containment areas for the permitted storage and treatment units.
1.5.2 Determining Cleanup Goals
For the purposes of estimating closure costs, it is assumed that all ofthe HWMUs will be clean
closed. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(l). All closures will
assess real and potential impacts to human and ecological exposures. It is anticipated that the
HWMUs will be clean closed and will not require post-closure care.
1.5.3 Site Cleanup
1.5.3.1 Inventory Removal [40 CFR 264.112(b)(3) and UAC R315-8-7]
The maximum inventory ofhazardous waste on hand at any given permitted facility is based on
the maximum allowed under this permit, or a quantity distance limit for explosives, imposed by
the Department of Defense and ATK. These limitations are specified in section 1.3 ofthis
closure plan.
Transportation and disposal of all hazardous waste during closure ofa facility will be based on
hiring of a third party company. The transportation contractor will be licensed and insured, and
the disposal facility will be permitted with the EPA or State to accept the waste ATK sends. The
only exception to the use of a third party disposal facility, will be for disposal of reactive
hazardous wastes.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Due to the inherent hazardous nature of reactive wastes, and limited disposal options nation
wide, ATK plans to properly treat and dispose ofthis waste on site. Cost calculations for
treatment, disposal and equipment decontamination will be based on maintaining an ATK staff
sufficient to complete these efforts.
1.5.3.2 Disposal or Decontamination of Equipment and Structures [40 CFR 264.112(b)(4),
264,112(e), and 264.114 and UAC R315-8-7]
Decontamination of equipment and stmctures at the Promontory facilities will follow one of two
plans. These plans cover the open buming units, and all other facilities.
The open buming facilities utilize bum trays, pipes, concrete vaults or rocket cases to contain the
waste to be treated. Most ofthe material bumed is hazardous by characteristic only. Any waste
that may be contaminated with, or contains solvents or hazardous heavy metals is designated as a
derived waste, and the ash collected for offsite disposal. Therefore, except for the derived trays,
all bum ash in trays, vaults, cases, and on the ground around these imits will be collected and
sent to the on site ATK landfill for disposal. The bum trays will then be high pressure water
washed and the rinsate sent to an off site disposal facility. After the final rinse, a composite
sample from the trays will be collected and analyzed at an independent lab to verify proper tray
decontamination. Each sample will include rinsate from 5 trays. Samples will be tested for
those constituents specified in tables 4 & 5 as appropriate.
All facilities except for the bum grounds, are designed with secondary containment. This
containment includes a concrete pad with curbing and blind sump to simplify wash down and
cleanup. The entire containment pad and sump is coated with a chemical resistant epoxy to
prevent liquid migration through the concrete. These pads are inspected daily, when in use, and
maintained as needed. After removal of all containerized waste, the containment pads will be
high pressure water washed, and rinsate collected for third party offsite disposal. After final
wash, rinse water samples will be collected from each sump and tested for the organics and
metals found in table 4 or 5 ofthis plan, to verify cleanliness. All samples will be sent to a State
certified third party laboratory for analysis.
1.5.3.3 Closure Containers [40 CFR 264.178,264.112(b)(3), and 270.14(b)(13) and UAC
R315-8-9.9, R315-807, and R315-3-5(b)(13)|
All hazardous ash, rinse water and other contaminated debris will be placed in a UN container or
a bulk USDOT authorized containers for offsite shipment to permitted disposal facilities. Empty
containers will be cleaned in compliance with 49 CFR, and sent for disposal.
2.0 Closure Certification [40 CFR 264.115 and UAC R315-8-7]
Within 60 days ofcompletion of closure of each facility, ATK will submit to the DSHW, a
certification by registered mail, that the hazardous waste management facility was closed in
compliance with this closure plan. This certification will be signed by ATK and an independent
registered professional engineer licensed in Utah. Documentation supporting the engineer's
registration will be provided upon request.
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
September 2008
UTD009081357
3.0 . Closure Cost Estimate [40 CFR 264.142]
The total closure cost is estimated to be $704,082. A detailed breakdovm of these costs is
presented below in the Closure Cost Estimate Figures 1 through 8 in current dollars. The entire
estimate is based on hiring a third party, except for the thermal treatment and disposal of reactive
waste, which will be handled onsite.
4.0 Financial Assurance Mechanism for Closure [40 CFR 264.143 and R315-309]
ATK will maintain current financial assurance meeting the requirements outlined in the above
referenced Federal and State regulations. ATK will provide documentation to DSHW supporting
compliance with financial mechanism requirements.
5.0 Post Closure Plan
If it is determined that a HWMU can not be clean closed, contaminants may be left in place, and
ATK will develop a post-closure or site management plan for all areas ofthe unit(s) that can not
be clean closed. Any proposal for post-closure care or site management will be developed in
accordance with UAC R315-8-7, UAC R315-8-8 and 40 CFR 264 Subparts G and H and will be
submitted to the Executive Secretary for approval. If this approach is necessary, the Post
Closure Permit may be modified to provide post closure care for the sites that are not clean
closed.
TABLE 1
Estimated Closure Schedule for Each Facility (
Task
1
2
3
4
5
6
7
8
Closure Activity
Mobilize
Thermally treat reactive waste and place ash in
landflll or prepare for off site disposal as
appropriate.
Decontaminate bum trays and clean area around
trays.
Collect soil samples and obtain lab results
Demobilize
Review and validate soil and water lab results
Write closure report and obtain independent
engineer closure certification
Monitor and implement post-closure activities
:M-136, M-225)
Start Date
Day-1
D-4
D-15
D-26
D-51
D-54
D-50
D-100 If
required
Completion
Date
D-3
D-14
D-25
D-50
D-53
D-74
D-100
To be
determined
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
September 2008
UTD009081357
TABLE 2
Estimated Closure Schedule for Each Facility (V
Task
1
2
3
4
5 .
6
7
8
Closure Activity
Mobilize
Transport reactive waste to the M-l 36 Bum Grounds
Thermally treat reactive waste
Sweep and clean floor as needed
Visually inspect building and loading area looking for
signs of contamination
Demobilize
Obtain independent engineer closure certification
Prepare and submit closure letter to DEQ
1-47, M-603)
Start
Date
Day-1
D-4
D-15
D-26
D-37
D-48
D-52
D-83
Completion
Date
D-3
D-14
D-25
D-36
D-47
D-51
D-82
D-93
TABLE 3
Estimated Closure Schedule for Each Facility (M-186, M-705S, E-501, T-29)
Task
1
2
3
4
5
6
7
8
Closure Activity
Mobilize
Profile and prepare waste for offsite shipment
Ship waste to offsite permitted TSDF
Sweep and wash down building floor as needed
Visually inspect building and loading area looking for
signs of contamination
Demobilize
Obtain independent engineer closure certification
Prepare and submit closure letter to DEQ
Start
Date
Day-1
D-4
D-45
D-66
D-71
D-74
D-78
D-l 09
Completion
Date
D-3
D-44
D-65
D-70
D-73
D-77
D-108
D-l 20
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
September 2008
UTD009081357
TABLE 4
M-136 constituents of concern
Explosives
HMX
RDX
Nitroglycerin
Organics/other
Ammonium Perchlorate
1,1,1 -Trichloroethane
Tetrachloroethylene
Acetone
Pyridine
Methylene Chloride
Carbon Tetrachloride
Benzene
Metals
Cadmium
Barium
Chromium
Silver
Lead
Mercury
Molybdenum Disulflde
Cobah
•
TABLE 5
M-225 constituents of coneem
Explosives
HMX
RDX
Nitroglycerin
Organics/other
Ammonium Perchlorate
1,1,1 -Trichloroethane
Tetrachloroethylene
Acetone
Pyridine
Methylene Chloride
Carbon Tetrachloride
Benzene
Metals
Cadmium
Baiium
Chromium
Silver
Lead
Mercury
Molybdenum Disulfide
Cobalt
Sodium Azide
10
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Figure 1
CLOSURE COST ESTIMATE, M-186
Removal of Waste Inventory Total ($)
a. Transportation & Disposal (400 dmms @ $250/drum) 100,000
b. Technician Labor (32 hrs @ $35/hr) 1,120
Decontaminating Pad
a. Technician Labor (16hrs @ $35/hr) 560
b. Transportation & Disposal
500 gal. of rinse water @ $4.00/gallon 2,000
Water Sampling & Analysis
a. Technician Labor (4 hrs @ $35/hr) 140
b. Sample Analysis (4 @ 500/sample) 2,000
Closure Certification
a. Engineer Labor (32 hrs @ $75/hr) 2,400
b. Engineer Expenses (4 days @ $100/day) 400 Subtotal $108,620
Contingency: 15 percent $16,293
Administration: 15 percent $16,293
Total $141,206
11
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Figure 2
CLOSURE COST ESTIMATE, M-705S
1. Removal of Waste Inventory Total ($)
a. Transportation & Disposal (32 drums @ $250/dmm) 8,000
b. Technician Labor (16hrs @ $35/hr) 560
2. Decontaminating Pad
a. Technician Labor (16 hrs @ $35/hr) 560
b. Transportation & Disposal
500 gal. of rinse water @ $4.00/gallon 2,000
3. Water Sampling & Analysis
a. Technician Labor (4 hrs @ $35/hr) 140
b. Sample Analysis (1 @ 500/sample) 500
4. Closure Certification
a. Engineer Labor (32 hrs @ $75/hr) 2,400
b. Engineer Expenses (4 days @ $100/day) 400 Subtotal $14,560
Contingency: 15 percent $2,184
Administration: 15 percent $2,184
Total $18,928
12
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Figure 3
CLOSURE COST ESTIMATE, E-501
Removal of Waste Inventory Total ($)
a. Transportation & Disposal (160 dmms @ $250/dmm) 40,000
b. Technician Labor (16hrs @ $35/hr) 560
Decontaminating Pad
a. Technician Labor (16 hrs @ $35/hr) 560
b. Transportation & Disposal
500 gal. of rinse water @ $4.00/gallon 2,000
Water Sampling & Analysis
a. Technician Labor (4 hrs @ $35/hr) 140
b. Sample Analysis (1 @ 500/sample) 500
Closure Certification
a. Engineer Labor (32 hrs @ $75/hr) 2,400
b. Engineer Expenses (4 days @ $ 100/day) 400 Subtotal $46,560
Contingency: 15 percent $6,984
Administration: 15 percent $6,984
Total $60,528
13
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Figure 4
CLOSURE COST ESTIMATE, M-136
1. Removal of Waste Inventory Total ($)
a. Treatment & Disposal (100,000 lbs @ $,20/lb) 20,000
2. Decontaminating Trays
a. Technician Labor (32 hrs @ $35/hr) 1,120
b. Transportation & Disposal
1,000 gal. of rinse water @ $4.00/gallon 4,000
3. Water & Soil Sampling & Analysis
a. Technician Labor (80 hrs @ $35/hr) 2,800
b. Sample Analysis (20 @ 600/sample) 12,000
4. Excavation & Removal of Contaminated Soil
a. Excavate & Load Tmcks 30 hrs @ 100 3,000
b. Transportation & Disposal 50 tons @ 100 5,000
5. Closure Certification
a. Engineer Labor (40 hrs @ $75/hr) 3,000
b. Engineer Expenses (5 days @ $100/day) 500 Subtotal $51,420
Contingency: 15 percent $7,713
Administration: 15 percent $7,713
Total $66,846
14
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 -- Closure Plan UTD009081357
Figure 5
CLOSURE COST ESTIMATE, M-225
1. Removal of Waste Inventory Total ($)
a. Treatment & Disposal (50,000 lbs @ $.25/lb) 12,500
2. Decontaminating Trays
a. Technician Labor (24hrs @ $35/hr) 840
b. Transportation & Disposal
500 gal. of rinse water @ $4.00/gallon 2,000
3. Water & Soil Sampling & Analysis
a. Technician Labor (40 hrs @ $35/hr) 1,400
b. Sample Analysis (12 @ 600/sample) 7,200
4. Excavation & Removal of Contaminated Soil
a. Excavate & Load Tmcks 20 hrs @ 100 2,000
b. Transportation & Disposal 25 tons @ 100 2,500
5. Closure Certification
a. Engineer Labor (30 hrs @ $75/hr)
b. Engineer Expenses (4 days @ $100/day)
Subtotal
Contingency: 15 percent
Administration: 15 percent
Total $40,418
2,250
400
$31,090
$4,664
$4,664
15
ATK Launch Systems Inc. - Promontory September 2008
Attachment 5 - Closure Plan UTD009081357
Figure 6
CLOSURE COST ESTIMATE, T-29B
1. Hydrazine Dilution and Removal of Waste Inventory Total ($)
a. Transportation & Disposal (2 drums @ $400/dmm) 800
b. Technician Labor (16 hrs @ $35/hr) 560
2. Decontaminating Pad
a. Technician Labor (10 hrs @ $35/hr) 350
b. Transportation & Disposal
500 gal. of rinse water @ $4.00/gallon 2,000
3. Water Sampling & Analysis
a. Technician Labor (4 hrs @ $35/hr) 140
b. Sample Analysis (2 @ 500/sample) 1,000
4. Closure Certification
a. Engineer Labor (16 hrs @ $75/hr) 1,200
b. Engineer Expenses (2 days @ $100/day) 200 Subtotal $6,250
Contingency: 15 percent $938
Administration: 15 percent $938
Total $8,126
16
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
September 2008
UTD00908I357
Figure 7
CLOSURE COST ESTIMATE, M-47
Removal and Disposal of Waste Inventory
a. Transportation to Bum Grounds 80 hrs @ 75
b. Treatment & Disposal 840,000 lbs @ .25
Sweep/Clean Facihty Pad
a. Technician Labor (10 hrs @ $35/hr)
Closure Certification
a. Engineer Labor (lOhrs @ $75/hr)
b. Engineer Expenses (2 days @ $100/day)
Total ($)
6,000
210,000
350
750
200
Subtotal
Contingency: 15 percent
flP Administration: 15 percent
Total
$217,300
$32,595
$32,595
$282,490
17
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
September 2008
UTD009081357
3.
Figure 8
CLOSURE COST ESTIMATE, M-603
Removal and Disposal of Waste Inventory
a. Transportation to Bum Groimds 60 hrs @ 75
b. Treatment & Disposal 240,000 lbs @ .25
Sweep/Clean Facility Pad
a. Technician Labor (10 hrs @ $35/hr)
Closure Certification
a. Engineer Labor (10 hrs @ $75/hr)
b. Engineer Expenses (2 days @ $ 100/day)
Total ($)
4,500
60,000
350
750
200
Subtotal
Contingency: 15 percent
Administration: 15 percent
$65,800
$9,870
$9,870
Total $85,540
18
.y I
/
\ • \
\ •
?^\ A
v.y
M-186
AREA OF INFLUENCE-
PERMITTED AREA
= DRAINAGE FLOW
M-136 BURN GROUND
CLOSURE PLAN FIGURE 1
= DRAINAGE FLOW
M-225 BURN GROUND
CLOSURE PLAN FIGURE 2
.,/
CHEMICAL RESISTANT CONCRETE
FLOOR WITH CONTAINMENT CURBS
AND SUMPS
\ N*.
PAD WITH CONTAINMENT
CURB AND SUMP
\
M-186
M-186
CLOSURE PLAN FIGURE 3
GRAVEL M-47 RAILS
-riL
tr t^
CONCRETE
ASPHALT ROAD
GRAVEL
AREA OF INFLUENCE i
M-47
CLOSURE PLAN FIGURE 4
/
AREA OF INFLUENCE
E-501
HAZARDOUS WASTE
DRUM STORAGE PAD
CONCRETE FLOOR
WITH CONTAINMENT
CURB & EPOXY COATING
LOCKED VALVE \
BLIND SUMP
/
D
/
E-501
CLOSURE PLAN FIGURE 5
SCALE: 1' = 60r-OP
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ATTACHMENT 7
SECURITY PLAN
ATK Launch Systems Inc. - Promontory September 2008
Attachment 7 - Security UTD009081357
07 HAZARDOUS WASTE MANAGEMENT
07.01.1 SECURITY PROCEDURES
07.01.1 Purpose and Scope
The work performed at the ATK Launch Systems, Promontory facility
primarily involves Department of Defense and NASA contracts; therefore,
comprehensive security agreement measures have been instituted. These
security measures meet the requirements ofthe Division of Solid and
Hazardous Waste Administrative Rules R315-8-2.5. No waiver from
these requirements is being sought as the facility has both a twenty-four
hour surveillance system and an artificial barrier around the facilities to
minimize the possibility of unknown entry of livestock or personnel.
07.01.2 Surveillance System
Security is maintained by a trained security force which controls entry and
exit from the facility and provides patrol, escort, and other activities within
the plant. All plant entrances are maimed by a minimum of one security
officer twenty-four hours per day, every day. All other gates are locked
and only used when authorized by attending Security. All employees
entering the facility must show identification badges at the gate and wear
them in plain sight throughout the day. All visitors and vendors are
required to wear special identification badges.
07.01.3 Artificial Barrier
There are artificial or natural barriers around the entire plant. The primary
barrier consists ofa chain link and barbed wire fence with controlled
access at the main entrances to the plant. The chain link fence runs along
the highway from building A until it runs into the gully formed by Blue
Creek just west of M-46. A natural barrier is provided by the Blue Creek
gully which is approximately 15 feet deep with near vertical sides. This
barrier extends for approximately 8,000 feet to a five-foot, four-strand
barbed wire fence. This fence extends to the north, changes to chain Unk,
and runs around the north end ofthe Plant. The chain link fences are
seven feet high and topped with barbed wire. This fence is continued by a
five-foot, four-strand barbed wire fence, which completes the primary
barrier by encircling North Plant, Test, and South Plant. Plant III is
encircled by a five-foot, four-strand barbed wire fence and also has
controlled access at the main entrance. Each hazardous waste
management area also has an artificial barrier.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 7 - Security UTD00908I357
E-501: The Container Storage Area is surrounded by a seven-foot chain link
fence and has controlled access. The gate is locked when no one is
present.
M-136: A five-foot, four-strand barbed wire fence surrounds the Buming
Grounds area. It has a gate, which is locked when no one is present.
M-186: A five-foot, four-strand barbed wire fence surrounds the Container
Storage Area. It has a gate, which is locked when no one is present.
M-225: The Buming Grounds are surrounded by an eight-foot, chain link
fence. It has a gate, which is locked when no one is present. A five-
foot, four-strand barbed wire fence surrounds the mnoff dispersion
area.
M-705 S: The hazardous waste management area is inside a building with
lockable doors to provide access control. In addition, the facility uses
the plant's artificial barrier.
M-47: The propellant/motor storage area remains locked except when
occupied by personnel for placement of material into storage or
removal from storage.
M-603: The propellant/motor storage and disassembly building is restricted
and requires check in at building M-l92 before entry is permitted.
T29B: Building T29B remains locked at all times and is controlled by
authorized Test Service personnel.
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.
ATTACHMENT 8
PREPAREDNESS AND PREVENTION PLAN
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
8-1 PROCEDURES, STRUCTURES, AND EOUIPMENT
8-1-1 Purpose and Scope
Precautions have been taken to minimize the accidental or sudden release
of hazardous waste or waste constituents into the environment. The
precautions comply with the requirements of R315-8-3.2.
8-1-2 Loading and Unloading Operations
Several precautions have been taken to minimize hazards during the
loading and unloading ofhazardous waste. These precautions are divided
into three classes of Waste Management: Open Buming, Dmm Storage
and Propellant^Explosives Storage.
Open Buming of hazardous waste explosives and propellants requires
special precautions. Precautions taken during loading and unloading
operations are described in M-136 Buming Grounds Operating procedures
and in M-225 Buming Grounds Operating procedures. Safe loading and
unloading of explosive waste helps to minimize waste release into the
environment and reduce the possibility of unplanned ignition of waste
material.
Waste energetic material received from off-site for storage prior to open
buming, will be handled under the same precautions as all other wastes
accepted for disposal at the burn grounds. Loading/off-loading areas will
be inspected each day waste is received, and at a minimum of once per
week.
Several precautions are also taken at the Dmm Storage areas. Spill control
equipment is located at each area and can be used in loading and unloading
operations. All drums are on pallets and are loaded and unloaded by a
forklift. The design ofthe Drum Storage facilities allows adequate aisle
space for movement of dmms with a forklift to minimize the actual
handling ofthe drums. Permit condifions II.J.6. and III.E.4. state that, at a
minimum, the Permittee shall maintain 30 inches of aisle space between
containers or pallets ofcontainers at storage areas M-186 and E-501. All
forklift tmck operators must have a license to operate the forklift tmck.
The operator receives this license by attending a training program which
includes an actual driving test that must be passed. The hazardous waste
operators must also participate in the Hazardous Waste Training Program
discussed in Attachment 3.
Waste propellant, explosives and rocket motors are carefully off loaded
from tmcks using fork lifts, building cranes or a trailer mounted knuckle
boom. Small containers, less than 50 lbs, may be off loaded by hand. All
1
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
operators ofthe equipment listed above, under go extensive training in the
proper use ofthe equipment they operate. This training includes class
room as well as hands on training. All ATK propellant moving, grounding
and bonding procedures will apply.
Many precautions are taken during the transfer of waste hydrazine during
the dilution process that is used to prepare this waste for off-plant disposal.
These precautions include medical certification, operator knowledge of
chemical properties, special safety equipment, and specific operating
instmctions.
8-1-3 Prevention of Run-on and Run-off
Run-on and mn-off are controlled at the drum storage pads M-l 86 and
E-501 by a concrete berm around the facility. The M-705 storage and
consolidation room is totally enclosed preventing run-on from entering the
facility and eliminating any possibility for mn-off. Details of these
stmctures and how they control mn-off are found in Attachment 6 ofthis
Permit.
Run-on and mn-off at the Buming Grounds, M-225, and M-136 are
controlled by diversion, collection ditches, and trenches. A diversion ditch
directs rim-on around the Buming Grounds. The mn-off at M-136 is
collected in a ditch and dispersed in a dispersion area. The mn-off at
M-225 is dispersed in an area directly in front ofthe buming area. Both
areas will be included in the zone of Engineering Control. Drawings
showing the control systems for M-136 and M-225 are included in
Attachment 6.
Run-on and run-off at buildings M-47 and M-603 are controlled since the
facilities are fully enclosed buildings which are elevated above the
surrounding grade to prevent rain intmsion. Drawings of these buildings
are found in Attachment 6 ofthis permit.
8-1-4 Prevention of Water Supplv Contamination
The drum storage areas, M-186, E-501, and M-705S each have a
containment system which is designed to prevent releases of contaminants
to the environment. Each system is constmcted to be leak-proof and divert
run-on. These containment systems are shown in the facility drawings
contained in Attachment 6.
The propellant/motor storage buildings store only solid materials, and do
not require secondary containment. The nature ofthis solid waste,
combined with ftilly enclosed storage buildings, greatly reduce the
potential for contaminating water supplies.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
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
controlling 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.
Historical management ofhazardous waste has resulted in groundwater
contamination at ATK. Semiannual groundwater monitoring is conducted
in the area ofthe M-136 Buming Grounds, and down-gradient, in
accordance with ATK's Post-Closure Permit. Groundwater flow and
transport models have been developed to help predict the migration of
contaminant plumes. Risk assessments and potential corrective measures
will be conducted once the Division of Solid and Hazardous Waste
approves the groundwater models.
8-1 -5 Mitigating Effects of Equipment Failures and Power Outages
A power outage or equipment failure will have little effect on the
hazardous waste storage and treatment areas. Any equipment failures,
such as tmck breakdowns, pump repairs, etc.; can be managed by on-plant
maintenance. Power outages can occur, but all critical operations have
backup generators so hazardous waste can be controlled. ATK maintains
an electrical lineman crew that has the necessary equipment and
experience to repair on plant power outages. In the event ofa very large
power outage or repair. Rocky Mountain Power will.be contacted and
necessary measures taken to restore power.
8-1-6 Prevention of Undue Exposure to Personnel
Exposure to personnel handling hazardous waste is minimized by
containing and safely packaging waste and supplying personnel with
proper protection and safety equipment. Section 111 F ofthe Contingency
Plan (Attachment 4) lists the equipment available to all plant personnel.
Specific procedures and requirements for personnel protection during the
handling ofhazardous waste are specified in area standard operating
procedures.
8-1-7 Emergency Equipment
This equipment is inspected on a monthly basis. The emergency
equipment is intended to help respond to small emergencies such as leaks
or spills. It is not intended to respond to major incidents, fires, nor
explosions. It is limited to equipment that is manually operated and is
easily portable. Monthly inspections assure there are adequate supplies of
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
material on hand and mechanical items are operable so that immediate
response to small emergencies can be safely handled.
ATK maintains a spill response trailer which is used to respond to spills
that are medium to large. The trailer contains safety and spill response
equipment. This 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.
8-1-8 General Areas
The general area of each hazardous waste storage site is inspected on a
daily basis when in use. These inspections consist of observing the area
for possible spills or mismanagement ofhazardous waste. These areas
need daily inspections when in use to minimize potential for
mismanagement ofhazardous wastes during loading, unloading, or
handling.
8-1-9 Safety Equipment
Safety equipment is inspected monthly. Monthly inspections include
testing equipment to make sure it is in working order and ensuring that all
equipment is complete and in place. These inspections help to maintain a
safe work environment and minimize human health incidents.
8-1-10 Storage and Containment System
The storage and containment system shall be inspected as directed in
Attachment 2. In some cases, inspections are required, as stated in the
attachment, after each storm event. A storm event is defined as more than
one inch of precipitation in a one-hour period. This is not only a
regulatory requirement, but these inspections help to operate the container
storage area in a safe manner and minimize environmental incidents.
Inclement weather and mismanagement are the primary sources of
deterioration ofthe containment system and containers.
Standing liquids in the containment system and/or sumps must be
managed according to Section 9-4.3 of Attachment 9 - Container
Management Procedures. Inspections are conducted in order to effectively
manage standing liquid. These inspections minimize environmental
impacts from the actual storage ofhazardous wastes in the storage areas.
If a leaking or deteriorating drum is identified during the inspection, 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
ATK Launch Systems Inc. - Promontory September 2008
Attachmenl 8 - Preparedness and Prevention UTD009081357
transfer action must be noted in the inspection log. The transfer ofthe
leaking or deteriorating dmm can be handled in two ways: the contents of
the container can be transferred by pump to a new dmm,or the drum can
be placed in an 85-gallon over-pack drum with the space between the two
drums filled with an absorbent to control any possible leaks.
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.
In addition, containers stored in bum trays at M-136 are inspected to
ensure that they are in good condition, closed and labeled. Bum trays are
inspected for cracks and gaps and accumulation of leaked liquids or
precipitation. Inspections conducted as described above, provide the time
necessary to correct maintenance and erosion or wear problems. They also
minimize the environmental impact at the Buming Grounds.
8-1-12 General Facility
Equipment and PPE required to properly manage hazardous waste and for
spill clean up is kept at the permitted facilities and regularly inspected.
New materials are purchased as needed to assure an adequate supply.
8-1-13 Fire Department Equipment
The Fire department inspects their equipment on a routine basis and after
each use. This equipment is especially important to aid in minimizing the
effects from fires, explosions, and spills. The inspections are performed
and records are kept by the Fire Department personnel.
8-1-14 Heavy Equipment
Most ofthe heavy equipment is used on a regular basis for constmction
services and for the management of solid wastes. It is also available for
use in emergencies. This equipment is handled at the heavy equipment
garage and is inspected on an hour-usage basis rate of 100-150 hours
depending on the equipment type and working conditions. A detailed
checklist is covered by Maintenance that is checked thoroughly by trained
personnel. All inspection records on heavy equipment are kept on file at
Maintenance Control and are available for inspection.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
8-1-15 Inspection 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. Environmental Services keeps the inspection
logs ofthe 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.
8-2 CONTINGENCY PLAN
8-2-1 Purpose and Scope
ATK has developed and supplied a contingency plan as required by R315-
3-2.5(b)(7) and R315-8-4. This plan has been devised as a separate
document so that it can be used independently of this permit.
A copy ofthe contingency plan is in Attachment 4. The plan has been
designed to minimize hazards to human health and the environment from
fires, explosives, or any unplanned or sudden release ofhazardous wastes.
8-3 PREPAREDNESS AND PREVENTION
8-3-1 Purpose and Scope
The hazardous waste treatment and storage facilities have been designed,
constructed, maintained, and operated to minimize the possibility of
unplanned fires, explosions, or discharges ofhazardous wastes. In the
event of an emergency, the responsibilities of responders, organizational
stmcture, and procedures required to ensure effective waming, response,
and control to minimize hazards to human health or the environment are
addressed in detail in the Contingency Plan (Attachment 4).
8-3-2 Required Equipment
All hazardous waste facilities are equipped to respond effectively to an
emergency situation. Should an emergency situation arise, such as a
discharge ofhazardous waste, a fire, or an explosion, employees who are
in hazardous waste management areas should be able to respond according
to the procedures outlined in the Contingency Plan.
All hazardous waste facilities are equipped with intemal and extemal
communication systems. Intemal communications are provided by voice
signals and commands specified in the Contingency Plan in Section E. All
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
hazardous waste facilities are in open-space areas and there are no loud,
industrial noises that could muffle voice commands or signals. These
voice commands provide immediate onsite emergency instmctions to
employees in the hazardous waste management areas. An extemal
communication system using telephones is provided for employees at each
area. These telephones can be used to contact Intemal Emergency
Response or initiate the Contingency Plan. Storage buildings not equipped
with alarms or hard wired phones, will utilize cellular phones to contact
ATK's emergency responders if needed.
To prevent encouraging personnel to fight fires in the waste rocket
motor/propellant storage buildings and adjacent waste docks, fire
extinguishers are not provided. All other hazardous waste storage areas
are equipped with fire extinguishers.
The buildings that have separate electrical rooms, have extinguishers that
are to be used in the electrical rooms only. Spill clean up material will be
provided in each of these buildings as outlined in section III.F ofthe
Contingency Plan. The location ofthe fire extinguisher is shown on the
evacutation plan in Appendix 1 ofthe Contingency Plan. Along with
these portable extinguishers, ATK maintains a Fire department to respond
to fires or explosions. Descriptions of fire equipment, available water, and
the Fire department are described in Section I G of the Contingency Plan.
Buildings M-47 does not have water immediately available, but rely on
ATK's full time, fiilly equipped and trained Fire Department for any
emergency response action. Building M-603 is equipped with a fire
sprinkler system, which is checked at least annually.
8-3-3 Testing and Maintenance of Equipment
All emergency and safety equipment is inspected on a routine basis to
ensure it is in working order and in good repair. These inspections are
documented and are available for inspection.
8-3-4 Access to Communications or Alarm Systems
All employees who manage hazardous waste have immediate access to
both intemal and extemal communication systems. All employees have
access to telephones or cellular phones and are trained on how to summon
extemal emergency assistance if required.
8-3-5 Required Aisle Space
Aisle space has been designed into each drum storage pad. This type of
drum storage allows easy access to thoroughly inspect the area around
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
each dmm and allows adequate room to transfer hazardous waste into a
new dmm if a dmm is found to be leaking or in poor condition. There is
enough aisle space and clearance around each storage pad to allow free
movement of fire protection equipment, spill control equipment, and any
needed decontamination equipment. Detailed drawings ofthe dmm
storage areas are found in Attachment 6 of this Permit. An aisle space of
30 inches minimum between containers or pallets ofcontainers will be
maintained at storage areas M-186 and E-501. Hazardous waste stored in
containers at M-705S, M-47, M-603 and M-136 will be stored so that they
may be readily inspected and hazardous waste labels are visible.
8-4 PRECAUTIONS TO PREVENT IGNITION AND REACTION
8-4-1 Purpose and Scope
Precautions to prevent accidental ignition or reaction are essential to the
safety of all personnel. The precautions taken ensure compliance with
R315-8-2.8. The precautions are a part of everyday manufacturing and
production activities at ATK.
8-4-2 Precautions for Open Buming of Explosives and Propellants
Many precautions are taken to prevent accidental ignition or reaction of
hazardous waste materials at the Buming Grounds at M-136 and M-225.
Because ofthe extremely sensitive nature of these wastes, special
precautions are taken for each source of ignition.
Safety procedures for handling energetic and sensitive materials are found
in ATK's Hazardous Operations Standard Manual (AHOPS) and the
Reactive Waste Disposal Instmctions (RWDI) which are available at the
facility for inspection.
8-4-3 Precautions for Dmm Storage ofHazardous Waste
The drum storage buildings have been designed to hold flammable liquids.
The front of M-186 and all sides of E-501 are open to ensure that proper
ventilation is maintained in each storage area. Doors are opened as needed
at M-705S to provide adequate ventilation. Unauthorized personnel are
kept out ofthe storage areas. The areas are inspected on a weekly or daily
basis and all leaking or damaged containers are replaced as addressed
above and in Attachment 9.
In the event ofa spill ofhazardous waste or material which, when spilled,
becomes hazardous waste, the person responsible for the material at the
time ofthe spill shall immediately take appropriate action to minimize the
8
ATK Launch Systems Inc. - Promontory September 2008
Attachment 8 - Preparedness and Prevention UTD009081357
threat to human health and the environment and comply with UAC R315-9
and implement the Contingency Plan if necessary.
8-4-4 Precautions for Propellant/Motor Storage
All propellants/motors will be safely handled in accordance with AHOPS.
These procedures include, but are not limited to, proper grounding and
bonding protocol. All permitted hazardous waste storage and treatment
facilities are located more than 50 feet from any property line to help
minimize the fire potential of adjoining property. General site maps which
show these buildings, as well as the property lines, are found in
Attachment 6.
ATK Launch Systems Inc. - Promontory
Attachment 8 - Preparedness and Prevention
September 2008
UTD009081357
TABLE 8A
Precautions Against Accidental Ignition and Reaction ofHazardous Waste
Explosives and Propellants
IGNITION SOURCE
Smoking
Open Flames
Static Electricity
Incompatible Materials
Friction and Sparks
Electrical Equipment
" .::§»RECAUTIONS ^ Y ....
Buming grounds are designated as areas
where smoking is a fire hazard and as such
must meet the requirements of company
procedures. Requirements for smoking are
strictly enforced by the Safety department.
The use of a flame, heat, or spark-emitting
device in any area requires a permit.
Requirements for uses and restrictions of
these permits are found in company
procedures. These permits are issued prior to
starting work.
Static electricity can be an ignition source. To
avoid static charges, all explosive or
propellant waste is packed in a container with
either a conductive or static dissipative liner.
During storage and prior to and/or during
transportation of wastes to the buming
grounds, all conductive waste containers are
grounded to prevent static spark. Upon
placement in the metal bum tray, grounding is
no longer required. Rocket motors for disposal
will not be packaged in these liners, but will
be grounded to the case prior to being placed
into position for open buming.
Incompatible materials are not placed in the
same containers and incompatible wastes are
segregated at each waste pickup dock.
Vehicles hauling waste propellant must have
spark arresters in the exhaust line. Non-
sparking rakes are used in preparing the
trenches for buming or re-buming. A porous,
non-sparking tmck bed is also used.
No electrical work is allowed in areas where
explosives or propellant are present.
10
ATK Launch Systems Inc. - Promontory
Attachment 8 - Preparedness and Prevention
September 2008
UTD009081357
TABLE SB
Precautions Against Accidental Ignition and Reaction ofHazardous Waste in
Drum Storage
IGNITION SOURCE
Smoking
Open Flames
PRECAUTIONS
The dmm storage areas are designed as
areas where smoking is a fire hazard and as
such must meet the requirements of
company procedures. Requirements for
smoking are strictly enforced
The use of a flame, heat, or spark-emitting
device in any area ofthe plant requires a
permit. Requirements for uses and
restrictions of these permits are found in
company procedures. These permits are
issued prior to starting work.
11
ATTACHMENT 9
CONTAINER MANAGEMENT PROCEDURES
ATK Launch Systems Inc. - Promontory September 2008
Attachment 9 - Container Managemenl UTD009081357
CONTENTS
USE AND MANAGEMENT OF CONTAINERS 3
9-1 PURPOSE AND SCOPE 3
9-1.1 Facility Description 3
9-2 MANAGEMENT OF CONTAINERS 4
9-2-1 Types of Containers for Storage 4
9-2-2 Waste Compatibility 5
9-2-3 Storage of Containers 6
9-2-4 Inspections 8
9-2-5 Operating Record 8
9-3 LAB PACKS AND WASTE CONSOLIDATION 8
9-3-1 Lab Pack Preparation 8
9-3-2 Lab Pack Labeling 9
9-3-3 Containment Sealer 9
9-3-4 Lab Pack Compatibility 9
9-4 CONTAINMENT 9
9-4-1 Capacity of Containment 9
9-4-2 Containment Sealer 10
9-4-3 Removal of Free Liquids From
Containment Area 10
9-5 RUN-ON AND RUN-OFF CONTROL 11
9-6 REOUIREMENTS FOR IGNITABLE AND REACTIVE
WASTES 12
ATK Launch Systems Inc. - Promontory September 2008
Attachment 9 - Container Management UTD009081357
9 USE AND MANAGEMENT OF CONTAINERS
9-1 PURPOSE AND SCOPE
ATK Launch Systems - Promontory (ATK) currently manages the drum
storage areas at M-186, E-501, M-705S, the solid propellant storage
buildings at M-47 and M-603 and solid propellant storage in bum trays
and at Bum Station 14 at M-136 in accordance with the Division of Solid
and Hazardous Waste Administrative Rules R315-8-9. These waste
storage areas are owned and operated by ATK. All containers are being
temporarily stored waiting thermal treatment on-site, or shipment off-site
for recycling, treatment and/or disposal.
The dmm storage site at M-186 is designed to hold 400, 55-gallon dmms
of various types of waste intended for treatment or disposal. The drum
storage site at E-501 is designed to hold 160, 55-gallon drums of various
types of waste intended for treatment or disposal. The M-705S storage
and consolidation room is designed to store a maximum of 32, 55-gallon
dmms, both rooms include palletainers of various types of waste intended
for consolidation or lab packing. For solid propellant storage capacities,
see Module III section E.
9-1.1 Facilitv Description
The M-l 86 storage pad is permitted for the storage ofthe hazardous
wastes identified in Permit Condition III.B.l. The storage pad is divided
into five storage bays to keep incompatible materials separated. The pad is
a coated concrete floor with secondary containment. The M-186 storage
facility is shovwi in Figure E-l of Attachment 6.
The E-501 storage pad is permitted for the storage ofthe hazardous wastes
identified in Permit Condition III.B. 1. The pad is a coated concrete floor
with secondary containment. The E-501 storage facility is shown in
Figure B-l of Attachment 6.
The M-705S Storage and Consolidation Room is a single room with a
coated concrete floor and secondary containment. It is permitted for the
storage ofthe hazardous wastes identified in Permit Condition III.B.l.
The room is equipped with plastic containers to keep incompatible
materials separated. Poly-spill pallets are used to provide separate
containment for each consolidation dmm and lab pack dmm as needed.
The M-705S storage facility is shown in Figure C-l of Attaclmient 6.
M-47 is designed for storage of solid propellant/ explosives. This building
is sited for the maximum quantity of propellant/explosives based on
Quantity/Distance, DOD siting criteria found in the contractor safety
ATK Launch Sy.stems Inc. - Promontory September 2008
Anachment 9 - Container Management UTD009081357
manual, 4145.26m. Each building is set up to permit proper grounding
and cross bonding as appropriate. The M-47 storage facility is shown in
Figure G-1 of Attachment 6.
Building M-603 follows the same maximum quantity criteria as storage
building M-47. This building is also permitted for treatment ofthe waste,
in accordance with Module IV, through disassembly of motors or other
procedures needed to prepare the waste for disposal through open buming
or other similar techniques. The M-603 storage,and treatment facility is
shown in Figure D-l of Attachment 6.
The storage of solid propellant wastes received from off-site at M-136 is
only permitted for a maximum of 14 days. This includes waste stored in
containers placed in bum trays and waste rocket motors that contain solid
propellant placed on the ground at Bum Station 14. The storage of waste
materials received from off-site at M-136 is permitted in order to facilitate
more efficient and safer waste handling practices, and to accommodate
delays in waste treatment due to weather or other uncontrollable delays.
Storage ofthis waste will be in compliance with this permit and R315-8-9.
9-2 MANAGEMENT OF CONTAINERS
9-2.1 Tvpes of Containers for Storage
The containers to be used for storage, lab packing, or consolidation at
M-186, E-501, and M-705S will meet the UN or USDOT criteria or will
be a sturdy liquid tight altemative container. No more than 400 drums will
be stored at M-186; 160 dmms at E-501; and 32 drums at M-705S.
Substitute containers will reduce the number of drums that can be stored
based on the volume ofthe container chosen.
The containers that will be used for storing solid, reactive wastes at
M-47 and M-603 include rocket motor cases, bags, dmms or other
containers as approved by the UN or USDOT for the appropriate waste.
All solid reactive waste received from off-site and stored in bum trays at
M-136 will be stored in bags, drums or other containers as approved by the
UN or USDOT for the appropriate waste. Storage of these containers is
permitted in liquid tight bum trays or on the ground at Bum Station 14 for
intact rocket motors. All containers will be kept closed during storage.
Lab pack and consolidation dmms used for different compatibility groups
will be separated using a portable secondary containment system (PSCS)
such as a Poly-spill pallet. The PSCS will have the capacity to hold a
minimum of 55 gallons. Most PSCSs are unsatisfactory for storing most
ATK Launch Systems Inc. - Promontory
Attachment 9 - Container Management
September 2008
UTD009081357
organic waste; therefore, flammable/combustible waste lab packs or
consolidation drums will be placed on a pallet and stored on the floor
using the room's containment system. Lab pack and containment drums
with non-hazardous waste will be stored on the floor. Non-hazardous
waste found to be incompatible with solvents would be placed on a PSCS
for which it was found to be compatible. All fiill consolidation or lab pack
drums will be transferred from M-705S to a permitted storage facility to
stay within M-705S's storage capacity.
TABLE 9-2
HAZARDOUS WASTE COMPATIBILITY FOR STORAGE AT
M-186, E-501, M-705S, M-47 and, M-603
General Compatibility Groups
1. Flammable/combustible liquids
and non-flammable solvents
DOT Hazard Class in Group
a. Flammable Liquids
b. Combustible Liquids
2. Corrosives (acids)
3. Corrosives (bases)
4. Reactive Chemicals
a. Corrosive Liquids (acids only)
a. Corrosive Liquids (bases only)
a. Organic Peroxides
b. Oxidizes
5. Toxic Chemicals a. Toxic
b. Infectious
6. Explosives a.
b.
1.1
1.3
9-2.3 Storage of Containers
M-186, E-501 and M-705S
Before any waste container is accepted at M-705S, E-501, and M-186, it
shall be inspected to determine whether the waste matches the identity of
the waste specified on the accompanying manifest or shipping paper. In
addition, the containers shall be inspected to ensure that they are in good
ATK Launch Systems Inc. - Promontory September 2008
Attachment 9- Container Management UTD009081357
condition, are closed, and labeled in accordance with 40 CFR 262.34
(incorporated by reference in R315-5-3.34) and R315-5-3.31.
If the drum is found to be unacceptable, it must be immediately repacked
and relabeled or the waste transferred to a new dmm. Each dmm or
container must be entered into the operator's log (see Section 9-2.5) when
the drum or the container is accepted in to the drum storage area. A
forklift and/or pallet jack is used to move the pallet into the storage area.
Dmms or containers in the holding bays at M-186 and at E-501 will be
sampled according to Attachment 1 ofthis permit. The wastes are
accumulated until enough containers exist to complete a load. The
containers are then loaded into a tmck and shipped to the disposal facility
for proper treatment and/or disposal.
All drums stored at the M-705S, E-501, and M-186 storage areas will be
stored with either both plugs closed or with the top ofthe drum sealed. No
waste containers will be open unless waste is being added or removed.
Adding or removing waste will only occur at these storage facilities ifa
container is damaged, leaking, for sampling, for waste consolidation,
and/or for lab packing. A container may be filled if spilled material is
found in a sump during the transfer of waste containers. A container being
filled or replaced will be located in the containment area. This will
provide containment ifany spillage results from an incident during
transferring procedures. Precautions to be taken during the transfer ofthe
waste include: insuring all transfer equipment (i.e., hoses, pumps, funnels)
is located inside the containment area; ensuring a proper dmm is used
when transferring waste material.
An aisle space of 30 inches minimum between containers or pallets of
containers will be maintained at storage areas M-186 and E-501.
Hazardous waste stored in containers at M-705S, M-47, M-603 and M-136
will be stored so that they may be readily inspected and hazardous waste
labels are visible. 55-gallon drums may be stacked at a maximum of two
high at storage areas M-186 and E-501 only.
All storage containers shall have hazardous waste labels attached that meet
the requirements of 40 CFR 262.34 (incorporated by reference in R315-5-
3.34). All personnel required to complete RCRA labeling shall receive
training as appropriate.
M-47 and M-603
All waste propellant/explosives stored at M-47 and M-603 must be entered
into the operating record. Building inspections must begin upon first
receipt of material and end when all hazardous waste has been removed
from the building. All containers must be kept closed except when adding
ATK Launch Systems Inc. - Promontory Seplember 2008
Attachment 9 - Container Management UTD009081357
or removing waste. Adequate aisle space must be provided to permit
proper container inspection. Storage containers may not be stacked in
these storage buildings. Total quantity limitations are as outlined in
module III section E.
All containers shall have hazardous waste labels attached that meet the
requirements of 40 CFR 262.34 (incorporated by reference in R315-5-
3.34).
M-136 Bum Trays and Bum Station 14
All solid reactive wastes received from off-site shall be inspected prior to
placement into bum trays or Bum Station 14 at M-136 to determine
whether the waste matches the identity ofthe waste specified on the
accompanying manifest or shipping paper. In addition, the containers shall
be inspected to ensure that they are in good condition, are closed, and
labeled in accordance with 40 CFR 262.34 (incorporated by reference in
R315-5-3.34) and R315-5-3.31.
If a container holding hazardous waste is not in good condition, e.g.,
apparent stmctural defects, or if it has begim to leak, ATK personnel shall
take steps as appropriate to prevent a release from the container to the
environment.
Prior to placement ofhazardous wastes into bum trays, the tray shall be
inspected as outlined in Attachment 2. Once the container or waste rocket
motor received from off-site is placed in a bum tray or Bum Station 14,
the date ofthe placement shall be added to the hazardous waste label,
begimiing the 14 day maximum period which the waste may be stored.
Containers stored in bum trays at M-136 shall remain closed during
storage, except when it is necessary to add or remove waste. A container
holding hazardous waste shall not be handled or stored in a manner which
may rupture the container or cause it to leak. Containers shall be stored
such that the hazardous waste labels may be readily inspected.
9-2.4 Inspections
All container storage areas are inspected on at least a weekly basis.
Details ofinspection requirements for the storage areas are outlined in
Attachment 2. If a container is found with severe corrosion, structural
defects, rusty bungs, or leaking, 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
ATK Launch Systems Inc. - Promontory September 2008
Attachment 9 - Container Management UTD009081357
the inspection log and the Environmental Waste Disposal technical staff
must be notified.
9-2.5 Operating Record
All waste brought into the M-186, E-501, M-705S, M-47, M-603 and M-
136 storage areas are entered into a hazardous waste log compliant with
R315-8-5.3. This log is kept for all wastes.
If a waste material is consolidated, the consolidation drum is recorded in
the hazardous waste log in such a way as to allow the consolidated
material to continue to be tracked. Waste materials to be lab packed are
placed in a lab pack drum and recorded in a hazardous waste log in such a
way as to allow the material and the drum to also be tracked.
The operating record is kept for all hazardous wastes. These records are
used to track wastes as they come in from on and off-plant generators and
satellite generator facilities.
9-3 LAB PACKS AND WASTE CONSOLIDATION
9-3.1 Lab Pack Preparation
ATK disposes of several hazardous wastes in lab packs. Completed lab
packs are stored in the drum storage bays. Before a lab pack is accepted at
the drum storage bay, it must be prepared, labeled, and documented in
accordance with 40 CFR 262 Subpart C (incorporated by reference in
R315-5-3.34) and R315-5-3.31.
Materials in small containers may be stored at the lab packing and
consolidation room at M-705S or at M-l 86 for lab packing or waste
consolidation. The materials are separated into compatibility groups based
on DOT hazard classification. The materials are generally in small
containers ranging from one or two ounces to 5-gallon cans. The small
containers are then stored in palletainers or on a shelf until ready to lab
pack or consolidate. Incompatible materials are not allowed to be stored
in the same palletainer, or containment bay.
9-3.2 Lab Pack Labeling
Each waste container must be labeled with a complete hazardous waste
label.
8
ATK Launch Systems Inc. - Promontory
Attachment 9 - Container Management
September 2008
UTD00908I357
9-3.3 Containment Sealer
9-3.4
The concrete containment area where consolidation and lab packing occur
at M-186 and M-705S, is sealed with a high build polyamide epoxy
coating system or equivalent. The Material Safety Data Sheet and
compatibility chart for this material can be found on the manufacturer's
web site.
Lab Pack Compatibility
Under no circumstances will a lab pack contain wastes that are
incompatible. Compatibility of wastes will be determined by using the
MSDS or other reference sources. Ifa waste is not found in the reference
material, then the material will be assumed incompatible with all wastes
and lab packed separately unless research by Environmental Waste
Disposal's technical staff documents compatibility. Reactive wastes will
be lab packed or thermally treated at the M-136 bum grounds. Lab
packing will be done in accordance with USDOT regulations and the
requirements ofthe disposal company.
9-4
9-4.1
CONTAINMENT
Capacity of Containment
All the container storage areas and consolidation/lab packing areas at
M-186, E-501, and M-705S are designed to hold a minimum often
percent ofthe volume of waste stored in the area or the volume ofthe
largest container, which ever is greater. Table 9-5A summarizes the
calculations.
TABLE 9-5A
Containment Capacity of Dmm Storage Areas
Storage Container
M-186 Storage Bay
E-501 Storage Pad
M-705S Room
M-705S Poly-spill pallet
Number of Dmms
to be Stored
80 Dmms
160 Drums
16 Drums*
4 Dmms
Needed
Containment
440 Gal
880 Gal
88 Gal
55 Gal
Containment
Available
980 Gal
895 Gal
830 Gal
85 Gal
* Includes Palletainers
Buildings M-47and M-603 are not pennitted for storage of liquids. Each
container will be inspected to assure no liquids are present upon arrival at
the storage facility. These storage buildings are fully enclosed to prevent
9
ATK Launch Systems Inc. - Promontory September 2008
Attachment 9 - Container Management - UTD009081357
contact ofthe waste with rain water, and do not require secondary
containment. Roof leaks must be repaired as soon as is practicable.
9-4.2 Containment Sealer
The containment area at the M-186 and M-705S storage facilities are
coated with an epoxy resin to resist liquid penetration. No leakage or
spillage is anticipated during waste storage; however, in the event spills or
leaks do occur, the epoxy will prevent the material form penetrating the
concrete.
The containment system at E-501 is coated with an epoxy sealer that is a
high-build chemical resistant coating. The chemical compatibility and
properties ofthis epoxy are available from the manufacturer.
9-4.3 Removal of Free Liquids From Containment Area
Removal of free liquids at M-186, E-501, and M-705S must be done with
a pump or vacuum tmck. When free liquids are found in the sump, a
portable drum pump, either electric or hand operated, is used to transfer
the liquid to a UN 55 gallon drum. A vacuum tmck can also be used to
pump out collection of rain water and snow melt. Water pumped with the
vacuum tmck will be taken to a UPDES permitted waste water treatment
facility (M-705) for processing. All free liquids taken from the sumps will
be managed as hazardous wastes until waste analysis or inspection dictates
otherwise.
Precautions will be taken to avoid spills. All spills are cleaned
immediately, imless the size demands spill response. After the liquids are
transferred into drums, a sample will be taken form each dmm according
to the sampling procedure in the Waste Analysis Plan, contained in
Attachment 1. The dmms will be managed as hazardous waste until a
determination has been made classifying the contents. If the analysis
indicates the liquid is a hazardous waste as defined by the Division of
Solid and Hazardous Waste Administrative Rules R315-2, then the drums
will continue to be managed as a hazardous waste. If the liquid is a
wastewater, the liquid will be taken to M-705 Wastewater Treatment
Facility.
Occasionally, small amounts of liquid such as nitroglycerine can drip from
rocket motors onto the concrete floor. These drips are typically less than
1 -inch in diameter and may drip as much as once per week. Any sign of
out-of-place waste will be checked during the regular inspections outlined
in Attachment 2. Clean up of dripped materials will be completed as soon
as is practicable using rags and acetone or other appropriate cleaners.
10
ATK Launch Systems Inc. - Promontory Seplember 2008
Attachment 9 - Container Management UTD009081357
M-136 Bum Trays
Although the bum trays at M-136 are only permitted for the storage of
solid reactive wastes in containers for no more than 14 days, some of these
containers contain small amounts of desensitizing fluid (e.g. diesel,
shingle oil, etc.). Therefore, the containment requirements of R315-8-9.6,
as discussed below, apply to the storage of wastes in the bum trays.
The bum trays shall be free of cracks or gaps and be sufficiently
impervious to contain leaks, spills, and accumulated precipitation until the
collected material is detected and removed.
Spilled or leaked waste and accumulated precipitation shall be removed
from the bum trays in as timely a manner as is necessary to prevent
overflow ofthe tray. Inspection requirements for bum trays and the
accumulation of liquids are outlined in Attachment 2.
If the collected material is a hazardous waste under R315-2, it shall be
managed as a hazardous waste in accordance with all applicable
requirements ofthe State of Utah Hazardous Waste Management Rules. If
the collected material is discharged through a point source to waters ofthe
United States, it is subject to the requirements of section 402 ofthe Clean
Water Act, as amended.
9-5 RUN-ON AND RUN-OFF CONTROL
Run-on and run-off water is prevented form entering the M-l 86 and E-501
drum storage pads. Three sides of each pad contain a curb that is six
inches in height and a sloped grade in the front that is three inches above
the ground surface. Each pad has sufficient height to prevent run-on from
entering the dmm storage containment system. Detailed drawings of these
facilities are contained in Attachment 6.
The storage facility at M-705S is totally enclosed to prevent any run-on
water from entering the building.
Calculations have been performed for the M-l 86 storage pad and these
indicate that no mn-on or run-off should enter the storage building and
affect the capacity ofthe containment area. The calculations were based
on a 24-hour, 25-year storm event and were submitted with the Part B
Permit Application.
The terrain around the bum grounds has been graded and drainage ditches
surround the area in order to minimize mn-on. The topography and
11
ATK Launch Systems Inc. - Promontory September 2008
Attachment 9 - Container Management UTD009081357
drainage ditches at M-136 and M-225 are shown in Attachment 5, Figures
1 and 2. In addition, all waste will be in water tight bum trays to prevent
run-on and mn-off Waste Rocket motors will be covered to eliminate
contact with rain water, and will sit on chalks or pallets to avoid direct
contact with flowing storm water.
9-6 REOUIREMENTS FOR IGNITABLE AND REACTIVE WASTES
All container storage areas are located more then 50 feet from facility
property lines. The aerial photograph contained in Attachment 6
(Figure 6A) shows the property boundaries and facility location.
12
ATTACHMENT 10
T-29B HYDRAZINE DILUTION PROCEDURES
ATK Launch Systems Inc. - Promontory September 2008
Attachment 10 - Hydrazine Treatment UTD009081357
10 HYDRAZINE DILUTION PROCESS 3
101 PURPOSE AND SCOPE . 3
10-2 PROCESS DESCRIPTION 3
10-3 ENVIRONMENTAL PERFORMANCE STANDARDS 4
10-3-1 Prevention of Releases to Ground Water or
Subsurface Environment 4
10-3-2 Prevention of Releases to Surface Water,
Wetlands, or Soil Surface 4
10-3-3 Prevention of Releases to Air 4
10-4 MONITORING. ANALYSIS, INSPECTION,
RESPONSE. REPORTING, AND CORRECTIVE
ACTION 5
10-5 RECORD KEEPING AND REPORTING 5
10-6 CLOSURE 5
ATK Launch Systems Inc. - Promontory September 2008
Attachment 10- Hydrazine Treatment UTD009081357
10 HYDRAZINE DILUTION PROCESS
10-1 PURPOSE AND SCOPE
ATK Launch Systems - Promontory (ATK) operates a small treatment
process to dilute waste hydrazine at Building T-29B. This process dilutes
hydrazine waste with water so that waste hydrazine solutions do not
exceed hydrazine concentrations above 50 percent. The dilution process is
necessary because ofthe extreme flammability and reactivity of hydrazine
and the lack of a disposal facility for concentrated hydrazine. The diluted
waste hydrazine is shipped off plant to an incinerator for destmction.
10-2 PROCESS DESCRIPTION
The dilution of waste hydrazine with water is a simple process. ATK does
not generate large amounts of waste hydrazine, but because hydrazine is
extremely flammable and reactive, special care must be used in its
disposal.
The hydrazine is collected at a satellite accumulation site and taken to
Building T-29B in a small, nitrogen purged, trailer mounted tank. This
tank is equipped with a scmbber vent system which is utilized during
initial transfer into the tank. Approximately 25 gallons of water is placed
into a 55-gallon dmm at T-29B. A tube is mn from the tank into the
bottom ofthe 55-gallon dmm. The hydrazine is then dispensed into the
drum through the tube using nitrogen pressure. Once all hydrazine in the
tank has been dispensed into the dmm, additional water will be added to
bring the level to within approximately six inches ofthe top. This transfer
is performed with personnel in Level A personal protective equipment
(PPE). After the transfer is complete, the air in the room is tested to
assure safety before the Level A PPE is removed.
The system is designed and operated to prevent any releases and to safely
transfer the material. 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.
Lab samples from quality assurance testing ofthe hydrazine product are
also dumped directly into the water filled/hydrazine diluted dmm for
disposal.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 10- Hydrazine Treatment UTD009081357
10-3 ENVIRONMENTAL PERFORMANCE STANDARDS
The T-29 Hydrazine dilution process has been located, designed, operated,
maintained and will be closed in a manner that will ensure protection of
human health and the environment. This section addresses the prevention
of releases due to migration ofhazardous constituents into the ground
water or subsurface environment, surface waters, wetlands, surface soils,
and in the air.
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 time and that this process is
all done within a containment system. 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.
10-3-2 Prevention of Releases to Surface Water, Wetlands, 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. The sump is only used ifa 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 use ofthis containment along with careful procedures and the low
volume of waste reduces the potential for any adverse effect on human
health or the environment.
10-3-3 Prevention of Releases to Air
The transfer of hydrazine is conducted with strict safeguards and
procedures to prevent the migration of waste constituents in the air. This
process transfers the hydrazine using nitrogen. Escaping gases are
minimized by discharging through a tube under water in the collection
dmm. These procedures minimize the quantity of any hydrazine
migration through the air and minimize the potential for any adverse
effects to human health or the environment.
ATK Launch Systems Inc. - Promontory September 2008
Attachment 10 - Hydrazine Treatment UTD009081357
10-4 MONITORING, ANALYSIS, INSPECTION, RESPONSE.
REPORTING. AND CORRECTIVE ACTION
Because hydrazine requires special handling precautions and safety
procedures, ATK personnel shall follow intemal procedures for
performing the dilution process. ATK will conduct the dilution process in
a manner that will ensure protection of human health and the environment.
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.
ATK will comply with the ignitable and reactive waste regulations as
required by UAC R315-8-2.8.
ATK will inspect Building T-29B in accordance with the inspection
schedule contained in Attachment 2.
10-5 RECORD KEEPING AND REPORTING
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.
10-6 CLOSURE
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 of
this Permit.
A