DSHW-2008-025624 - 0901a068801e2497 (5)

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

RE: Hazardous Waste Emergency Permit
ATK Launch Systems - Promontory Facility
EPA I.D. #UTD009081357

Dear Mr. Gosen:

The Division of Solid and Hazardous Waste has completed its review of your request, dated May 21, 2008, for an emergency permit for 30 days to treat, by open-detonation, mortars that
fail to detonate during testing procedures. As described in your letter, the mortar tests are being conducted at ATK’s T-75 testing facility for a Department of Defense contractor.

Based on the information provided in your letter, ATK has determined that mortars that fail to detonate during these tests, which are “designed to simulate the mortars being hit by metal
fragments from bombs or other similar sources,” are unsafe to move due to the potential damage sustained from the test shots. An emergency permit for treatment is needed so that ATK
may open detonate the mortars that do not detonate when shot at with metal slugs. The mortars that will be tested, and covered by this permit, include 16, 60 mm and 21, 81mm mortars
that contain 1 pound and 1.5 pounds respectively of “Comp B” explosive.

Enclosed is Utah Hazardous Waste Emergency Permit #UT-017-2008 providing ATK authorization for the treatment of mortars, as identified above that have been characterized as unsafe to
move. This permit is based on the premise that the information provided by ATK is accurate and that the treatment of the mortars will be conducted as specified in your letter.

May 29, 2008
Page 2
TN200800429

Waste material collected after the treatment is complete shall be properly characterized and transported to an approved disposal facility. The Division requires that ATK maintain records
of the open detonation activities. These records shall include the date and time of treatment, the name of the person(s) conducting the treatment, the number and type of mortars treated,
a description of the final disposal of waste residues and a description of the condition of the T-75 site after these tests are complete. These records shall be included in a report
that is to be submitted to the Executive Secretary within 14 days of the expiration date of the permit.

In addition, the T-75 testing facility shall be added to the Post-Closure Permit, Solid Waste Management Unit (SWMU) list. Due to the treatment of hazardous waste at the site, and the
likely use of the site for similar practices in the future, it shall be investigated as appropriate sometime in the future.

This permit became effective on May 20, 2008 and will expire on June 19, 2008. Emergency permits are issued under the authority of 19-6-101 through 105, Utah Code Annotated, as amended
and R315-3-6.2. If you have any questions, please contact Jeff Vandel at 538-6170.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 5/29/08

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

DRD\JV\tjm

Enclosure

c: Gene Curtis, ATK Launch Systems
Lloyd Berentzen, Deputy Director, Bear River Health Department
Kathy Barker, DSHW

File to: ATK Launch Systems – Promontory

STATE OF UTAH EMERGENCY PERMIT UT-017-2008

Permittee:
ATK LAUNCH SYSTEMS - PROMONTORY
P.O. BOX 707
BRIGHAM CITY, UT 84302-0707

Pursuant to the Utah Solid and Hazardous Waste Act, 19.6.101-122, et. seq., Utah Code Annotated as amended and the Utah Administrative Code (R315-1 through R315-13, R315-50 and R315-101)
as adopted by the Utah Solid and Hazardous Waste Control Board, an emergency permit is issued to ATK Launch Systems - Promontory (hereafter called the “Permittee”) to treat, by open
detonation, 60mm and 81mm mortars containing “Comp B” explosive that fail to detonate during testing procedures. State of Utah Administrative Rules allow application for an emergency
permit pursuant to R315-3-6.2 if an imminent and substantial endangerment to human health or the environment is present. The Permittee has requested an emergency permit based on its
determination that it is unsafe to move “Comp B” mortars that do not detonate after being shot with metal slugs to simulate the mortars being hit by metal fragments from bombs or other
similar sources. It was determined that the safest way to manage these potentially damaged mortars is to detonate them in place prior to transporting them for disposal. The U.S. Environmental
Protection Agency has authorized the Executive Secretary to issue such a permit under Section 3006(b) of the Resource Conservation and Recovery Act.

The Permittee shall comply with all terms and conditions of this permit. The permit consists of all applicable portions of R315-1 through R315-13, R315-50, and R315-101 incorporated
by reference. Applicable rules are those which are in effect on the date of issuance of this permit.

In addition, all waste generated from the treatment shall be properly characterized and transported to an approved disposal facility. The Permittee shall maintain records of the open
detonation activities. These records shall include the date and time of treatment, the name of the person(s) conducting the treatment, the number and type of mortars treated, a description
of the final disposal of waste residues and a description of the condition of the T-75 site after these tests have been completed. These records shall be included in a report that is
to be submitted to the Executive Secretary within 14 days of the expiration date of the permit.

This permit is based on the premise that the information provided in a letter dated May 21, 2008 and through discussions with ATK personnel is accurate and that the treatment will be
conducted as specified. The Permittee shall inform the Executive Secretary of any deviation from, or changes in the information provided which could affect the Permittee's ability to
comply with the applicable regulations. Any inaccuracies or misrepresentations in the information provided may be grounds for the termination of this permit, in accordance with R315-3-6.2(b)(4)
of the Rules.

This permit is effective on May 20, 2008 and shall expire on June 19, 2008.

Signature: Date: ____________
Dennis R. Downs
Executive Secretary
Utah Solid and Hazardous Waste Control Board

NOTICE

The Executive Secretary of the Utah Solid and Hazardous Waste Control Board has issued an emergency hazardous waste treatment permit (# UT-017-2008) to the ATK Launch Systems – Promontory
facility. This permit was issued so that ATK personnel could treat, in accordance with the Utah Hazardous Waste Management Rules, mortars that are potentially damaged by testing procedures
conducted at the site. The permit is effective on May 20, 2008 and expires on June 19, 2008. Utah Administrative Rules allow application for an emergency permit if an imminent and
substantial endangerment to human health or the environment is present. ATK personnel requested an emergency permit to treat mortars in place at the Promontory facility by open detonation
based on the determination that mortars that do not detonate are unsafe to move due to the potential damage sustained from the testing procedure.

Copies of the permit are available for public inspection during normal business hours, or other hours with prior arrangement, at the Division of Solid and Hazardous Waste located on
the 4th floor of the Martha Hughes Cannon Health Building, 288 North 1460 West, Salt Lake City. For further information, contact Jeff Vandel at [phone]. In compliance with the
American Disabilities Act, individuals with special needs (including auxiliary communicative aids and services) should contact Brooke Baker, Office of Human Resources at 536-4412 (TDD
536-4414).

May 29, 2008

288 North 1460 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
TN200800429 Printed on 100% recycled paper

State of Utah

Department of Environmental Quality

Richard W. Sprott
Executive Director

DIVISION OF SOLID AND HAZARDOUS WASTE
Dennis R. Downs
Director

JON M. HUNTSMAN, JR.
Governor

GARY HERBERT
Lieutenant Governor