DSHW-2010-033717 - 0901a06880188bbb

May 3, 2010
82dO-FYll-005
HAND DELIVERED
MAY 0 3 2010
UTAH DIVISION OF
SOLID & HAZARDOUS WASTE
Scott T Anderson
Division of Solici and Hazardous Waste
Department of Environmental Quality
P O Box 144880
Salt Lake City, UT 84114-4880
RE ATK Launch Systems-Promontory, EPA ID number UTD009081357
Request for Class 3 Permit Modification to Implement 40 CFR 264 600
Requirements and Other Items as Specified
Dear Mr Anderson,
In accordance with R315-3-4 3 (incorporated by reference 40 CFR 270 42), ATK Launch
Systems - Promontory (ATK) requests a Class 3 permit modification to implement the
foUow^ing changes
• Delete Module IV dated September 30, 2008 which regulates an obsolete
operation, and replace it with the attached Module IV containing proposed
operatmg conditions to comply with 40 CFR 264 600 requirements
• Attachment 11 is bemg provided to describe process and facility information for
open buming and open detonation (OBOD) treatment activities
• Revise Attachment 5 (Closure Plan) dated September 30, 2008 to add S-633 as a
permitted storage area, reduce the storage capacity in M-603, and adjust the
operatmg capacities for M-136 and M-225 to be consistent with the values used in
the OBOD risk assessment
• Revise Attachment 4 (Hazardous Waste Contingency Plan) dated September 30,
2008 to provide required information for S-633 and to update emergency contact
information
Revise Attacliment 2 (Inspection Schedules and Procedure) dated September 30,
2008 to provide an inspection schedule for S-633
Modify conditions in Module I, Module II and Module III dated September 30,
2008 to reflect changes resulting from revising Module IV and Attachment 5.
Modify Module III.B.4 to include the use of plastic tray covers as approved
containers for off-site waste. Similar covers are approved for use as containers
for unburned waste and residue at the NIROP facility. Refer to Attachment 4.6.4,
Hazardous Waste Storage and Subpart X treatment Permit, September 2009,
UT3170027277.
As specified in R315-3-4.3, ATK as the permittee will send a notice of this modification
request to the latest facility mailing list, maintained by your department. We will also
publish this notice in the Herald Joumal, Standard Examiner and the Box Elder News
Joumal. This notice will announce a 60 day public comment period and a public meeting
to be held at the Brigham City Library. All requirements as outlined in R315-3-4.3 will
be followed.
If you have any question or need additional clarification, please contact Blair Palmer of
my staff at [phone]. Thank you for your attention to this matter.
Sincerely,
David P. Gosen, P.E/
Director, Environmental Services
c: Jeff Vandel, DSHW
George Gooch, ATK
Paul Hancock, ATK
Blair Palmer, ATK
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MODULE I - STANDARD PERMIT CONDITIONS
I A EFFECT OF PERMIT
I A 1 The Permittee is allowed to store hazardous waste in containers and to treat hydrazine,
by dilution, m contamers at the ATK Launch Systems-Promontory (ATK) Facihty, Box
Elder County, Utah in accordance with the conditions of this Permit In addition, the
Permittee is allowed to store and disassemble waste rocket motors at the facility in
accordance with the conditions of this Permit Any treatment, storage, or disposal of
hazardous waste not authorized in this Permit, is prohibited
IA 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 of this 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 within UAC R3I5-I through 101 or attachments to this Permit
IB 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
IC OTHER AUTHORITY
ICI The Executive Secretary expressly reserves any right of entry provided by law and any
authority to order or perform emergency or other response activities as authorized by
law
ID PERMIT ACTIONS
I D 1 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 planned 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 of this Permit
I D 3 The Permit may be modified at the request of the Permittee according to the procedures
of UAC R315-3-4 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
1 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
IE SEVERABILITY
I E 1 The provisions ofthis Permit are severable and if any provision of this Permit, or the
application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances and the remainder of this 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
IF DUTIES TO COMPLY
I F I 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 of the 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 of the other listed
remedies
I F 2 Compliance with the terms of this Permit does not constitute a defense to any order
issued or any action brought under Sections 3007, 3008, 3013, or 7003 of RCRA (42
USC Sections 6927, 6928, 6934 and 6973), Section 106(a), 104, or 107 ofthe
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42
USC 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
IG 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 of this Permit, the Permittee
shall submit a complete application for a new permit, in accordance with UAC R315-3-
2 lg and UAC R315-3-3 1(b), at least 180 days before this Permit expires
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IH PERMIT EXPIRATION
I H 1 This Permit shall be effective for ten years from the date it is issued
II CONTINUATION OF EXPIRING PERMIT
11 1 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 of the Permittee, the Executive Secretary has neither issued nor denied a new
permit under UAC R315-3-5 2 on or before the expiration date of this permit
IJ NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE
IJI 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 of this Permit
IK DUTY TO MITIGATE
IKI In the event of noncompliance with the Permit, the Permittee shall take all reasonable
steps to minimize releases of hazardous waste, hazardous waste constituents, and
perchlorate salts to the envirormient resulting from the noncompliance, and shall carry
out such measures as are reasonable to prevent significant adverse impacts on human
health or the envirormient
IL PROPER OPERATION AND MAINTENANCE
ILI 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 of this 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 of this Permit
IM DUTY TO PROVIDE INFORMATION
IMI 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
IN INSPECTION AND ENTRY
IN 1 Pursuant to the UCA 19-6-109, the Permittee shall allow the Executive Secretary, or an
authonzed representative, upon the presentation of credentials and other documents, as
may be required by law, to
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IN 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
of this Permit,
IN 1 b Have access to and copy, at reasonable times, any records that are kept as required by
the conditions of this Permit,
IN 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,
IN 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
IN I 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 of the recording device Photographic
and video recording shall comply with the safety and security requirements of the
Permittee
lO MONITORING AND RECORDS
I O 1 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 of this Permit, including any and
all data to support human health and ecological nsk assessments for cleanup and closure
activities All of the above referenced material shall be retained for a period of at least
three years from the date of the sample, measurement, report, certification, or recording
unless a longer retention period for certain information is required by other conditions
of this 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 of the enforcement action Recordkeeping may be
accomplished usmg 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 shall be capable of reproducing complete, accurate and legible records
10 2 Pursuant to UAC R315-3-3 10)(3), records of monitoring information shall specify at a
minimum
I O 2 a The date(s), exact place, and times of sampling or measurements,
I O 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 O 2 d The individual(s) who performed the analyses,
I O 2 e The analytical techniques or methods used, and
I O 2 f The results of such analyses
10 3 Samples and measurements taken for the purpose of monitoring shall be representative
of the monitored activity The method used to obtain a representative sample of the
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 (Thtrd
Edition November 1986)" or most currently promulgated edition, "Standard Methods
for Examination of Water and Wastewater (17th Edition, 1989) or most curtently
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
10 4 When requesting substitute or additional analytical methods, the Permittee shall submit
to the Executive Secretary a request for substitution of analytical 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)
IP REPORTING PLANNED CHANGES
IPI The Permittee shall give vmtten 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 v^th UAC
R315-3-3 I(1) and R315-3-4 3 Planned 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)
Construction or operation of new or modified HWMUs shall not begin imless the
provisions of UAC R315-4-1 5 are met
IQ REPORTING ANTICIPATED NONCOMPLIANCE
I Q 1 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 of this Permit Advance notice shall not constitute a defense for any
noncompliance
IR CERTIFICATION OF CONSTRUCTION OR MODIFICATION
IRI The Permittee shall not commence storage, treatment, or disposal of hazardous 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 I 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 1 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 constructed or modified in accordance with the
approved modification request and this Permit, and
I R 1 a 11 As-built engineering drawings and specifications as appropriate
I R 1 b The Executive Secretary or designated representative has reviewed and inspected the
modified or newly constructed unit and has notified the Permittee in writing that the
unit was found in compliance with the conditions of this Permit
I R 2 If within fifteen (15) calendar days of the date of receipt of the letter required by Permit
Condition I R 1 a i, the Permittee has not received notice from the Executive Secretary,
of the intent to inspect, prior inspection is waived and the Permittee may commence
treatment, storage, or disposal of hazardous waste in the permitted unit, if certified in
accordance with Condition I R 1 a i
IS 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 of the Facility during its operating life, the
Permittee shall notify the new ovraer or operator, in writing, of the 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 of the Rules and this Permit
IT TWENTY-FOUR HOUR REPORTING
ITI 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-I(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 of the 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 of hazardous waste, or of a fire, or explosion
at the Facility, which could threaten human health or the environment
I T 4 c A description of the occurrence and its cause,
I T 4 d The name, title, and telephone number of the individual reporting,
I T 4 e The name, address, and telephone number of the ovmer or operator,
I T 4 f The name, address, and telephone number of the Facility,
I T 4 g The date, time, and type of the incident,
I T 4 h The location and cause of the incident,
I T 4 1 The name and quantity of materials involved,
I T 4 J The extent of injuries, if any,
I T 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 of the 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 of the time the Permittee is required to provide the reports specified in
Conditions ITI through IT 4 , the Permittee shall submit to the Executive Secretary a
written report
I T 6 The wntten report shall include, but not be limited to the following
I T 6 a The name, title, address, and telephone number of the individual reporting,
I T 6 b A description including the date, time, location and nature of the reported incident,
I T 6 c The extent of injuries, if any,
I T 6 c The name and quantity of material(s) involved in the spill,
I T 6 d An estimated quantity and disposition of the 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 shall also include whether or not the results of the
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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 plarmed to adequately remediate the release
IU MONITORING REPORTS
I U 1 Monitoring information shall be recorded and maintained as specified in Condition I O
I V COMPLIANCE SCHEDULES
IVI 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
IW MANIFEST DISCREPANCY REPORT
I W 1 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
of hazardous 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 drum 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 If a
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 vsath UAC R315-8-5 4
IX 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
IYI 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 of the following even numbered year in accordance with UAC R315-8-5 6
IZ OTHER NONCOMPLIANCE
I Z 1 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 of this Permit Reporting shall not constitute a defense for any
noncompliance
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I AA OTHER INFORMATION
I AA 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
IBB SIGNATORY REQUIREMENT
I BB 1 All reports, notifications, submissions or other mformation 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
ICC CONFIDENTIAL INFORMATION
I CC 1 The Permittee may claim confidential any information required to be submitted by this
Permit in accordance with Utah Code Annotated 63-2-101 et seq and Utah Code
Annotated 19-1-306
IDD REPORTS. NOTIFICATIONS. AND SUBMISSIONS
I DD 1 All reports, notifications, or other submissions which 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 of the Executive Secretary on the first business day
followmg notification to the 24-hour answering service
I EE DOCUMENTS TQ 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 of the Permit imtil closure is certified in accordance with Condition IIN ,
I EE 1 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 m accordance with Condition
IIO,
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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 IIN,
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 IIN,
I EE 1 g Closure Plans (Attachment 5), as required by UAC R315-8-7 and this permit, imtil
closure is certified in accordance with Condition IIN,
I EE 1 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 II P of this Permit,
I EE I 1 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 IIN
IFF PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
I FF 1 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
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MODULE II - GENERAL FACILITY CONDITIONS
HA APPLICABILITY
II A 1 The requirements of this permit module pertain to all Hazardous Waste Management
Units (HWMUs) identified within Modules I, II and III
IIB DESIGN AND OPERATION OF FACILITY
II B 1 The Permittee shall design, constmct, maintain and operate all of the HWMUs and
surrounding areas to minimize the possibility of a fire, explosion, or any sudden or non-
sudden release of hazardous 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 IRI and UAC R315-3-3 I(l)(2)(i)
II B 3 After review of the as-built drawings and field verification of the 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 m this permit
IIC REQUIRED NOTICE
II C 1 As required by UAC R315-8-2 3(a)( 1), the Permittee shall notify the Executive
Secretary in wnting at least four weeks in advance of the date the Permittee expects to
receive hazardous waste from a foreign source Notice of subsequent shipments of the
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 of this written notice as part of the
operating record as required by UAC R315-8-2 3(b)
IID WASTE ANALYSIS PLAN
II D 1 The Permittee shall follow the procedures of the Waste Analysis Plan included as
Attachment 1 of this Permit In addition, the Permittee shall comply with any other
conditions involving waste analysis in Modules I, II, III and IV
IID 2 The Permittee shall use the test methods described in the Waste Analysis Plan
(Attachment I) or an equivalent procedure that satisfies Condition 10 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, m 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 bemg used by the
Permittee's analytical laboratory, the Executive Secretary will submit wTitten
notification to the Permittee The Permittee shall notify the Utah Department of Health,
Bureau of Laboratory Improvement of the requested update within 30 days of receipt of
the Executive Secretary's determination The Permittee shall have 180 days from the
receipt of the 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 of the data
The Permittee shall inform the laboratory in writing that it must operate under the
Waste Analysis Plan conditions set forth in this Permit
HE SECURITY
II E 1 The Permittee shall comply with the security conditions and procedures contained in
Attachment 7 of this Permit
IIF GENERAL INSPECTION REQUIREMENTS
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 malfiinction as required by UAC R315-
ATK Launch Systems hic - Promontory May 2010
Module II - General Facility Conditions UTD009081357
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 of the 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, contmued operation
of the waste management unit involved in the inspection could endanger human health
or the environment, the Permittee shall cease operation of the 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)
II G RISK THRESHOLDS
II G 1 The thermal treatment operations at both of the ATK Promontory thermal treatment areas shall
be conducted to minimize the risk to human health and the environment The risk thresholds
identified in Condition II G and the operating conditions in Module IV for the NIROP Buming
Grounds are based on the mformation provided m Attachments to this Permit and the following
site specific documents available for review in the Department of Environmental Quality,
Division of Solid and Hazardous Waste files
IIG 1 The thermal treatment operations at both of the ATK Promontory thermal treatment areas shall
be conducted to minimize the risk to human health and the environment The risk thresholds
identified in Condition II G and the operating conditions in Module IV for the treatment areas
are based on the information provided or referenced in Attachments to this Permit and the
following site specific documents available for review in the Department of Environmental
Quality, Division of Solid and Hazardous Waste files
IIG 1 a The Waste Characterization and Air Dispersion Modeling Protocol for use in the Human Health
and Ecological Risk Assessments - ATK Launch Systems - Promontory, November 2009,
IIG 1 b The response to the Division of Solid and Hazardous Waste comments on the Waste
Characterization and Air Dispersion Modeling Protocol for use in the Human Health and
Ecological Risk Assessments,
II G 1 c ODOBI Test Results, Emission Factors
IIG 1 d The Human Heahh Risk Assessment Protocol for OB/OD Operations at the ATK Promontory
Facility, February 2010
Note The human health risk assessment is currently being conducted Specific restrictions on
bum ground operations are pending and will be included in the second draft ofthe permit
modification document There will be an additional public comment period for this document
Additional site specific documents on the HHRA will be available for review at that time
ATK Launch Systems Inc - Promontory May 2010
Module II - General Facility Conditions UTD009081357
II G 2 The Permittee shall submit to the Executive Secretary by March T' of each calendar year, an
annual report on the operation of the Promontory Thermal Treatment areas This report shall at
a minimum include the following
II G 2 a An accounting of the quantities and types of reactive hazardous waste treated at the M-136 and
M-225 thermal treatment areas, including all donor material and ignition compounds,
II G 2 b The estimated quantity of tetrachlorodibenzo(p)dioxin toxic equivalents (TCDD TEQs) released
annually The quantity shall be calculated by assuming a TCDD TEQ emission rate to be
determined through approval ofthe air dispersion model Based on the Human Health Risk
Assessment identified in Condition II G 1 d, or II G 1 e , the Permittee shall not emit more than
a quantity to be determined of the TCDD TEQs in a calendar year,
II G 2 c An evaluation of the emission factors, identified in Condition II G 1 c , used in the human
health risk assessment to determine whether these factors need to be updated, and
II G 2 d A review of the of the human health risk assessment, identified in Condition II G 1 d or
IIG 1 e , to evaluate whether the slope factors and reference doses for carcinogenic and non-
carcinogenic health effects related to the chlorinated dioxin, chlorinated furan and semi-volatile
compounds have changed, and a review of the potential human health risk scenarios, identified
in Condition IIG 1 a and b, used in the risk assessment to assure that these scenarios have not
changed
II G 3 If the Executive Secretary determines after reviewing this annual report that any component of
the risk assessment needs to be updated, he will inform the Permittee in writing which
components of the human health risk assessment to update
IIG 4 If the Permittee is required to update the human health risk assessment for the
M-136 or M-225 Thermal Treatment areas, the Permit shall be modified in accordance with
Condition I D of this Permit
II H PERSONNEL TRAINING
II H 1 The Permittee shall conduct personnel traimng 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
withm six (6) months of their hire date, assignment to the facility or assignment to a
new position at the facility
II H 2 Facility personnel 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 H 3 The Permittee shall maintam 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
ATK Launch Systems Inc - Promontory May 2010
Module 11 - General Facility Conditions UTD009081357
Training Plan m Attachment 3 These records shall indicate the type and amount of
training received
II H 4 The Permittee shall maintain a copy of the Training Plan at the Facility until it is fully
closed and closure is certified
II H 5 Employees working at the rocket motor disassembly and storage building (M-603) shall
receive task specific on-the-job-trainmg in addition to the training outlined in
Attachment 3 This training shall be documented and maintained in the operatmg
record until the specific program is completed
III GENERAL REQUIREMENTS FOR IGNITABLE. REACTIVE. OR
INCOMPATIBLE WASTE
II11 The Permittee shall comply with the requirements of UAC R315-8-2 8
III 2 In addition 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
IIJ LOCATION STANDARDS
IIJ 1 The Permittee shall comply with the location standards specified by UAC R315-8-2 9
II K PREPAREDNESS AND PREVENTION
II K 1 The Permittee shall follow the Preparedness and Prevention Plan, Attachment 8
II K 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 K 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 K 4 The Permittee shall maintain records of the 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 K 5 The Permittee shall maintain access to the communications or alarm system as required
by UAC R315-8-3 5
II K 6 At a minimum, the Permittee shall maintain 30 inches of aisle space between containers
or pallets of containers at storage areas M-186 and E-501
II K 7 The Permittee shall attempt to make arrangements (Coordination Agreements) with
State and local authorities as required by UAC R315-8-3 7 Copies of the Coordination
Agreements shall be kept m the Operating Record The attempts to make such
agreements, any refusals and all final agreements shall be documented in the Operating
Record
ATK Launch Systems Inc - Promontory May 2010
Module II - General Facility Conditions UTD009081357
IIL CONTINGENCY PLAN
II L 1 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 of hazardous 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 L 2 The Permittee shall provide copies of the Contingency Plan to emergency agencies who
may be called in an emergency, shall maintain a copy of the Plan at the facility, and
shall provide a copy upon request in accordance with UAC R315-8-4 4
II L 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 L 4 A trained emergency coordinator shall be available at all times m case of an emergency,
in accordance with UAC R315-8-4 6 and identified in Attachment 4
IIM MANIFEST SYSTEM
II M I 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 m the Operatmg Record
with each waste load that arrives or leaves the Permittee's facility
IIN RECORDKEEPING AND REPORTING
II N I The permittee shall maintam an accurate written Operatmg 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)
IIN 2 The Permittee shall, by March I of each year, submit to the Executive Secretary a
certificafion pursuant to UAC R315-8-5 3 [40 CFR 264 73(b)(9) incorporated 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 of hazardous 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 future threat to
human health or the environment
II N 3 The Permittee shall comply with the biermial 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 N 4 The Permittee shall submit additional reports to the Executive Secretary in accordance
with UAC R315-8-5 8
IIN 5 All reports, notifications, applications, or other materials required to be submitted to the
ATK Launch Systems Inc - Promontory May 2010
Module II - General Facility Conditions UTD009081357
Executive Secretary shall be submitted in accordance with Condition I DD
IIO CLOSURE/POST-CLOSURE
II O 1 The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101
and Attachment 5
II O 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 of this 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 O 3 The Permittee shall amend the closure/post-closure plan in accordance with UAC R315-
8-7 and Condition ID whenever necessary, or when required to do so by the Executive
Secretary
II O 4 The Permittee shall notify the Executive Secretary in writing of the partial closure of
any portion of the 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
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 m
accordance with Condition I D
II O 5 After receiving the final volume of hazardous 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 O 6 The Permittee shall decontaminate or dispose of all facility equipment, stmctures, soil
and rinsate as required by UAC R315-8-7, R315-8-9 and Attachinent 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 O 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 engineenng field
II O 8 In the event that any of the hazardous waste management units covered by this permit
carmot be clean closed by decontaminating or removing contaminated stmctures or soil,
or releases have occurred which have impacted soil or groimdwater, the Permittee shall
modify the Closure/Post-Closure Plan for that hazardous waste management unit in
accordance with Condition I D Within 30 days of the 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 O 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 of the certification of closure
for the HWMU, in accordance with UAC R315-8-7 and R315-101
ATK Launch Systems Inc - Promontory May 2010
Module II - General Facility Conditions UTD009081357
IIP COST ESTIMATES FOR HWMU CLOSURE
II P 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 P 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, of the 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)
II P 3 On the five year anniversary date of the submittal of the closure cost estimates required
by Condition II O 2 above, the Permittee shall conduct a detailed evaluation of the
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 of the Permit in
accordance with Condition I D to the Executive Secretary 90 days after the report is
submitted
II P 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)
II P 5 For each new HWMU placed mto 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
IIQ FINANCIAL ASSURANCE FOR FACILITY CLOSURE
II Q 1 The Permittee shall demonstrate continuous financial assurance compliance by
providing a third party financial assurance certification of at least the amount of the
closure/post-closure cost estimates established in Condition II O 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 Q 2 The financial assurance document shall be updated within 60 days of the annual
adjustment for inflation or withm 60 days of the approval of a revised closure/post-
closure cost estimate in accordance with UAC R315-8-8
IIR LIABILITY REQUIREMENTS
II R 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 occurrence 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
ATK Launch Systems Inc - Promontory May 2010
Module 11 - General Facility Conditions UTD009081357
II R 2 Changes in liability coverage mechanisms shall be approved by the Executive Secretary
60 days prior to such a change
IIS INCAPACITY OF OWNER OR OPERATORS. GUARANTORS. OR
FINANCIAL INSTITUTIONS
II S 1 The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (40 CFR 264 148 incorporated by reference)
ATK Launch Systems Inc - Promontory September 2008
Module 111 - Storage in Containers UTD009081357
Modified June 16 2009
MODULE III - STORAGE IN CONTAINERS
III A APPLICABILITY
III A 1 The requirements of this permit Module pertain to the operation of hazardous waste
container storage areas at the facility The Permittee shall comply with R315-8-9 and
all conditions of this 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, Bum Station 14 at M-136, and S-633
Drawings of these storage areas are presented in Attachment 6
IIIB 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, DOlO 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, P012, P022, P028, P029, P030, P047, P048, P064, P067, P077, P087, P092,
P093, P095, P098, P102, 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, U080, U085, U088, U092, U093, U095, U098,
UlOl, U102, U103,U105, U108, Ul 12, Ul 13, Ul 17, Ul 18, U120, U121, U122, U123,
U131, U133, U134, U140, U147, U148, U149, U151, U154, U156, U159, U160, U161,
U162, U165, U168, U169, U170, U171, UI85, U186, U188, U190, U196, U201, U209,
U2I0, U2II, U218, U2I9, 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 solid reactive hazardous waste , EPA hazardous waste code
D003, in storage Building M-47 subject to the terms of this Permit
III B 3 The Permittee may store tsolid reactive hazardous waste , EPA hazardous waste code
D003, in Building M-603 in accordance with Module IV of this Permit
III B 4 The Permittee may store solid reactive hazardous 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 drums,
boxes, plastic bags, woven bags, US Department of Transportation (DOT) pproved
shipping contamers or containerize as describe m Attachemnt 11 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 contam 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
ATK Launch Systems Inc - Promontory September 2008
Module 111 - Storage in Containers UTD009081357
Modified June 16 2009
III B 6 The Permittee may store solid reactive hazardous waste , EPA hazardous waste code
D003, in Building M-633 subject to the terms of this Permit
III B 7 The Permittee is prohibited from storing hazardous waste that is not identified in
Section III B of this Module Any addition of hazardous waste codes to Condition
III B 1 requires modification of the permit in accordance with Condition I D 3
IIIC CONDITION OF CONTAINERS
III C 1 If a container holding hazardous waste is not in good condition (e g , severe msting,
bulging, apparent structural 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
HID COMPATIBILITY OF WASTE WITH CONTAINERS
III D 1 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
HIE MANAGEMENT OF CONTAINERS
III E 1 The Permittee shall manage containers in accordance with this module ofthe 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 of the container storage areas are shovm 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-186 - 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 contamers or the equivalent
III E 3 The Permittee shall store solid reactive hazardous waste in containers at storage areas
M-47, M-603, M-136 and S-633 Drawings of the storage areas are shovm m
Attachment 6 At capacity, the Permittee may store the followmg amounts of wastes
III E 3 a M-47 - 300,000 lbs I 3 or 21,000 lbs 1 1 solid propellant,
III E 3 b M-603 - 120,000 lbs 1 3 r 8,000 lbs 1 1 solid reacttve hazardous waste,
III E 3 c M-136 - 106,500 lbs of 1 3 or 20,000 lbs of 1 1 solid reactive hazardous waste in bum
trays or in a rocket case placed on the ground, and
ATK Launch Systems Inc - Promontory September 2008
Module III - Storage in Containers UTD009081357
Modified June 16 2009
III E 3 d S-633 - 75,000 lbs of 1 3 or 20,000 lbs of 1 1 solid reactive hazardous waste
III E 4 The Permittee shall maintain an aisle space of 30 inches minimum between containers
or pallets of containers at storage areas M-186 and E-501
111 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-I86 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 of hazardous waste
for storage within 10 days followmg arrival at the site Arrival for purposes of this
permit shall be the day the vehicle arrives at the facility
III E 9 The Permittee shall provide storage for and maintain on-site, 85 gallon overpack dmms
at areas where liquid hazardous waste is stored
IHF 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-
96
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 stonng 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 of the
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 of the bum trays shall be conducted m accordance with
Attachment 2
ATK Launch Systems Inc - Promontory
Module III - Storage in Containers
September 2008
UTD009081357
Modified June 16 2009
IIIG
IIIG 1
IIIG 2
IIIH
IIIH 1
IIIH 2
IIIH 3
IIII
IIII 1
III I 2
IIIJ
III J 1
III J2
SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE
The Permittee shall not locate containers holding ignitable or reactive waste within 15
meters (50 feet) of the facility boundary
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
SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTE
The Permittee shall not place incompatible wastes, or incompatible wastes and
materials, in the same container, m accordance with UAC R315-8-2 8 and UAC R315-
8-9 8(a)
The Permittee shall not place hazardous waste or materials in an unwashed container
that previously held an incompatible waste or material m accordance with UAC R315-
8-2 8 and UAC R315-8-9 8(b)
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
INSPECTION SCHEDULES AND PROCEDURES
The Permittee shall inspect the hazardous waste storage and treatment facilities
identified in Condition III B of this Permit as specified in the Inspection Schedules
contained in Attachment 2 The purpose of this inspection shall be to detect leaking
containers, standing liquids, deterioration of containers, and to detect deterioration of,
or liquids in, the secondary contamment system caused by corrosion and other factors as
specified in R315-8-9 5
If problems are observed durmg the inspections, the Permittee shall correct the problem
in accordance with Module II, Section F
CLOSURE/POST-CLOSURE
The Permittee shall close the storage areas in accordance with UAC R315-8-7, UAC
R315-8-9 9, Condition II O and Attachment 5 of this Permit
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 Systems Inc Promontory May 2010
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
MODULE rv - THERMAL TREATMENT OF ENERGETIC WASTES
IVA APPLICABILITY
rv A 1 The requirements of this permit module apply to the thermal treatment of energetic or
reactive hazardous waste at the ATK Launch Systems - Promontory facility. Box Elder
County, Utah The Permittee shall comply with UAC R315-8 and all conditions of this
module and Permit
rv A 2 The permit conditions of this module allow thermal treatment at the two Hazardous Waste
Management Units, designated as the M-136 and M-225 Thermal Treatment Areas, as
designed and described in the drawings and specifications in Attachments 6 and 11 The
M-136 Thermal Treatment Area consists of 14 bum stations and 2 open detonation areas
The M-225 Thermal Treatment Area consists of 4 bum stations and 1 open detonation area
rv A 3 Thermal treatment at both of the Promontory Thermal Treatment Areas shall only be
accomplished by properly trained ATK personnel in accordance with ATK's Standard
Operating Procedures, the conditions of this Permit and its attachments
rv A 4 This Permit has been developed in accordance with the applicable requirements of UAC
R315-1 through 101 All conditions in this Permit shall supercede conflicting statements,
requirements, or procedures found in UAC R315-1 through 101 or attachments to this
Permit
IVB PERMITTED AND PROHIBITED WASTE IDENTIFICATION
rv B 1 The Permittee may treat energetic or reactive hazardous waste at the two Promontory
Thermal Treatment Areas by open buming and detonation These energetic and reactive
hazardous wastes are generated from the following sources
rv B 1 a Class 1 1 and 1 3 propellants and explosives manufactured at the Promontory, Bacchus, and
other ATK facilities as well as Autoliv ASP, DOD, NASA or other govemment and private
facilities (e g cured and uncured propellants, excess propellants and propellant scraps)
including the following,
IV B 1 b Production materials contaminated with class 1 1 and 1 3 propellants and explosives and
reactive residues (e g , rags, gloves, other personal protective equipment, plastics, mbber
and paper that were contaminated with explosive materials during the manufacturing
process),
IV B 1 c Large and small class 1 1 and 1 3 rocket motors and initiating devices,
IV B I d Class 1 3 Pyrotechnic, Illuminants, Metal Powders, or Autoliv ASP Products
rv B 1 e Production materials contaminated with class 1 3 Pyrotechnic, Illuminants, Metal Powders,
or Autoliv ASP Products and other reactive residues (e g, rags, gloves, other personal
protective equipment, plastics, mbber and paper that were contaminated with explosive
materials during the manufacturing process),
IV B 1 f Reactive laboratory wastes which may contain solvents.
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Module IV - Thermal Treatment of Energetic Wastes UTD009081357
rv B 1 g Wastewater treatment sludge generated from the processing of explosive ingredients and
propellants defined in UAC R315-2 as a K044 listed hazardous waste,
rv B 1 h Reactive bag house dust generated from the processing of explosive ingredients and
propellants,
rv B 1 1 Waste developmental propellants, explosives and associated contaminated production
materials
rvrv B 2 Only reactive hazardous waste as defined by UAC R315-2 may be treated at the
Promontory Thermal Treatment Areas Reactive hazardous waste thermally treated at the
Promontory Thermal Treatment Areas may contain the follow EPA waste codes DOOl,
DOOS, D005, D007, D008„ D030, D038, FOOl, F002, F003, F004, F005 and K044
rv B 3 The Permittee is prohibited from thermally treating reactive hazardous waste classes and
compositions not included in Condition IV B 2 including wholly inert items and
improvised explosive devices (e g homemade bombs), chemical and energetic reactive
hazardous wastes that will detonate under open buming conditions
rv B 4 The Permittee shall only thermally treat reactive hazardous wastes at the Promontory
Thermal Treatment Areas that are identified in Conditions rV B 1 and rV B 2
rv B 5 The addition of hazardous waste codes to Condition fV B 2 requires modification of the
permit as specified in UAC R315-4-1 5 and Condition I D
rv B 6 The Permittee shall comply with the waste compatibility requirements of Condition II H
rVC GENERAL OPERATING CONDITIONS
rv C 1 The Permittee shall comply with the following treatment limits for the M-136 Thermal
Treatment Area
rv C 1 a The Permittee shall not treat more than 106,500 pounds of reactive hazardous waste in a
calendar day,
rv C 1 b The Permittee shall not treat more than 106,500 pounds of reactive hazardous waste in a
calendar day at bum stations 1,2,3,4,5,6,7,8,9,10,11,12,
The Permittee shall not treat more than 50,000 pounds of reactive hazardous waste in a
calendar day at bum station 13,
The Permittee shall not treat more than 106,500 pounds of reactive hazardous waste in a
calendar day at bum station 14,
rv C 1 c The Permittee shall not treat more than 600 pounds of reactive hazardous waste by open
detonation per event,
rv C 1 d reserve
rv C 1 e The Permittee shall operate the M-136 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11 section 5
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Module IV -Thermal Treatment of Energetic Wastes UTD009081357
rv C 1 f The Permittee shall not treat more than 10,000,000 pounds of reactive hazardous waste at
the M-136 Thermal Treatment Area in a calendar year This 10,000,000 pound limit shall
be established by adding the Net Explosive Weight (NEW) and all donor and initiator
materials Donors shall include all pallets, cardboard, packaging material, absorbents and
diesel fuel
rv C 2 The Permittee shall comply with the following treatment limits for the M-225 Thermal
Treatment Area
rv C 2 a The Permittee shall not treat more than 4,500 pounds of reactive hazardous waste per
calendar day,
rv C 2 b The Permittee shall not open burn more than 4,500 pounds of reactive hazardous waste at
any bum station or combination of stations per calendar day,
rv C 2 c The Permittee shall not treat more than 600 pounds of reactive hazardous waste by open
detonation per event,
rvrv C 2 d The Permittee shall operate the M-225 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11 section 5
rv C 2 e The Permittee shall not treat more than 55,000 pounds of reactive hazardous waste at the
M-225 Thermal Treatment Area in a calendar year This limit shall be established by
adding the Net Explosive Weight (NEW) and all donor and initiator materials Donors
shall include all pallets, cardboard, packaging material, absorbents and diesel fuel
rv C 3 The Permittee shall maintain the integrity of the Promontory Thermal Treatment Areas to
ensure that they meet the performance standards of UAC R315-8-16 and minimize the
potential impacts to human health and the environment The Permittee shall adhere to
applicable provisions of Attachments 2 and 11 and the following conditions
rv C 3 a The Permittee shall conduct all open bum operations within the secure areas designated as
the M-136 or M-225 Thermal Treatment Areas with controlled access as identified in
Attachment 11,
rv C 3 b The Permittee shall post waming signs around both of the Thermal Treatment Areas to
keep unauthorized personnel out,
rv C 3 c The Permittee shall maintain the egress paths for both of the Thermal Treatment Areas
identified in Attachment 4,
rv C 3 d The Permittee shall disable the firing system whenever operators are in the QD for this
treatment unit The firing system shall only be active or armed when operators are
conducting a pre-bum continuity check, as specified in Attachment 11, Section 8 2 3, or
when the firing system is being maintained and no waste is present in the treatment area, or
after all operators have exited the tteatment unit and retreated to the firing controi room in
preparation of initiating an ignition as specified in Condition fV F 2 i,
rv C 3 e The Permittee shall assess and monitor meteorological conditions to ensure operators are
not exposed to risks from lightning strikes or other adverse weather conditions that would preclude the s
rv C 3 f The Permittee shall comply with all requirements for pre-placement of waste, placement of
waste in treatment units, wiring and ignition and the post-bum inspection and clean up
actifVties identified in Condition rV D, E, F, G, H and 1
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Module IV - Thermal Treatment of Energetic Wastes UTD009081357
rv C 3 g The Permittee shall provide operators with access to a telephone that can be used to contact
support personnel, including security, safety and fire fighting units, whenever the operators
are inside the M-136 or M-225 Thermal Treatment Areas,
rv C 3 h The Permittee shall maintain the integrity of the two Promontory Thermal Treatment Areas
and support equipment through regular inspections and in accordance with the mspection
plan in Attachment 2 Inspection records shall be maintained at the facility,
rv C 3 I The Permittee shall train all operators of the Promontory Thermal Treatment Areas in
accordance with Condition II G and Attachment 3 of this Permit,
rv C 3 J The Permittee shall not operate either of the Promontory Thermal Treatment Areas without
containment measures (e g firebreaks) to assure the confinement and control of any fire
resultmg from the open bum and open detonation operations at the Promontory Thermal
Treatment Areas, and
rv C 3 k The Permittee shall not treat propulsive items at the Promontory Thermal Treatment Areas,
unless the item has been rendered non-propulsive or is contained in accordance with
Attachment 11
FV C 4 The Permittee shall operate the Promontory Thermal Treatment Areas to prevent
unacceptable risk of cancer and non-cancer effects to on-site workers and off-site residents
and to minimize significant effects to the ecosystem surrounding the Promontory Thermal
Treatment Areas The Permittee shall maintain compliance with the environmental
performance standards listed in UAC R315-8-16 and comply with Permit Condition II G 2
rv C 5 The Permittee shall adhere to the following conditions to prevent unacceptable risk of
cancer and non-cancer effects due to exposure to emissions from the open buming
operations
rv C 5 a The cumulative carcinogenic risk to on-site workers shall not exceed an occurrence rate of
10X10"^ (one in ten thousand) for the closest potential receptors which are Promontory
facility workers The risk shall be calculated according to the methodology in Condition
IIG 2 a and II G 2 d The maximum NEW, including donors and initiators, to be treated at
the Promontory Thermal Treatment Areas shall not exceed 106,500 pounds per bum at the
M-136 Thermal Treatment Area and 4,500 pounds per bum at the M-225 Thermal
Treatment Area, and
Note The human health risk assessment is currently being conducted Specific restrictions
on bum ground operations are pending and will be included in the second draft of the
permit modification document There will be an additional public comment period for this
document
rvrv C 5 b The cumulative carcinogenic risk to actual or potential off-site receptors shall not exceed
1 OX 10 * (one in a million) The cumulative non-carcinogenic hazard to actual or
potential off-site receptors shall not exceed a hazard index of 1 0 for any 24-hour period
followmg initiation of a bum
rv C 6 Based on the air dispersion and deposition modeling and the human health risk assessment
for the Promontory Thermal Treatment Areas, the Permittee shall adhere to the following
conditions
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ATK Launch Systems Inc Promontory May 2010
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
Note The human health risk assessment is currently being conducted Specific restrictions
on bum ground operations are pending and will be included in the second draft of the
permit modification document There will be an additional public comment period for this
document
rv C 6 a ATK shall nottfy Box Elder County Dispatch before each treatment operation involving
reactive material,
rv C 6 b The Permittee shall only conduct bums when the surface wind speed is not greater than 15
miles per hour,
rv C 6 c The Permittee may conduct bums and open detonations between the hours of 10 00 am and
6 00 pm
IVD WASTE TRACKING
rv D 1 The Permittee shall track all reactive hazardous waste in accordance with Attachment 11
and maintain this information in the operating record for both of the Promontory Thermal
Treatment Areas
rVE PRE-BURN ACTIIVTIES
rv E 1 Prior to bringing any reactive hazardous waste into either of the Promontory Thermal
Treatment Areas for thermal treatment. The Permittee shall conduct pre-bum activities in
accordance with the requirements identified in Attachment 11, and the pre-bum inspection
requirements in accordance with the inspection schedule included in Attachment 2 The
Permittee shall also comply with the following conditions
rv E 1 a If the treatment units have not been inspected the same day the unit is loaded, the treatment
unit shall be inspected prior to placing reactive waste in the treatment unit,
rv E 1 b Any tteatment unit that fails one or more of the inspection cnteria shall be removed from
service until the problem is corrected,
rv E 1 c No treatment is permitted unless either radio or telephone communication with emergency
services is available,
rv E 1 d No treatment is permitted if the emergency equipment listed in Attachment 2, Table II-B,
"Inspection Schedule for Thermal Treatment Area at M-136" or Table II-C, "Inspection
Schedule for Thermal Treatment Areas at M-225" is not available for use at each respective
location,
rv E 1 e All leaks or spills of diesel fuel shall be cleaned up before the Promontory thermal
treatment areas can be operated, and
rv E 1 f The loss of the flashing light will require that the unit be shut down until the problem is
corrected If the Permittee must use the treatment unit when the flashing light is not
working, the supervisor shall visually inspect the area within the QD of the treatment unit
and assure that no unauthorized employees are present in the area If any unauthorized
employees are found within this area, they will be escorted from the area Treatment
operations can commence once the supervisor verifies in the operating record that the area
is clear
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Module IV - Thermal Treatment of Energetic Wastes UTD009081357
rVF PREPARING WASTE FOR THERMAL TREATMENT BURN
rv F 1 Prior to placing any reactive hazardous waste in a treatment unit, the Permittee shall
comply with all provisions Conditions rV C, D and E of this Permit The Permittee shall
also comply with the following conditions
rv F 1 a There shall be at least two operators present when a treatment unit is in the process of being
loaded with reactive hazardous wastes as defined in Condition IV B 1,
IV rv
rv F 1 b The tteatment unit shall be loaded in accordance with internal safety procedures and the
ATK Hazardous Operation Standard 1-3 Handling & Disposal of Explosives & Other
Hazardous Wastes, an intemal and confidential document which is part of the operating
record, and the provisions identified in Attachment 118,
rvrv F 1 c All cardboard, wood and diesel used as donor material to assure a complete bum shall be
counted towards the daily tteatment limits, and recorded in the operating record,
rv F 1 d All reusable propellant buckets used as accumulation containers for reactive waste shall be
inspected after use If there is any contamination in the containers they shall be cleaned or
decontaminated in accordance with the procedures identified in Attachment 11 before being
reused,
rv F 1 e The Permittee shall document in the operating record the bum station for each container of
reactive hazardous waste treated
rv F 2 Prior to beginning the final preparations for an open bum, the Permittee shall comply with
the following conditions
rv F 2 a Reactive waste shall not be prepared for ignition, as described in Attachment 11 8 2 3, until
all non-essential personnel leave the tteatment area,
rv rv F 2 b All wiring and ignition operations, described in Attachment 11 8 2 3, shall be conducted by
at least two employees,
rv rv F 2 c The Permittee may reactivate the firing system treatment areas only after all operators have
exited the QD for the treatment unit,
rv F 2 d As the operators leave the tteatment area following operations described in Attachment 11,
Section 8 2 3, they shall close the gate to the treatment area.
rv F 2 e After all operators have exited the treatment area and retreated to the firing conttol room,
the operators may replace the firing system interlock in the firing system conttol console
and activate the firing system,
rv F 2 f After activating the firing system, the operators shall confirm that the flashing red light was
activated to alert all personnel that a treatment event is about to start and that they should
vacate the QD area for the treatment area If the flashing light is not operational, the
Permittee shall comply with Condition fV E 1 f before initiating the thermal treatment.
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Module IV -- Thermal Treatment of Energetic Wastes UTD009081357
rv F 2 g After the waming identified m Condition IV F 2 f has been completed, the Permittee shall
conduct a pre-ignition continuity check of the firing system to assure that the igniters have
been installed correctly into the hard-wired portion of the firing system If any firing
circuit fails this test, the Permittee shall perform the following tasks
rv F 2 g I Remove the interlock for the firing control system, deactivating the firing control system,
rv F 2 g u At least two operators shall reenter the treatment area, and correct the problem,
rv F 2 g HI If the resistance problem cannot be immediately corrected, the operators may connect a
separate igniter wire to an adjacent stanchion, and
rv F 2 g IV After the problem with the firing circuit has been corrected the operators shall repeat the
steps described in Conditions rV F 2 g
rv F 2 h The freatment units shall be fired in accordance with the provision of Attachment 11,
Section 8 2 3 of this Permit,
rv F 2 1 All thermal treatment events shall be observed with a video camera from the firing confrol
room or immediately outside the firing confrol room,
rv F 2 j In the event that none of the treatment units ignite, the operators shall wait 30 minutes
before removing the firing system interlock and reentering the treatment area to correct the
problem After correcting the problem, the operators shall repeat the steps described in
Conditions fV F 2 c, d, e, f and g, and proceed with activating the firing system,
rv F 2 k If at least one treatment unit ignites, then the operators shall wait at least 16- hours before
reentermg the freatment area, and correctmg the problem After the problem has been
corrected, the operators shall repeat the steps described in Conditions IV F 2 c, d, e, f and g,
and proceed with activating the firing system,
rv F 2 I Prior to ignition, the area supervisor or designee, shall review the placement of the waste on
the treatment units, and
rv F 2 m All freatment data shall be maintained in accordance with the requirements of UAC R315-
8-5 3 and shall be entered into the operating record for the Promontory facility in
accordance with attachment 11 6
IV G POST-BURN ACTIIVTIES
rv G 1 Following treatment, the Permittee shall conduct the post-bum inspection activities
identified in Attachment 2, and clean up activities identified in Attachment 1 lof this
Permit, and shall comply with Conditions fV C 1, 2 and 3, and shall have completed and
complied with all provisions of Conditions, fV E and F
rv G 2 The post-bum inspection shall be conducted within 24 hours of completing a treatment
event, and perform the following unless one of the exceptions identified in fV G 2 j or k
applies
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rv G 2 a Prior to entering the treatment area, the operators shall deactivate the firing control system
and remove the interlock,
rv G 2 b Document any treatment unit with an open flame, hot spot or smoldering residue,
rv G 2 c Document any treatment unit with unburned residue,
rv G 2 d Document any treatment unit with unbumed reactive hazardous waste and identify if
possible in the operating record why the waste did not bum,
rv G 2 e Inspect for any unbumed waste that was ejected from a treatment unit during the last
treatment event Such waste shall be picked up and placed in a tteatment unit,
rv G 2 f Record on the inspection form the date that the treatment units were cleaned, or the reason
why the units were not cleaned within 24 hours after completing the treatment event,
rvrv G 2 g Identify the treatment unit where unbumed waste is being stored,
rv G 2 h Evaluate the condition of the safety equipment identified m Attachment 2, Table II-B and
Table II-C,
rv G 2 I The Permittee may postpone post-bum activities if lightning sfrikes or adverse weather
conditions prohibit the safe operation of the treatment areas Lightning strikes closer than
30 miles restrict attended operations at the Promontory Facility The Permittee shall
document the reasons for the delay in the facility's operating record, and
rv G 2 J The Permittee may delay the post-bum inspection for bums involving bulk propellant and
bulk explosives that occurred on a Friday The post-bum inspection shall be conducted on
the following Monday, unless the meteorological conditions identified in Condition
rv G 2 J prohibit re-entry into the treatment area The Permittee shall document the
reasons for the delay in the facility's operating record
rv G 3 Within 24 hours of completing an open bum that generates a characteristic or listed ash or
residue, the Permittee shall remove all characteristic or listed residues from the treatment
area and mange the waste m accordance with R315-5 of the UAC If the Permittee can not
remove these treated residues from the freatment area within 24 hours due to weather
conditions, such as, snow or ice covering the treatment area, the Permittee shall document
the followmg information in the operating record
rv G 3 a The reason for the delay in doing the post-bum clean up,
rvrv G 3 b The date when the freatment unit was cleaned, and
rv G 3 c Except as delayed by the conditions described in Condition IV G 2 j, the area supervisor, or
designee, shall review the Promontory Thermal Treatment Areas log and post-bum
inspection forms within 24 hours of completing a thermal treatment event The review
shall assure that all of the recorded information is correct and identify any items that may
require corrective action including any treatment unit that failed to ignite, had an ignition
problem or misfired, had an unplanned detonation, where the bum did not propagate as
expected or any other unexpected event
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ATK Launch Systems Inc Promontory May 2010
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
rv G 4 Open bum operations at the Promontory Thermal Treatment Areas may result in the
generation of untreated residue and unbumed wastes The Permittee shall manage these
residues and wastes in accordance with the following provisions
rv G 4 a Small amounts of unfreated residue shall be considered newly generated waste and shall be
logged and tracked as such in the explosive waste tracking system This small amount is
defined as less than 5% of the total volume placed treatment unit The primary option for
managing this waste is to burn it by 6 00 pm of the following calendar day If the untreated
residue cannot be treated by 6 00 pm of the following calendar day then it shall be managed
in accordance with UAC R315-5,
rv G 4 b Unbumed waste resulting from a misfire or an interrupted ignition shall be treated by 6 00
pm of the calendar day following the date of the first attempt to freat this waste For the
purposes of this Permit, an intermpted ignition occurs when anything greater than 5% of
the waste placed on in a freatment unit or in a station fails to ignite This unreacted waste
shall not be considered a newly generated residue If the Permittee is unable treat the
unbumed waste by 6 00 pm of the following calendar day, the Permitttee shall cover the
waste and manage the treatment unit or station in accordance with UAC R315-5 If the
cumulative storage time for the unbumed waste both while in storage prior to treatment and
while on the treatment unit or in the bum station is greater than 90 days, the Permittee shall
request an emergency storage permit in accordance with UAC R315-3-6 2,
rv G 4 c For reactive hazardous wastes that have been in storage for greater than 90 days when they
are placed on in a freatment unit or in a bum station and which do not completely bum, the
Permittee shall freat all unbumed or unreacted waste by 6 00 pm of the calendar day
following the date of the initial attempt to freat the waste If the Permittee is unable to treat
the unbumed or unreacted waste by 6 00 pm of the following calendar day, then the
Permittee shall request an emergency storage permit in accordance with UAC R315-3-6 2,
and
rv
rvrv G 5 The Permittee shall manage all freatment residues generated from the freatment of listed
and/or characteristic wastes during post-bum activities in accordance with this Permit and
UAC R315-5
IV H STORMWATER MANAGEMENT AND RUN-ON AND RUN-OFF CONTROLS
rv H 1 The Permittee shall manage all stormwater collected from treatment units in accordance
with this Permit, Attachment 11, Sectton 11 and UAC R315-5
rv H 2 The Permittee shall maintain run-on diversion sfructures in accordance with this Permit and
UAC R315-8-16 which incorporates by reference 40 CFR 264 601 The Permittee shall
inspect the condition of those stmctures annually to assure that they are in good repair The
annual inspection shall be documented in the operating record for Promontory Thermal
Treatment Areas
rv H 3 Run-off from precipitation that falls within the operating area of the Promontory Thermal
Treatment Areas shall be managed in accordance with UAC R315-8-16, which incorporates
by reference 40 CFR 264 601, using berms, and ground slope
rv H 4 The Permitee will submit a proposal for managing run-off precipitation within 180 days
from the issue date of this permit
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Module IV - Thermal Treatment of Energetic Wastes UTD009081357
IVI TREATMENT RESIDUE AND ASH MANAGEMENT
rv n AU treatment residue and ash generated from the Promontory Thennal Treatment
operations shall be managed in accordance with Condition fV G 5 and the procedures
identified in Attachment 11
rv I 2 Sampling and analysis of treatment residues and ash generated during operations at the
thermal treatment areas shall be performed in accordance with Attachment 1 and 11
IVJ INSPECTION SCHEDULES AND PROCEDURES
rv J 1 The Permittee shall conduct inspections of the Promontory Thermal Treatment areas in
accordance with Attachment 2 and 11
IV K ENIVRONMENTAL MONITORING REGUIREMENTS
rv K 1 Withm 180 days of issuance of this Permit or completion of the Human Health Risk
Assessment, whichever occurs later, the Permittee shall submit a Soil Monitoring Plan to
the Executtve Secretary for approval The Soil Monitoring Plan shall, at a minimum,
address the following
rv K 1 a The impact of thermal treatment operations on soils within the tteatment zone as identified
by the air dispersion and deposition model contained in the human health risk assessment
identified in Condition ir G 1 ,
rv K 1 b Risks to human health from exposure to media impacted by emissions from the Promontory
Thermal Treatment Areas operations shall be assessed Acceptable risks are specified m
Conditions fV C 5 a and IV C 5 b rV The receptors to be evaluated are listed m the Human
Health Risk Assessment identified in Condition II G 1 The risk assessment methodology
shall be consistent with UAC R315-101, and
rv K 1 c The plan shall identify analytes, sampling protocols and data quality objecttves for the soil
monitoring program
rv K 2 If the Executive Secretary does not approve the Soil Monitoring Plan, he shall provide
written comments to the Permittee identifying the deficiencies in Soil Monitoring Plan
The Permittee shall address the comments and submit a revised Soil Monitoring Plan to the
Executive Secretary for approval within 60 days of receipt of written comments
rv K 3 Within 30 days of receipt of the Executive Secretary's approval of the Soil Monitoring
Plan, the Permittee shall submit a request to modify the Permit in accordance with
Condition 1 D to incorporate the requirements of the Soil Monitoring Plan into this Permit
rv K 4 Within 180 days of the issuance of this Permit, the Permittee shall submit a Groundwater
Monitoring Plan to the Executive Secretary for approval The Groundwater Monitoring
Plan shall, at a minimum, address the following
rv K 4 a The impact of thermal treatment operations on groundwater up and down gradient of the
M-136 and M-225 Thermal Treatment Areas, and
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Module IV - Thermal Treatment of Energetic Wastes UTD009081357
rv K 4 b The plan shall identify analytes, sampling protocols and data quality objectives for the
groundwater monitoring program In addition, the plan shall propose a statistical method
for determining if existing groundwater contamination concenfrations increase due to
ongoing thermal freatment operations
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ATK Launch Systems Inc Promontory May 2010
Module IV-Thermal Treatment of Energetic Wastes UTD009081357
IVL ECOLOGICAL RISK
rv L 1 Within 180 days of issuance of this Permit or completion of the human health risk
assessment, which ever occurs later, the Permittee shall submit an Ecological Risk
Assessment Protocol document for evaluating thermal treatment operations to the
Executive Secretary for approval If the Executive Secretary is unable to approve the
Ecological Risk Assessment Protocol document, he shall provide written comments to the
Permittee identifying the deficiencies in Ecological Risk Assessment Protocol document
The Pennittee shall address the comments and submit a revised Ecological Risk
Assessment Protocol document to the Executive Secretary for approval within 60 days of
receipt of written comments
rv L 2 Within one year of receiving approval of the Ecological Risk Assessment Protocol
document, the Permittee shall submit an Ecological Risk Assessment for evaluating thermal
treatment operations to the Executive Secretary for approval If the Executive Secretary is
unable to approve the Ecological Risk Assessment, he shall provide written comments to
the Permittee identifying the deficiencies in Ecological Risk Assessment The Permittee
shall address the comments and submit a revised Ecological Risk Assessment to the
Executive Secretary for approval within 60 days of receipt of wntten comments
rv L 3 Withm 30 days of receiving approval of the Ecological Risk Assessment, the Permittee
shall submit a request to modify Condition IIG of this Permit in accordance with
Condition 1 D to add performance standards for the acceptable ecological risk associated
with the operation of both of the Promontory Thermal Treatment areas
rVM ACUTE HUMAN HEALTH RISK
Note The human health risk assessment is currently being conducted The acute human
health risk will be evaluated Specific restrictions on bum ground operations are pending
and will be included in the second draft of the permit modification document There will
be an additional public comment period for this document
IV N FACILITY MODIFICATION/EXPANSION
rv N 1 Modification of the design plans and specifications in Attachment 6 or construction of
additional treatment units shall be allowed only in accordance with UAC R315-4-1 5
FVO CLOSURE AND POST CLOSURE
rv O 1 The Permittee shall close the Promontory Thermal Treatment Areas m accordance with the
Closure Plan in Attachment 5
IV P PROMONTORY THERMAL TREATMENT AREAS OPERATING RECORD
rv P 1 The Permittee shall maintain an operating record at the Promontory facility that describes
the operation of the Thermal Treatment areas The operating records for the M-136 and
M-225 Thermal Treatment Areas shall, at a minimum, include the following mformation
rv P 1 a All information required by UAC R315-8-5 3,
rv P 1 b Copies of all mspections required by this module,
rv P 1 c All waste tracking information maintained in the electronic Waste Tracking Record
identified in Attachment 11
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Module IV - Thermal Treatment of Energetic Wastes UTD009081357
rvrv P 1 d A description of the meteorological conditions described in Condition IV C 3 e during
each bum,
rv P 1 e Copies of all reports identified in Condition II G 1 and required by Condition 11 G 2 and
rv K and rv L, and
rv P 1 f A running total of the type and quantity of reactive hazardous waste that has been treated at
both of the Promontory Thermal Treatment areas during the calendar year
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ATK Launch Systems Inc - Promontory May 2010
Attachment 2 - Inspection Schedules and Procedures UTD009081357
ATTACHMENT 2
INSPECTION SCHEDULES AND PROCEDURE
ATK Launch Systems Inc - Promontory May 2010
Attachment 2 - Inspection Schedules and Procedures UTD009081357
INSPECTION SCHEDULES AND PRQCEDURES
IIA Purpose and Scope
The inspection schedule used by ATK for the hazardous waste management areas
has been designed to meet the requirements of R315-8 2 6 The design ofthe
schedule promotes the detection of malfunctions, deterioration, discharges, and
other Situations which may be causing or leading to a release of hazardous waste
constituents into the environment or pose a threat to human health Inspections are
conducted by personnel trained to identify potential problem areas and to use the
inspection schedule and the inspection log Eight areas are designated for
inspection the container storage area at E-501, M-705S, M-186, the Thermal
Treatment Areas at M-136 (mcluding the LTTAs, bum trays and Bum Station 14),
M-225, T-29B hydrazine dilution and the solid propellant/motor storage
buildings, M-47, M-603 and storage pad S-633
Waste solid propellant and rocket motors are stored at buildings M-47, M-603,
and storage pad S-633 only occasionally and waste hydrazine is treated (by
dilution) at building T-29B periodically Therefore inspections of these facilities,
m accordance with their inspection schedules, are only required when hazardous
waste is bemg stored or treated at the facility A facility must be inspected,
however, prior to receiving hazardous waste for storage or treatment if inspections
were discontinued during the period of inactivity If any problems are identified
with the areas of concem 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 Mamtenance
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 of the inspection, the name of the inspector, a
notation of the observations made, and the date and nature of any repairs or
maintenance taken
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
IID
May 2010
UTD009081357
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 mspection schedule 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 mch in a one-
hour period It shall be documented in the inspection log that the mspection was
conducted in response to a storm event
TABLE II-A ^
INSPECTION SCHEDULE FOR DRUM STORAGE AT JVl-186
EOUIPMENT
MINIMUM
FREOUENCY AREAS OF CONCERN
I Security Equipment
Fences Weekly Visually inspect all fence lines and look for
broken or downed fence lines, loose wires
Signs
Gates
Weekly
Weekly
Readable signs, signs in place
Able to properly close gate, safety
flags in place
Lock Weekly In working order, able to lock
2 Area
Roadway Daily' Inspect road for spills,
soil discoloration
Loading/ Daily
Unloading Areas
Periphery Daily'
Inspect loading areas for
spills, soil discoloration
Inspect groimds for any spills, soil
discoloration or stressed vegetation
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
3 Safety Equipment
Eyewash/Shower Monthly
May 2010
UTD00908I357
Ensure in working order by
testing, check water supply
Telephone/Radio Monthly
4 Storage Containment
Containers Weekly
Pads Weekly^
Sumps/Pads Daily'
Drainage Area Weekly^
Roof Weekly
5 Emergency Equipment
Fire Monthly
Extinguisher
Absorbent Monthly
Repack Dmms Monthly
55-Gallon dmms Monthly
Generator Monthly
Pump Monthly
Working condition
Number of contamers, severe
corrosion (i e , flaking, large rust buildup,
msty bungs), dented drums, 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)
Two repack dmms with seals
Six empty 55-gallon drums with btmgs
in good condition, no dents, etc
Routme oil check, fill with gas, test startup
Good working order, hoses intact, test
startup and pump
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
' When m use
May 2010
UTD009081357
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 lVI-136
EQUIPMENT
1 Security Equipment
Fences
Signs
Gates
Lock
2 Area
Roadway
Loading/
Unloading Areas
Periphery
3 Safety Equipment
MINIMUM
FREOUENCY
Weekly
Weekly
Weekfy
Weekly
Daily'
Daily'
Daily'
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
Telephone/Radio Monthly
4 Bum Ground Area
Erosion Weekly^
Check operating condition of equipment
Survey area and note severe erosion on
grounds
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
5 Storage/Containment
May 2010
UTD009081357
Burn tray
Fire
Extinguisher
Weekly .2 3
Container Weekly^
6 Emergency Equipment
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 mch of precipitation in
a one-hour period
TABLE II-C
INSPECTION SCHEDULE FOR BURNING GROUNDS AT lVI-225
EOUIPMENT
1 Security Equipment
Fences
Signs
Gates
Lock
2 Area
Roadway
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Weekly
Daily'
Loading/Unloading Daily
Areas
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
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
Periphery Daily'
3 Safety Equipment
Telephone/Radio Monthly
May 2010
UTD009081357
Spills, discolored soil, stressed
vegetation
Check operating condition of equipment
4 Bum Ground Area
Erosion Weekly^
Bum Tray Weekly^
5 Emergency Equipment
Fire Extinguisher Monthly
Survey area and note severe erosion on
grounds
Tray is intact and liquid tight, accumulation
of liquids
Fire extinguisher fiill 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
ROOIM AT 1VI-705S
EOUIPMENT
1 Security Equipment
Signs
ME^IMUM
FREOUENCY
Weekly
AREAS OF CONCERN
Readable signs, signs in place
2 Area
Roadway Daify' Spills, discolored soil
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
Loading/Unloading Daily'
Areas
May 2010
UTD009081357
Periphery Daily'
3 Safety Equipment
Eyewash/Shower Monthly
Telephone/Radio Monthly
4 Storage contamment
Containers Weekly
Pads, Sumps Weekly
Portable Secondary Daily
Roof Weekly
Sump, pads Daily'
5 Emergency Equipment
Fire Extinguisher Monthly
Absorbents Monthly
Repack Dmms Monthly
Spills, discolored soil
Spills, discolored soil, stressed
vegetation
Ensure in working order by testing,
check water supply
Check operating condition of equipment
Number of containers, severe corrosion (i e
flaking, large mst buildup, msty bungs),
dented drums, hazardous waste labels in
place, properly marked, readable, no open
bungs, no standing liquid on the drums
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 fiill and in working order
Adequate supply (minimum 25 lbs )
Two repack drums with seals
55-Gallon Dmms Monthly Six empty 55-gallon drums with bimgs in
good condition, no dents, etc
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
' When m use
May 2010
UTD009081357
TABLE II-E
INSPECTION SCHEDULE FOR lVI-47, lVI-603
(Note As stated in section II A of this Attachment, inspections of these
storage buildings are not required during periods when hazardous waste is not
being stored at the facility)
EQUIPMENT
1 Security Equipment
Signs
Bay Doors
Lock
2 Area
Roadway
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Daify'
Loading/Unloading Areas Daily
Periphery Daily'
3 Communications Equipment
Telephone Monthly
4 Storage Containers
Motors/bags, etc Weekly
AREAS OF CONCERN
Readable signs, signs in place
Function 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 matenal and check for leakage,
or liquid discharge from waste solid
rocket motors and propellant
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
Building Weekly
May 2010
UTD009081357
Verify no damage done to exterior of
facility
Roof
5 Emergency Equipment
Fire Extinguisher
Weekly
Monthly
General condition including holes or
defects
In working order and full
' When hazardous waste is transported to and from the building
TABLE H-F
INSPECTION SCHEDULE FOR DRUM STORAGE PAD AT E-501
EOUIPMENT
1 Security Equipment
Fences
Signs
Gates
Lock
2 Area
Roadway
MINIMUM
FREOUENCY
Weekly
Weekly
Weekly
Weekly
Daify'
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
Loading/ Daily
Unloading Areas
Periphery Daily'
Inspect loading areas for
spills, soil discoloration
Inspect grounds for any spills, soil
discoloration or stressed vegetation
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
May 2010
UTD00908I357
3 Safety Equipment
Eyewash/Shower Monthly Ensure m working order by
testing, check water supply
Telephone/Radio Monthly
4 Storage Containment
Containers Weekly
Pads Weekly
Sumps/Pads Daily'
Drainage Area Weekly^
Roof Weekly
5 Emergency Equipment
Fire Monthly
Extinguisher
Absorbent Monthly
Repack Dmms Monthly
Working condition
Number of containers, severe
corrosion (i e , flaking, large mst buildup,
msty bungs), dented drums, 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 fiill, in working order
Adequate supply (minimum 25 lbs)
One repack drum with seals
55-Gallon dmms Monthly Three empty 55-gallon dmms with bungs
in good condition, no dents, etc
When in use
ATK Launch Systems Inc - Promontory May 2010
Attachment 2 - Inspection Schedules and Procedures UTD00908I357
^ And after each storm event A storm event is defined as more than one inch of precipitation in
a one-hour period
TABLE II-G
INSPECTION SCHEDULE FOR T-29B Hydrazine Dilution Bay
(Note As stated in section II A of this Attachment, inspections of building T-29B are not
required during periods when hazardous waste is not being treated at the facility)
EOUIPMENT
1 Security Equipment
Signs
Door Locked
2 Area
Roadway
Loading/
Unloading Areas
Periphery
3 Safety Equipment
Eyewash/Shower
Telephone(cell)
4 Storage Containment
Containers
MINIMUM
FREOUENCY AREAS OF CONCERN
Pnor to treatment Readable signs, signs in place
Prior to treatment In working order, locked
Daily'
Daily'
Daily'
Prior to treatment
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
Prior to treatment Working condition
Prior to treatment Number of containers, severe
corrosion (i e , flaking, large mst buildup,
msty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bimgs, no standing liquid on dmms
ATK Launch Systems hic - Promontory
Attachment 2 - hispection Schedules and Procedures
May 2010
UTD009081357
Floor Prior to treatment Chips, cracks,or irregularities in concrete,
general condition
Roof Prior to treatment
5 Emergency Equipment
Prior to treatment
General condition includmg holes or defects
Fire
Extinguisher
Absorbent
Fire extinguisher full, m working order
Prior to treatment Adequate supply (minimum 25 lbs)
' When hazardous waste is ttansported from the building
TABLE II-H
INSPECTION SCHEDULE FOR STORAGE PAD S-633
(Note As stated in section IIA of this Attachment, inspections of this storage
pad IS not required during periods when hazardous waste is not being stored
on the pad)
EOUIPMENT
1 Security Equipment
MINIMUM
FREOUENCY AREAS OF CONCERN
Fences Weekly Visually inspect all fence lines, look for
loose wires or broken lines
Signs Weekly Readable signs, signs in place
Gate Weekly Able to properly close gate
Lock Weekly In working order, able to lock
2 Area
ATK Launch Systems Inc - Promontory
Attachment 2 - Inspection Schedules and Procedures
Roadway Daily'
Loading/Unloading Daily'
Areas
May 2010
UTD009081357
Periphery
Erosion
Daily'
Weekly^
3 Storage Containers
Motors/containers, etc Weekly^
Spills, discolored soil
Spills, discolored soil
Spills, discolored soil, stressed
vegetation
Survey area and note severe erosion on or
around storage pad
Verify condition of motors/containers,
properly marked and labeled, out of
place matenal and check for leakage, or
liquid discharge from waste solid rocket
motors and propellant
When hazardous waste is transported to and from the storage pad
^ And after each storm event A storm event is defined as more than one inch of precipitation in a
one-hour period
^Inspect upon arrival, then each calendar week
HAZARDOUS WASTE MANAGEMENT
Contingency Plan and
Emergency Procedures
For Spills of
Hazardous Materials
May 2010
ATK Launch Systems
Promontory Plant
P.O. Box 689 Brigham City UT 84302-0689
[phone]
ATK Launch Systems - Promontory May 2010Attachment 4 - Contingency Plan
PREFACE
This document, HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES FOR SPILLS OF HAZARDOUS MATERIALS, (herein referred to as Contingency Plan), provides
written instructions on how to take care of spills of hazardous substances It is mtended 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 mstead of, the ATK Launch Systems -
Promontory EMERGENCY AND DISASTER RESPONSE PLAN, or any other plan which outlines procedures to
be followed durmg general emergencies, disasters, civil disturbances, nots bomb threats, etc
Most spills mvolving hazardous substances will not require use of the EMERGENCY AND DISASTER
RESPONSE PLAN Spills that create an emergency situation mvolving possible mjury to personnel or damage to
property will require use ofthe EMERGENCY AND DISASTER RESPONSE PLAN to take care ofthe emergency
This CONXrNGENCY PLAN applies to containment and cleanup of a hazardous waste spill
Defmitions m the HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES reflect EPA and State of Utah environmental language while those m 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 m language between these documents and must evaluate the
applicability of each document to the particular situation
ATK Launch Systems - Promontory May 2010Attachment 4 - Contingency Plan
TABLE OF CONTENTS
INTRODUCTION
A PURPOSE
B SCOPE
C NOTIFICATION
D POSTING
E REVISIONS AND UPDATING
F DEFINITIONS
G PLANT LOCATIONS AND SITE INFORMATION
H PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES
II REPORTING PROCEDURES AND rNCIDENT IDENTIFICATION
A EVACUATION CRITERIA
B IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL
C REPORTING OF EMERGENCY INCIDENTS
D PERSONNEL RESPONSIBILITIES
E ALARM SYSTEMS
F LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND
HOSPITALS
7
7
7
8
8
19
15
III SPILL CONTAINMENT AND CLEANUP 16
A CONTROL PROCEDURES 16
B SPILL CONTAINMENT AND CONTROL 16
C SPILL CLEANUP 16
D FOLLOWUP PROCEDURES 17
E INCOMPATIBLE WASTE 18
F CLEANUP MATERLVL AND EQUIPMENT 18
G DECONTAMINATION EQUIPMENT AND PROCEDURES 20
H EQUIPMENT DECONTAMINATION AND REPLENISHMENT 20
IV INSTALLATION RESPONSE TEAM TRAINING
A TRAINING
B SIMULATION
21
21
22
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 DRJLL 22
H BOMB SEARCH TECHNIQUES 22
I FIRE BARRICADE/CORDON AREAS 23
J EMERGENCY IVIEDICAL 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 May 2010Attachment 4 - Contmgency Plan
Q
R
S
HANDLING OF REMAINS
NOTIFICATION PROCEDURES
RESCUE EFFORTS
24
24
24
TABLES
TABLE I COMPATIBILITY INFORMATION
TABLE II EMERGENCY COORDINATOR CALL LIST
25
26
FIGURES
FIGURE 1 DECONTAMINATION/SPILL SCENE
FIGURE 2 DECONTAMINATION
27
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
M-136 SITE MAP AND EVACUATION PLAN
M-186 SITE MAP AND EVACUATION PLAN
E-501 STORAGE YARD FACILITY FUNCTION TABLE
E 501 SITE MAP AND EVACUATION PLAN
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE
M-225 SITE MAP AND EVACUATION PLAN
34
35
36
37
38
39
40
T 29B SATELLITE ACCUMULATION AREA FUNCTION TABLE
T-29B SITE MAP AND EVACUATION PLAN
41
42
M-705 WASTEWATER TREATMENT FACILITY FUNCTION TABLE
M 705 HAZARDOUS WASTE CONSOLIDATION ROOM
M-705 SITE MAP AND EVACUATION PLAN
43
43
44
M-47 PROPELLANT STORAGE FUNCTION TABLE
M-47 SITE MAP AND EVACUATION PLAN
45
46
M-603 PROPELLANT STORAGE FUNCTION TABLE
M-603 SITE MAP AND EVACUATION PLAN
47
48
ATK Launch Systems - Promontory May 2010Attachment 4 - Contmgency Plan
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 May 201 OAttachment 4 - Contmgency Plan
I INTRODUCTION
A PURPOSE
This plan may be activated by requestmg emergency response on phone number 2222 or 911
The purpose of this Contmgency Plan and Emergency Procedures is to set forth responsibilities,
establish organizational structure, and outlme the procedures requu-ed to ensure effective wammg,
response, and control to mmmuze hazards to human health or the environment from fires explosions,
or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to
au-, soil, or surface water
B SCOPE
This organizational plan is mtended to meet requirements of the Utah Hazardous Waste Management
Rules and Subpart D of the Resource Conservation and Recovery Act
The provisions of this plan will be carried out immediately whenever there is a fire, explosion, or
release of hazardous waste or hazardous waste constituents at one of the permitted facility that could
threaten human health or the environment This plan specifically addresses company actions to be
mitiated m the event of a spill or release of hazardous materials
C NOTIFICATION
Incidents covered by this contmgency plan and which meet applicable State of Utah and U S EPA
reportmg requirements will be reported to the appropriate agencies by Envu-onmental Specialists The
Envu-onmental Specialist should confer with the Director or Manager of Environmental Services pnor
to notification
D POSTING
Copies of the Contmgency Plan and all revisions must be
1 Mamtamed 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 regardmg emergency services that would be provided as
requu-ed Letters of agreement are kept m the Environmental Services Central Files )
E REVISIONS AND UPDATING
This contmgency plan will be reviewed and amended whenever
1 Applicable regulations are revised
2 The plan fails m an emergency
3 The facility changes its design, construction, operations, mamtenance or other circumstances m
a way that materially mcreases the potential for fires, explosions, or release of hazardous waste
or hazardous waste constituents, or changes the response necessary m an emergency
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
4 The list of emergency coordinators change
5 The list of emergency equipment changes
F DEFINITIONS
1 Disaster An event m which loss of life, senous and/or multiple mjuries, major property or
environmental damage, or major disruption of normal operations has occurred This mcludes
serious fu-es or major hazardous material spills, explosions, mjuries to multiple people, and acts
of nature such as floods, violent storms, or earthquakes
2 Discharge - The accidental or mtentional spillmg (see Spill), leakmg, pumpmg pourmg,
emittmg, emptymg, or dumpmg of hazardous waste on or mto the air, land, or water
3 Emergency - A simanon which, if not quickly controlled, can lead to death, serious and/or
multiple mjuries, 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 m the full scope admmistration of the emergency
5 Emergency Commander - The General Manager or his designee, as head of the Command
Unit, is responsible for the overall direction, coordmation, and function of all units charged with
providmg countermeasures to cope with conditions and/or events withm the scope of this plan
The Command Unit will consist of any and all persons selected by the Emergency Commander
NOTE
The Emergency Commander -will be the head of the Command
Unit for all civil disturbances bomb threats national
emergencies and natural disasters
The Command Unrt will operate from a pre-designated Emergency Operations Center specified
by the Emergency Disaster Response Plan or the Emergency Commander
6 Emergency Operations Center (EOC) The location of senior management where decisions
and mcident specific policies are made
7 Environmental Specialist - The Envu-onmental Specialist is the Spill Team Leader from
Environmental Services He or his designated alternate will assist the Incident Commander m
the evaluation of the impact on the environment resultmg from any emergency, disaster, or
hazardous substance discharge
NOTE
When required notification of Federal State and/or local
environmental agencies shall be through the Environmental
Specialist Company policy requires that the event be discussed
•with the Vice President of the applicable division and A TK
Corporate Environmental
8 Fire Brigade - A group of employees, generally from mamtenance, who have received
HAZWOPER trammg and are called on as needed to assist the full-time fu-e department m
emergency response
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
9 Fire Warden A designated mdividual assigned in advance to assist the fire department m
evacuation procedures and give mformation on the buildmg and surroundmg area
10 Hazardous Waste - Identified m 40 CFR 261 and m Utah Hazardous Waste Management Rules,
Section 2 1 on the basis of specific listed material and general characteristics Specific listed
wastes are found m these documents The EPA regulations provide detailed technical
specifications of four characteristics
Ignitable (DOOl)-
Corrosive (D002) •
Reactive (D003)
An ignitable compressed gas, an oxidizer a liquid havmg a flashpomt <
140^F or a non-1 iquid capable of causmg 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 mches/year on steel
A solid waste that
a Is unstable and readily undergoes violent change without detonatmg
b Reacts violently with water
c Forms potentially explosive mixtures with water
d Generates toxic gases, vapors or fumes in a quantity sufficient to present
a danger to human health or the environment when mixed with water
e Is a cyanide or sulfide bearmg waste which can generate toxic gases,
vapors, or fiimes in a quantity sufficient to present a danger to human
health or the environment when exposed to pH conditions between 2 and
125
TCLP Toxicity (as determmed by Toxicity Characteristic Leachate Procedures) - Presence of
certam listed toxic matenals at levels greater than those specified in the
regulation
11 Hazardous Communication Web (Haz Com Web) - a computer based system which contams
a scanned unage of the MSDS, plus additional safety and disposal information
12 Hazardous Waste Profile Data (HWPD) Sheet An ATK document that lists all EPA, DOT,
and chemical mformation needed for markmg, labelmg, and identifymg waste streams on plant
13 Hazardous Waste Operations and Emergency Response (HAZWOPER) Refers to specific
trammg requirement for handling hazardous materials and for emergency operations These
requirements are foimd m 29 CFR 1910 120
14 Human Resource Coordination - An intermediate between management and personnel who
deals with employee concems and mterests
15 Incident Commander/Emergency Coordinator - The Incident Commander will be the on duty
Assistant Fire Chieflncident Commander
The Incident Commander will direct the activities of all Field Units from a designated control
3
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
pomt at the scene of the emergency disaster, or other event
The Security Manager will be the Incident Commander for countermeasures m situations caused
by hostile persons
The Fire Prevention Captam will act as Incident Commander until relieved by an Assistant Fire
Chief
The followmg items are identified as prmciples for the Emergency Commander and Incident
Commander to apply to the unique circumstances of the emergency or disaster
a Assist the mjured
b Stabilize situation and site
c Assure evidence is not destroyed, lost, or moved
d Record situation through text photographs, videos, and/or mappmg
e Notify State and local officials
f Secure and admit only qualified essential personnel to the site
g Debrief participants
16 Matenal Safety Data Sheet (MSDS) - Provides mformation on safe handlmg, proper PPE, and
disposal mformation for each chemical This document is prepared by the chemical manufacture
For additional mformation contact your local Indusfrial Hygiene representative
17 Non-sudden Release - The accidental dischargmg (see Discharge), spillmg leakmg, pumpmg,
pourmg, emittmg, empfymg, or dumpmg of hazardous wastes or materials which, when spilled
become hazardous wastes, mto or on any land or water over an extended penod of time This
also mcludes spills onto asphalt or concrete pads
18 Reportable Spill (Discharge) - A hazardous waste spill which must be reported to the Utah
Department of Envu-onmental Response and Remediation, National Response Center and/or
other applicable Federal, State or local authorrties The Utah Hazardous Waste Management
Rules list reportable spill quantities as
a One kilogram (2 2 lb) of material m accordance with R315-9-1 (b)( 1) A spill of a lesser
quantity must be reported if there is a potential threat to human health or the envu-onment
b One-hundred kilograms (220 lb) of hazardous waste or material which when spilled,
becomes hazardous waste, m accordance with R315-9-1 (b)(2) A spill of a lesser quantity
must be reported if there is a potential threat to human health or the envu-onment
c Subpart J of 40 CFR Part 265 of the Resource Conservation and Recovery Act stipulates
that a spill of 1 lb from a leakmg hazardous waste sump is a reportable quantity
NOTE
For complete descriptions and listings contact Environmental
Services or refer to R315-9 of the Utah Hazardous Waste
Management Rules
ATK Launch Systems - Promontory May 201 OAttachment 4 - Conttngency Plan
The followmg is a partial list of matenals used at ATK and the quantities which, if spilled, would
require State or Federal notification
EPA Utah
Material Quantity Quantitv
Acetone 5000 lbs 220 lbs
Methanol 5000 lbs 220 lbs
Methylchloroform 1000 lbs 220 lbs
Methylene Chlonde 1000 lbs 220 lbs
Methyl Ethyl Ketone 5000 lbs 220 lbs
Methyl Isobutyl Ketone 5000 lbs 220 lbs
Nitt-oglycerm 10 lbs 2 2 lbs
Propellants, reactive
materials (HMX)
oxidizers (AP) 100 lbs 220 lbs
Sodium Azide 1000 lbs 2 2 lbs
Toluene 1000 lbs 220 lbs
Xylene 100 lbs 220 lbs
A more complete list of reportable quantities is found m GM 3 1, Table IX
19 Solid Waste - Any discarded matenal that is a solid, liquid, semi solid or contamed gaseous
material resultmg from industrial, commercial, mmmg, or agricultural operations and is not
excluded under 40 CFR 261 4(a), 260 30, or 260 31
20 Spill - The accidental discharging (see Discharge), spillmg, leakmg, pumpmg, pourmg, emittmg
emptymg, or dumpmg of hazardous wastes or matenals which, when spilled become hazardous
wastes, mto or on any land or water This also mcludes spills onto asphalt or concrete pads
21 Environmental Services - A department with expertise m the areas of hazardous waste, au- and
water management, includmg environmental regulations m 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 Bngham 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 boundanes The plant site is composed of
four major areas in which manufactunng 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 requinng the production of solid rocket
propellants rocket motor testing and industnal support necessary to achieve each
program's objectives Solid rocket motors manufactured during this penod vary from
motors containing 7-9 lb of propellant to 1,100 000 lb Programs have included Space
Shuttle SRM Peacekeeper Trident SRAM HARM Standard Genie Minuteman
Poseidon and a variety of ground and air launched flares
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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 solid 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 industnal 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 descnbed in Table I
4 Fire hydrants are located as follows 101 hydrants in the Administrative and
Manufactunng 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 Capacity (gal)
X-1 200 000
X-2 20 000
M-131 50 000
M-132 50 000
M-133 100 000
M-587 (North Plant) 1,000 000
M-696 20,000
T-59 (Test) 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
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
p67
6 All buildings with 10 or more regular occupants have an evacuation plan posted at all
6
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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 matenals 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 expenenced individual who will take all possible steps to
prevent a recurrence to limit the extent of the 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 occurnng If
a non-sudden release of matenals 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 matenal
2 The Matenal 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
7
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
to for proper disposal of the waste
C REPORTING OF EMERGENCY INCIDENTS
1 Spilled matenal 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
D 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 authonty 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
e Do not attempt to contain spills that are beyond capability or training
3 FIRST LINE SUPERVISORS
a Ensure personnel evacuate buildings or areas to the assembly point indicated on
8
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
the Emergency/Evacuation Plan located in each building
NOTE
Handicapped personnel must be provided priority and
assistance dunng 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 appropnate 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 matenals that may be exposed to fire or
explosion (Quantity Distance Critena)
c Applicable Quantity Distance Cntena
d Assume control of emergency area
e Declare severity of event such as an emergency or disaster as appropnate
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 appropnate 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 matenal has taken place
I Identify safe response routes for follow-on units
j Coordmate activities with other emergency units
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
9
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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
unauthonzed 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 Industnal Secunty Manual
f Establish penmeter 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 of the Incident Commander notifies appropnate 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
radiation hazards
c Perform the following activities as necessary
I Sample air at the scene including any sumps which have to be pumped (if
10
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
determined to be necessary by the Industnal 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 matenals
V Advise the Incident Commander to notify public health authonties
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 barncading and shonng as necessary per direction of Incident
Commander
d As Fire Bngade assist when needed
e Provide construction type matenals and services for containment of hazardous
matenal spills
f Performs these duties per direction of Incident Commander
10 ENVIRONMENTAL SERVICES PERSONNEL
a Report to the Incident Commander at the command post when notified by Secunty
Police Radio Dispatch
b Perform duties as directed by the Incident Commander after matenal 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
11
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contmgency Plan
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
d Expedite printing and delivery of the 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 km 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 of a building deluge system which in
turn caused the building sump to overflow
12
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contmgency Plan
b Initiate reports required by the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) and Utah Solid and Hazardous Waste
Regulations
c 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
d Notify the State and Federal environmental agencies as required
e 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
I Name and telephone number of reporter
II Name and address of facility
III Time and type of incident (such as discharge fire etc)
IV Name and quantity of matenal(s) involved to the extent known
V The extent of injunes if any
VI The possible hazards to human health or to the environment outside the
facility
f Notify the Corporate Environmental Engineer if the spill is reportable
David Shead
[phone]
g 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 wntten 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 matenal(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
13
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
h Notify the community emergency coordinator for the local emergency planning
committee in compliance with requirements outlined in 40 CFR 355 40 where
applicable
I Immediately after an emergency the Environmental Specialist must provide
direction for treating stonng or disposing of recovered waste contaminated soil or
surface water, or any other matenal that results from a discharge fire, or explosion
at the facility
J The Environmental Specialist and the Incident Commander must ensure that in the
affected area(s) of the 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 matenal 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
b Record all significant events and actions
c Initiate and maintain record information in a time line log
d Assist in the preparation of intenm and final reports
ALARM SYSTEMS
1 Alarm systems are available at ATK for fires or building evacuations if an emergency or
disaster situation exists
Type People/Matenals Sound
Fire and Building People Fire Alarm
Evacuation
Hazardous Waste People Verbal Signal (or fire alarm if
available)
Storage and
14
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
Thermal Treatment Matenals 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 mam 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 vanous hazardous waste sites and area
evacuation plans are found in Appendix I p 40
F 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 familianze them with the layout descnption 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
fire/explosion/spill site by an ATK authonzed agent This will ensure the units reach the
location as quickly and efficiently as possible
III 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 Hazardous Waste Profile Data
(HWPD) There are over 1 000 chemical entnes 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 contams
Matenal Safety Data Sheet (MSDS) information as well as other information There are
approximately 100 sets of MHSI distnbuted 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
15
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
suspected of containing chemicals at concentrations above the levels normally
discharged The report should mclude 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 dnp to the floor
These dnps will be checked for dunng 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
"Dunng an emergency the Emergency Commander must take all 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 matenal 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
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
2 Response procedures to be used dunng container spills or leaks are as outlined
a Identify the matenal
I From the hazardous waste label
I From Waste Management and Environmental Services inventory records
I Through laboratory analysis
I From earner manifest or placard DOT guide number
16
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
b Protect personnel through the use of personal protective equipment specific to the
identified matenal (refer to MHSI or Material Safety Data Sheet available from
Industnal Hygiene)
c Stops the spill or leak
d Contain the matenal
' Eliminate the source
I Use Quicksorb or other approved methods
e Clean up the matenal
I Re-drum
I Wipe up use absorbent matenal excavate soil
f Dispose of the matenal (refer to Haz Com Web and Disposal Instructions for
Waste Materials GM-3 1)
g Decontaminate the site and clean the equipment
FOLLOWUP PROCEDURES
1 When the spill has been properly contained and stopped appropnate equipment
will be used to remove the spilled matenal to a disposal site
2 Spills involving very large quantities of matenal 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 matenal into a
tank truck the onginal 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
Waste Management and Environmental Services for use
3 Proper steps will be taken to repair equipment and facilities and/or remove the
cause of the 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 matenal dunng the cleanup of a 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
17
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
per Haz Com Web All items can be obtained from Stores or from a call contract
Item Stock No Use
Coveralls
Smocks
Tyvek Suit (m)
Tyvek Suit (1)
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 Purifying
Respirator
Full-face Cart
Respirator Fresh Air
Respirator No 8710
Fliter S (Gray)
Filter H (Purple)
Filter GMA (Black)
Filter GMC (Yellow)
Filter GMD (Green)
Filter (Purple/Black)
GMA-H
Fliter (Purple/
Yellow) GMC-H
Filter (Black/Ohve)
GMP
Acetone
Rumple cloth
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
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
18
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
Chemliner bag Contain solvent rags
H
Velostat bag Conductive bag to contain chemiliner
In addition the following materials are available if required
item Location Bet Description
Lumber M-90 2680/2757 Plywood Lumbers
Sawdust M-90 2680/2757 Bulk
Pipe M-90 2680/2757 All dimensions
Quicksorb (27-200002) M-3 (Stores) 2757 50 Ib Bag
Absorption Clay Landfill 2837 Bulk
Hydrated Lime (54-426006) M-3 (Stores) 2757 50 Ib Bag
Chemical Spill J T Baker
Neutralizer
Acids (General) M-53 2617 3 2 kg
Bases (General) M-53 2617/7436 1 2 kg
Flammable Solvents M-53 2617 (1 1 kg) (18 kg)
Mercury Cleanup Kits M-53 2617 0 9 kg
NG Spill and M-585 8446 5 liter bottle
Detector Kit
Bulldozer (Space/DLV) M-55/M-321 2837/2455 D-8
Front-end Loader M-55/M-321 2837/2455 1/4 and 3 yd bucket
Portable Lights and M-6 3431 2 Mercury Lamps
Generator
Sump Tank M-136 2520 3 000 gal
Portable Diaphragm Pumps M-55/M-321 2837/2455
General Trucks M-55/M-321 2837/2455 172-5 Ton
SCBA Respirators Fire Dept 2222 30 Mm Tank
Water Ops Equip M-705 2222 Sump Trucks Etc
Spill Response Truck Fire Dept 2222 Spill Response
and Rescue
DECONTAMINATION EQUIPMENT AND PROCEDURES
1 Equipment available for decontamination includes two 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
Laboratones
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
19
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
sources listed in Paragraph F
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 matenals and supplies are generally selected based
on availability Soft-bnstle 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 nnse 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 temporanly 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-bnstle brush
followed by nnsing 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
harmful substance dunng 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 matenals 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 nnse 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 matenals is done in an appropnate
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
20
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
Regulators must be maintained according to manufacturers 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 wrth contaminants such as tires and scoops Wash water generated during
the decontamination process must be contained and disposed of m a proper
manner
IV INSTALLATION RESPONSE TEAM TRAINING
Building/area personnel responding to spills of hazardous matenals 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 of the 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
awareness of the locations of cleanup matenals and equipment and the procedures for the
operation of such equipment
B SIMULATION
The Spill Contingency Plan will be simulated annually under the direction of the 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 cntique phases Re-
training and review should be completed at least annually The following is an outline of trainmg plan
elements
A SCOPE AND PURPOSE OF THE CONTINGENCY PLAN
B REVIEW OF LEGAL REQUIREMENTS
1 Authonty
2 OSHA requirements
3 State requirements
4 EPA requirements
21
ATK Launch Systems - Promontory May 2010Attachment 4 - Contmgency Plan
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
4 Evacuation
5 Suspect Items (Isolate don t touch or disturb)
I FIRE BARRICADE/CORDON AREAS
1 Function
2 Initiate/release
J EMERGENCY MEDICAL TREATMENT
1 EMT training equipment
2 First response first aid
K SECURITY OF SITE
1 Purpose
2 Authonty
3 Who authorizes access
L INVESTIGATION
1 OSHA
2 EPA
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ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
3 Local Law enforcement
4 Medical Examiner/Coroner
5 Customer
6 ATK
M PUBLIC RELEASE OF INFORMATION
1 Who authorizes
2 Importance of controlling
3 Who releases
4 Who reviews
5 Next of km
N FACT-FINDING METHODS
1 Initial interview
2 Follow-up interview
3 Recordings
4 Photo Coverage
5 Mapping damage
a Who?
b How?
c Why?
6 Personnel security checks
7 Drug and alcohol tests
8 Weather conditions
9 Product status
10 Operational status
11 Equipment records and history
12 Facility tooling modification and history
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
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ATK Launch Systems - Promontory May 201 OAttachment 4 - Conttngency Plan
1 When?
2 Who?
3 How?
4 Venfication
RESCUE EFFORTS
1 When?
2 When not to
3 How to determine
24
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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 Expenence
Located on the Haz Com Web
Knowledge of each member of the Response Team
when responding to a discharge
25
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contmgency Plan
TABLE II
EMERGENCY COORDINATOR CALL LIST
Pnmary Coordinator
Steve Winn
Alternate Coordinators
Dee Madsen
Work No
801-699-2473
435-279-6191
Tony Auger 435-279-6191
Wayne Jewkes 435-279-6191
26
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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 matenal Other situations such as contaminated equipment or
fixtures require steam cleaning and the use of a detergent Frequently the nnse 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 nnse should be tested for the contaminant and managed
appropnately
27
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
TheSplllScene • '-/t;''.
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 May 201 OAttachment 4 - Conttngency Plan
APPENDIX I
FACILITY FUNCTION TABLES SITE MAPS & EVACUATION PLANS
NORTH PLANT SITE MAP
MANUFACTURING AREA SITE MAP
TEST AREA SITE MAP
PLANT 3 SITE MAP
M-136 BURNING GROUNDS FACILITY FUNCTION TABLE
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE
M-136 SITE MAP AND EVACUATION PLAN
M-186 SITE MAP AND EVACUATION PLAN
E-501 STORAGE YARD FACILITY FUNCTION TABLE
E-501 SITE MAP AND EVACUATION PLAN
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE
M-225 SITE MAP AND EVACUATION PLAN
T-29B SATELLITE ACCUMULATION AREA FACILITY FUNCTION TABLE
T-29B SITE MAP AND EVACUATION PLAN
M-705 WASTEWATER TREATMENT FACILITY FUNCTION
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM
M-705 SITE MAP AND EVACUATION PLAN
M-47 PROPELLANT STORAGE FUNCTION TABLE
M-47 SITE MAP AND EVACUATION PLAN
M-603 PROPELLANT STORAGE FUNCTION TABLE
M-603 SITE MAP AND EVACUATION PLAN
30
31
32
33
34
34
35
36
37
38
39
40
41
42
43
43
44
45
46
47
48
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ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
NORTH PLANT SITE MAP
30
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
MANUFACTURING AREA SITE MAP
(South Plant)
31
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
vmr—
TEST AREA SITE MAP
32
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
PLANT 3 SITE MAP
33
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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
Method of
Disposal
Methyl Chloroform Store for
Methyl Ethyl Ketone off-plant
Xylene shipment
Toluene
Paint
Thinners
Oil Store for
Lab Chemicals off-plant
Photographic Fixer Solution shipment
Rags & debns
Spill Cleanup/Handling
SIX UN Drums
Quicksorb 1001b
Two shovels
One broom
One fire extinguisher
Emergency shower/eye wash
Two overpack drums
Saranex suit (level B)
34
ATK Launch Systems - Promontory May 201 OAttachment 4 - Conttngency Plan
EVACUATE AREA THEN PROCEED TO ASSEMBLY POINT
200 FEET WEST ON APPROACH ROAD
NEW
POND
TANK2 •
TANK1
BURNINQ PIT It
PIT 17
Pine
PIT 15
PIT14
N
M-136
DETONATION PITS
D D D D
NO 11 NO 10 NO 9 NO S
PITT
PITS
PITS
PIT 4
'—
PIT 3
• •
PIT1 PIT 2
PROPELLANT BED J
LEGEND
• FIRE EXTINGUISHER
M-136
AND BURNING PITS
35
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contmgency Plan
EVACUATE THEN PROCEED TO ASSEMBLY POINT
SOUTHWEST AT M-381
LEGEND
• FIRE EXTINGUISHER
HAZARDOUS WASTE TREATMENT,
STORAGE, DISPOSAL, AND FACILITIES
M-186
36
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contmgency Plan
BUILDING E-501 STORAGE YARD
FACILITY FUNCTION Hazardous Waste Storage Yard
Waste Products Into Area
Various
Other assorted matenals
that may be recycled
Method of
Disposal
Shipment
off-plant
for disposal
N/A
Spill Cleanup/Handling
Two fire extinguishers
Absorbent
Two repack drums
Electncal pump
Telephone/radio
Eyewash/shower
Safety gates
Safety flags
SIX UN 55-gal drums
(empty)
Saranex suit (level B)
37
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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 May 201 OAttachment 4 - Contingency Plan
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
HMX from M-208 M-210
AP from M-210 (fine only)
Binder premix (NG or other
nitrate etc)
PEP contaminated waste (rags
contamers etc)
Miscellaneous (motor igniters)
Method of
Disposal
Burn
Burn
Burn
Burn with
diesel
Burn with
propellant
Spill Cleanup/Handling
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 wrth 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 matenals
and/or condition
Burn wrth
respective
propellant
Burn or
detonate
depending
on matenals
and/or con-
dition
Pick up clean with method used for
respective propellant
or ingredient
Each case must be dealt wrth on an
individual basis
39
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contmgency Plan
EVACUATE AREA TO lim228A BUNKER
M-225
40
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
T-29B SATELLITE ACCUMULATION AREA
BUILDING FUNCTION Hydrazine Storage and Dilution Facility
Waste Product Method of disposal
From Building
Pure hydrazine
Hydrazine-citnc
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/Handling
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 May 201 OAttachment 4 - Contingency Plan
N
EVACUATE BUILDING, THEN PROCEED TO ASSEMBLY POINT 300 FEET NORTH OF BUILDING
[
©
T-29B
42
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
M-705 WASTEWATER TREATMENT FACILITY
BUILDING FUNCTION Removal of reactive wastes from sump water
Method of
Waste Products From Area Disposal Spill Cleanup/Handling
Lime Sludge (Heavy Metals) Shipment Two shovels
to off-One broom
plant Plastic gloves
disposal One bin
company Saranex surt (level B)
Potassium Perchlorate Burning
Classifier Decanter Solids Burning
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/Handling
Two shovels
One broom
Plastic Gloves
One Fire Extinguisher
Emergency shower/eyewash
Quicksorb 1001b
Two overpack drums
Six UN drums
Saranex surt (level B)
43
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
EVACUATE BUILDING 300 FEET, THEN PROCEED TO
ASSEMBLY POINT ON R" AVENUE NEAR M-366
M-705
44
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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
Burnmg/slurned
recovery/neutralization
Spill Cleanup Matenals
Obtain clean up matenal as needed
1 IC Propellant and Motors Burnmg/slurned
explosives/AP
recovery/neutralization
Obtain clean up material as needed
45
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
EVACUATE BUILDING THEN PROCEED
TO ASSEMBLY POINT 500 FEET SOUTH ON 6TH AVENUE
N
M-47
46
ATK Launch Systems - Promontory May 201 OAttachment 4 - Conttngency Plan
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 IC Propellant and Motors
Method of
Disposal
Burning/slurried
explosives/AP
recovery/neutralization
Burnmg/slurned
explosives/AP
recovery neutralization
Spill Cleanup Materials
Obtain clean up matenal as needed
Obtain clean up matenal as needed
47
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
EVACUATE BUILDING 500 FEET THEN PROCEED
TO ASSEMBLY POINT AT BUILDING M-e43
CALL HEADQUARTERS WITH HEADCOUNT N
TRUCK
BAY
OD
m
•
LEGEND
• FIRE EXTINGUISHER
O MANUAL ALARM
B ALARM RESET
mi EVACUATION HORN
A SYSTEM RISER
• HEAT DETECTOR
9 INSPECTORS TEST
M-603
48
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
S-633 REACTIVE HAZARDOUS WASTE STORAGE PAD
STORAGE PAD FUNCTION Storage of reactive hazardous waste propellant/propellant
contaminated materials and motors and non-waste propellant
Waste and non-waste Products
1 3C Propellant/propellant
contaminated materials
1 3C Rocket Motors
1 1C Propellant/propellant
contaminated matenals
1 IC Rocket Motors
1 3C Donor Burn Propellant
Method of
Disposal
Thermal Treatment
Thermal Treatment
Thermal Treatment
Thermal Treatment
Burn Enhancer
Spill Cleanup Materials
Obtain clean up matenal as needed
Obtain clean up matenal as needed
Obtain clean up matenal as needed
Obtain clean up matenal as needed
Obtain clean up matenal as needed
49
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
EVACUATE PAD, THEN PROCEED TO ASSEMBLY POINT AT M 381
S-633
50
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
APPENDIX II
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
51
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
BULK FLAMMABLE LIQUID STORAGE AREAS
Type of Capacity Above/Below
Location Flammable Liguid (Gallons) Ground
M-4 Butanol 40 Above
Ethanol 60 Above
Isopropanol 530 Above
Methanol 500 Above
Methyl Ethyl Ketone 400 Above
Paint 500 Above
Paint Thinner 120 Above
M-53 Acetone 60 Above
Ethanol 10 Above
Heptane 10 Above
Methanol 50 Above
Methyl Ethyl Ketone 60 Above
M-55 Gasoline 17 000 Below
M-66 Assorted 80 Above
1-10 Methanol 15 Above
Methyl Ethyl Ketone 50 Above
M-585 Acetone 50 Above
Ethyl Acetate 15 Above
Methanol 10 Above
Toluene 30 Above
M-711 Gasoline 10 000 Below
E-510 Ethanol 100 Above
Isopropanol 1 660 Above
Methanol 35 Above
E-512 Acetone 100 Above
Isopropanol 50 Above
Paint Thinner 50 Above
Polyester Resin 160 Above
Toluene 50 Above
Xylene 160 Above
E-517 Isopropanol 170 Above
Kerosene 50 Above
Methyl Ethyl Ketone 450
T-29B Hydrazine 100 Above
52
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
B PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE
Building
Number Location
1-10 Shed west of building
M-4 Building north of M-3
system
M-8 Two sheds west of
building
M-43B Shed south of building
M-53A Shed south of building
M-66 Shed southwest of
building
M-504 Shed south of building
M-585 Shed east of building
M-605 Waste dock north of
building
E-512 Shed west of building
E-517 Shed north of building
Direction of Flow*
Has self-containment concrete berm
Liquid would run west across asphart into dram
Spill would dram 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 dram into ditch
Spill would dram into ditch
Spill would drain into ditch
Spill would dram into ditch
All other storage areas have self-containment
Fire flows and/or spilled matenal from these buildings will flow into a gated spill
containment structure below M-2 The gates are hand operated
53
ATK Launch Systems - Promontory May 201 OAttachment 4 - Contingency Plan
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
durmg normal busmess 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
mformation 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
SherifPs 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 of Environmental 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 of the 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
Bngham City Community Hospital
Box Elder County Sheriffs Department
Utah Highway Patrol
Box Elder County Fire Department
Tremonton Fire Department
The most recent copy of the Contingency Plan will be sent to each of these agencies in order to
familiarize them with the layout, description of hazardous 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
54
ATK Launch Systems Inc - Promontory May 2010
Attachment 5 - Closure Plan UTD009081357
CLOSURE PLAN AND FINANCIAL REQUIREMENTS
This Closure Plan describes the steps that will be taken to close the hazardous waste
management imits (HWMUs) at the ATK Launch Systems Inc - Promontory (ATK) facility
Estimates of the closure costs associated with these steps are also detailed in this Plan HWMUs
mcluded in this document are M-186, M-705S, E-501, M-136, M-225, T-29B, M-47, M-603
and S-633
The Closure Plan was developed to comply with R315-8-7 and R315-8-9 9 of the 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 HWMUs in current operation are being managed in a maimer that facilitates clean closure
Historical sites, such as the LTTAs do require post closure care, and are covered in owe Post
Closure Permit
1 0 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 of the steps needed to close storage and treatment facilities, as
identified above, at the end of their operating life Copies of this plan will be maintained at the
Promontory Facility The closure plans will be followed as written, imless modification to the
original plans have been submitted and approved by the Utah Department of Environmental
Quality, Division of Solid and Hazardous Waste (DSHW) 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
environment These goals will be achieved by one of the 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 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 assiuned that all of the 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)( 1) All closures will
assess real and reasonably likely impacts to human and ecological exposures
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Preliminary remediation goals can be established prior to implementing any of the closure plans
Screening levels published by USEPA or site-specific risk based levels based on UAC R315-
101-5 2 may be used
If contammation from hazardous waste or constituents is discovered at a HWMU above risk
based goals, further investigation will be performed to determine the extent of the contamination
Based on the results of this investigation, a Corrective Measure Study (CMS) may be prepared
for review and approval by the DEQ, prior to implementation
If investigation suggests that clean closure is not a practicable approach, a Site Management Plan
will be prepared 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-315-8-7]
This plan is designed to accommodate both partial and final closure The plan includes separate
steps to close storage, consolidation & disassembly areas, and open burning/open detonation
areas Details for closing permitted facilities are provided in Tables 1 through 8
Soil monitoring has been conducted at the M-136 and M-225 bum grounds since 1991 Semi-
annual groimdwater monitoring is also conducted, in accordance with ATK's Post-Closure
Permit
1 3 Maximum Waste Inventory and Disposal Method [40 CFR 264 112(b)(3) and UAC
R315-8-7]
The maximum inventory of hazardous waste onsite at any one time durmg the life of the
facilities IS based on permit limitations for inert facilities, and Quantity/Distance(QD) limitations
for live materials, based on Department of Defense Explosive Safety Standard 4145 26M or a
lesser designated amount If storage capacities change, the Permit will be modified These
quantity limitations are listed below
M-186 (inert) 400 ea 55 gallon drum equivalent
M-705S (inert) 32 ea 55 gallon drum equivalent
E-501 (inert) 160 ea 55 gallon drum equivalent
M-136 (live) 106,500 lbs 1 3 / 20,000 lbs 1 1
M-225 (live) 55,000 lbs 1 3 / 1,500 lbs 1 1
T-29B (inert) 1 ea 55 gallon drum (pure) equivalent
M-47 (live) 300,000 lbs 1 3 / 21,000 lbs 1 1
M-603 (live) 240,000 lbs 1 3 / 65,000 lbs 1 1
S-633 (live) 75,000 lbs 1 3/20,000 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 under interim status Wastewater is
ATK Launch Systems Inc - Promontory May 2010
Attachment 5 - Closure Plan UTD009081357
collected and treated on site and discharged through one of two UPDES permitted treatment
facilities All other hazardous wastes are transported by 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]
Section 1 4 1 of this plan provides an estimated closure schedule for all activities associated with
implementation of this 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 vsathm 30 days following shipment of the final volume of
hazardous waste If more time is required, a request will be submitted to the Executive
Secretary All hazardous wastes will be removed or treated within 90 days of (1) plan approval,
or (2) after receiving the final volume of hazardous waste, whichever is later Final closure
activities will be completed wathin 180 days of (1) plan approval, or (2) after receiving the final
volume of hazardous waste, whichever is later
14 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]
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, regular maintenance, and prompt clean up of any spilled materials
These practices should greatly reduce the need for significant remediation efforts upon closure
15 1 Soil and Groundwater Sampling
Groundwater sampling is not covered under this plan A groundwater monitoring program is
currently in place as discussed above Soil sampling should not be required for any of the
permitted facilities, except for the two bum groimd areas (M-136 and M-225) and S-633
Soil samples will be collected within the top 12" of the surface Samples will first be collected at
locations most likely to have been affected by waste management practices - as approved by
DSHW persormel Twenty soil samples will be collected at M-136, twelve soil samples will be
collected at M-225 and eight soil samples will be collected at S-633 These samples will be sent
to a State of Utah certified laboratory for analysis Sample collection, preservation and handlmg
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UTD009081357
methods will follow those outlined in the Waste Analysis Plan of this permit, and will be in
compliance with all applicable SW-846 methods All samples will be processed and analyzed by
a Utah Certified Laboratory in accordance with R444-14-3(2)UAC Analytical and extraction
methods to be used are shown below
Analytical and Extraction Methods
Parameter Analytical procedure Extraction Procedure
Volatiles SW-846, 8260B SW-846, 5030B(W), 5035S
Semi-Volatiles SW-846, 8270C SW-846, 3510C(W), 3550(S)
RCRA Metals SW-846, 601 OB SW-846, 3005A(W),7471A(S)
Mercury SW-846, 7470A/7471A SW-846,7470A(W), 7471A(S)
Explosives SW-846,8330 Modified SW-846, 8330 Modified
Perchlorate EPA 314 0 EPA 314 0
15 11 Samplmg 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 used to clean all sampling equipment that could come in contact
with soil samples
15 12 Sampling Waste Management
All waste generated from field sampling and decontamination operations will be managed in
accordance with the current UAC R315 mles Water used in the decontamination process will be
sent to the M-705 wastewater treatment plant onsite, and discharged in accordance with UPDES
permit requirements Soils will be stored in UN containers pending lab results Any soil
determined to be hazardous waste will be managed appropriately
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, test methods and
constituents for which to analyze
15 13 Health and Safety Procedures
Soil and water sampling will be performed by trained and qualified personnel A determination
of appropriate personal protective equipment (PPE) to be used 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 consultation with Industrial Hygiene professionals
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Attachment 5 - Closure Plan UTD009081357
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 durmg removal of waste and
during decontamination of contamment areas for the permitted storage and treatment units
15 2 Determinmg Cleanup Goals
For the purposes of estimating closure costs, it is assumed that all of the 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 reasonably anticipated potential impacts to human and ecological exposures It is
anticipated that the HWMUs will be clean closed and will not require post-closure care
15 3 Site Cleanup
15 3 1 Inventory Removal [40 CFR 264 112(b)(3) and UAC R315-8-7]
The maximum mventory of hazardous 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 of this
Closure Plan
Transportation and disposal costs of all hazardous waste during closure of a facility will be based
on hiring a third party The transportation contractor will be licensed and insured, and the
disposal facility will be a permitted facility Reactive hazardous wastes may be open bumed 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 burmng facilities use bum trays, pipes, concrete vaults or rocket cases to contain the
waste to be treated Most of the 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
denved waste, and the ash collected for offsite disposal Therefore, except for the derived trays,
all ash in trays, vaults, cases, and on the ground around these units will be collected and disposed
on-site The bum trays will then be high pressure water washed and the rinsate collected for
disposal After the final rinse, a composite sample from the trays will be collected and analyzed
at a Utah certified lab to verify proper tray decontamination Each sample will include rinsate
from 5 trays Samples will be extracted and analyzed as described in 1 5 1
All facilities except for M-136, M-225 and S-633 are designed with secondary contairmient The
secondary containment includes a concrete pad with curbing and blind sump to simplify
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Attachment 5 - Closure Plan UTD009081357
cleaning The containment pads and sumps are coated with a chemical resistant epoxy to prevent
liquid migration through the concrete Secondary containments are mspected daily, when in use,
and maintained as needed After removal of all containerized waste, the containment pads will
be high pressure water washed, and the rinsate will be collected for disposal After the final
wash, rinse water samples will be collected from each sump and characterized for disposal
Samples will be sent to a State certified 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)]
Non-reactive hazardous waste requiring off-site disposal will be placed in a UN 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 of completion of closure of each facility, ATK will submit a certification to the
DSHW by registered mail, that the hazardous waste management facility was closed in
comphance 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
3 0 Closure Cost Estimate [40 CFR 264 142]
Closure costs are summarized in Table 11 A detailed breakdown of these costs is provided in
Tables 1 through 8 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 m 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't be clean closed, contaminants may be left in place, and a
post closure or site management plan will be developed 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 Plan may be modified to provide post closure care
for the sites that are not clean closed
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UTD009081357
Table 1
M-136 Closure Cost Estimate*
Item No Description Means No /Source Units Est Quan Unrt Price Total Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 20 83 44 1 669
2 Site prep (technician) 33-22-0112x2 hr 40 50 96 2 038
3 Treat remaining waste ATK Ib 106 500 0 25 26 625
4 Excavate contaminated soil 17-03-0231 hr 20 105 63 2 113
5 Load soil and burned waste 17-03-0222 hr 8 68 13 545
Haul waste and soil to Clean
6 Harbors 33-19-0221 truck-mi 1 050 2 50 2 625
7 Landfill disposal waste and soil 33-19-7214 ton 50 169 45 8 473
8 State disposal fee waste and soil Utah DEQ ton 50 32 50 1 625
9 Steam clean burn pans 33-17-0812 sf 1 000 0 39 390
10 Load rinsate 33-19-0103 drum 5 4 87 24
11 Haul rinsate to Clean Harbors^ 33-19-0243 truck-mi 350 2 26 791
12 Landfill disposal rinsate^ 33-19-7214 drum 5 145 00 725
13 State disposal fee nnsate^ Utah DEQ ton 1 28 00 28
14 Demolish pans 17-02-0105 cf 2 000 0 14 280
15 Load pan debns 17-03-0222 hr 4 68 13 273
16 Haul pan debns to Clean Harbors 33-19-0221 truck-mi 350 2 50 875
17 Landfill disposal pan debns 33-19-7263 ton 50 169 45 8 473
18 State disposal fee pan debns Utah DEQ ton 50 32 50 1 625
19 Sample collection Site crew hr 40 65 00 2 600
20 Sample analyses metals Chemtech-Ford ea 20 210 00 4 200
21 Sample analyses explosives Chemtech-Ford ea 20 210 00 4 200
22 Sample analyses volatiles Chemtech-Ford ea 20 250 00 5 000
SUBTOTAL 75 196
INFLATION ADJUSTMENT=1 204^ 90 536
Misc costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 4 527
Engineenng/permitting 10 % 9 054
DSHW oversight 10 % 9 054
Contingency 10 % 9 054
TOTAL ESTIMATED COST 122 225
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Table 2
M-225 Closure Cost Estimate'
Means
Item No Descnption No /Source Units Est Quan Unrt Pnce Total Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 8 83 44 668
2 Site prep (technician) 33-22-0112x2 hr 20 50 96 1 019
3 Treat remaining waste ATK Ib 55 000 025 13 750
4 Excavate contaminated soil 17-03-0231 hr 12 105 63 1 268
5 Load soil and burned waste 17-03-0222 hr 4 68 13 273
6 Haul waste and soil to Clean Harbors 33-19 0221 truck-mi 350 2 50 875
7 Landfill disposal waste and soil 33-19-7214 ton 25 169 45 4 236
8 State disposal fee waste and soil Utah DEQ ton 25 32 50 813
9 Steam clean burn pans 33-17-0812 sf 400 0 39 156
10 Load nnsate 33-19-0103 drum 3 4 87 15
11 Haul nnsate to Clean Harbors^ 33-19-0243 truck-mi 350 2 26 791
12 Landfill disposal nnsate^ 33-19-7214 drum 3 145 00 435
13 State disposal fee nnsate^ Utah DEQ ton 1 28 00 28
14 Demolish pans 17-02-0105 cf 800 0 14 112
15 Load pan debns 17-03-0222 hr 4 68 13 273
16 Haul pan debns to Clean Harbors 33-19-0221 truck-mi 350 2 50 875
17 Landfill disposal pan debns 33-19-7263 ton 20 169 45 3 389
18 State disposal fee pan debns Utah DEQ ton 20 32 50 650
19 Sample collection Site crew hr 20 65 00 1 300
20 Sample analyses metals Chemtech-Ford ea 5 210 00 1 050
21 Sample analyses explosives Chemtech-Ford ea 5 210 00 1 050
22 Sample analyses volatiles Chemtech-Ford ea 5 250 00 1 250
SUBTOTAL 34 274
INFLATION ADJUSTMENT = 1 204^ 41 266
Misc costs as a percent of the inflation-adjusted
Subtotal
Mob/demob 5 % 2 063
Engineenng/permitting 10 % 4 127
DSHW oversight 10 % 4 127
Contingencv 10 % 4 127
TOTAL ESTIMATED COST 55 710
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UTD009081357
Table 3
M-47 Closure Cost Estimate'
Item Means Est Total
No Descnption No /Source Units Quan Unrt Pnce Pnce
1 Matenals prep (CIH) 33-22-0111 x 2 hr 12 83 44 1 001
2 Materials prep (technician) 33-22-0112x2 hr 20 31 58 632
3 Load waste motor (crane) Crew SIWSM hr 8 393 57 3 149
4 Haul motor to burning ground Crew C0ET2 hr 16 93 31 1 493
5 Off-load motor Crew SIWSM hr 8 393 57 3 149
6 Handling evaluation/planning Site personnel hr 80 65 00 5 200
9 Motor handling Site personnel hr 40 65 00 2 600
10 Disposal at burning ground ATK Ib 300 000 0 25 75 000
11 Sweep area 33-22-0112x2 hr 8 31 58 253
12 Steam clean floor 33-17-0812 sf 5 680 0 39 2215
13 Load nnsate/sweepmgs 33-19-0103 drum 10 4 87 49
14 Load drums 33-19-0103 ea 10 3 05 31
15 Haul to Clean Harbors 33-19-0243 truck-mi 350 2 26 791
16 State disposal fee Utah DEQ ton 1 28 00 28
17 Sample collection 33-22-0112x2 hr 4 31 58 126
18 Sample analyses metals/exp Chemtech-Ford ea 2 210 00 420
SUBTOTAL 96 135
INFLATION ADJUSTMENT = 1 204^ 115 747
Misc costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 5 787
Engineenng/permitting 10 % 11 575
DSHW oversight 10 % 11 575
Contingency 10 % 11 575
TOTAL ESTIMATED COST 156 258
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Table 4
M-603 Closure Cost Estimate'
Item Means Est Total
No Descnption No /Source Units Quan Unrt Pnce Pnce
1 Matenals prep (CIH) 33-22-0111 x2 hr 8 83 44 668
2 Materials prep (technician) 33-22-0112x2 hr 12 31 58 379
3 Load waste motor (crane) Crew SIWSM hr 8 393 57 3 149
4 Haul motor to burning ground Crew C0ET2 hr 12 93 31 1 120
5 Off-load motor Crew SIWSM hr 8 393 57 3 149
6 Handling evaluation/planning Site personnel hr 40 65 00 2 600
9 Motor handling Site personnel hr 20 65 00 1 300
10 Disposal at burning ground ATK Ib 120 000 0 25 30 000
11 Sweep area 33-22-0112x2 hr 8 31 58 253
12 Steam clean floor 33-17-0812 sf 1 830 0 39 714
13 Load nnsate/sweepings 33-19-0103 drum 4 4 87 19
14 Load drums 33-19-0103 ea 4 3 05 12
15 Haul to Clean Harbors 33-19-0243 truck-mi 350 2 26 791
16 State disposal fee Utah DEQ ton 1 28 00 28
17 Sample collection 33-22-0112x2 hr 4 31 58 126
18 Sample analyses metals/exp Chemtech-Ford ea 2 210 00 420
SUBTOTAL 44 727
INFLATION ADJUSTMENT = 1 204^ 53 851
MISC costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 2 693
Engineenng/permitting 10 % 5 385
DSHW oversight 10 % 5 385
Contingency 10 % 5 385
TOTAL ESTIMATED COST 72 699
10
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May 2010
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Table 5
M-186A Closure Cost Estimate
Item Means Est Total
No Descnption No /Source Units Quan Unrt Pnce Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 8 83 44 668
2 Site prep (technician) 33-22-0112x2 hr 24 31 58 758
3 Load drums 33-19-0103 ea 400 3 05 1 220
4 Haul drums to Clean Harbors 33-19-0243 truck-mi 1 750 2 26 3 955
5 Landfill disposal 33-19-7214 drum 400 145 00 58 000
6 State disposal fee Utah DEQ ton 100 28 00 2 800
7 Truck washout/decon 33-19-0311 ea 1 158 00 158
8 Steam clean floor 33-17-0812 sf 1 930 0 39 753
9 Rinsate sample collection Site crew hr 4 65 00 260
10 Sample analyses metals Chemtech-Ford ea 1 210 00 210
11 Sample analyses explosives Chemtech-Ford ea 1 210 00 210
SUBTOTAL 68 991
INFLATION ADJUSTMENT = 1 204^ 83 065
Misc costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 4 153
Engineenng/permitting 10 % 8 307
DSHW oversight 10 % 8 307
Contingency 10 % 8 307
TOTAL ESTIMATED COST 112 138
11
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Table 6
M-705S Closure Cost Estimate'
Item Means Est Total
No Descnption No /Source Unrts Quan Unrt Pnce Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 4 83 44 334
2 Site prep (technician) 33-22-0112x2 hr 8 31 58 253
3 Load drums 33-19-0103 ea 32 3 05 98
4 Haul drums to Clean Harbors 33-19-0243 truck-mi 350 2 26 791
5 Landfill disposal 33-19-7214 drum 32 145 00 4 640
6 State disposal fee Utah DEQ ton 8 28 00 224
7 Truck washout/decon 33-19-0311 ea 1 158 00 158
8 Steam clean floor 33-17-0812 sf 1 850 0 39 722
9 Rinsate sample collection Site crew hr 4 65 00 260
10 Sample analyses metals Chemtech-Ford ea 1 210 00 210
11 Sample analyses explosives Chemtech-Ford ea 1 210 00 210
SUBTOTAL 7 899
INFLATION ADJUSTMENT = 1 204^ 9510
Misc costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 475
Engineenng/permitting 10 % 951
DSHW oversight 10 % 951
Contingency 10 % 951
TOTAL ESTIMATED COST 12 838
12
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Table 7
E-501 Closure Cost Estimate'
Item Means Est Total
No Description No /Source Units Quan Unrt Pnce Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 4 83 44 334
2 Site prep (technician) 33-22-0112x2 hr 8 31 58 253
3 Load drums 33-19-0103 ea 160 3 05 488
4 Haul drums to Clean Harbors 33-19-0243 truck-mi 700 2 26 1 582
5 Landfill disposal 33-19-7214 drum 160 145 00 23 200
6 State disposal fee Utah DEQ ton 40 28 00 1 120
7 Truck washout/decon 33-19-0311 ea 1 158 00 158
8 Steam clean pad 33-17-0812 sf 1 760 0 39 686
9 Rinsate sample collection Site crew hr 4 65 00 260
10 Sample analyses metals Chemtech-Ford ea 1 210 00 210
11 Sample analyses explosives Chemtech-Ford ea 1 210 00 210
SUBTOTAL 28 501
INFLATION ADJUSTMENT = 1 204^ 34 315
MISC costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 1 716
Engineenng/permitting 10 % 3 431
DSHW oversight 10 % 3 431
Contmgency 10 % 3 431
TOTAL ESTIMATED COST 46 325
13
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May 2010
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Table 8
T-29B Closure Cost Estimate'
Item Means Est Total
No Descnption No /Source Unrts Quan Unrt Pnce Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 4 83 44 334
2 Site prep (technician) 33-22-0112x2 hr 8 31 58 253
3 Extra drum for dilution 33-19-0402 ea 1 80 00 80
4 Transfer and dilute hydrazine Site crew hr 4 65 00 260
5 Load drums 33-19-0103 ea 2 3 05 6
6 Haul drums to Clean Harbors 33-19-0243 truck-mi 350 2 26 791
7 Landfill disposal 33-19-7214 drum 2 145 00 290
8 State disposal fee Utah DEQ ton 1 28 00 28
9 Truck washout/decon 33-19-0311 ea 1 158 00 158
10 Steam clean floor 33-17-0812 sf 200 0 39 78
11 Rinsate sample collection Site crew hr 4 65 00 260
12 Sample analyses metals Chemtech-Ford ea 1 210 00 210
13 Sample analyses explosives Chemtech-Ford ea 1 210 00 210
SUBTOTAL 2 958
INFLATION ADJUSTMENT = 1 204^ 3 561
MISC costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 178
Engineenng/permitting 10 % 356
DSHW oversight 10 % 356
Contingency 10 % 356
TOTAL ESTIMATED COST 4 807
14
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Attachment 5 - Closure Plan
May 2010
UTD009081357
Table 9
S-633 Closure Cost Estimate'
Item Means Est Total
No Descnption No /Source Units Quan Unrt Price Pnce
1 Site prep (CIH) 33-22-0111 x2 hr 4 83 44 334
2 Site prep (technician) 33-22-0112x2 hr 8 50 96 253
3 Disposal at Burning Ground ATK hr 75 000 0 25 18 750
4 Sample Collection Site crew Ib 8 65 00 520
5 Sample analyses metals Chemtech-Ford ea 5 210 00 1 050
6 Sample analyses explosives Chemtech-Ford ea 5 210 00 1 050
7 Sample analyses volatiles Chemtech-Ford ea 5 210 00 1 250
SUBTOTAL 23 207
INFLATION ADJUSTMENT = 1 204^ 27 941
MISC costs as a percent of the inflation-adjusted subtotal
Mob/demob 5 % 1 397
Engineenng/permitting 10 % 2 794
DSHW oversight 10 % 2 794
Contingency 10 % 2 794
TOTAL ESTIMATED COST 37 720
Closure Cost Estimate Footnotes
' All cost estimates were provided by EarthFax Engineering, Inc , using Means 2005
Remediation Cost Data adjusted for inflation except as otherwise noted Cost estimates assume
usmg Level C PPE
Subtotals multiplied by an inflation adjustment (1 204) based on July 2005 cost index of 151 6
from Means 2009 Heavv Constmction Cost Data and July 2009 cost index of 182 5 from the
Means web site
Closure cost estimates are based on rinsate from M-136 and M-225 being shipped off-site for
disposal Rinsate from the other HWMUs will be treated on-site and discharged in accordance
with the UPDES permit
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Attachment 5 - Closure Plan
May 2010
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Table 10
Summary of Closure Cost Estimates
Hazardous Waste Management Unit Estimated Cost ($)
M-136 122,225
M-225 55,710
M-47 156,258
M-603 72,699
M-186 112,138
M705S 12,838
E-501 46,325
T29B 4,807
S-633 37,720
Total 620,720
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II 0 PROCESS INFORMATION
All reactive waste management operations at the facility are conducted and are under
the management of ATK The reactive waste management process is described in
the following text
III Facihty Description
The ATK Promontory facility is located in a remote area of west Box Elder County,
Utah, approximately 30 miles northwest of Brigham City, and approximately 11 miles
north of the Great Salt Lake The facility was purchased by Thiokol in 1956, with the
exception of a 1,500-acre tract that was sold to the U S Air Force in 1958 and then
repurchased in 1995 The facility has been held in its entirety since purchase
ATK Launch Systems conducts thermal treatment of reactive hazardous wastes at two
treatment units (1) the main facility, M-136, located centrally to the two mam
manufacturing sites, and (2) M-225 located in a remote development location called
Plant III
M-136 IS the pnmary treatment area for conducting open buming at the Promontory
facility Open detonation is also conducted at M-136 which is a secured fenced facility
within the main facility fence
The M-225 treatment area receives small amounts of the reactive hazardous waste
materials from the Plant III propellant development area The M-225 treatment unit is
surrounded with an 8-foot high chain link fence The waste matenals are treated via
open buming or open detonation
The M-136 and M-225 treatment areas are fenced and are located withm a controlled and
fenced facility that is patrolled and mamtamed by a secunty department The treatment
areas have wammg signs posted around the peruneter The vegetation is controlled within
the treatment areas through application of herbicide and puttmg m place loads of gravel
and road base Surroundmg both treatment areas are a large system of fu-e breaks that are
constmcted usmg large equipment to till and cultivate a large strip of land removmg any
vegetation The system of fire breaks are designed to contain a fire within its boundaries
Contamed withm the boimdaries of the M-136 treatment area are twelve former surface
impoundments called Liquid Thermal Treatment Areas (LTTAs) These impoundments
were used for the disposal of hazardous waste and wastewater and then capped and closed
The units are currently under post closure care and managed through a Post Closure Permit
which includes requirements for groimdwater monitormg and corrective action The Post-
Closure groundwater monitormg program mcludes all wells around the M-136 and M-225
treatment areas as part of the groundwater monitormg system These wells are routmely
monitored thorough the permit requirements which mcludes the Samplmg and Analysis
and Quality Assurance Plans
The Promontory facility is located in the Blue Spring Valley which is bounded on the
east by the Blue Spring Hills and on the west by Engineer Mountain and the
Promontory Mountain ranges Within the Blue Spring Valley, the terrain is
characterized by topography that slopes down from the mountain crest at an elevation
of approximately 6,050 feet above mean sea level (AMSL) toward the center of the
Blue Creek Valley at an elevation of 4,250 feet AMSL As a result, the surrounding
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environment extending out to 6 2 miles (10 kilometers) from both treatment units can
be characterized as complex terrain
GEOLOGY
The ATK facility is located in the Southem Blue Creek Valley, northwest of the Salt
Lake Valley, which is the eastem most structural valley of the Basin and Range
physiographic province, which includes parts of Utah, Idaho, Nevada, Arizona, and New
Mexico The Basm and Range province consists of a number of north-south aligned
mountain ranges and valleys bounded by high-angle normal faults The Blue Creek
Valley, m which ATK is located, is bounded on the east and west by the Blue Springs
Hills and the Engineer and Promontory Mountain ranges, respectively Movement along
the faults has displaced the mountains upward relative to the adjacent valley Likewise,
the mountains immediately west of ATK are bounded on their eastem margin by one or
more fauhs which are partly buried by recent deposits
Bedrock, composed of Middle Paleozoic shale, sandstone, and limestone, is exposed in
the ranges adjacent to the site The bedrock is highly fractured with some folding
During the Mississippian and Permian Periods, marine sediments consisting of sand, clay,
and calcareous detritus were deposited in shallow marine environments In the late
Cretaceous Period, compressional forces from the west resulted in folding and thrast
faulting in conjunction with uplift of the region into mountain ranges Extensive jointing
and fracturing of the bedrock were caused by this folding and faulting episode Tensional
stresses in the early to middle Tertiary Period resulted in north south trending normal
faults that formed a series of high linear mountain ranges with intervening basins which
received sediment from adjacent highlands This activity was associated with volcanism
and ancient lake deposition
In the late Tertiary Period, a series of geologic units tentatively identified as the Salt Lake
Group were formed from deposition of sediments in large lakes which developed within
the valleys These lake deposits are composed primarily of silts and clays with minor
amounts of sand and gravel and are characterized by low to moderate permeabilities,
extensive deposits of volcanic ash are also present in the Salt Lake Group The alluvial
fan deposits were overlapped by more recent lake sediments of Pleistocene Lake
Bonneville, the predecessor to the present Great Salt Lake Lake Bonneville covered
much of westem Utah and parts of Idaho and Nevada between about 23,000 and 12,000
years ago Deposits associated with the lake consist of lakebed and alluvial materials
reworked by lake bottom and shoreline processes Lake Bonneville sediments thicken
southward
The most recent sedimentary deposits consist of stream alluvium and mud and debris
flows The stream alluvium consists primarily of silty and clayey sand and gravel The
mud and debris flow deposits are characterized by a broad gradation of sediments from
clay-size fines to boulders as large as 3 feet in diameter
HYDROGEOLOGY
Ground water in Blue Creek Valley occurs under unconfined and confined conditions
These two conditions exist in fractured and faulted bedrock, lake clays and gravels,
unconsolidated alluvium, gravel, and sandy deposits Precipitation, surface water
infiltration, and plant discharges that infiltrate into sediments may migrate slowly,
vertically, and horizontally to form perched water tables above the 50- 150-foot depth of
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the regional water zone The perched ground water may eventually migrate to the deeper
regional system The regional system ranges from 50- 600 feet in depth depending on the
topographical location Blue Creek may recharge shallow aquifers in the center of the
Blue Creek Valley The direction of movement within the faulted and fractured bedrock
will be controlled by the connection of faults and fractures Regionally, the ground water
flow trend is from north to south Depth to groundwater at the M-136 treatment units is
an average 300 feet Depth to groundwater at the M-225 treatment unit is 600 feet
The ground water quality in Blue Creek Valley is generally poor due to naturally
occurring chlorides and total dissolved solids Levels of dissolved solids range from 400
to over 12,000 mg/1 Quality of ground water depends upon the sediments, which it has
contacted Quality is quite good in local, up gradient areas of water recharge, but
degrades rapidly as it moves from mountain to the valley axis High levels of total
dissolved solids m lowland areas are probably due to slow migration through Tertiary
sediments Down gradient from the ATK sites, quality deteriorates rapidly as it enters the
mudflats of the Great Salt Lake
CLIMATE
ATK has a 10-meter meteorological tower and instraments to measure and record air
temperature, barometric pressure, relative humidity, solar radiation, precipitation, vertical
and horizontal wind speed, and direction
The ATK plant site is classified as semiand, with an average annual total precipitation of
14 88 inches at the ATK meteorology station During the winter months, the average total
snowfall amounts to 24 inches Precipitation typically occurs on 95 days out of the year
(includes trace precipitation) During the year, it would be expected that 35 percent of the
days would be clear, 30 percent of the days would be partly cloudy, 34 percent would be
cloudy, and fog would be expected to occur about 1 percent of the time According to
interpreted weather data for the ATK facility, the 25-year storm with 24-hour duration
would result in 2 4 inches of precipitation
Evaporation rates are high throughout the year, with the Great Salt Lake averaging 66 in
a year The average area evapotranspiration rate is 46 6 inches The consistently low
precipitation and high evaporation allow little if any percolation into subsurface soils
The average annual temperature in the ATK Promontory area is in the 45 to 50 degree
range, with generally hot, dry summers Relative humidity averages between 20 and 30
percent during summer afternoons Nights are usually cool, but daytime maximums
occasionally exceed 100 degrees F On clear nights, cold air usually drains from the
slopes of the adjacent ranges and accumulates on the valley floor, while the foothills and
bench areas, such as at Thiokol, remain relatively warm The average daily temperature
ranges from about 11 to 32 degrees F in January and from about 54 to 91 degrees F in
July
On an annual basis, the winds for the valley tend to prevail from the north during the
earlier moming hours and south to southeast, averaging about 10 mph, during the
afternoon
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Blue Creek is the only perennial stream in the valley drainage basin and is the closest
water body to the M-136 treatment unit Blue Creek originates some 15 miles north of
the Promontory facility from a warm saline spring, which flows along the westem
boundary of the facility
The Promontory area is characterized as a very sparsely populated rural region, with
primarily dry farms and ranching activities Low growing perennial grasses and shrubs
characterize the vegetation in the area The ecological habitat found at the Promontory
facility includes many head of mule deer and large populations of vanous birds, rabbit,
and predator species
11 2 WASTE CHARACTERIZATION
Wastes will be characterized to identify hazardous properties to ensure they are
properly managed The Waste Analysis Plan (see Attachment 1) will be used to
characterize and classify reactive wastes
11 3 REACTIVE WASTE DESCRIPTION
The primary products produced at the facility include solid rocket motors, military and
aviation flares, and high explosive/high energy compounds Solid rocket motors are
typically cast with composite propellants Composite propellants are classified as a
DOT 1 3 material, and typically contain a non-explosive liquid binder mixed with
aluminum powder and ammonium perchlorate Flares are generally classified as a
DOT 1 3 material, and typically contain an inert binder, a metal powder, and an
oxidizer High explosive compounds are generally classified as DOT 1 1 material and
are generally nitramine compounds developed for specific military requirements
Reactive wastes are produced from the manufacturing process include, but are not
limited to the following cured and uncured propellants, rocket motors, small initiating
devices, explosives articles, propellant scrap, and explosive ingredients such as HMX,
RDX, CL-20, explosive contaminated metal powders such as aluminum and
magnesium and oxidizers such as ammonium perchlorate and potassium perchlorate
The facility also contams both quality assurance and research and development
laboratories The quality assurance laboratories generate wastes similar to
manufacturing wastes The Research and Development laboratones generate a small
quantity, but a wide variety of both explosive compounds and precursors to explosive
compounds
Reactive wastes are characteristic hazardous wastes for reactivity (D003) Nearly all of
the reactive wastes are reactive due to the presence of propellants and explosives
Some reactive wastes, such as those from laboratory operations, may contain solvents
which would also be a listed waste defined by R315-2 of the UAC Wastewater
treatment sludge generated from the processing of explosives is a K044 listed
hazardous waste Reactive wastes also include materials such as rags, gloves, other
personal protective equipment, plastics, rubber and paper contaminated with explosive
materials during the manufacturing process
Reactive wastes may also be received from off-site sources With one exception, off-
site wastes are rocket motors, propellants or explosives with similar formulations and
ingredients to those generated on site The exception is wastes received from Autoliv
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ASP Inc which are generally DOT Class 1 3 materials containing compounds similar
in nature to flare compounds (provide additional information about Autoliv
constituents , also explain that gas generates were developed here and we continue to
do some development)
11 4 REACTIVE WASTE GENERATION AND COLLECTION
ATK uses a variety of containers to store reactive wastes at the Facility The standard
containers used at the Facility are described in this section However, due to the nature
of our business, new types of containers may be required in the future, and can't be
described in this application To ensure that all containers are safe to use, containers
will be selected using the DOD Contractor's Safety Manual for Ammunition and
Explosives (DOD 4145 26-M) All containers for reactive waste that are currently
used, or will be used in the future will meet the DOD 4145 26-M requirements
Operating buildings generating reactive wastes use a variety of collection containers as
described below
• Conductive Containers -Electncally conductive containers are typically bags
made of opaque, volume-conductive carbon-impregnated polyolefin or
polypropylene They can be grounded to prevent he build up of static electricity
The bags are available in a variety of sizes from small containers to large than one
cubic yard They are typically used to line other containers, but can be used
without an outside container Typical conductive containers include Velostat®
bags, Velostat® sheet material, and conductive sling bag and Super Sack®
containers
• Static Dissipative Contamers -Static dissipative containers are typically bags
made of a polyethylene material The material prevents the build-up of static
electricity by continually dissipating the charge These bags are typically used to
line other containers, but may be used without an outside container Typical static
dissipative containers include pink poly bags, pink poly sheet material and static
dissipative Cromhmiq™ sack containers
Fiberboard drums - Wastes may be collected directly into commercially available
30-gallon fiberboard drams These drums have a removable hd that can be sealed
in place with a locking chime after the drum is filled Fiberboard drams selected
for this application are approved by DOT for highway transportation of hazardous
matenals and can be used to ship these wastes off-site for treatment and disposal
Sumps- Explosive contaminated wastewater is collected in sumps at the point of
generation When appropriate, propellant "chips" and other suspended solids are
filtered out before the wastewater reaches the tank, and when the wastewater is
pumped out of the tanks The wastewater is pumped into tanker tracks where it is
treated at M-705 and discharged under a UPDES permit Filters containing "chips
and other suspended solids are accumulated , and treated and disposed of in
accordance with the applicable hazardous waste management rules
Other Containers - Large blocks of cured propellant are containerized by wrapping
the waste in plastic and placing it on wood pallets Ammunition cans are used to
hold initiating and ordnance items Waste rocket motors are generally large
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enough to be their own container Plastic buckets are used to hold conductive and
static dissipative bags The buckets are reused and become contaminated with
reactive material The buckets are cleaned by removing the contaminated material
using a rag The contaminated rag is then collected for disposal and managed as
directed in UAC 315-5 If a bucket cannot be cleaned, it is managed as a hazardous
waste and treated by open buming Laboratory waste may come in a variety of
sizes and types of containers such as plastic, metal or glass DOT containers for
Class 1 1 and 1 3 reactive materials may also be used A plastic cover secured to a
tray may be used as a container for unbumed residue or containers of off-site waste
stored in a tray for up to 14 days from to thermal treatment
Operating personnel accumulate reactive waste in these containers as it is generated
When a reactive waste container is full or at the end of an operating shift, it is closed
or sealed as applicable for the container A hazardous waste label is filled out and
attached to the container Operators at the buildings that generated the waste enter
pertinent information into the electronic waste tracking system described in Section
11 5
Most operating buildings that generate reactive waste have an explosive waste
collection area located approximately 50 feet from the operating building Except as
described below, waste containers are placed in the collection area to facilitate removal
of waste propellant, explosive and reactive wastes from the operating buildings The
collection sheds are constructed of wood or corrugated metal and are secured to a
concrete floor
When managing reactive wastes, ATK building operators use the temporary collection
sheds as 90-day or satellite accumulation stations Reactive wastes are placed in the
collection area either as they are generated or at the end of each operating shift Waste
containers that are not fiill at the end of a shift are sealed, a hazardous waste label is
attached to the container and they are moved to the temporary collection area
Containerized explosive wastes are picked up from the collection location using a
vehicle approved for the transport of explosive wastes Extreme care is used when
handling all explosive wastes Wastes are transported directly to either the M-136 or
M-225 burning ground Reactive wastes generated at Plant 3 are transported to M-225
All other reactive wastes are transported directly to M-136
Propellant and explosive operatmg buildings at the facility, including explosive waste
90-day storage and satellite accumulation areas, are designed and constracted in
accordance with strict federal standards These standards identify the criteria that must
be used to constract buildings where reactive material will be used and/or stored
These standards also require that explosive buildings to be separated by sufficient
distance, or a quantity-distance relationship, to prevent an explosive event in one
building from propagating to another building Quantity-distance rules also control the
location of propellant and explosive operatmg buildings with regard to public property
(highways, parks, etc,) and private property All buildings used for temporary storage
of waste explosives, including the temporary storage sheds, are correctly sited with
respect to the applicable quantity-distance rules
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11 5 QUANTITY DISTANCE DETERMINATION
The facility uses the Department of Defense (DOD) guidance to calculate quantity
distance relationships The evaluation was conducted according to NAVSEA OPS,
Volume 1, Revision 4, Paragraph 11-32 The method used to determine safe quantity
distance relationships for both Class 1 1 and I 3 propellants is provided below
The quantity distance relationship for Class 1 3 propellant is determined by the following
formula D = SW''' Where W is the weight of Class 1 3 propellant and D is the safe
distance The formula applies to Class 1 3 propellant and Class 1 3 propellant mgredients
The safe distance is defined as the mterline protection for mass fire for Class 1 3
propellant
The quantity distance relationship for Class 1 1 propellant is determmed by the
following formula D = ISW"'' Where W is the weight of a Class 1 1 explosive and D
IS the safe distance The formula applies to Class 1 1 propellant and Class 1 1 propellant
mgredients The safe distance is defined as the unbamcaded interline protection for Class
1 1 propellant
11 6 WASTE TRACKING
ATK maintains an electronic waste tracking record to collect and manage information
about reactive wastes generated at the facility This tracking system uses a
combination of paper records and an electronic database
Wastes being accumulated in containers at operating area within the facility are labeled
and managed in accordance with R315-5 of the UAC for either a satellite accumulation
or less than 90-day hazardous waste storage area The electronic tracking system
maintains the following information to monitor cradle to grave waste handling
practices
ID# - container identification number
Date - accumulation date
Building # - identifies where the waste was generated,
RWD1# - identifies the reactive waste disposal instraction
Profile # - identifies the profile
Quantity of PEP - quantity of propellant, explosive or pyrotechnic matenal,
Quantity of Contaminated waste - Explosive and total weight of the container.
Material Description - description of the material
Propellant name - describes the propellant by type, program other identifier
Log Date - date logged into the system
The electronic tracking system maintains information on all containers of reactive
waste in 90- day storage at M-136 and M-225 It also tracks the total weight of waste
placed on each bum tray, and the total weight of waste bumed on any given day
In the event reactive waste is shipped off-site for treatment, the system maintains the
following information the manifest number, transporters, manifest ship date, and
manifest retum date
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In the event the electronic tracking system is not operable, the information will be
tracked using paper copies until the electronic system is operable In the event this
occurs, ATK will transfer all information to the electronic system within 72 hours of
the system becoming operational again
117 REACTIVE WASTE STORAGE
ATK may store hazardous wastes prior to disposal Reactive wastes are stored in
designated facilities as described in this section, and are segregated according to
compatibility requirements
M-47 - This building can be used to store any of the explosive wastes listed in
Section 11 2 All containers of waste m storage will be closed except when waste is
being added to or removed from the container Adequate aisle space must be
provided to permit proper container inspection, all containers will be labeled and
managed in accordance with R315-5 of the UAC This building does not have water
immediately available, and relies on the Fire Department for any emergency action
Employees are not permitted to fight fires mside an explosive storage building This
building IS a totally enclosed, so there are no precipitation run-on or run-off concems
M-603 - This building can be used to store any of the explosive wastes listed in
Section 11 2 All containers of waste in storage will be closed except when waste is
being added to or removed from the container Adequate aisle space must be
provided to permit proper container inspection All containers will be labeled and
managed in accordance with R315-5 of the UAC This buildmg is equipped with a
fire sprinkler system, which is checked annually Employees are not permitted to
fight fires inside an explosive storage building This building is totally enclosed, so
there are no precipitation run-on or ran-off concems
M136- trays at M-136 can be used to store off-site waste for up to 14 days All
containers of waste must be closed, labeled and managed in accordance with R315-5
ofthe UAC
S-633- This storage pad can be used to store any of the explosive wastes listed in
Section 11 2 All containers of waste in storage will be closed except when waste is
being added to or removed from the container Adequate aisle space must be
provided to permit proper container inspection S-633 is approximately 100' x 100'
in size It IS secured by a perimeter fence, a vehicle access gate that can be locked,
and has the appropriate waming signs for a storage area It has a road base surface,
and has lighting protection All containers will be labeled, and managed in
accordance with R315-5 of the UAC This area does not have water immediately
available, and relies on the Fire Department for any emergency action Employees
are not permitted to fight fires inside an explosive storage building Precipitation
run-on or run-off is prevented by a combination of diversion ditches, collection
ditches and trenches
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11 8 TREATMENT OF REACTIVE WASTE
The facility utilizes thermal treatment methods to safely dispose reactive hazardous
wastes Thermal treatment methods include both open buming and open detonation
Reactive hazard wastes may also be shipped off-site and treated at other permitted
treatment storage and disposal facilities
118 1 OFF-SITE TREATMENT OF REACTIVE WASTE
All hazardous reactive wastes treated off-site will comply with all applicable local.
State and Federal regulations
118 2 ON-SITE TREATMENT
The M-136 and M-225 facilities are thermal treatment units designed to treat reactive
hazardous wastes using open buming or open detonation Treatment at M-136 is
limited to a maximum of 106,500 pounds per day Each bum station 1-12 and 14 may
treat all or a portion of the 106,500 pounds Bum station 13 can treat a maximum of
50,000 pounds per day Treatment by open detonation will be conducted at bum
stations 13 and 14 only, and is limited to 600 pounds per event Figure 11-2 shows the
security fence, control bunk, and vehicle access points for M-136
Treatment at M-225 is limited to a maximum of 4,500 pounds per day Each bum
station 1-4 may bum all or a portion of the 4,500 pound limit Treatment by open
detonation is limited to the 600 pounds per day in the M-225 open detonation area
Figure 11-2 shows the security fence and vehicle access points for M-225
The process flow for open buming at both treatment areas is identified below
1 Pre-planned Activities
2 Post-bum Inspection and Cleanup
3 Wiring and Ignition
4 Post-bum Inspection and Cleanup
The following precautions are used to ensure operator safety while working at the M-
136 and M-225 bum grounds
1 Emergency egress routes are always maintained while employees are working in
the treatment areas
2 The firing systems are disabled using an interlock to prevent accidental ignition
3 Weather conditions are monitored to assure operators are not exposed to risks from
lightning strikes
118 2 1 PRE- PLACEMENT ACTIVITIES
OBOD operations at the facility are a continuous process Wastes are transported from
the generation areas and brought into the treatment areas on a daily basis Wastes are
off-loaded and placed in trays and managed under 90-day rules until treatment occurs
When treatment is completed, the trays are cleaned, inspected and the loading process
begins again Pre-placement inspections occur during the post-burn inspection and
clean-up phase of the treatment process
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Prior to placing reactive waste for treatment at the OBOD facilities, operators visually
verify the following tasks were completed during post-bum inspection and cleanup
activity
1 Any untreated waste and/or unbumed residue has been identified, collected and is
being properly managed,
2 Storm water accumulated in the trays has been removed
3 Trays which do not meet the inspection criteria have been removed from service
118 2 2 PLACEMENT OF WASTE IN TREATMENT UNITS
Reactive hazardous waste is transported to the OBOD facilities using a vehicle which
meets explosive safety requirements Reactive hazardous waste may be offloaded by
hand or mechanical means including a knuckle boom, forklift, crane, or other
appropriate equipment Reactive hazardous waste is not collected, transported, or
unloaded during a lighting waming, which is defined as lightning within 30 miles of
the facility If collection, transportation, or unloading operation has started, the
operation is brought to a safe halt
Treatment units used to treat and contam waste are listed below but are not limited to,
the followmg
• Burn Trays - Metal trays constructed in several different sizes including, 4'X 10',
5'X16', 8'X8', and 8'X20' Typical construction is out off steel plate A36 grade
steel ranging thicknesses of 3/8", 1/2", 74", and 1 inch
• Clamshell Disposal Trays- Used for the disposal of items that have the potential
to be propulsive Typical constraction is a square welded box 1-inch thick, A36
steel plate with a vented hd that enables treatment of potentially propulsive items,
while safely containing the propulsive energy
• Restraining Trays are fypically constracted of 1 -inch thick A3 6 steel plate
welded into a square box that is filled with sand There are several different
designs for restraining trays which include (1) steel tubes sitting on end in the sand
are used to hold potentially propulsive items which are secured to the tube allowing
the exhaust to vent out of the open end of the steel tubes, and (2) used without steel
tubes where propulsive items are secured at the base for items where the exhaust
will vent from the side of the item
• Small Motor Disposal Vaults- Constructed from a concrete 10x10 foot sump
filled with sand Small rocket motors such are placed into the sand with the aft end
exposed perpendicular to the ground Motors are treated with the propulsive force
directed into the concrete sump and the sand
The vehicle is to be parked near the receiving tray with any side rails lowered to
facilitate offloading of the waste Containers are transferred directly from the tmck and
carefully placed mto the bum tray Items to be open detonated are offloaded from the
vehicle by hand, knuckle boom, or by forklift and then placed on the ground for
treatment
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Items that have the potential to be propulsive are offloaded mto the clamshell, sandbox,
or small motor disposal vault by hand, knuckle boom, or by forklift After offloading.
Items are restrained using engineered restraints allowing for safe treatment Potentially
propulsive items (e g rocket motors) may also be offloaded into station 14 using the
knuckle boom, forklift, or crane The case may be placed on the ground, sand/dirt
mounds, chocks, or other support media for treatment
PEP waste which generates ash or residue which is listed or characteristic is segregated
from PEP waste which generates non-regulated ash Ash and residue is managed as
described in 11 7 2 3
1182 3 WIRING AND IGNITION
After waste has been placed on a tray, the next step is to complete a resistance check on
the ignition system As a safety precaution, a physical interlock (e g key) is used to
prevent the firing panel from being accidently engaged during the resistance check
The key remains in under the control of the operators during the resistance check and
all subsequent operations until the operators retum to the control bunker to complete
treatment Each firing stanchion must have 10 ohms or less A firing stanchion that
has a resistance of 10 ohms or greater must be tagged out until repairs are made
Once the resistance check is completed igniter installation is performed The igniter is
attached to the firing system by connecting the lead wire from the initiating device to
the firing stanchion Igniter installation operations are performed by a minimum of two
operators The types of igniters commonly used are listed below
1 Bum Grounds Igniter -Propellant with a hot wire
2 Bag Igniters - Propellant, explosive, pyrotechnic with electric match or other
electric initiation device
3 Blasting Caps - Small amount of pnmary explosive
4 Electric Matches - wire attached to small explosive device
5 Fuse - a tube, cord, or the like, filled or saturated with combustible matter
6 EBW - Exploding Bridge Wire, a fme that contacts explosives fired by a high
voltage electricity source
7 TBI - Through Bulkhead Initiator, shock initiation of an energetic matenal
provided through an integral barrier
Linear shaped charge may also be used to facilitate thermal treatment of potentially
propulsive wastes and items contaminated with reactive hazardous wastes
Reactive hazardous wastes may be desensitized by adding one of the liquids listed
below The addition of these liquids modifies the reactive nature of the waste making it
safer to store, handle and transport It also slows the buming rate of the material during
treatment
1 Oils
2 Water
3 Alcohol
4 Tnacetin
5 Physical Media (e g Conductive and static dissipative packaging)
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When necessary, additional bum enhancers may be used to promote a more complete
burn Additives include, but are not limited to, the followmg
1 Diesel Fuel
2 Wood (eg Pallets)
3 Propellant
The buming ground operators verify the treatment area has been evacuated of all
personnel before proceeding with ignition The buming ground operators retreat to the
control bunker and close the door The lockout key is inserted into the control system
which allows power to the firing panel Circuit continuity is checked at the firing panel
which verifies that igniters were properly installed A flashing red light is activated
once the firing system is operational to alert personnel inside the area that a treatment
operation is about to begin The appropriate stanchion is chosen and the igniter fired
by pressing the ignition buttons Two operators are required for this operation
In the event of a misfire, operators must wait a minimum period before reentering the
treatment area to correct the problem If a misfire occurs on the first tray, bemg bumed
the process stops, and personnel are required to stay in the bunker for at least 30
minutes After 30 minutes, the igniter which failed in uninstalled This process
requires two employees and is done by (1) the two employees performing the task
remove the physical interlock and keep it in their possession, (2) the igniter wires are
removed from the stanchion where the misfire occurred then twisted together to short
the circuit The igniter is not physically removed from its position A new igniter is
installed, and the operators retum to the control bunker and repeat the process
If a misfire occurs and it is not the first tray in the bum sequence, the operators retum
after 16 hours and repeat the process described above
The Box Elder County Dispatch is notified prior to each treatment This notification
can be made by telephone, fax or email, and may be made immediately prior to ignition
or an undefined number of hours prior to igniting the waste Notification must be made
the same day as the waste is treated
118 2 4 POST-BURN INSPECTION AND CLEANUP
Following an open buming treatment event, the area where the bum occurred cannot be
re-entered for at least 16 hours after completion of the bum without specific approval
from ATK management A preliminary inspection is performed before the cleanup
begins This inspection includes checking for hot spots and checking for unbumed
reactive hazardous waste Hot spots include visual indications of hot material (flame,
smoke, high temperature) If these conditions exist, post-bum clean is postponed until
the hot spots are gone
All residues remaining on the bum trays are visually inspected to determine if there is
any unbumed reactive material Unbumed reactive material will be rebumed
Depending on the nature of the material that did not bum, donor material or burn
enhancers such as diesel or wood I may be used to ensure the material will completely
bum Unburned waste ejected from the tray will be collected and placed on a bum tray,
and treated in the same manner
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Small amounts of untreated residue will be considered as newly generated waste and
will be tracked as such in the tracking system Small amount is defined as less than or
equal to 5% of the total volume placed on the tray or treatment area The primary
option for managing this waste is to bum it by 6pm the following calendar day If
untreated residue cannot be treated by 6pm the following calendar day then it will be
managed in accordance with R315-5 of the UAC
Unbumed waste that results from a misfire or an interrapted ignition can remain on a
bum tray An interrapted ignition occurs when anything greater than 5% of the waste
on the tray fails to ignite In this situation, the waste is considered unreacted waste
instead of newly generated residue ATK will attempt to rebum the waste by 6 pm of
the following calendar day If unforeseen circumstances prevent the bum from
occurring by 6pm of the following day, the waste will be covered and the bum tray will
be labeled and managed as a 90-day storage area in accordance with the requirements
of R315-5 of the UAC The cumulative storage time for the waste both in storage prior
to burning and on the bum tray may not exceed 90-days If it is necessary to storage
this waste for greater than 90-days, an emergency permit would be requested
The clean process begins after the preliminary inspection is completed Cleaning is
accomplished using a variety of tools and equipment such as rakes, shovels, a forklift
and a tractor Ash is classified for disposal as descnbed in 11 8 2 5 The majority of
the waste treated is classified as EPA waste number D003 reactive only The ash
resulting from treating D003 reactive waste is collected, and transported to the on-site
landfill where it is disposed
Ash classified as hazardous is collected and managed in accordance with the
requirements of R315-5 of the UAC Ash resultmg from the treatment of K044
collected and disposed in the on-site landfill After the tray is cleaned, it is inspected
for holes, weld cracks, and 6 inches of wall height If a tray fails the inspection criteria.
It IS removed from service These inspections are maintained onsite in the operating
record In the event a tray is not going to be used for an extended period, it is stored in
a manner to prevent stormwater accumulation (e g stored upside down or with a lid) If
accumulated liquid is present in a bum tray it is removed and delivered for treatment at
a UPDES permitted facility
Typically, the post-bum and cleanup activities described in this section will be
conducted the next calendar day following treatment The only exception is when bulk
reactive waste is being treated Bulk reactive waste is defined as waste in any amount
containing no contaminated materials Bulk waste will completely bum and leave no
listed or characteristic residue
11 8 2 5 Ash Classification
A waste assessment is conducted prior to receiving waste for treatment The waste
assessment is made using generator knowledge of the production process, the raw
materials used to produce the material, and the chemical composition of the materials
If the assessment identifies that, at the point of generation, the waste meets any of the
following three criteria, all ash from the initial treatment is collected, and the ash is
sampled and analyzed using the protocol described in Attachment 1
1 It could potentially contain 40 CFR 261 31 listed constituents
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2 It could potential contain toxicity characteristic constituents above the 40 CFR
261 24 regulatory level
3 It could potentially contain underlying hazardous constituents above the 40
CFR268 48 treatment standards
Based on the analytical results, the ash is managed using the logic in Attachment 1
Figure 3-2 All ash classified as hazardous based the above criteria is managed in
accordance with the requirements of R315-5 of the UAC
11 9 RECEIVING HAZARDOUS WASTE FROM OFF-SITE
ATK periodically receives reactive hazardous waste from off-site sources All
hazardous waste received from an off-site source will be managed at one of the
permitted storage units All off-site generated hazardous waste will be reviewed and
approved prior to being accepted using the following criteria
EPA hazardous waste number(s).
Physical description.
Chemical description.
Source of the waste.
Sampling frequency.
Parameter for Analysis,
Handling code,
Tracking system number,
DOT shipping description, and
Safe handling instractions
Upon receipt, all off-site generated hazardous waste will be visually inspected to ensure
that it meets the acceptance criteria, the manifest is correct, and the containers are
labeled, closed, m good condition and compatible with the waste All deficiencies will
be resolved with the generator before the waste is received After the waste has been
accepted, it will be managed using the tracking systems described in Sections 11 4
11 10 Environmental Performance Standards
11 10 1 40 CFR 264 600 contams requirements for treatment, storage and disposal facilities to
meet environmental performance standards to ensure operations are conducted in a
manner that ensures protection of human health and the environment The follow areas
of concem have been or are in the process of being addressed to ensure compliance with
the performance standard requirements
Prevention of Releases Due to Migration of Waste Constituents in the Ground
Water or the Subsurface Environment - the standard requires actions to prevent the
releases that may have adverse effects on human health or the environment due to
migration of waste constituents in the ground water or subsurface environment Topics
that must be considered are
• The volume and physical and chemical characteristics of the waste in the unit,
including its potential for migration through soil, liners, or other containing
structures,
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The hydrologic and geologic characteristics of the unit and the surrounding area.
The existing quality of ground water, including other sources of contamination and
their cumulative impact on the ground water.
The quantity and direction of ground-water flow,
The proximity to and withdrawal rates of current and potential ground-water users.
The pattems of land use in the region.
The potential for deposition or migration of waste constituents into subsurface
physical structures, and into the root zone of food-chain crops and other vegetation.
The potential for health risks caused by human exposure to waste constituents, and
The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents.
Prevention of Releases Due to Migration of Waste Constituents in Surface Water,
Wetlands or on the Soil Surface -The standard requires actions to prevent releases
that may have adverse effects on human health or the environment due to migration of
waste constituents in surface water, or wetlands or on the soil surface Topics that must
be considered are
• The volume and physical and chemical characteristics of the waste in the unit,
• The effectiveness and reliability of containing, confining, and collecting systems
and stractures in preventing migration,
• The hydrologic characteristics of the unit and the surrounding area, including the
topography of the land around the unit,
• The pattems of precipitation in the region,
• The quantity, quality, and direction of ground-water flow,
• The proximity of the unit to surface waters,
• The cunent and potential uses of nearby surface waters and any water quality
standards established for those surface waters,
• The existing quality of surface waters and surface soils, including other sources
of contamination and their cumulative impact on surface waters and surface
soils,
• The pattems of land use m the region,
• The potential for health risks caused by human exposure to waste constituents,
and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents
Prevention of Releases Due to Migration of Waste Constituents in the Air - the
standard requires actions to prevent releases that may have adverse effects on human
health or the environment due to migration of waste constituents in the air Topics that
must be considered are
• The volume and physical and chemical characteristics of the waste in the
unit, including its potential for the emission and dispersal of gases, aerosols
and particulates,
• The effectiveness and reliability of systems and structures to reduce or
prevent emissions of hazardous constituents to the air,
• The operatmg characteristics of the unit.
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• The atmospheric, meteorologic, and topographic characteristics of the unit
and the surrounding area,
• The existing quality of the air, including other sources of contamination and
their cumulative impact on the air,
• The potential for health risks caused by human exposure to waste
constituents, and
• The potential for damage to domestic animals, wildlife, crops, vegetation,
and physical structures caused by exposure to waste constituents
1110 2 Compliance With Environmental Performance Standard Requirements
All of these factors have been and will continue to be evaluated until closure of the
facility to ensure waste treatment methods are conservative and will not adversely affect
human health or the environment Control measures include, but are not limited to the
following
Human Health Risk Assessment - a Human Health Risk Assessment (HHRA) is being
conducted to evaluate the risk to the public from open buming and open detonation
operations at the facility Tasks associated with the HHRA include developing an air
dispersion model, evaluating sources, source parameters, and waste materials, and
characterizing emissions The HHRA will address the following environmental
performance related concems
• The volume and physical and chemical characteristics of the waste in the unit,
including its potential for the emission and dispersal of gases, aerosols and
particulates,
• The effectiveness and reliability of systems and stractures to reduce or prevent
emissions of hazardous constituents to the air,
• The operating characteristics of the unit,
• The atmospheric, meterologic, and topographic characteristics of the unit and the
sunounding area,
• The potential for health risks caused by hOuman exposure to waste constituents, and
The methods used in the HHRA are based on the United States Environmental Protection
Agency (U S EPA) modeling guidance, and to the extent possible, the dispersion
modeling methodology within the Human Health Risk Assessment Protocol (HHRAP)
for Hazardous Waste Combustion Facilities (U S EPA, September 2005) The completed
HHRA will be reviewed and approved by the Utah Division of Solid and Hazardous
Waste Limits on OBOD operations will be based on this assessment
Ecological Risk assessment - an Ecological Risk Assessment (ERA) will be conducted
to determine potential risks to ecological receptors that may be affected by OBOD
operations It will evaluate the potential for damage to domestic animals, wildlife, crops,
vegetation, and physical stractures The completed ERA will be reviewed and approved
by the Utah Division of Solid and Hazardous Waste, and will be a factor in establishing
limits on OBOD operations
Soil Monitonng Plan - a Soil Monitoring Plan (SMP) will be developed to verify the air
dispersion and deposition models developed by the HHRA The SMP will be used to
evaluate the existing quality of surface waters and surface soils, including other sources
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of contamination and their cumulative impact on surface waters and surface soils Risks
to human health and the environment will be evaluated using the data collected during
implementation of the SMP
Ground Water Monitoring - a ground water monitoring program has been in place at
the facility since 1986 The program addresses the following concems
• The hydrologic and geologic characteristics of the unit and the sunounding area
• The existing quality of ground water, mcluding other sources of contamination and
their cumulative impact on the ground water,
• The quantity and direction of ground-water flow, and
• The proximity to and withdrawal rates of current and potential ground-water users
The sampling method, constituents of concem, sampling frequency, sampling results and
analytical methods are closely reviewed and monitored by the DSHW
Annual Review of Limits - the operating permit requires ATK to conduct an annual
review of emission factors established by the HHRA, the reference doses for selected
health effects, and to review the potential health risk scenarios to assure that the scenarios
have not changed An annual accounting of the types and quantities of reactive waste
treated is also required
Stormwater Management - Stormwater run-on and run-off is controlled by a
combination of soil grading and drainage ditches The terrain around M-136 and M-225
has been graded and drainage ditches sunound the areas in order to minimize stormwater
run-on and ran-off The topography is shown in Attachment 6, Figures F-l and I-l
Stormwater collection and drainage is shown in Attach 11 Figure 11-1 and Figure 11-2
The combination of controlling run-on and run-off containing waste in water -tight bum
trays, lack of precipitation, high evaporation rate and depth to groundwater prevents
waste constituents from being released to the ground water and or subsurface
environment Ongoing soil and groundwater monitonng are used to verify these controls
are effective in preventing adverse effects to human health and the environment
Actions to Prevent Releases to the Environment - all spills of hazardous materials are
promptly cleaned up Intemal procedures require that chemicals be properly
containerized, labeled, stored, used and disposed The workplace is routinely audited to
ensure compliance with procedures When spills do occur, the released matenal is
promptly cleaned up and R315 reporting requirements are followed
Open Burning is Conducted in Steel Containers - Open buming is conducted in
containers which minimizes the potential for waste constituents to migrate to the ground
water, surface water or related environments The Operating Permit requires routine
mspections to ensure the containers are properly maintained Containers requiring repair
are removed from service until repairs are completed
Ash Management - ash and residue from OBOD operations are promptly collected and
disposed Ash is managed and classified as described in sections 8 2 4, and 8 2 5 of this
attachment
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Storage and Inspections - All PEP and residues from OBOD treatment are stored in
accordance with Section 4 of this attachment and R315-5 Hazardous Waste Generator
Requirements Storage and treatment areas are inspected as required by Attachment 2,
and operated in accordance with Attachment 8 of this permit
Regulatory Oversight- the facility is subject to strict regulatory oversight by the Utah
Division of Solid and Hazardous Waste All aspects of hazardous waste management
described in this Attachment are subject to their review When necessary deficiencies are
observed and conective action is taken by the permittee
llll RUN-ON RUN-OFF CONTROLS
40 CFR 264 601 contains performance requirements to prevent releases that adversely
affect the groundwater or subsurface environment Stormwater run-on and run-off is
controlled by a combination of soil grading and drainage ditches The tenain around
M-136 and M-225 has been graded, and drainage ditches sunound the areas in order to
minimize stormwater run-on and ran-off Drainage ditches are shown in Figure 11 1
and 11 2 The combination of controlling run-on and ran-off, containing waste in water
-tight bum trays, lack of precipitation, high evaporation rate and depth to groundwater
prevents waste constituents from being released to the groundwater and or subsurface
environment Ongoing soil and groundwater monitoring are used to verify these
controls are effective in preventing adverse effects to human health and the
environment
4 18
0 60 120
SCALE 1 =60
M225G4 DWG
ATK Launch Systems /nc
FACajTIES ENGINEERING
PO Boor707imimMSZ
Brigham aiy Utth 14301
M-225 BURN GROUNDS
DWG SIZE SCALE
1"=60'
DRAWING NO
FIGURE 11-2