DSHW-2010-036152 - 0901a068801b040e

HAND DELIVERED
JUL 2 8 2010
UTAH DIVISION OF
27 July 2010 ^ HAZARDOUS WASTE
8200-FYl 1-022 ^O/C O^l^^^^
Mr. Scott T. Ancderson, Executive Secretary
State of Utah Department of Environmental Quality
Division of Solid an(J Hazardous Waste
195N.1950 W.
P.O.Box 144880
Salt Lake City, Utah 84114-4880
Attention: JeffVandel
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
Response to Comments on the Waste Characterization and Air Dispersion
Modeling Protocol
Dear Mr. Anderson:
ATK has completed their review of your comments on the Waste Characterization and
Air Dispersion Modeling Protocol documents that were submitted. Reponses to your
comments have been generated and the affected sections of the Protocols have been
updated to reflect these changes.
Please contact me if you have any questions concerning this report. My telephone
number is [phone] or you can contact Blair Palmer at [phone].
Sincerely
David P. Gosen, P.E., Director
Environmental Services
July 27, 2010
ATK LAUNCH SYSTEMS, INC., PROMONTORY FACILITY
RCRA SUBPART X EVALUATION AND PERMIT MODIFICATION
PROMONTORY, UTAH
ATK LAUNCH SYSTEMS' ATK RESPONSES TO UTAH DIVISION OF SOLID AND
HAZARDOUS WASTE GENERAL COMMENTS REGARDING ATK'S WASTE
CHARACTERIZATION AND AIR DISPERSION MODELING WORK PLAN
GENERAL COMMENTS
1. ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol,
Revision 1, Section 2.0, ATK Promontory Facility Process Description
Section 2.3.1, M-136 Treatment Activities, and Section 2.3.2, M-225 Treatment Unit,
indicate trays at M-136 and M-225, respectively, may be lined with soil but most trays do
not contain soil. No discussion of the potential impact of the soil on the open buming
process is offered in either section. In addition, the criteria used to determine if a bum
tray should be lined is not provided. Revise the ATK Launch Systems Waste
Characterization and Air Dispersion Modeling Protocol, Revision 1 dated November 4,
2009 (the Air Dispersion Modeling Work Plan) to discuss any impacts of lining the bum
trays with soil on process emissions. Include the criteria used to determine if soil lining
is necessary. Indicate if soil lined bum trays will be addressed in the air modeling for M-
136 and M-225. If not, propose an approach for addressing the use of soil lined trays in
the uncertainty analysis of the risk assessment or demonstrate that impacts from the soil
lining are insignificant.
ATK Response: The potential impact to soil at M-136 and M-225 is expected to be
minimal due to the operating procedures used by ATK to minimize contamination and
soil sampling to measure contamination levels. ATK utilizes post-bum operating
procedures that are designed to minimize the impact to soil by collecting any waste
materials that have ejected on to the soil during the treatment process. The ongoing soil
sampling program is designed to periodically measure contaminant concentrations in the
soil to determine the relative impact of each treatment.
The post-bum activities include the following operating procedures:
• Following treatment, the ATK shall conduct the post-bum inspection activities and
post-bum clean-up activities as identified in Attachment 11 of the draft Permit, and
shall comply with Conditions FV.C.l, 2 and 3, and shall have completed and
complied with all provisions of Conditions, FV.E and F.
• 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 IV.G.2.j or k applies:
July 27, 2010
> Prior to entering the treatment area, the operators shall deactivate the firing
control system and remove the interlock;
> Document any treatment unit with an open flame, hot spot or smoldering
residue;
> Document any treatment unit with unbumed residue;
> Document any treatment unit with unbumed reactive hazardous waste and
identify if possible in the operatmg record why the waste did not bum
The post-bum activities also include inspecting the bum areas 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 treatment unit
As a side note, UDSHW is aware of the Zone of Engineering Control (ZOEC) soil
sampling that is conducted each year at both M-136 and M-225. UDSHW has received
some of the ZOEC sampling results from the past years. ATK conducts this sampling to
assess the impacts to the soil in the buming grounds from the daily treatment operations.
The criteria used ATK to determine if a bum tray should be lined with soil is: 1) if the
waste being loaded into the tray is on a pallet, and will be handled with a forklift, die tray
will have soil installed allowing the forklift to set the pallet on a pad of soil that is not
recessed lower than the upper lip of the bum tray. 2) if the waste propellant being burned
will generate extremely high temperatures, soil will be installed in the bottom of the steel
tray to protect the structural integrity of the tray.
M-136 only has six trays that are routinely lined with soil. Three trays are use for a
scheduled bum event and then the other three trays will be used for the next scheduled
bum event.
M-225 does not have any soil lined trays.
As a side note, UDSHW is aware of the Zone of Engineermg Control (ZOEC) soil
sampling that is conducted each year at both M-136 and M-225. UDSHW has received
some of the ZOEC sampling results from the past years. ATK conducts this sampling to
assess the impacts to the soil in the buming grounds from the daily treatment operations.
Section 2.3 has been revised to incorporate the above information.
July 27, 2010
ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol,
Revision 1, Section 4.0, Air Quality Modeling Methodology
Section 4.0 does not clearly identify the types of air quality impacts to be modeled. Table
4-3, summary of Deposition Modeling Parameters, indicates air concentration will be
modeled for gas phase mns and deposition rate will be modeled for particulate phase
mns. However, information provided in Section 3.0, indicates gas phase, particle phase,
and particle-bound phase constituents will be emitted from all three types of wastes
considered in the air modeling analysis. It is expected that at a minimum, gas phase air
concentrations, particle-phase air concentrations, particle-bound phase air concentrations,
particle phase gravitational deposition, and particle-bound phase gravitation deposition
would be modeled using OBODM. Revise Section 4.0 to clearly indicate the types of
impacts to be modeled by OBODM.
ATK Response: Section 4.0 has been revised to clearly indicate the types of modeling
impacts that will be modeled by OBODM for each treatment unit, which will include gas
phase air concentrations, particle-phase air concentrations, particle-bound phase air
concentrations, particle phase gravitational deposition, particle-bound phase gravitation
deposition, and gas phase deposition.
Revisions have been made to Section 4.4.1 (M-136) and Section 4.4.2 (M-225). In
addition. Section 4.5 has been renamed Types of Dispersion Modeling and discusses in
separate subsections each type of dispersion modeling that will be conducted for M-136
and M-225.
ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol,
Revision 1, Section 4.0, Air Quality Modeling Methodology
Section 4.4, OB/OD Treatment Scenarios, provides general information on the treatment
scenarios to be addressed in the air modeling analysis. Stakeholders are referred to
Sections 4.4.1 and 4.4.2 for a summary of source parameters and other assumptions to be
used in modeling the M-136 ad M-225 treatment units. However, Sections 4.4.1 and
4.4.2, and referenced Tables 4-1 and 4-2, do not provide the dimensions of the merged
sources. Source 1 at M-136 and Source 1 at M-225, to be addressed in the air modeling
analysis. In addition, the second bulleted item in Section 4.4.1.2, Other Modeling
Assumptions for M-136, indicates modeled sources within M-136 will be assigned to
source groups so individual contributions from different sources and different types of
wastes can be delineated. There is no mention of source groups in the discussion related
to M-225; thus, it is unclear if source groups will be used in modeling those sources.
Revise the Air Dispersion Modeling Work Plan to provide the dimensions (i.e., length,
width, and depth) that will be used to characterize merged Source 1 at M-136 and merged
Source 1 at M-255 in the air modeling analysis. Also, indicate if source groups will be
used in modeling the sources at M-225. Provide a table that lists the modeled sources to
be included in each source group used in the air modeling analysis.
July 27,2010
ATK Response: Section 4.4 has been revised to provide the dimensions of the merged
sources. Source 1 at M-136 and Source 1 at M-225. Revisions have also been made to
Sections 4.4.1.2 and 4.4.2.2 to indicate that source groups will be used to conduct
modeling for all sources (merged and not merged) at M-136 and M-225. Sections 4.4.1.2
and 4.4.2.2 now identify the individual sources groups for both M-136 and M-225.
4. ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol,
Revision 1, Section 4.0, Air Quality Modeling Methodology
Section 4.4 of the Air Dispersion Modeling Work Plan indicates the air modeling results
will be subjected to post processing to account for the treatment quantities proposed in
Tables 2-1 and 2-2. Stakeholders are referred to Section 4.9, Post-Processing Activities,
for discussion of the proposed post processing steps. Step 1 is described as a review of
all air modeling results to determine the maximum 1-hour and annual air dispersion and
deposition factors. No information on manipulation or modification of the air modeling
results, as implied by the discussion in Section 4.4, is described. Revise Section 4.9 to
indicate how (or it) the air modeling results will be modified (i.e., post processing) to
reflect the treatment quantities proposed in Tables 2-1 and 2-2.
ATK Response: Section 4.9 has been revised to indicate how the air modeling results
will be modified via post-processing to calculate the maximum air concentrations based
on the proposed treatment quantities in Tables 2-1 and 2-2.
5. ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol,
Revision 1, Section 4.0, Air Quality Modeling Methodology
Based on the information provided in Section 4.4.1.2, Other Modeling Assumptions for
M-136, and the first paragraph of Section 4.4.2, M-25 Treatment Unit Scenarios, it
appears 1.5 meters will be used as the source diameter for detonation processes. Table 4-
1, M-136 Source Parameters, and Table 4-2, M-225 Source Parameters, also list Ground
Level as the Effective Release Height for OD sources. Section 3.4, Source Data, of
Volume I of the OBODM User's Guide (Bjorkiund et al., 1998a) states OBODM can be
directed to compute the effective release height and diameter of the initial cloud from a
detonation. Alternately, the user can enter the effective release height and initial
diameter parameters. Section 3.4 continues that for an instantaneous source (i.e., the type
of source assumed for a detonation), OBODM requires the diameter of the resulting
fireball. Based on the information provided in the Air Dispersion Modeling Work Plan it
is not clear how OBODM will be configured in modeling OD sources. Revise the Air
Dispersion Modeling Work Plan to indicate if OBODM will calculate the effective
release height for OD sources or if the user will supply the required effective release
height and initial diameter. Regardless of which option is indicated, ensure the text
and/or Tables 4-1 and 4-2 reflect the information that w will be supplied as input to
OBODM when modeling the OD sources at ATK.
July 27, 2010
ATK Response: OBODM will calculate the eff'ective release height for OD sources at
M-136 and M-225. Tables 4-1 and 4-2 have been revised to indicate that the effective
release height for OD sources at M-136 and M-225 will be calculated by OBODM.
6. ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol,
Revision 1, Section 4.0, Air Quality Modeling Methodology
Details regarding how the air modeling was performed will be available in the air
modeling files. These files must be provided to the DSHW in order to convey a clear
understanding of how the air modeling analysis was conducted and to allow for the re-
creation of the analysis, if necessary. Please revise the Air Dispersion Modeling Work
Plan to indicate electronic copies of all OBODM input and output files will be submitted
to DSITW. Further, state that copies of the model-ready meteorological data file, as well
as any other files (e.g., hourly source strength files) used in generating the modeled
resuhs will be provided.
ATK Response: A new Section 4.10, OBODM Modeling Files, has been added to the
protocol to indicate that OBODM input and output files and model-ready meteorological
data files will be provided to DSHW for review of modeling analysis.
SPECIFIC COMMENTS
7. Section 2.3.1, M-136 Treatment Activities, Page 2-4
Based on the description provided in Section 2.3.1, it is not clear that Table 2.1, M-136
Risk Assessment Treatment Unit Wastes Treated, Treatment Limits, and Model Quantity,
reflects the appropriate established daily quantity limits. Table 2.1 indicates one of the
options for achieving the 50,000 pounds per day established daily quantity limit at Source
2 is to bum 1.1 pure propellant and contaminated material at one bum station. However,
the discussion in Section 2.3.1 indicates 1.1 neat propellant and contaminated materials
would be limited to 20,000 pounds per day at bum station 13, the only station associated
with Source 2. Review the discussion in the text and the information in Table 2.1 and
revise them as appropriate to clarify the type, nature and quantity of potential bum
materials allowed to ensure consistency within the text and Table.
ATK Response: The reference to treatment quantities at M-136 has been changed to
reference Table 2-1 which now contains the correct treatment quantities for M-136 source
groups. Also note that the model treatment quantities for M-136 have changed since the
draft protocol was submitted in early 2010 on the basis of recendy established Draft
permit conditions.
July 27, 2010
8. Section 2.3.2, M-225 Treatment Unit, Page 2-6
Based on the description provided in Section 2.3.2, it is not clear that Table 2.2, M-225
Risk Assessment Treatment Unit Wastes Treated, Treatment Limits, and Model Quantity,
reflects the correct description of the established daily quantity limits. Table 2.2
indicates one of the options for achieving the 2,000 pounds per week established daily
quantity limit at Source 1 is to bum 1,000 pounds per tray of 1.1 or 1.3 pure propellant
and contaminated material. However, the discussion in Section 2.3.2 states open buming
treatment quantities are limited to 500 pounds per tray of propellants and 1,000 pounds
per tray of propellant contaminated material. Review the discussion in the text and the
information m Table 2.2 and revise them for clarity and consistency. Further, change the
header on the column entitled Established Daily Quantity Limits to Established Weekly
Quantity Limits.
ATK Response: The reference to treatment quantities at M-225 has been changed to
reference Table 2-2 which now contains the correct treatment quantities for M-225 source
groups. Also note that the model treatment quantities for M-225 have changed since the
draft protocol was submitted in early 2010 on the basis of recently established Draft
permit conditions.
It is not clear why the State is requesting a change to the header on the column entitled
Established Daily Quantity Limits to Established Weekly Quantity Limits. ATK draft
pennit conditions IV.C.2.a. and IV.C.2.b, which pertain to treatment limitations at M-
225, clearly states that treatment limits are limited on a per calendar day basis and not a
weekly basis. The State's request is inconsistent with ATK's interpretation and
understanding of the draft permits conditions for M-225. As a result, the header on Table
2-2 has not been changed.
Section 3.2.1, Class 1.3 Waste Emission Factors, Page 3-5
In order to characterize the class 1.3 wastes that are treated at the facility by open buming
or detonation, ATK made the effort to conduct emissions testing on three different
compositions of waste materials (PWlOO, PW85-15 and PW65-35). Apparently, ATK is
plaiming to use an average value, calculated from the three sets of emission factors, to
evaluate the risk associated with open buming/detonating these waste materials. The
option of comparing the risk associated with buming wastes with a higher percentage of
trash with wastes containing a lower percentage of trash will be lost using this approach.
Please explain why ATK has decided to use an average value as opposed to calculating
the risk associated with each composition.
ATK Response: As stated in Section 3.2.1, UDSHW has directed ATK to evaluate, the
range of risk associated widi buming 1.3 wastes using two test data sets that will reflect
the range of possible emissions and risk based on the available test data. The first
emission factor data set consists of a more "conservative" data set uses the full method
July 27, 2010
detection limit (MDL) for non-detected compounds and background and blank values
have not been subtracted out from the test results. The second set of emissions data
represents a "corrected" (less conservative) in which all non-detects are replaced with Vi
MDL (or EDL) and background/blank correction has been performed.
ATK acknowledges that the approach using the average emission factor of all tests may
not address the issue regarding risk with variable percentages of trash. In an effort to
allow the human health and ecological risk assessments to provide reasonable maximum
exposure (RME) estimates, ATK is proposing to revise the "conservative" and
"corrected" emission factors (Tables 3-5 and 3-6) to reflect the maximum constituent
emission factor measured over the three trial bums for each waste mix scenario. This
approach is consistent with the USEPA recommendation in Section 2.2.1 (Estimating
Stack Emissions for Existing Facilities) of the Human Health Risk Assessment Protocol
for Hazardous Waste Combustion Facilities (USEPA< 2005), which states that risk
assessments should utilize the "maximum of the three emission test rates".
ATK believes this approach addresses the issue of risk associated with buming wastes
with variable amounts of trash and ensures protection of human health and ecological
receptors. This approach will also reduce the effort needed to prepare the risk assessment
if ATK decided to calculate risk separately for each composition as mentioned in the
State's comment.
Section 3.2.1 and Tables 3-5 and 3-6 have been revised to describe the class 1.3 emission
factors that will be used in the air dispersion modeling and risk assessments.
10. Section 3.2.3, Category E Emission Factors, Page 3-6
The second paragraph of Section 3.2.3 states that constituent data from the Munitions
Items Disposition Action system (MIDAS) database was reviewed to determine that the
M816, 81-mm Infrared (IR) Illumination Cartridge was a suitable surrogate for the
Category E wastes treated at ATK. However, the components of the M816, Sl-mm IR
Illumination Cartridge are not provided. Revise Section 3.2.3 to include a comparison of
the constiments in the Category E wastes and those in the M816, 81-mm IR Illumination
Cartridge to fully demonstrate that the Cartridge is an appropriate surrogate.
ATK Response: ATK manufactures three types of military/commercial flares: (1) a
visible illumination flare; (2) a near infrared illumination flare: and (3) a decoy flare. A
comparison between the Munitions Items Disposition Action system (MIDAS) database
and the EPA AP 42, Compilation of Air Pollutant Emission Factors website was done to
locate surrogate flare emission factor from AP-42 and determine the ingredients of the
surtogate from the MIDAS data base.
Two flares were found that were similar in base ingredients and had existing emission
factors in AP 42. The M816 IR Illumination Cartridge and the M314 Illumination
July 27,2010
Cartridge were found to contain similar base ingredients to ATK's near infrared
illumination flare and the visible illumination flare.
Information presented in Section 15.3.22 of US EPA's AP-42 Emission factor website
indicates that the C484, M816 81-mm Infrared (IR) Illumination Cartridge (DODIC
C484) is a pyrotechnic mortar that is used to provide infrared illumination that cannot be
detected by the human eye in the target area but that can be detected using standard night
vision devices. This ammunition is used during combat and on firing ranges during
training. It should be noted that the emission factors presented in AP-42 are only
associated with the detonation of the cartridge.
A comparison of emission factors from the M816 IR Illumination Cartridge and the
M314 Illumination Cartridge was conducted and the M816 IR Illumination Cartridge
presented the most conservative emission factors, and as a result, was selected as the best
surrogate currently available.
hi a letter from the UDSHW dated September 22, 2009 it was stated that "the division
may determine that it is not appropriate to assess some of the waste profiles or categories
by using the Class 1.3 ODOBi emission factors." As a result, ATK is proposing the
M816 IR Illumination emission factors as a better surrogate for the reactive Category E
waste, than the class 1.3 ODOBi emission factors.
Table 3-2 presents the primary constituents of ATK flares (Reactive Group E). The
material listings in Table 3-2 are controlled by ATK and have distribution restrictions. In
lieu of listing ingredients from the MIDAS database for the M-816 IR flare in what will
become a public document, ATK prefers that Tech Law access the MIDAS database and
do a comparison of MIDAS data versus the constituents in ATK flares.
Section 3.2.3 has been revised to incorporate the above information relative to the
selection of a surrogate for characterizing Category E waste emissions.
11. Section 4.1, Air Quality Dispersion Model Selection, Page 4-3
The next to last bulleted item in Section 4.1 indicates the modeling domain includes areas
of complex terrain. As stated in the discussion, OBODM contains a screening-level
algorithm for estimating air quality impacts in complex terrain. However, this algorithm
is restricted to predicting air concentrations. As stated in Section 2.3 of Volume I,
User's Instructions, and Section 2.7, Complex Terrain Screening Procedures, of Volume
II, Technical Description, of the Open Bum/Open Detonation Dispersion Model
(OBODM) User's Guide (Bjorkiund et al., 1998a, 1998b), the complex terrain option
caimot be used when calculating concentration with gravitational deposition occurring or
gravitational deposition for particulates with appreciable settling velocities. The Air
Dispersion Modeling Work Plan does not address how gravitational settling will be
addressed or calculated in complex terrain. Revise the Air Dispersion Modeling Work
Plan to propose an approach for calculating particulate deposition (via gravitational
July 27, 2010
settling) in areas of complex terrain.
ATK Response: ATK is proposing to use the OBODM modeling results for particulate
dosage to calculate particulate deposition for complex terrain receptors. As indicated in
Table 4-3, ATK is assuming that the emission surrogate for OBODM particulate phase
model runs is aluminum, which has the density of aluminum is of 2.7 g/cm^, and the
mean particle diameter is assumed to be 30 micrometers, which is consistent with the
particulate size distribution used by OBODM. Based on these assumptions for
particulate emissions, a dry deposition velocity for a spherical particulate has been
estimated from data presented by Harma (Hanna, et al., 1982) to be approximately 0.10
meters/second. As a result, the particulate phase dry deposition at complex terrain
receptors only will be calculated as follows:
Complex Terrain Dry Deposition (|ig/m^-yr) = Annual Particulate dosage ([ig-secW) x
Particulate Deposition Velocity (m/sec)
Section 4.1 of the Air Dispersion Modeling Protocol has been revised to incorporate this
procedure for calculating particulate deposition (via gravitational settling) in areas of
complex terrain.
12. Section 4.2, Land Use Analysis, Page 4-4
The last paragraph of Section 4.2 indicates a count analysis was conducted as part of
determining the land use classification for the modeling domain. It appears that the
Administration and Manufacturing area falls within the 3 km radius that was included in
the analysis. What land use classification was assigned to this area? The details of the
analysis are not provided in the Air Dispersion Modeling Work Plan. For completeness
and transparency, revise the Air Dispersion Modeling Work Plan to include the count
analysis or provide a statement that the count analysis will be included in the air
dispersion modeling report.
ATK Response: Section 4.2 has been revised to indicate that the Land Use count
analysis will be included in the air dispersion modeling report.
13. Section 4.4, OB/OD Treatment Scenarios, Page 4-5
The discussion at the bottom of page 4-5 indicates a heat content of 1,471 calories per
gram (cal/g) was determined for 1.3 class materials using the NASA-Lewis
Thermochemical Model. Further, the discussion indicates the facility will be conducting
tests to determine the heat content for 1.1 and Category E class materials. Some general
information related to the determination of the heat content for 1.3 class materials is
provided; however, this information is not sufficient to demonstrate to stakeholders how
the value was derived. Revise Section 4.4 to describe how a value of 1,471 cal/g was
determined for 1.3 class materials. Summarize all input information considered and
July 27, 2010
illustrate how the NASA-Lewis Thermochemical Model was used in obtaining the
reported value. Provide electronic copies of the input and output information for any
model runs. Also, describe how the heat contents for 1.1 and Category E class materials
will be provided to Utah DEQ and provide details regarding how the values will be
determined.
ATK Response: NASA-Lewis Thermochemical model runs were completed for three
compositions buming 1.3 propellant at ambient pressure. The goal of the model
calculations was to examine theoretical flame temperatures of the propellant and the
mixtures. The first composition was pure propellant (PWlOO); the second composition
was an 85:15 mixture of propellant and decane (to simulate PW85:15); the third was a
65:35 mixture of propellant and decane (to simulate PW65:35). The results of the runs
are shown in Table 1.
Table 1
tSA-Lewis Model Output
PWilW^
Flame Temperature, °F 4976 2950 2260
Heat Content, cal/g 2058 1870 1471
Table 2 lists the Heat of Explosion, which is the heat generated by the propellant when it
is bumed in an inert gas atmosphere using a bomb calorimeter. This value would be
conservative in comparison to open buming since the testing was performed in an inert
gas atmosphere (oxygen deficient).
Table 2
J770812 1464
J770812 1399
J770812 1492
Average 1452
J956002 1442
J956002 1365
J956002 1449
Average 1419
On June 3, 2009, ATK presented this data and information to the Utah Division of Solid
and Hazardous Waste, (Brad Maulding, Jeff Vandel, Bill Walhier, Rick Page, Deborah
Ng, and Chris Bittner). During this meeting, it was agreed that based on this data, a value
in fourteen hundreds was appropriate for a 1.3 propellant heat content value. The 1.3
10
July 27, 2010
heat content value of 1471 cal/g was chosen since it was the most conservative value
resulting from the NASA-Lewis Model output, and it corresponded well with the test
results from the bomb calorimeter.
Heat content values for class 1.1 propellants and Category E were also measured, again
using a bomb calorimeter in an inert gas atmosphere. The result from these tests are
illustrated below m Tables 3 and 4 below. The DLQ152 Flare Illuminate, which is a
similar illuminate to the M816, Infrared (IR) Illumination Cartridge that is being used as
a surtogate for the Category E wastes treated at ATK, was used for this heat content
testing.
Table 3
Run#l 1395.0
Run #2 1372.6
Run #3 1438.5
Average 1402.0
Table 4
^^^^:fcal/B;,.:•..;^,••r»
Run#l 832.4
Run #2 821.3
Run #3 820.4
Average 824.7
lare Xlluminate)
Section 4.4 has been revised to incorporate the above information regarding the
derivation of heat content values for 1.3, 1.1 and Category E materials.
14. Section 4.4.1.1, M-136 Source Parameters, Page 4-6
It is unclear what treatment quantities will be used in the air dispersion model analysis for
the different waste classifications (e.g. 1.1 or 1.3) that are treated at M-136 and M-225.
Table 4-1 (referenced in this section of the text) shows the modeled treatment quantity
per event for Source 1 is 106,500 pounds. Will this quantity be used for all waste
classifications? Table 2-1 shows different daily quantity limits for the waste
classifications shown. How will these limits be represented in the air dispersion model
analysis? This question also applies to the other sources at the two bum grounds. In
addition, what is the daily quantity limit for the Category E waste category?
11
July 27, 2010
ATK Response: Tables 2-1 and 4-1 have been revised to show consistent values for
treatment operations at M-136 for each classification of waste. Also note that the model
treatment quantities for M-136 have changed since the draft protocol was submitted in
early 2010 on the basis of recently established Draft permit conditions.
Section 2.3.1 have been revised to reference Table 2-1, which incorporates the Draft
permit condition treatment quantities for M-136 sources.
15. Section 4.4.1.2, Other Modeling Assumptions for M-136, Page 4-7
The third bulleted item on page 4-7 indicates each OB source will be based on an average
pan size of 6 feet by 17 feet. It is not clear how this average size pan was determined.
Revised the Air Dispersion Modeling Work Plan to describe how the average pan size of
6 feet by 17 feet was determined.
ATK Response: The typical pan sizes used at M-136 are 5'x 16', 8'x 20', and 8'x 8'.
Curremly, seventy percent of the trays are 5'x 16'. When they bum the trays at Source 1
(BS 1-12), they are usually placed in a long row of 12 - 14 trays in the row. When they
bum the trays at Source 2 (BS 13), they typically use 3 small trays, 3'x 7', and an 8'x 8'
and then a 6'x 6' that are essentially arranged in a rectangular configuration. There are
no bum pans at Source 3 (BS-14) or Source 4 (BS-14).
Based on the bum pan configurations describe above, ATK is proposing the following
revised dimensions for each M-136 source:
• Source 1 - 224' x 5' (14, 5' x 16' trays in a row which is the maximum bum
scenario for Source 1)
• Source 2 - 17' x 7' (an area that includes 3 small trays, 3'x 7', and an 8'x 8' and
then a 6'x 6', which is the maximum bum scenario for Source 2)
Section 4.4.1.2 has been revised to describe the maximum operating scenario at each M-
136 treatment unit that utilizes bum pans to treat waste materials.
16. Section 4.4.1.2, Other Modeling Assumptions for M-136, Page 4-7
The fourth bulleted item on page 4-7 states a release height of 2.0 meters will be assumed
for bum station 14 at M-136. Table 4-1, M-136 Source Parameters, indicates an effective
release height of 1 meter for the OB pans at bum station 14 (i.e., source 3 at M-136).
Revise the text and table to consistently reflect the value to be used in the air modeling
analysis.
ATK Response: The original fourth bullet (now bullet five) item in Section 4.4.1.2 has
been changed to indicate that the release height for OB treatment at all M-136 OB source
groups is 1.0 meter. This statement is now consistent with Table 4-1.
12
July 27,2010
17. Section 4.4.2, M-225 Treatment Unit Sources, Page 4-8
Based on the information provided in the second paragraph of Section 4.4.2 it appears the
OB and OD sources at M-225 ".. .will be modeled as a single emission source..." in a
single model run. No information regarding how this will be accomplished is provided.
Revise the Air Dispersion Modeling Work Plan to describe how the OB and OD
operations at M-225 will be modeled as a single emission source. As part of the
description, confirm OBODM can model two operations with different source
characteristics at the same time and at the same location. In addition, provide the source
inputs that will be used in OBODM to model both processes in the Air Dispersion
Modeling Work Plan.
ATK Response: The information provided in the second paragraph of Section 4.4.2 was
a bit ambiguous and needed further clarification. The second paragraph in Section 4.4.2
has been revised to indicate that the OB and OD sources at M-225 will be modeled as
separate sources in OBODM and not as a single source.
18. Section 4.4.2.1, M-225 Source Parameters, Page 4-8
In regard to the modeled treatment quantity and daily quantity limits for the M-225 Bum
Grounds, Table 4-2 (referenced in this section of the text) shows a modeled treatment
quantity of 2,000 pounds per event for Source 1. Draft permit condition VI.C.5.a. states
that the maximum treatment quantity shall not exceed 4,500 pounds at M-225. Please
clarify what the maximum quantities are for the M-225 Bum Grounds. Does ATK intend
to use the maximum quantity for the air dispersion modeling analysis?
ATK Response: The draft permit condition VI.C.5 was established after the Draft Air
Dispersion Modeling Protocol was submitted to the State for review earlier this year.
Table 4-2 has been revised to indicate that the modeled treatment quantities at M-225 will
be 4,500 pounds for OB and 600 pounds for OD, which are consistent with draft permit
condition VI.C.5.
19. Section 4.5.1, Particle Phase Dry Deposition, Pages 4-10 and 4-11
ATK has proposed the same particle size distribution for modeling both OB and OD
operations. No information supporting or justifying this approach is provided. Revise
the Air Dispersion Modeling Work Plan to include information supporting the use of
identical particle size distributions in modeling OB and OD operations. If necessary,
include information establishing the need to use one PSD for both operations. In
addition, indicate the use of a single PSD in the air modeling analysis will be addressed
as a source of uncertainty in the air modeling and risk assessment reports.
13
July 27, 2010
ATK Response: ATK has not conducted particle size distribution testing of OB and OD
emissions. Unfortunately, particle size distribution data for treatment of OB and OD of
energetic materials, let alone energetic materials containing contaminated waste, cannot
be identified at this time. The particle size distribution is likely dependent on the
materials and procedures used specifically for OD at a source. A literature search has
resulted in no available test data specific for OB versus OD treatment. In the case of
ATK specific operations, there is no available test data on particle size distribution. As a
result, ATK feels there is no representative available test data to determine separate
particle size distributions for OB and OD treatment and as a result ATK will use a single
PSD in the air modeling analysis for both OB £ind OD. ATK will address the use of a
single PSD as a source of uncertainty in the air modeling and risk assessment reports.
Section 4.5.2 (Types of Dispersion Modeling) has been revised to include the above
information supporting the use of a size PSD for OB and OD dispersion modeling at
ATK.
20. Section 4.5.1, Particle Phase Dry Deposition, Pages 4-10 and 4-11
As discussed in Section 3 of US EPA's Human Health Risk Assessment Protocol for
Hazardous Waste Combustion Facilities (USEPA, 2005), particle deposition should be
addressed in two phases, the particle phase and the particle-bound phase. Constituents
present in the particle phase are modeled using a mass weighting of the assumed particle
size distribution while particle bound phase constituents are modeled using a surface area
weighting of the assumed distribution. Section 3.2.3 of the HHRAP outlines a technique
for calculating the surface area weighting factors from the mass fractions for each particle
size category. The discussion in Section 4.5.1 of the Air Dispersion Modeling Work Plan
does not address the difference between modeling gravitational deposition for particle
phase and particle-bound phase constituents. Revise Section 4.5.1 to describe how the
difference between gravitation deposition for particle phase and particle-bound phase
constituents will be addressed in the air modeling analysis.
ATK Response: Section 4.5 has been retitled as "Types of Dispersion Modeling" and is
now divided into subsections 4.5.1 to 4.5.4, which discusses the different types of air
dispersion modeling and addresses the difference between gravitation deposition for
particle phase and particle-bound phase constituents in Section 4.5.2. The approach
presented is consistent with Section 3 of US EPA's Human Health Risk Assessment
Protocol for Hazardous Waste Combustion Facilities (USEPA, 2005), utilizing surface
area weighting. A new table. Table 4-4, has been added to Section 4.5, which presents
the assumed particle size distribution data and calculated fraction of total surface area for
particle-bound deposition modeling.
14
July 27,2010
21. Section 4.5.[2], Gas Phase Dry Deposition, Page 4-11
Section 4.5.[2] indicates ATK will estimate gas phase dry deposition using the equation
presented on page 4-11 (gas phase dry deposition = annual gas concentration x deposition
velocity x conversion factor). Section 2.5.2, Dry Deposition, of Volume II of the
OBODM User's Guide (Bjorkiund et al., 1998b) explains that OBODM models
gravitational deposition but not dry deposition (defined as the product of total ground-
level dosage and an empirical or theoretical dry deposition velocity). Equation 2-49 is
provided as the preferred means of estimating dry deposition from OBODM air modeling
results:
Dry (x,y) = Vd x D(x,y,0)
Where:
Dry (x,y) = dry deposition at downwind distance x and crosswind distance y;
Vd = dry deposition velocity; and
D(x,y,0) = total ground level dosage (predicted by OBODM) at (x,y).
Revise Section 4.5.[2] of the Air Dispersion Modeling Work Plan to demonstrate the
methodology used to estimate gas phase dry deposition at ATK is equivalent or more
conservative than the approach outlined in Section 2.5.2 of Volume II of the OBODM
User's Guide.
ATK Response: Section 4.5 (Types of Dispersion Modeling) has been revised to indicate
that ATK will use the same approach as described in Equation 2-49 from Volume II of
the OBODM User's Guide as the preferred means for calculating dry deposition for gas
dry deposition using total aimual ground level dosage instead of the annual ground level
concentration (See Section 4.5.3). The equation for calculating gas phase dry deposition
in the ATK modeling analysis will be:
Gas Phase Dry Deposition (^ig/m^-yr) = Annual Gas Phase Dosage (|ag-sec/m'') x Gas
phase dry deposition velocity (m/sec).
22. Section 4.6, Receptor Networks, Page 4-11
This section discusses the applicable receptor grids that would be used and references the
use of the United States Geological Service (USGS) Digital Elevation Map (DEM) to
support the receptor grid development. However, it is not clear from what source (e.g.,
vendor, web site) this information will be obtained. Revise the Air Modeling Work Plan
to address this issue.
ATK Response: As stated in Section 4.6, the DEM data to support the receptor grid has
been obtained via the United States Geological Service. The website to access DEM files
15
July 27, 2010
from the USGS is http://data.geocomm.com/dem/demdownload.html. The
GeoCommunity website has a partnership with USGS to provide the DEM data.
Section 4.6 has been revised has been revised to indicate the source of the United States
Geological Service (USGS) Digital Elevation Map (DEM) data.
23. Section 4.6.1, Discrete Receptor Grid, Page 4-12
It is understood that OSHA exposure concentration values will be used to evaluate ATK
worker exposure at each treatment unit. However, it appears that the Administration and
Manufacturing Area, and other similar areas at the facility, should be included as discrete
receptors since the workers in these areas are not directly involved with the activities at
the treatment units. Please provide a discussion on the assessment of the risk posed to
these workers associated with open buming at the facility.
ATK Response: ATK is proposing two new onsite discrete receptor to assess potential
risk to ATK workers that are not directly involved with the activities at the M-136 and
M-225 treatment units. The proposed new onsite receptors represent areas where most
non-treatment related employees spend their time onsite.
The new onsite discrete receptors include the following:
• North Plant Main Administration Building and Main Manufacturing Area- 2.5 miles
north of M-136 and 6.7 miles north-northwest of M-225
• South Plant Main Administration Building and Main Manufacturing area - 1.8 miles
south of M-136 and 3.9 miles west-northwest of M-225
Section 4.6.1 has been revised to indicate that ATK will utilize these new onsite discrete
receptors to assess potential risk to ATK workers that are not directly involved with the
activities at the M-136 and M-225 treatment units.
24. Section 4.7.1, Surface Data, Page 4-16
In addition to die information already provided, please indicate if surface data from Hill
Air Force Base (AFB) has been used as a surrogate (i.e., "substitute") for missing surface
data in previous air dispersion modeling analyses at ATK. In addition, the Air Dispersion
Modeling Work Plan should indicate the use of surface data from Hill AFB will be
addressed as a source of uncertainty in the air modeling and risk assessment reports.
ATK Response: Previous air dispersion modeling has not been conducted for OB and
OD treatment operations at M-136 and M-225. As a result, surface meteorological data
from Hill Air Force Base (AFB) has not been used as a surrogate for missing surface data
16
July 27, 2010
in previous air dispersion modeling analyses at ATK.
In addition to the meteorological parameters measured at the M-245 monitoring station,
the meteorological preprocessor used to prepare the meteorological input file for
OBODM requires hourly values of opaque cloud cover and ceiling height. These
parameters are not measured at M-245. Hourly values of opaque cloud cover and ceiling
height are only available from 1*' class NWS reporting stations. The closest l" class
reporting station to ATK is located at Hill AFB. In addition to being the closest 1^'
reporting station to ATK, Hill AFB and M-245 have climatological and topographical
similarities that support of the selection of Hill AFB as a source of substitute data based
on elevation, alignment of the terrain and valley at both locations and other conditions
described in Section 4.7.1. The use of surface data from Hill AFB will be addressed as a
source of uncertainty in the air modeling report.
Section 4.7.1 has been revised to address prior use of Hill AFB as a surrogate for surface
meteorological data and states that it will be addressed as a source of uncertainty in the
air modeling report.
25. Section 4.7.2, Upper Air Observations (Mixing Height Data), Page 4-17
The first full paragraph on Page 4-17 concludes with "ATK will use a combination of
upper air data from Salt Lake City and surface temperature observations from Hill AFB
to produce twice-daily mixing heights." The second full paragraph on Page 4-17
indicates cloud cover and ceiling height observations from Hill AFB will be used ".. .in
the calculation of stability class..." Based on the information fumished in Section 4.7,
Meteorological Data, it was expected that surface temperature observations, cloud cover,
and ceiling height observations from the M-245 meteorological monitoring station would
be used for these purposes. No information supporting the use of Hill AFB data in these
analyses has been provided. Review the information presented in Section 4.7.2. Ensure
it accurately reflects the information sources ATK will use in preparing the model-ready
meteorological data file for the air modeling analysis. If ATK intends to use Hill AFB
surface temperatiure observations, cloud cover data, and ceiling height observations in
lieu of data from M-245, Section 4.7.2 should be revised to explain why the Hill AFB
data must be used and demonstrate that the Hill AFB observations are the best values to
use in determining mixing heights stability class for the ATK air modeling analysis.
ATK Response: Section 4.7.2 already explains why the Hill AFB must be used as a
source of surrogate data required the meteorological preprocessor (PCRAMMET). As
stated in Section 4.7.2, "cloud cover and ceiling height observations are not measured at
M-245". These parameters are required by the meteorological preprocessor
(PCRAMMET) in order to prepare the meteorological input file necessary for OBODM.
Cloud cover and ceiling height are only measured at l" class National Weather Service
(NWS) stations. Of the limited number of The Hill AFB is the closest l" class NWS to
M-245 and is considered to be most representative due to its close proximity to ATK.
17
July 27, 2010
Section 4.7.2 also discusses the topographical similarities between Hill AFB and M-245
that support the selection of Hill AFB as a source of substitute data.
ATK feels there is sufficient information in Section 4.7.2 to explain why the Hill AFB
should be used to provide the necessary meteorological parameters that are not available
from M-245. As a result, no change has been made to this section to respond to this
comment.
26. Section 4.8, Comparison to Air Quality Standards and Exposure Criteria, Page 4-18
The contribution from background and the contribution from ATK OB and OD
operations should be clearly identified in the comparisons to air quality standards
described in Section 4.8; Revise Section 4.8 to indicate the contributions from
background and OB and OD operations will be clearly delineated in the comparative
analyses.
ATK Response: The Utah Department of Air Quality has been contacted to identify
potential sources of background air quality data for use in the ATK air dispersion
modeling assessment. Currently, there is only one monitoring location in Box Elder
County. However, the UDAQ also recommended Ogden, Utah as a source of
background data. Unless directed otherwise, ATK will utilize historical air quality data
from the Utah Air Pollution Data Archive from Box Elder and Ogden as background air
quality concentrations for the comparative analysis. It is important to note that
background values may not be available for all criteria pollutants because of limited
sampling conducted by the State.
Section 4.8 has been revised to indicate that the comparative analysis, applicable
standards and TSLs, will clearly delineate the contribution from background sources and
the contribution from ATK OB and OD sources.
18
REFERENCES
Auer. 1978. "Correlation of Land Use and Cover with IVIeteoroiogical Anomalies." Journal of Applied
Meteorology, Volume 17, May 1978.
Bulletin of the American Meteorological Society (AMS). 2002. "A Climatological Study of Thermally
Driven Wind Systems of the U.S. Intermountain Wesf. Jebb Q. Stewart, C. David Whiteman,
W. James Steenburgh, and Xindi Bian. Volume 83, Number 5, Pages 699-708, May 2002.
DOE, 1984. The Toxicological Effects of Non-nuclear Pollutants, Section 17-17, Particulates, Department
of Energy Publication "Atmospheric Science and Power Production, Office of Scientific and Technical
Information, United States Department of Energy.
Hanna, S.R., and P.J. Davis (1987): Guidelines for Use of Vapor Cloud Dispersion Models, New York:
Center for Chemical Process Safety, American Society of Chemical Engineers.
Lakes Environmental, 2003a. "IRAP-h View Industrial Risk Assessment Program for Human Health,
Lakes Environmental, Ontario, Canada.
Lakes Environmental, 2003b. "EcoRisk View Ecological Risk Assessment Program". Lakes
Environmental, Ontario, Canada.
NASA, 1973. "NASA/MSFC Multilayer Diffusion Models and Computer Program for Operational
Prediction of Toxic Fuel Hazards", Dumbald, R.K., Bjorkiund, J.R., H.E. Cramer Company for the National
Aeronautics and Space Administration, Marshall Space Flight Center, Alabama.
Kramer, H. E., 1997. "Open Burn/Open Detonation Dispersion Model (OBODM) User's Guide", H. E.
Cramer Company, Sandy, Utah 84091-0411, and West Desert Test Center, U.S. Army Dugway Proving
Ground, Dugway, Utah, DPG Document No. DPG-TR-96-008a, July 1997.
Radian International LLC, 1998. Draft Sampling Results for Alliant "Slum" Emission Characterization,
Volumes 1,2, and 3; Prepared for U.S. Army Dugway Proving Ground Dugway, Utah, March 1998.
Stewart, J. Q., et al. "A Climatological Study of Thermally Driven Wind Systems of the United States
Intermountain Wesf, Bulletin of the American Meteorological Society, Volume 83, Number 5, Page 669,
May 2002.
090904/P R-1
URS Corporation, 2005. "Human Health Risk Assessment in Support of Alliant Techsystems' Bacchus
Works, RCRA Subpart X Activities", Magna, Utah, Final Report, September 2005.
URS, 2008. Sampling Results for USAEC Phase IX Emission Characterization of Exploding Ordnance
and Smoke/Pyrotechnics, URS Group, Inc., Oak Ridge, Tennessee, June 2008.
U.S. Army. Munitions Items Disposition Action System (MIDAS) Database System, website,
https://midas.dac.army.mil/, U.S. Army Defense Ammunition Center, McAlester, Oklahoma.
U.S. Army, January 1992. "Development of Methodology and Technology for Identifying and Quantifying
Emission Products from Open Burning and Open Detonation Thermal Treatment Methods". U.S. Army
Armament, Munitions and Chemicals Command, Rock Island, Illinois.
U.S. Army, 2006. Detailed Test Plan for Phase IX Emission Characterization of Burning
Smoke/Pyrotechnics and Propellants, West Desert Test Center, U.S. Army Dugway Proving Ground,
Utah, April 2006.
U.S. Army, 2009. Sampling Results for Emission Characterization of Open Burning Waste Propellant
Materials, Volume I - Summary Report, Prepared for ATK Launch Systems, Promontory, Utah, Prepared
by U.S. Army Dugway Proving Ground, U.S. Army, 2009.
U.S. Army Defense Ammunition Center (DAC), 2009. Munitions Items Disposition Action System
(MIDAS) database; DAC McAlester, OK.
USEPA, 1987. "Ambient Monitoring Guidance for Prevention of Significant Deterioration (PSD), Office of
Air Quality Planning and Standards, Research Triangle Park, N.C. EPA-450/4-87-007, May, 1987,
USEPA, 1992. Technical Memorandum: "Procedures for Substituting Values for Missing NWS
Meteorological Data for Use in Regulatory Air Quality Models". Office of Air Quality Planning, and
Standards, Research Triangle Park, North Carolina, July 7,1992.
USEPA, 1995a. "User's Guide for The Industrial Source Complex Dispersion Models, Volumes 1 and 11".
Office of Air Quality Planning, and Standards. Emissions, Monitoring, and Analysis Division, Research
Triangle Park, North Carolina. EPA-454/B-95-003a.
USEPA, 1995b. "PCRAMMET User's Guide." Office of Air Quality Planning and Standards. Emissions,
Monitoring, and Analysis Division, Research Triangle Park, North Carolina. October 1995.
090904/P R-2
USEPA, 1997. "Procedures for Preparing Emission Factor Documents", Office of Air Quality Planning
and Standards, Research Triangle Park, North Carolina. EPA-454/R-95-015, November 1997.
USEPA, 2000. "Meteorological Monitoring Guidance for Regulatory Modeling Applications". EPA-454/R-
99-005, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina.
USEPA, 2005, "Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities",
Office of Solid Waste and Emergency Response, EPA530-D-98-001 A, September 2005.
USEPA, 2005. "Guideline on Air Quality Models", Title 40, Code of Federal Regulations Part 51,
Appendix W. November 2005.
USEPA, 2009. AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary
Point and Area Sources, Volume I, Chapter 15: Ordnance Detonation, Section 15.3.22, Pages 15.3-99 to
15.3-102.
090904/P R-3
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2.0 ATK PROMONTORY FACILITY PROCESS 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 (see
Figure 2-1). 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. Figure 2-1 shows the ATK property boundary, the location of the M-136 and
M-225 treatment units, and the on-site meteorological monitoring station. Also located within the
boundary of the Promontory facility is the Autoliv facility (formeriy Morton, Inc.). This facility produces
activators for automobile air bag restraint systems. Autoliv operates as an independent commercial
business and is not associated with ATK.However, explosive and propellant waste materials generated at
Autoliv, are treated by the Promontory facility at the M-136 treatment unit.
2.1 FACILITY OPERATIONS
Both hazardous and non-hazardous solid wastes are generated and managed at the facility. Hazardous
wastes generated at the facility include waste such as solvents, metals (primarily aluminum), and reactive
wastes including 1.1 propellant, 1.3 propellant, propellant contaminated waste, reactive laboratory waste,
waste solid rocket motors, propellant ingredients such as nitroglycerin, ammonium perchlorate, aluminum,
cyclotetraethylenetetranitramine (HMX), and similar propellant, explosive and pyrotechnic ingredients.
Reactive wastes are treated by open burning and open detonation at the M-136 Unit and the M-225 Unit.
The location of the M-136 and M-225 treatment units is shown in Figure 2-1.
2.2 TERRAIN AND SITE DESCRIPTION
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, respectively
(see Figure 2-1). 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 environment extending out to 6.2 miles (10 kilometers) from both treatment units can be
characterized as complex terrain.
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 western boundary of the facility (see Figure 2-1).
090904/P 2-1
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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 various birds, rabbit, and predator species.
2.3 TREATMENT UNIT LOCATIONS
ATK Launch Systems conducts open burning and open detonation of reactive wastes at two treatment
units: (1) the main facility, M-136, located centrally to the two main manufacturing sites; and (2) M-225
located in a remote development location called Plant III. The location of each treatment unit (in
relationship to the Promontory facility boundary) is shown in Figure 2-1. Variable scale drawings of the
M-136 treatment unit are shown in Figures 2-2, 2-3, and 2-4 and for the M225 treatment unit in
Figures 2-5 and 2-6. A detailed description of the treatment activities and waste profiles for M-136 and
M-225 is presented in Sections 3.1 and 3.2, respectively.
The waste materials treated at M-136 and M-225 are either placed into burn pans, on the ground or in
detonation pits. Some of burn pans are lined with soil at M-136. M-136 only has six trays that are
routinely lined with soil. Three trays are use for a burn event and then the other three trays will be used
for the next burn event. M-225 does not have any soil lined trays. As a result, soil lined trays will be
assumed only for M-136.
The criteria used ATK to determine if a burn tray should be lined with soil is: 1) if the waste being loaded
into the tray is on a pallet, and will be handled with a forklift, the tray will have soil installed allowing the
forklift to set the pallet on a pad of soil that is not recessed lower than the upper lip of the burn tray. 2) if
the waste propellant being burned will generate extremely high temperatures, soil will be installed in the
bottom of the steel tray to protect the structural integrity of the tray.
In an effort to reduce the potential impact to soil surrounding each treatment unit, ATK uses a
combination of post-burn operating procedures and annual soil sampling. The post-burn operating
procedures are designed to minimize the impact to soil by collecting any waste materials that have
ejected to the soil during the treatment process. The soil monitoring program is designed to periodically
monitor concentrations of emission products in the soil to determine the relative impact of each treatment.
The post-burn activities include the following operating procedures:
• Following treatment, the ATK shall conduct the post-burn inspection activities and post-burn
clean-up activities as identified in Attachment 11 of the draft Permit, and shall comply with
090904/P 2-2
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Conditions IV.C.1, 2 and 3, and shall have completed and complied with all provisions of
Conditions, IV.E and F.
• The post-burn inspection shall be conducted within 24 hours of completing a treatment event, and
perform the following unless one of the exceptions identified in IV.G.2.j or k applies:
> Prior to entering the treatment area, the operators shall deactivate the firing control system
and remove the interiock;
> Document any treatment unit with an open flame, hot spot or smoldering residue;
> Document any treatment unit with unburned residue;
> Document any treatment unit with unburned reactive hazardous waste and identify if possible
in the operating record why the waste did not burn
The post-burn activities also included inspecting the burn areas for any unburned waste that was ejected
from a treatment unit during the last treatment event. Such waste shall be picked up and placed in a
treatment unit.
2.3.1 M-136 Treatment Activities
M-136 is the primary treatment unit for conducting open burning at the Promontory facility. Open
detonation is also conducted at M-136 which is a secured fenced facility within the main facility fence.
The layout of the M-136 treatment unit (showing all burn stations) is provided in Figures 2-2 through 2-4.
The M-136 Burn Grounds is comprised of 14 burn stations. Open burn treatment is conducted at all burn
stations. However, open detonation treatment is only conducted at Stations 13 and 14. The burn stations
are located in three general areas and are aligned in an east-west direction across the treatment unit.
The change in elevation between the three general areas is relatively minor (less than 20 feet per area).
Burn Stations 1 through 12 are located in one treatment area that measures approximately 820 feet x
574 feet. All Burn Stations are located within a 394-foot radius of the center of the area represented by
the active burn stations. Burn Station 13 is located approximately 820 feet due east of Burn Stations 1
through 12. Burn Station 14 is located approximately 820 feet due east of Burn Station 13.
Open burning is conducted at ground level in burn trays. Burning trays are constructed in several different
sizes including, 4'X10', 5'X16', 8'X8', and 8'X20'. These trays are constructed to contain the propellant
and withstand the intense heat from the open burning process. They are made from steel plate A36 grade
steel ranging thicknesses of 3/8", Vz", and 1 inch.
Lids for the burn trays may be used during the wet weather months to keep moisture out of the trays. If
the trays are empty, they may also be turned upside down to avoid the collection of moisture in the empty
090904/P 2-3
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trays. If excess water exists in the burn trays, a sump truck is used to remove the water and then taken to
the M-705 wastewater treatment facility. The trays may be lined with soil to facilitate burning operations;
however, most trays do not contain soil. The number of trays at each burn station varies. Burn stations 1
through 12 typically have 15 burn trays, Burn Station 13 typically has six trays. Burn station 14 is used
to open burn motors. Operation of this station is described below. Trays may be moved between
stations as needed.
Open detonation is conducted at either Burn Station 13 or 14. Based on Quantity Distance (QD)
limitations, open detonation may be preformed aboveground or underground in a hole or pit, depending
on the item to be detonated.
The M-136 Burn Grounds also has three specially designed disposal units that are used to handle the
disposal of rocket motor igniters, small rocket motors, and other items that have the potential to become
propulsive. These disposal units are the Clamshell Disposal tray, Sandbox Disposal tray, and Small Motor
Disposal vaults, which are used to contain the propulsive force of the igniters and small rocket motors, but
allow for safe disposal.
The Clamshell Disposal tray is used for the disposal of closed end rocket motor igniters, and other items
that have the potential to be propulsive. The Clamshell Disposal tray is a square welded box 1-inch thick,
A36 steel plate with a vented lid that enables the potentially propulsive items to be burned, while safely
containing the propulsive energy. The Clamshell Disposal tray is portable and can be used at several
burn stations ranging from 1 through 13.
The Sandbox Disposal tray is used for the disposal of open-end rocket motor igniters, and other items
that have the potential to be propulsive. It is constructed of 1-inch thick A36 steel plate welded into a
square box that is filled with sand, and has four 1-inch thick steel tubes sitting on end in the sand. The
potentially propulsive items are placed in the tubes allowing the exhaust to vent out of the open end of the
steel tubes. Steel bars are then slid into the end of the exposed tubes to contain the igniters. The
Sandbox Disposal tray is portable and can be used at several burn stations ranging from 1 through 13.
The two Small Motor Disposal vaults are constructed from a concrete 10x10 foot sump filled with sand.
The small rocket motors such as the STAR motor are placed into the sand with the aft end exposed
perpendicular to the ground. The motors are then burned with the propulsive force directed into the
concrete sump and the sand. These small motor disposal vaults are located at Burn Station 9:
Large-scale obsolete rocket motors are open burned at Burn Station 14. The rocket motor is positioned
near Station 14 and is offloaded by a mobile crane. The obsolete motor is placed on sand or wooden
090904/P 2-4
Rev 2
blocks in Station 14. Systems of Linear Shaped Charges (LSC) are then placed on the rocket motor to
split the rocket motor case, rendering it non-propulsive allowing the open burning of the rocket motor
while it is still being burned within the existing rocket motor case. This also allows the rocket motor case
to act as the "burn tray" for the burning propellant.
The firing stanchions electrical circuits for each burn station are buried underground throughout the
Burning Grounds. Burn Stations 1 through 12 contain a multiple firing stanchions (firing posts) for each
burn station. Burn Stations 13 and 14 have a single firing stanchion for each burn station. The electrical
components for the relays, power supply, etc. are located in Bunker M-136. A heavy steel pylon is
located in each firing stanchion containing the ignition wire. This steel pylon is to protect the electrical
equipment from the intense heat generated during the open burning event. An electrical igniter is placed
in a minimum of one tray for each firing stanchion for the burn event.
Several safety interlocks are in place at M-136 to prevent inadvertent ignition of the system while
operators are in the Burning Grounds. Ignition of all the burning pans is completely remote and controlled
by a system of switches in the M-136 control bunker. Before initiating a burn, the resistance of each
circuit is tested to ensure all of the connections have been made properiy. Pressing the system activation
button initiates a warning siren. A siren will sound for approximately 40 seconds and the ignition system is
then armed and ready to fire. The ignition switches located in the control bunker can then ignite the rows
and stanchions that are selected. Generally, all firing stanchions that contain waste to be burned are
ignited consecutively with a delay between ignitions of firing stanchions. The burn is observed and
recorded in the control bunker via a closed circuit television system.
No entrance is allowed into the M-136 Burn Grounds during the burning process. After a burn, a 16-hour
waiting period is normally required prior to entering the area in the Burnings Grounds where the burn was
conducted. Entrance is then permitted and a thorough check for abnormalities that may have occurred
during the burn is done. This check involves looking for reactive material that was not completely treated
and may have left the burn trays during the burn event, or resulted from an unplanned detonation. Any
unburned reactive material is collected and placed in the nearest tray to be re-burned, A forklift is then
used to carry and dump the trays containing the burn ash to the Industrial Waste Trench (IWT) located in
the far eastern end of the M-136 Burn Grounds. If a burn event occurs at the end of the working week
such as Thursday, the ash generally is not transported to the IWT until the beginning of the next
workweek. A forklift or a backhoe is used to carry the large-scale obsolete rocket motor cases for
disposal in the IWT.
Table 2-1 presents a list of the M-136 sources, burn stations, wastes treated, model quantities, and
established daily and annual treatment limits. The established daily and annual treatment limits
090904/P 2-5
Rev 2
presented in Table 2-1 are based on draft permit conditions prepared by UDSHW in 2010, The air
dispersion modeling for each M-136 treatment source will be conducted using the "Model Quantity"
shown in column 4 of Table 2-1.
Open burning may occur daily at M-136. However, treatment usually takes place 3 days a week
(Tuesday through Thursday) during the afternoon hours when dispersion parameters are most favorable.
When wind velocity exceeds 15 miles per hour, disposal by burning cannot occur. This restriction is an
internal wind speed set by ATK's Fire Department to avoid conditions that could promote a fast moving
and spreading grass fire. Disposal operations are normally conducted between the hours of 1000 and
1800 hours.
Waste material is delivered to the Burn Grounds and packaged in a variety of containers and sizes
including but not limited to super sacks, conductive/static dissipative bags, and buckets. The Bacchus
waste is received in conductive/static dissipative bags and cardboard/wood containers. Autoliv waste is
received in high-density polyethylene bags and cardboard containers.
Some waste materials are desensitized prior to transporting to the M-136 Burn Grounds with shingle oil,
diesel fuel, or triacetin. The requirement to desensitize is identified in the waste profile system. This is
done to ensure the safe handling of static sensitive materials.
Material delivered to M-136 may be offloaded from the vehicle into the burn trays by hand, khuckle-boom-
crane, or by forklift. During tray loading, the vehicle is parked next to the receiving tray, then the
appropriate side rails on the trailer are lowered and the web belts are removed, if necessary, allowing the
material to be offloaded and placed into the burn tray.
The burn trays are inspected prior to loading. The burn tray inspection criteria includes: (1) holes in the
tray; (2) weld cracks; and (3) a minimum of 6-inches depth or wall height. The inspection is documented
in the Daily Propellant Log. Trays that fail the inspection are removed from service. The trays are also
checked for hot spots from the previous burns.
Typical waste treatment at M-136 includes but is not limited to 1.1 propellant, 1.3 propellant, propellant
contaminated waste, reactive laboratory waste, waste solid rocket motors, propellant ingredients such as
nitroglycerin, ammonium perchlorate, aluminum, cyclotetraethylenetetranitramine (HMX), and similar
propellant, explosive and pyrotechnic ingredients. Similar wastes are also received from Autoliv, other
ATK locations, and on rare occasion from other Department of Defense/government facilities. All wastes
received from off-site sources such as Autoliv and other ATK sites are burned within 14 days.
090904/P 2-6
Rev 2
The M-136 treatment unit consists of 14 Burn Stations. Open burning of reactive waste can be conducted
at Burn Stations 1 through 13. However, ATK's operating convention is to open burn reactive laboratory
waste at Burn Station 13, although some laboratory wastes, such as propellant test loaves may be
burned at Stations 1 through 12. The amount of laboratory wastes treated at Burn Station 13 constitutes
less than 1 percent of the total waste treated annually at M-136. Operation of Burn Station 14 has been
described previously.
Except for EPA waste numbers exempted by rule, reactive wastes with listed EPA waste numbers are
identified, and isolated from other material enabling the ash to be collected and shipped offsite for
disposal.
2.3.2 M-225 Treatment Unit
The M-225 treatment unit receives small amounts of the reactive waste materials from the Plant III
propellant development area. The waste containers are labeled and the material is stored in 90-day
storage on the wastes docks and then transferred to M-225 for treatment. The M-225 treatment unit is
surrounded with an 8-foot high chain link fence. The waste materials are treated via open burning or
open detonation. Open detonation is conducted no more than once per day. Open detonation at M-225
generally occurs once every three weeks. The layout of M-225 is shown in Figures 2-5 and 2-6.
Table 2-2 presents a list of the M-225 sources, biirn stations, wastes treated, model quantities, and
established daily and annual treatment limits. The established daily and annual treatment limits
presented in Table 2-2 are based on draft permit conditions prepared by UDSHW in 2010. The air
dispersion modeling for each M-225 treatment source will be conducted using the "Model Quantity"
shown in column 4 of Table 2-2.
The burn trays at M-225 are inspected once a week. The burn tray inspection criteria includes: (1) holes
in the tray; (2) weld cracks; and (3) a minimum of 6-inches depth or wall height. The inspection is
documented in the Daily Propellant Log. Trays that fail the inspection are removed from service. The
trays are also checked for hot spots from the previous burns. The M-225 treatment unit has the capability
of using the sump truck to remove the excess water from the trays and have it treated at the M-705
hazardous wastewater treatment plant.
Within the M-225 Burn Grounds are four burn stations with one burn stanchion in each station, and one
tray per station. Unlike M-136 operations, the trays at M-225 are not moved from one burn station to
another. Burn tray construction is comparable to those used at the M-136 Burn Grounds. The trays may
be lined with soil to facilitate burning operations; however, most of the trays do not contain soil.
090904/P 2-7
Rev 2
The M-225 treatment activities are very similar to the operations at M-136 with only a few differences. At
M-225, treatment typically occurs less frequently, and involves smaller quantities of waste material
(600 pounds or less). During the burn event, a burn tray is ignited and allowed to burn down, and then the
next tray is ignited. This routine is followed until all the trays have completed burning. The re-entry
waiting time following a burn event at M-225 is 16 hours. Open detonation is conducted at a designated
location within the M-225 fenced area. Based on QD limitations, open detonation may be preformed
aboveground or underground in a hole or pit, depending on the item to be detonated.
The M-225A building is the control bunker that contains the system for firing the igniters that are placed in
the burn trays. The firing system functions in the same manner as the M-136 treatment unit, which has
been described previously.
The reactive wastes treated by open burning at M-225 include neat double base (1.1) propellants and
composite propellants (1.3), as well as, reactive contaminated materials such as cloth and paper wipes,
metal containers, plastics, and propellant ingredients. Reactive wastes are collected in a variety of
containers and sizes including but not limited to super sacks and buckets lined with conductive/static
dissipative bags that may contain desensitized ingredients that are the same as those used for wastes at
M-136.
With the exception of U.S. EPA, waste numbers exempted by rule, the ash resulting from the treatment of
reactive wastes at M-225, with listed EPA waste numbers, is collected and shipped for offsite disposal.
Ail other ash is sent for disposal in the M-136 IWT. A sump truck is used to remove excess water in the
burn trays. The collected water is then taken to the M-705 wastewater treatment facility.
090904/P 2-8
TABLE 2-1
M-136 RISK ASSESSMENT TREATMENT UNIT
WASTES TREATED, TREATMENT LIMITS, AND MODEL QUANTITY
Modeled
Sources
Burn
Stations
Treated
Reactive
Waste
Categories
Model
Quantity
Established Daily Quantity
Limits
Total
Annual
Burn Limit
(lbs.)
106,500 lbs. per day consisting
of:
• 1.1 pure
propellant/contaminated
material from all burn stations
or
• 1.3 pure
propellant/contam inated
material from all burn stations
or
• 50,000 lbs Reactive
Category E/Flare Illuminate
propellant/contam inated
material from all burn stations
Source 1
Open Burn
1,2,3,4,5,6,7,
8,9.10,11,12
A, B, C. D, E,
F,G,H 106,500 lbs
• 1.1 pure
propellant/contaminated
material from all burn stations
or
• 1.3 pure
propellant/contam inated
material from all burn stations
or
• 50,000 lbs Reactive
Category E/Flare Illuminate
propellant/contam inated
material from all burn stations
7,500,000
• 1.1 pure
propellant/contaminated
material from all burn stations
or
• 1.3 pure
propellant/contam inated
material from all burn stations
or
• 50,000 lbs Reactive
Category E/Flare Illuminate
propellant/contam inated
material from all burn stations
50,000 lbs per day consisting of:
• 1.1 pure
propellant/contaminated
material for one burn station
or
• 1.3 pure
propellant/contaminated
material for one burn station
or
• 5,000 lbs Reactive Category
E/Flare Illuminate
propellant/contam inated
material for one burn station
or
• Miscellaneous reactive lab.
chemicals
Source 2
Open Burn 13 A, B, C, D, E,
F. G,H 50,000 lbs
50,000 lbs per day consisting of:
• 1.1 pure
propellant/contaminated
material for one burn station
or
• 1.3 pure
propellant/contaminated
material for one burn station
or
• 5,000 lbs Reactive Category
E/Flare Illuminate
propellant/contam inated
material for one burn station
or
• Miscellaneous reactive lab.
chemicals
496,400
50,000 lbs per day consisting of:
• 1.1 pure
propellant/contaminated
material for one burn station
or
• 1.3 pure
propellant/contaminated
material for one burn station
or
• 5,000 lbs Reactive Category
E/Flare Illuminate
propellant/contam inated
material for one burn station
or
• Miscellaneous reactive lab.
chemicals
Source 3
Open Burn 14 A, B, C, D 106,500 lbs
106,500 lbs per day consisting
of:
• 1.1 rocket motor
or
• 1.3 rocket motor
2,000,000
Source 4
Open
Detonation
13414 C, D,G, H 600 lbs
600 lbs per day consisting of:
• 1.1 article
or
• 1.3 article
3,600
Ml 36 Maximum Treatment Quantities 106,500 lbs 10,000,000
TABLE 2-2
M-225 RISK ASSESSMENT TREATMENT UNIT
WASTES TREATED, TREATMENT LIMITS, AND MODEL QUANTITY
Modeled
Sources
Burn
Stations
Reactive Waste
Categories
Model
Quantity
Established Daily Quantity
Limits
Total
Annual
Burn Limit
(lbs.)
Source 1 *
Open
Burning
1,2.3,4 A, B, C, D, E. F.
G. H
4.500 lbs 4.500 lbs/day consisting of:
• 1.1 pure
propellant/contaminated
material from all burn stations
or
• 1.3 pure
propellant/contam inated
material from all burn stations
or
• 500 lbs Reactive
Category E/Flare Illuminate
propellant/contaminated
material from all burn stations
52.500 lbs 4.500 lbs/day consisting of:
• 1.1 pure
propellant/contaminated
material from all burn stations
or
• 1.3 pure
propellant/contam inated
material from all burn stations
or
• 500 lbs Reactive
Category E/Flare Illuminate
propellant/contaminated
material from all burn stations
4.500 lbs/day consisting of:
• 1.1 pure
propellant/contaminated
material from all burn stations
or
• 1.3 pure
propellant/contam inated
material from all burn stations
or
• 500 lbs Reactive
Category E/Flare Illuminate
propellant/contaminated
material from all burn stations
Source 2*
Open
Detonation
1 C. D, G, H 600 lbs 600 lbs per day consisting of:
• 1.1 article
or
• 1.3 article
2,500 lbs
M225 Maximum Treatment Quantities 4.500 lbs 55.000 lbs
' Assumes Sources 1 and 2 will use same 1.1 and 1.3 emission factors used at M136.
Rev. 2
3.0 WASTE CONSTITUENTS/EMISSIONS CHARACTERIZATION
In order to conduct a risk assessment of ATK treatment operations, it is necessary to characterize the
waste constituents and emission products of the formulations that are treated via OB and OD at M-136
and M-225. The principal waste formulations treated at ATK include 1.1 and 1.3 class waste propellant
materials and flare wastes. The waste constituents and emissions associated with these formulations
have been characterized based on the following information:
• ATK detailed descriptions of reactive waste categories and associated reactive waste profiles - see
Section 3.1
• ODOBi emission test results for Class 1.3 propellants - See Section 3.2.1
• Bang Box emission test results for Class 1.1 propellants - See Section 3.2.2
• ODOBi emission test results for military ordnance illumination cartridges, which have similar
composition to flare wastes - see Section 3.2.3
The potential for air emissions associated with ATK treatment operations can result from pretreatment,
treatment, and post-treatment activities. Pretreatment emissions are very limited and primarily related to
the volatilization of some D003 type waste materials that are treated in burn pans. All waste materials are
delivered to each treatment unit in bags or other closed containers and are placed in the burn pans. The
waste materials remain in the bags or other closed containers , which prevents the wind dispersal of solid
waste materials prior to actual treatment process.
The potential for post-treatment emissions are limited to wind dispersal of burn pan ash. However. ATK
utilizes operating procedures that greatly reduce or eliminate the potential for wind blown emission of
solid materials from the burn pans. For example, the ash from treatment operations is collected following
a treatment event as soon as conditions are considered safe. The collected ash is either placed in a
covered drum for offsite disposal or placed in an onsite landfill. In addition, burn pan covers are used
whenever conditions prevent cleanout in a timely manner. In addition, the pans are covered after clean
out or tumed upside down to prevent precipitation from collecting in the pans.
As a result, fugitive emissions from pre-treatment and post-treatment operations are considered
insignificant and are not discussed in this protocol. The remainder of Section 3 pertains to the
characterization of emissions from ATK treatment events.
090904/P 3-1
Rev. 2
3.1 WASTE CHARACTERiZATiON
The reactive wastes open burned and open detonated at M-136 and M-225 are classified into company-
defined reactive categories A through H, which are described in Table 3-1. In order to facilitate the safe
handling of these reactive wastes, ATK further characterizes these waste materials into waste profiles,
which are shown in Table 3-2. Table 3-2 identifies the profile reference number, general description, and
summary of profile constituents associated with each reactivity group. Table 3-3 contains a separate
waste characterization for reactive category G. Profile Number PR53, which contains reactive and
unstable laboratory waste chemicals. ATK has developed specific in-house handling and disposal
instructions for each waste profile in order to avoid potential accidents from mishandling of these highly
energetic materials. Table 3.4 presents the ATK profile reference numbers associated with Autoliv waste
materials within reactive category E.
M-136 Treatment Unit
As described in Section 2.3.1, the M-136 treatment unit is composed of 14 burn stations that are located
in three general areas. Figure 2-3 shows the layout of each treatment station. Based on the treatment
processes and relative location of the 14 burn stations, the emission sources for M-136 can be
represented by three separate treatment sources for OB and one source for OD.
The table below identifies the M-136 emission sources that will be evaluated in the air dispersion
modeling analysis. The table also identifies the burn/detonation stations and reactive waste categories
that are treated at each source. In summary. M-136 treats 1.1 and 1.3 class wastes and flare wastes
associated with reactive category E.
M-138
Emission Sources
Burn/Detonation
Stations Reactive Waste Categories Treated
Open Burning Source 1 1,2, 3, 4, 5, 6. 7. 8,
9. 10, 11, 12
A, B. C. D. E. F, G, H
(1.1 and 1.3 class wastes)
Open Burning Source 2 13 A, B. C. D, E, F, G, H
(1.1 and 1.3 class wastes)
Open Burning Source 3 14 A, B. C, D
(1.1 and 1.3 class wastes)
Open Detonation Source 4 14 C, D, G, H
(1.1 and 1,3 class wastes)
090904/P 3-2
Rev. 2
M-225 Treatment Unit
As described in Section 2.3.2, the M-225 treatment unit is composed of four OB stations and one OD
station. Figure 2-6 shows the layout and relative location of the burn trays and OD pit. Based on the two
types of treatment processes, the emission sources for M-225 can be represented by two separate
treatment sources.
The table below identifies the M-225 emission sources that will be evaluated in the air dispersion
modeling analysis. The table also identifies the associated burn/detonation stations and reactive waste
categories that are treated at each source. In summary, M-225 treats 1.1 and 1.3 class wastes and flare
wastes associated with reactive category E.
M-225 Emission Source Burn/Detonation
Stations Reactive Waste Categories Treated
Open Burning Source 1 1 A. B. C. D, E, F, G, H
(1.1 and 1.3 class wastes)
Open Detonation Source 1 1 C. D. G, and H
(1.1 and 1.3 class wastes)
3.2 Emissions Characterization
A review of ATK treatment operations for the annual periods 2006. 2007. and 2008 indicates that the
ovenwhelming majority (96 percent) of wastes treated at ATK have been associated with reactive
category A, 1.3 class propellants. The inset table below summarizes the treatment quantities for all
reactive groups for the 3-year period. The 1.1 class propellants and Category E flare reactive groups
constituted only about two and one percent, respectively, of the total wastes treated.
Reactivity Group Class Waste Total Waste (ibs.)
Percent of Total
Burned
A 1.3 16791730 96.31%
B 1.3 15953 0.09%
C 1.1, 1.3 242682 1.39%
D 1.1 127530 0.73%
E Flares 207296 1.19%
F 1.3 43043 0.25%
G 1.1, 1.3 6487 0.04%
H 1.1, 1.3 108 <0.01%
Total 17434829 100.0%
The emission factors being proposed by ATK for the treatment of 1.1 and 1.3 class propellants and
category E flare are based on emissions testing of actual ATK waste materials. The emissions testing
090904/P 3-3
Rev. 2
was conducted at the Dugway Proving Ground (DPG), Open Detonation Open Burn Improved (ODOBi)
test chamber in Dugway, Utah. The emission factors being proposed for 1.3 and 1.1 class propellants
are discussed in Sections 3.2.1 and 3.2.2, respectively.
Emissions testing has not been conducted to characterize emissions associated with the treatment of
category E flare wastes, which include ATK flares and Autoliv reactive wastes. However. ATK is
proposing to use U.S. EPA. AP-42 (U.S.EPA, July 2009) ordnance specific emission factors to address
the impact from treatment of category E flares and Autoliv waste materials. The AP-42 emission factors
are based on open detonation emission testing of specific military ordnance (illuminating cartridges),
which have ingredients similar to the wastes associated with ATK category E flares. The emission factors
being proposed for ATK category E flares and Autoliv waste are discussed in Section 3.2.3.
3.2.1 Class 1.3 Waste Emission Factors
Although the waste materials treated at M-136 and M-225 include 1.1 and 1.3 class materials, the
majority of wastes treated by ATK are 1.3 class wastes. In 2006, ATK conducted emissions testing at the
DPG to obtained emission factors for Class 1,3 materials. The ODOBi test chamber was used to
determine emission factors for airborne compounds from three different compositions of Class 1.3
process waste (PW) materials. The tests were conducted from June 7 to 15, 2006. Test results are
presented in the report titled Sampling Results for Emission Characterization of Open Burning Waste
Propellant Materials (U.S. Army, 2009).
Emissions were measured from simulated OB events of the following three waste scenarios that are
considered representative of 1.3 class propellant waste:
• PWlOO: 100% ammonium perchlorate (AP) propellant
• PW85-15: 85% AP propellant + 15% trash
• PW65-35: 65% AP propellant + 35% trash
The first material (PW100) was 100% Class 1.3 propellant. The other two test materials (PW85-15 and
PW65-15) consisted of a mixture of Class 1.3 propellant blended with different percentages of materials
such as cloth, paper, paper wipes, plastics, and cleaning items. The PW85-15 trash sample was
determined by conducting a 2-week-long survey of the types and quantities of contaminated waste
coming from each live-area waste dock. The 15% trash ration was based on an analysis of daily
treatment data for the past 3 years. This sample is intended to be representative of most of the Class 1.3
contaminated waste streams treated at the ATK. The PW65-35 trash sample was determined in a similar
manner.
090904/P 3-4
Rev. 2
It is important to note that the 1.3 waste testing resulted in numerous analytical results being reported as
"non-detecf or "below background". Based on a re-evaluation of key aspects of the test, including non-
detects, blank corrections and how background values were used, the UDSHW has determined that the
inherent uncertainty associated with the emissions test and calculation of 1.3 emission factors needs to
evaluated using two data sets that reflect the range of possible emissions based on the available data.
The first emission factor data set consists of a more "conservative" data set uses the full method detection
limit (MDL) for non-detected compounds and background and blank values have not been subtracted out
from the test results. Table 3-5 shows the "conservative" emission factor data set, which represents the
average emission factor for all three test scenarios (PW100, PW85-15, and PW65-35).
The second set of emissions data represents a "corrected" (less conservative) set proposed by ATK in
which all non-detects are replaced with Vz MDL (or "^h EDL) and background/blank correction has been
performed. Table 3-6 shows the "corrected" emission factor data set, which represents the average
emission factor for all three test scenarios (PWlOO, PW85-15, and PW65-35).
Using the two sets of emissions data to assess risk will penmit evaluation of the potential impacts of some
of the uncertainties in the emissions data. This proposal assumes that the risk results of the
conservative, or uncorrected data set will be evaluated and if emissions are acceptable, no further
analysis is required. If some of the emission factors in the conservative data set produce an
unacceptable risk and the "corrected" data set does not. the risk results will be reviewed to determine if
using the less conservative estimate of emissions is justified.
The "conservative" and "corrected" emission factors for treatment of class 1.3 waste materials presented
in Tables 3-5 eind 3-6, respectively, have been approved by the UDSHW for use in the ATK evaluation of
Class 1.3 materials. The emission factors shown in Tables 3.5 and 3.6 represent the maximum emission
factors for all test burns conducted for each mix of waste materials (PW100, PW85-15, and PW65-15).
This approach is consistent with the USEPA recommendation in Section 2.2.1 (Estimating Stack
Emissions for Existing Facilities) of the Human Health Risk Assessment Protocol for Hazardous Waste
Combustion Facilities (USEPA, 2005), which states that risk assessments should utilize the maximum of
the three emission test rates.
3.2.2 Class 1.1 Waste Emission Factors
In September of 1997, samples representative of Class 1.1 explosive waste from the ATK Thiokol
Bacchus facility were tested and characterized at the Dugway Proving Grounds Bang Box chamber. Test
results are provided in the report titled Draft Sampling Results for Alliant "Slum" Emission
Characterization (Radian, 1998). These waste materials are considered representative of the 1.1 waste
090904/P 3-5
Rev. 2
materials treated at the M-136 and M-225 treatment units. Each test sample weighed about 3.8 pounds.
The materials tested included combinations of Class 1.1 propellants along with contaminated materials
such as cloth and paper wipes, plastics, and cleaning items as simulated in the 1.3 emission test
scenarios. The assumed combination of propellant and contaminated materials was 65 percent and 35
percent, respectively.
The 1.1 emission factors assigned half the detection level for all nondetect results. A few semi-volatile
and dioxin/furan compounds were tentatively but not positively identified by mass spectroscopy. These
compounds were originally considered non-detects but were switched to full detects for conservatism.
The Toxic Equivalency Factors (TEFs) for dioxins/furans are based on the World Health Organization
(WHO) recognized TEFs,
Table 3-7 shows the proposed emission factors for Class 1.1 materials that will be used in the risk
assessment for the evaluation of Class 1.1 materials treated at the M-136 and M-225 treatment units.
3.2.3 Category E Emission Factors
As indicated above, ATK has not conducted emissions testing for specific types of Category E waste
materials, which include ATK flare-type wastes and Autoliv wastes (reactive air bag waste). The DEQ
has requested ATK to address the treatment of these materials in the HHRA. In the absence of test data,
ATK is proposing to use ordnance specific emission factors to account for treatment of the specific
Category E waste materials identified above. The emission factors selected to represent treatment of
these waste materials are based on the detonation of specific military ordnance items, primarily
illuminating cartridges, which have ingredients that are similar to the illuminants (flares) associated with
Category E materials (see Table 3-1).
ATK manufactures three types of military/commercial flares: (1) a visible illumination flare; (2) a near
infrared illumination flare: and (3) a decoy flare. A comparison between the Munitions Items Disposition
Action system (MIDAS) database and the U.S. EPA AP 42 (Section 15.3.22). Compilation of Air Pollutant
Emission Factors website was done to locate surrogate flare emission factor from AP-42 and determine
the ingredients of the surrogate from the MIDAS data base. Two flares were found that were similar in
base ingredients and had existing emission factors in AP 42. The M816 IR Illumination Cartridge and the
M314 Illumination Cartridge were found to contain similar base ingredients to ATK's near infrared
illumination flare and the visible illumination flare.
The characterization of M816 emissions is based on open detonation emissions testing conducted at the
Dugway Proving Grounds, Utah. Details regarding the testing are described in the final test report titled
Sampling Results for USAEC Phase IX Emission Characterization of Exploding Ordnance and
090904/P 3-6
Rev. 2
Smoke/Pyrotechnic (URS. 2008) and the document titled Detailed Test Plan for Phase IX Emission
Characterization of Burning Smoke/Pyrotechnics and Propellants (U.S, Army. 2006). Information
presented in Section 15.3.22 of U.S. EPA's AP-42 Emission factor website indicates that the C484. M816
81-mm Infrared (IR) Illumination Cartridge (DODIC C484) is a pyrotechnic mortar that is used to provide
infrared illumination.
A comparison of emission factors from the M816 IR Illumination Cartridge and the M314 Illumination
Cartridge was conducted and the M816 IR Illumination Cartridge presented the most conservative
emission factors, and as a result, was selected as the best surrogate currently available.
Table 3-8 presents emission factors being proposed to evaluate the treatment of Category E ATK flare-
type wastes and Autoliv wastes.
090904/P 3-7
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 1 OF 6
Analyte Maximum Emission Factor
(lb/lb)
Particulates
TSP 1.5E-01
PM10 1.2E-01
PM2.5 6.0E-02
Metals
Aluminum 4,00E-02
Antimony 2.86E-05
Arsenic 5.53E-07
Barium 9,82E-06
Beryllium 2.21 E-07
Cadmium 6.14E-07
Chromium 2.01 E-05
Cobalt 6.14E-07
Copper 2,52E-05
Lead 4.11 E-05
Magnesium 8,19E-05
Manganese 9,42E-05
Mercury 7.37E-08
Nickel 5.79E-05
Phosphorus 1.09E-04
Selenium 1.61 E-06
Silver 1.19E-06
Thallium 4.30E-06
Zinc 3.53E-05
Perchlorates 4,91 E-07
SVOCs
1,2,4,5-Tetrachlorobenzene 5.48E-07
1,2,4-Trichlorobenzene 6.46E-07
1,2-Dichlorobenzene 5.59E-07
1,2-Dlphenylhydrazlne 5,48E-07
1,3,5-Trinitrobenzene 5.48E-07
1,3-Dichlorobenzene 6,24E-07
1,3-Dlnitrobenzene 5,70E-07
1,4-Dichlorobenzene 5,81 E-07
1 -Chloronaphthalene 5.48E-07
1-Naphthylamine 1.1 OE-05
2,3,4,6-Tetraohlorophenol 7.12E-07
2,4,5-Trichlorophenol 1.42E-06
2,4,6-Trichlorophenol 1.31 E-06
2,4-Dichlorophenol 9,26E-07
2,4-Dimethylphenol 6,90E-06
2,4-Dinitrophenol 2,41 E-05
2,4-Dinitrotoluene 5,4BE-07
2,6-Dlchlorophenol 5.48E-07
2,6-Dlnltrotoluene 5.63E-07
2-Acetylaminofluorene 5.48E-07
2-Chloronaphthalene 5.48E-07
2-Chlorophenol 1,92E-06
2-Methylnaphthalene 3,5BE-06
2-Methylphenol 3,29E-06
2-Naphthylamine 1.1 OE-05
2-Nitroaniline 5.48E-07
2-Nitrophenol 5.48E-07
3,3'-Dlchlorobenzldlne 8,11E-Q6
3,3'-DimBthyl benzidine 5.48E-05
3-Methylcholanthrene 5,48E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 2 OF 6
Analyte Maximum Emission Factor
(lb/lb)
3-Methylphenol & 4-MethylphenoI 2.igE-06
3-Nitroanlllne 2.19E-06
4,6-DinitrQ-2-methylphenol 9,53E-06
4-Aminoblphenyl 1.1 OE-05
4-Bromophenyl phenyl ether 5.48E-07
4-Chloro-3-methylphenol 6.79E-07
4-Chloroaniline 6.57E-06
4-Chlorophenyl phenyl ether 5.48E-07
4-Nitroanlline 2.19E-06
4-Nltrophenol 3.61 E-06
7,12-Dimethylbenz(a)anthracene 5.59E-07
Acenaphthene 5.48E-07
Acenaphthylene 5.48E-07
Acetophenone 2,68E-06
Aniline 8.00E-06
Anthracene 5.48E-07
Benzidine 5.59E-05
Benzo(a)anthracene 6,35E-07
Benzo(a)pyrene 5,48E-07
Benzo(b)fluoranthene 1.20E-06
Benzo(ghi)perylene 6.79E-07
Benzo(k)fluoranthene 1.75E-06
Benzoic acid 6.24E-05
Benzyl alcohol 3.83E-05
bis(2-Chloroethoxy)methane 5.48E-07
bis(2-ChIoroethyl) ether 6.13E-07
bis(2-Chloraisopropyl) ether 8.32E-07
bls(2-Ethylhexyl) phthalate 1.1 OE-05
Butyl benzyl phthalate 6.68E-07
Carbazole 7.01 E-07
Chrysene 7.01 E-07
CS 1.1 OE-06
Dibenz(a.h)anthracene 6.57E-07
Dibenzofuran 5,48E-07
Diethyl phthalate 8,00E-07
Dimethyl phthalate 5.48E-07
Dl-n-butyl phthalate 1,1 OE-05
Di-n-octyl phthalate 3,70E-06
Dinoseb 1.08E-06
Diphenylamine 5.48E-07
Ethyl methanesulfonate 5.48E-07
Fluoranthene 5.91 E-07
Fluorene 5.48E-07
Hexachlorobenzene 4.66E-06
Hexachlorobutadiene 8.11 E-07
Hexachlorocyclopentadiene 1.1 OE-05
Hexachloroethane 5.91 E-07
Hexachloropropene 7.89E-07
lndeno(1,2,3-cd)pyrene 5.91 E-07
Isophorone 5.48E-07
Isosafrole 5,48E-07
Methyl methanesulfonate 6.02E-07
Naphthalene 1,37E-G5
Nitrobenzene 6.24E-07
N-Nitro-o-toluldine 8.76E-06
N-Nitrosodiethylamine 5.48E-07
N-Nitrosodimethylamine 5.48E-07
N-Nitrosodl-n-butylamlne 5.48E-07
N-Nitrosodl-n-propylamine 5.48E-07
N-Nitrosodiphenylamine 9,53E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 3 OF 6
Analyte Maximum Emission Factor
(lb/lb)
N-Nitrosomethylethylamine 9.09E-07
N-Nitrosomorpholine 5.48E-07
N-Nltrosopiperidine 5,48E-07
N-Nitrosopyrrolidine 5.48E-07
o-Toluidine 7.01 E-06
phDImethylaminoazobenzene 5.48E-07
Pentachlorobenzene 5.48E-07
Pentachloroethane 5.48E-07
Pentachloronitrobenzene 5.48E-07
Pentachlorophenol 2.74E-05
Phenacetin 5,48E-07
Phenanthrene 7.04E-07
Phenol 2.41 E-06
Pyrene 5.81 E-07
Pyridine 8,11 E-07
Safrole 5.48E-07
DIoxIns/Furans
2,3,7,8-TCDD 2.33E-12
1,2,3,7,8-PeCDD 6.68E-12
1,2.3,4,7,8-HxCDD 3.49E-12
1,2.3,6,7,8-HxCDD 8.87E-12
1,2,3,7,8,9-HxCDD 6.15E-12
1,2,3,4,6,7,8-HpCDD 2.93E-11
OCDD 3.66E-11
2.3,7,8-TCDF 3,95E-11
1,2,3,7,8-PeCDF 7,96E-11
2,3,4,7,8-PeCDF 1,60E-10
1,2,3,4,7,8-HxCDF 2,55E-10
1,2,3,6,7,8-HxCDF 1,61E-10
2,3,4,6,7,8-HxCDF 1.89E-10
1,2,3,7,8,9-HxCDF 1,21E-10
1,2,3,4,6,7,8-HpCDF 7.31 E-10
1,2,3,4,7,8,9-HpCDF 1.93E-10
OCDF 5,26E-10
Carbonyis
2,5-Dlmethylbenzaldehyde 2.74E-05
Acetaldehyde 9,30E-05
Acetone 3,15E-05
Benzaldehyde 1,37E-05
Crotonaldehyde 1.37E-05
Formaldehyde 4.68E-05
Hexanal 1.37E-05
Isopentanal 1.37E-05
m,p-Tolualdehyde 1.37E-05
MEK/Butyraldehydes 1.37E-05
o-Tolualdehyde 4.01 E-05
Pentanal 1,74E-05
Propanal 5.20E-05
HCI/CI2/NH3
HCI 7.7E-03
Ct2 5,7E-03
NHS 1.7E-05
HCN 9.5E-06
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 4 OF 6
Analyte Maximum Emission Factor
(lb/lb)
VOCs
TNMOC 9.42E-04
1,1,1-Trichloroethane 8.95E-07
1,1,2,2-Tetrachloroethane 4.18E-07
1,1,2-Trlchloroethane 7.29E-07
1,1-Dichloroethane 3.21 E-07
1,1-Dichloroethene 4.35E-07
1,2,3-Trimethylbenzene 4.18E-07
1,2,4-Trichlorobenzene 1.26E-06
1,2,4-Trimethylbenzene 5.21 E-06
1,2-Dlbromoethane (EDB) 8.90E-07
1,2-Dichlorobenzene 4.76E-07
1,2-Dlchloroethane 5.43E-a7
1,2-Dichloropropane 3.66E-07
1,3,5-Trimethylbenzene 2.02E-06
1,3-Butadiene 2.42E-05
1,3-Dichlorobenzene 4.39E-07
1,3-Diethylbenzene 5.02E-07
1,4-Dichlorobenzene 7.32E-07
1,4-Diethylbenzene 6.69E-07
1,4-Dloxane 6.36E-07
1-Butene 2.20E-05
1 -Hexene 1.96E-05
1-Pentene 1,18E-05
2,2,4-Trimethylpentane 2,30E-06
2,2,4-Trimethylpentane 4.12E-06
2,2-Dlmethylbutane 8.78E-07
2,3,4'Trimethylpentane 2.84E-07
2,3-Dimethylbutane 2.93E-06
2,3-Dimethyl pentane 2.74E-06
2,4-Dimethylpentane 1.1 OE-06
2-Butanone (MEK) 3.95E-06
2-Ethyltoluene 4.48E-07
2-Hexanone 8.72E-07
2-Methylheptane 2,70E-06
2-Methylhexane 4.45E-06
2-Methylpentane 1.07E-05
2-Nitropropane 2.78E-06
2-Propanol 2.99E-07
3-Chloropropene 4.67E-06
3-Ethyltoluene 4.82E-06
3-Methylheptane 3.50E-06
3-Methylhexane 5.17E-06
3-Methylpentane 711 E-06
4-Ethyltoluene 5.27E-06
4-Ethyltoluene 2.63E-06
4-Methyl-2-pentanone 6.97E-07
Acetone 2.44E-05
Acetonitrile 1.88E-05
Acetylene 9.35E-05
Acrylonitrile 1,58E-05
alpha-Chlorotoluene 5.68E-07
Benzene 4,74E-05
Bromodichloromethane 7,75E-07
Bromoform 1.26E-06
Bromomethane 6.15E-07
Butane 1,85E-05
Carbon Disulfide 9.77E-06
Carbon Tetrachloride 1,52E-05
Chloroacetonltrlle 1.13E-06
Chlorobenzene 2.53E-06
Chloroethane 2.57E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 5 OF 6
Analyte MilxImum Emission Factor
(lb/lb)
Chloroform 6,08E-06
Chloromethane 1.41 E-05
cis-1,2-Dichloroethene 4,59E-07
cis-1,3-Dichloropropene 1.33E-G6
cis-2-Butene 1.67E-06
cis-2-Pentene 3.31 E-07
Cumene 4.18E-07
Cyclohexane 2.47E-06
Cyclopentane 1,81 E-06
Decane 1.66E-05
Dibromochloromethane 8.82E-07
Ethane 2.09E-05
Ethanol 1.60E-06
Ethene 1.83E-04
Ethyl Benzene 2.77E-06
Ethyl Ether 2.49E-06
Ethyl Methacrylate 1,56E-06
Freon 11 4.78E-07
Freon 113 1,03E-06
Freon 114 1,49E-06
Freon 12 2.39E-07
Heptane 7.24E-06
Hexachlorobutadiene 1,69E-06
Hexane 9.78E-06
Isobutane 2,76E-06
Isopentane 1.97E-05
Isoprene 4.07E-07
m,p-Xylene 1,09E-05
Methacrylonitrile 4,85E-06
Methyl Acrylate 1.18E-06
Methyl Methacrylate 1.62E-06
Methyl tert-butyl ether 4.16E-07
Methylcyclohexane 6.08E-06
Methylcyclopentane 5,64E-06
Methylene Chloride 7,09E-06
n-Butylchloride 1.15E-05
Nonane 1.32E-05
Octane 7.45E-C6
o-Xylene 3.47E-06
Pentane 1.90E-05
Propane 8.69E-06
Propylbenzene 1.01 E-06
Propylene 4,90E-05
Styrene 9,89E-07
Tetrachloroethene 2.48E-06
Tetrahydrofuran 8.97E-07
Toluene 1.90E-05
trans-1,2-Dichloroethene 7.24E-07
trans-1,3-Dichloropropene 6.08E-07
trans-2-butene 7.67E-06
trans-2-Pentene 1.72E-06
Trichloroethene 9.42E-07
Undecane 1.18E-05
Vinyl Chloride 7.61 E-06
C02 7.24E-01
CO 6.38E-03
HCI 1.61 E-04
NOX 6.43E-03
S02 5,00E-04
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" EMISSION FACTORS
ATK PROMONTORY. UTAH
PAGE 6 OF 6
Analyte Maximum Emission Factor
(lb/lb)
CEM - continuous emissions monitoring
CS - 2-chlorobenzalmalononitrile
HCN - hydrogen cyanide
SVOC - semi-volatile organic compounds
VOC - volatile organic compounds
HCL - hydrogen chloride
NOX - nitrogen oxide
S02 - sulfur dioxide
CO - carbon monoxide
C02 - carbon dioxide
TNMOC - total non-methane organic carbon
CDD -1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin
CDF -1,2,3,4,6,7,8,9-Octachlorodibenzo-p-furan
CL2 - chlorine
NH3 - ammonia
PM10 - particulate matter less than 10 microns in aerodynamic diameter
PM2,5 - particulate matter less than 2,5 microns in aerodynamic diameter
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS
ATK PROMONTORY. UTAH
PAGE 1 OF 6
Analyte Maximum Emission Factor (lb/lb)
Particulates
TSP 1.44E-01
PM10 1.16E-01
PM2,5 5,90E-02
Metals
Aluminum 4.00E-02
Antimony 2,86E-05
Arsenic 3.03E-07
Barium 4.91 E-06
Beryllium 1.11 E-07
Cadmium 3,07E-07
Chromium 2.01 E-05
Cobalt 3.07E-07
Copper 2.52E-05
Lead 3.36E-05
Magnesium 2,93E-05
Manganese 9.31 E-05
Mercury 3.68E-08
Nickel 5.79E-05
Phosphorus 1,04E-04
Selenium 1.72E-06
Silver 9,47E-07
Thallium 2,15E-06
Zinc 3,53E-05
Perchlorates 2.46E-07
SVOCs
1,2,4,5-Tetrachlorobenzene 2.74E-07
1,2,4-Trichlorobenzene 3,23E-07
1,2-Dichlorobenzene 2.79E-07
1,2-Diphenylhydrazine 2,74E-07
1,3,5-Trinitrobenzene 2.74E-07
1,3-Dlchlorobenzene 3.12E-07
1,3-Dinitrobenzene 2.85E-07
1,4-Dichlorobenzene 2.90E-07
1 -Chloronaphthalene 2.74E-07
1-Naphthylamine 5.48E-06
2,3,4,6-Tetrachlorophenol 3,56E-07
2,4,5-Trichlorophenol 7.12E-07
2,4,6-Trfchlorophenol 1,31 E-06
2,4-Dichlorophenol 9.26E-07
2,4-Dimethylphenol 3.45E-06
2,4-Dinitrophenol 1.20E-05
2,4-Dinitrotoluene 3.11 E-07
2,6-Dichlorophenol 3.97E-07
2,6-Dinitrotoluene 5.63E-07
2-Acetylaminofluorene 2.74E-07
2-Chloronaphthalene 2,74E-07
2-Chlorophenol 1.92E-Q6
2-Methylnaphthalene 3.58E-06
2-Methylphenol 1.64E-06
2-Naphthylamine 5.48E-06
2-Nitroaniline 2,74E-07
2-Nitrophenol 3.94E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 2 OF 6
Analyte Maximum Emission Factor (lb/lb)
3,3'-Dichlorobenzidine 4,05E-06
3,3'-Dimethylbenzidine 2.74E-05
3-Methylcholanthrene 2.74E-07
3-Methylphenol & 4-Methylphenol 1.1 OE-06
3-Nltroanlline 1.1 OE-06
4,6-Dlnitro-2-mBthylphenol 4.76E-06
4-Aminobiphenyl 5.48E-06
4-Bromophenvl phenyl ether 2.74E-07
4-Chloro-3-methylphenol 3.40E-07
4-Chloroaniline 3.29E-06
4-Chlorophenyl phenyl ether 2,74E-07
4-Nitroaniline 1,1 OE-06
4-Nitrophenol 1.81 E-06
7,12-Dimethylbenz(a)anthracene 2.79E-07
Acenaphthene 2.74E-07
Acenaphthylene 2.74E-07
Acetophenone 2.68E-06
Aniline 4.00E-06
Anthracene 2.74E-07
Benzidine 2.7gE-05
Benzo(a)anthracene 3.18E-07
Benzo(a)pyrene 2.74E-07
Benzo(b)fluoranthene 6.02E-07
Benzo(ghi)perylene 3.40E-07
Benzo(k)fluoranthene 8.76E-07
Benzoic acid 6.24E-05
Benzyl alcohol 1.92E-05
bis(2-Chloroethoxy)methane 2.74E-07
bis(2-Chloroethyl) ether 3.07E-07
bls(2-Chloroisopropyl) ether 4.16E-07
bls(2-Ethylhexyl) phthalate 5,48E-06
Butyl benzyl phthalate 3.34E-07
Carbazole 3.51 E-07
Chrysene 3.51 E-07
CS 5.48E-07
Oibenz(a,h)anthracene 3.29E-07
Dibenzofuran 2.74E-07
Diethyl phthalate 4,00E-07
Dimethyl phthalate 2,74E-07
Di-n-butyl phthalate 5.48E-06
Di-n-octyl phthalate 3.70E-06
Dinoseb 5.42E-07
Diphenylamine 2.74E-07
Ethyl methanesulfonate 2.74E-07
Fluoranthene 3,98E-07
Fluorene 4,17E-07
Hexachlorobenzene 4.66E-06
Hexachlorobutadiene 4.05E-07
Hexachlorocyclopentadiene 5.4aE-06
Hexachloroethane 2.96E-07
Hexachloropropene 3.94E-07
lndeno(1,2,3-cd)pyrene 2.96E-07
Isophorone 2.74E-07
Isosafrole 2.74E-07
Methyl methanesulfonate 3.01 E-07
Naphthalene 1.35E-05
Nitrobenzene 3.12E-07
N-Nitro-o-toluidine 4.38E-06
N-Nitrosodiethylamine 2,74E-07
N-Nitrosodimethylamine 2.74E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 3 OF 6
Analyte Maximum Emission Factor (lb/lb)
N-Nitrosodi-n-butylamine 2.74E-07
N-Nitrosodi-n-propylamine 2,74E-07
N-Nitrosodiphenylamine 4.76E-07
N-Nitrosomethylethylamine 4.55E-07
N-Nltrosomorpholine 2.74E-07
N-Nitrosopiperidine 2.74E-07
N-Nitrosopyrrolidine 2.74E-07
Q-Toluidine 3,51 E-06
p-Dimethylaminoazobenzene 2.74E-07
Pentachlorobenzene 2.99E-07
Pentachloroethane 2.74E-07
Pentachloronitrobenzene 2.74E-07
Pentachlorophenol 1.37E-05
Phenacetin 2.74E-07
Phenanthrene 7,04E-07
Phenol 2.1 OE-06
Pyrene 2,90E-07
Pyridine 4,05E-07
Safrole 2.74E-07
DIoxIns/Furans
2,3,7,8-TCDD 1.32E-12
1,2,3,7,8-PeCDD 6.68E-12
1,2,3,4,7,8-HxCDD 3.42E-12
1,2,3,6,7,8-HxCDD 8.87E-12
1,2,3,7,8,9-HxCDD e.15E-12
1,2,3,4,6,7,8-HpCDD 2.93E-11
OCDD 3,66E-11
2,3,7,8-TCDF 3.95E-11
1,2,3,7,8-PeCDF 7.96E-11
2,3,4,7,8-PeCDF 1.60E-10
1,2,3,4,7,8-HxCDF 2.55E-10
1,2,3,6,7,8-HxCDF 1.61 E-10
2,3,4,6,7,8-HxCDF 1.89E-10
1,2,3,7,8.9-HxCDF 1,21 E-10
1,2,3,4,6,7,8-HpCDF 7.31 E-10
1,2,3,4,7.8,9-HpCDF 1.93E-10
OCDF 5.21 E-10
Carbonyis
2,5-Dimethylbenzaldehyde 1.37E-05
Acetaldehyde 7.46E-05
Acetone 1.47E-05
Benzaldehyde 7.30E-06
Crotonaldehyde 6,84E-06
Formaldehyde 4.04E-05
Hexanal 8.24E-06
Isopentanal 6.84E-06
m,p-Tolualdehyde 6.a4E-06
MEK/Butyraldehydes 1,23E-05
o-Tolualdehyde 2.30E-05
Pentanal 1,22E-05
Propanal 3.80E-05
HCI/CI2/NH3
HCI 1.78E-02
CI2 1,47E-03
NH3 2.16E-05
HCN 1.19E-05
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS
ATK PROMONTORY. UTAH
PAGE 4 OF 6
Analyte Maximum Emission Factor (lb/lb)
VOCs
TNMOC 8.07E-04
1,1,1-Trichloroethane 4.47E-07
1.1,2,2-Tetrachloroethane 2.09E-07
1,1,2-Trichloroethane 3.64E-07
1,1-Dichloroethane 1.60E-07
1,1-Dichloroethene 2.17E-07
1,2,3-Trimethylbenzene 2.09E-07
1,2,4-Trichlorobenzene 6.31 E-07
1,2,4-Trimethylbenzene 5,21 E-06
1,2-Dibromoethane (EDB) 4.45E-07
1,2-Dichlorobenzene 2.38E-07
1,2-Dichloroethane 2.71 E-07
1,2-Dichloropropane 1.83E-07
1,3,5-Trimethylbenzene 2.02E-06
1,3-Butadiene 2.00E-05
1,3-Dichlorobenzene 2.20E-07
1,3-Diethylbenzene 2.51 E-07
1,4-Dichlorobenzene 3.66E-07
1,4-Diethylbenzene 3.34E-07
1,4-Dioxane 3,18E-07
1-Butene 2.08E-05
1-Hexene 1.96E-05
1-Pentene 1.18E-05
2,2,4-Trimethylpentane 2.30E-06
2,2,4-Trimethylpentane 4,12E-06
2,2-Dlmethylbutane 4.39E-07
2,3,4-Trimethylpenlane 1,42E-07
2,3-Dimethylbutane 2.93E-06
2,3-Dimethylpentane 2.74E-06
2,4-Dimethyl pentane 5.02E-07
2-Butanone (MEK) 3.95E-06
2-Ethvltoluene 2.24E-07
2-Hexanone 4,36E-07
2-Methylheptane 2,70E-06
2-Methylhexane 4,45E-06
2-Methylpentane 1.07E-05
2-Nitropropane 2.78E-06
2-Propanol 1.49E-07
3-Chloropropene 4.67E-06
3-Ethyltoluene 4.82E-06
3-Methylheptane 3.50E-06
3-Methylhexane 5.17E-06
3-Methylpentane 7.11 E-06
4-Ethyltoluene 5.27E-06
4-Ethyltoluene 2.63E-06
4-Methyl-2-pentanone 3,49E-07
Acetone 2.32E-05
Acetonitrile g.19E-06
Acetylene 7.45E-05
Acrylonitrile 6.59E-06
alpha-Chlorotoluene 2.84E-07
Benzene 4.36E-05
Bromodichloromethane 3,54E-07
Bromoform 6,30E-07
Bromomethane 3.08E-07
Butane 1.85E-05
Carbon Disulfide 9.37E-06
Carbon Tetrachloride 1.52E-05
Chloroacetonitrlle 5,64E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS
ATK PROMONTORY. UTAH
PAGE 5 OF 6
Analyte Maximum Emission Factor (lb/lb) ;
Chlorobenzene 2.53E-06
Chloroethane 1.29E-07
Chloroform 6.08E-06
Chloromethane 1.41 E-05
cis-1,2-Dichloroelhene 2.29E-07
cis-1,3-Dichloropropene 1.33E-06
cis-2-Butene 1.41 E-06
cis-2-Pentene 1.66E-07
Cumene 2.09E-07
Cyclohexane 2.47E-06
Cyclopentane 1,81 E-06
Decane 1.66E-05
Dibromochloromethane 4.41 E-07
Ethane 1,68E-05
Ethanol 1,60E-06
Ethene 1.48E-04
Ethyl Benzene 2.77E-06
Ethyl Ether 1.25E-06
Ethyl Methacrylate 7.82E-07
Freon 11 2.39E-07
Freon 113 5.15E-07
Freon 114 7.45E-07
Freon 12 1.20E-07
Heptane 7,24E-06
Hexachlorobutadiene 8,45E-07
Hexane 9.7aE-06
Isobutane 2.76E-06
Isopentane 1.97E-05
Isoprene 2.03E-07
m,p-Xylene 1,04E-05
Methacrylonitrile 4,85E-06
Methyl Acrylate 5,90E-07
Methyl Methacrylate 8.11 E-07
Methyl tert-butyl ether 2,08E-07
Methylcyclohexane 6.08E-06
Methylcyclopentane 5.64E-06
Methylene Chloride 7.09E-06
n-Bulylchloride 5.76E-06
Nonane 1,32E-05
Octane 7.45E-06
o-Xylene 3,47E-06
Pentane 1.90E-05
Propane 8.6gE-06
Propylbenzene 1.01 E-06
Propylene 4.30E-05
Styrene 9.89E-07
Tetrachloroethene 2.48E-06
Tetrahydrofuran 6.39E-07
Toluene 1 .B5E-05
trans-1,2-Dichloroethene 3.62E-07
trans-1,3-Dichloropropene 3.04E-07
trans-2-butene 7.67E-06
trans-2-Pentene 1.72 E-06
Trichloroethene 9.42E-07
Undecane 1.18E-05
Vinyl Chloride 7,61 E-06
C02 6.89E-01
CO 4.70E-03
HCI 1.61 E-04
NOX 5.76E-03
S02 4.09E-04
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS
ATK PROMONTORY, UTAH
PAGE 6 OF 6
Analyte Maximum Emission Factor (Ib/Ib)
CEM - continuous emissions monitoring
CS - 2-chlorobenzalmalononltrlle
HCN - hydrogen cyanide
SVOC - semi-volatile organic compounds
VOC - volatile organic compounds
HCL - hydrogen chloride
NOX - nitrogen oxide
S02 - sulfur dioxide
CO - carbon monoxide
C02 - carbon dioxide
TNMOC - total non-methane organic carbon
OCDD -1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxln
OCDF -1,2,3,4,6,7,8,9-Octachlorodibenzo-p-furan
CL2 - chlorine
NH3 - ammonia
PM10 - particulate matter less than 10 microns in aerodynamic diameter
PM2.5 - particulate matter less than 2.5 microns in aerodynamic diameter
Rev 2
4.0 AIR QUALITY MODELING METHODOLOGY
This section describes the methodology to assess the air quality impact of the M-136 and M-225
treatment units in the air dispersion modeling analysis. To the extent possible, the air dispersion
modeling methodology is designed to follow the procedures recommended in the HHRAP guidance
(USEPA, 2005) and direction received from UDEQ. As a result, this protocol may include slight variations
from the HHRAP protocol. Every effort has made to identify these variations and to present supporting
information to justify the protocol.
The following components of the modeling protocol are discussed in this section:
Air Quality Dispersion Model Selection - Section 4.1
Land Use Analysis - Section 4.2
Surface Roughness - Section 4,3
OB/OD Treatment Scenarios - Section 4.4
Types of Dispersion Modeling - Section 4.5
Receptor Networks - Section 4.6
Meteorological Data - Section 4.7
Comparison to Air Quality Standards and Exposure Criteria - Section 4.8
Post-Processing Activities - Section 4.9
OBODM Modeling Files - Section 4.10
4.1 AIR QUALITY DISPERSION MODEL SELECTION
Air dispersion modeling will be conducted to evaluate the impact of emissions from the M-136 and M-225
treatment units. It is important to note that the HHRAP guidance (USEPA, 2005) assumes the
combustion source can be evaluated using the Industrial Source Complex Short Term 3 (ISCST3)
dispersion model for risk assessment evaluations. However, ISCST3 is considered more applicable to
sources associated with industrial facilities, rather than OB and OD treatment operations. The HHRAP
(USEPA. 2005) guidance also acknowledges that other dispersion models may be required on a case-by-
case basis.
In the case of waste treatment activities at ATK Promontory, a special model is needed to simulate the
combustion, cloud rise, and dispersion of OB and OD source releases. OB treatment is considered a
quasi-continuous source because the treatment event is usually complete within one hour. OD is
considered as an instantaneous source because treatment is completed within milliseconds. ATK
conducts both OB and OD treatment at M-136 and M-225.
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The United States Environmental Protection Agency (USEPA) maintains a Support Center for Regulatory
Air Models called SCRAMS. The only SCRAM model that is specific to OB and OD treatnient operations
is the Open Burn/Open Detonation Dispersion Model (OBODM) (Cramer, H. E. 2008). OBODM has also
been identified by UDEQ as the model of choice for conducting the ATK air dispersion modeling analysis
in support of the human health and ecological risk assessments. The most recent update to the model
was issued in October 2008 (Version 1.3.24).
OBODM is specifically designed to predict the air quality impact of OB and OD treatment of obsolete
weapons, solid rocket propellants, and manufacturing wastes. The OB and OD treatment of waste
propellants and propellant contaminated materials at M-136 and M-225 can be classified as
instantaneous events for OD treatment and as quasi-continuous events for OB treatment. Because the
model is specifically designed for OB and OD treatment, it can accommodate source-specific input data
regarding treatment operations. This allows the model to provide detail regarding the spatial and
temporal variation of emissions and meteorological conditions and enhances the model's ability to
evaluate source impacts.
OBODM predicts the downwind transport and dispersion of pollutants using plume rise and dispersion
model algorithms taken from existing U.S. EPA approved dispersion models. OBODM uses the heat
content of the energetic material in plume rise equations to predict the buoyant rise of the plume. The
model is also designed to use either empirical emission factors such as those derived in the Dugway
Proving Ground (DPG) Bang Box™ or emissions predicted by a products of combustion model. OBODM
calculates peak air concentration, time-weighted air concentrations, and dosage (time-integrated
concentration) for OB and OD releases. It can also consider the effects on concentration and dosage of
the gravitational settling and deposition of particulates.
OBODM can produce the same output as produced by ISCST3 for input into the risk assessment
process. The capabilities and output products of OBODM include the following:
• Allows the calculation of air concentration based on a unit emission rate to preclude the use of
multiple model runs for each contaminant of potential concern.
• Provides output results for specific sources or source groups to evaluate the risk from each source.
• Allows the user to evaluate single case or sequential, hourly, preprocessed meteorological databases
ranging from one to 5 years.
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Rev 2
• Allows the user to specify the hours of the day in which materials are treated when using a sequential
houriy meteorological database.
• Allows specific input for each source, receptor location, meteorological data, and terrain features.
Source parameter data includes effective heat content, burn rate, total mass treated, and pollutant
emission factors. This feature allows the modeling analysis to be tailored to replicate treatment
operations at M-136 and M-225.
• As with ISCST3, OBODM can calculate vapor phase and particle phase air concentrations. OBODM
also calculates particle phase deposition based on particle size distribution. In this modeling analysis,
vapor phase deposition will be calculated using the vapor phase air concentration and deposition
velocity as recommended in Section 3.1.1 of the HHRAP (USEPA, 2005), Particulate deposition will
be calculated using gravitational settling. OBODM does not calculate wet deposition. However, the
wet deposition mechanism is not applicable at ATK Promontory because treatment is not conducted
during precipitation events.
OBODM has additional features that make it well suited for use at ATK, These features include:
• The topography in the immediate vicinity of ATK is characterized by significant changes in elevation
commonly referred to as "complex terrain". OBODM contains a screening procedure for addressing
air dispersion in complex terrain that is based on procedures used by the other USEPA approved
dispersion models (i.e., SHORTZ/LONGZ).
• OBODM uses semi-empirical Dugway Proving Grounds (DPG) dispersion coefficients, which directly
relates OB plume and puff growth to atmospheric turbulence and wind shear. OBODM also uses the
DPG vertical dispersion coefficient, which relates vertical OB plume grovrth to vertical turbulence
intensity and includes the effects of entrainment during buoyant plume rise.
4.2 LAND USE ANALYSIS
Land use information is used for the selection of certain air dispersion modeling variables. These
variables include air dispersion coefficients and surface roughness. The land use characteristics
surrounding a source of air emissions can be determined from United States Geological Service (USGS)
7.5-minute topographic maps, aerial photographs, or visual surveys of the area. The land use
classification for the area surrounding the M-136 and M-225 treatment units was determined from the
Thatcher Mountain 7,5-minute (1:24,000 scale) quadrangle using the Auer method (Auer, 1978). as
described in Section 3.2,2.1 of the HHRAP guidance (USEPA, 2005).
090904/P 4-3
Rev 2
Using this method, areas are defined as either "rural" or "urban". The Auer method establishes four
primary land use types: industrial, commercial, residential, and agricultural. Industrial, commercial, and
compact residential areas are classified as urban. For air quality modeling purposes, an area is defined
as urban if more than 50 percent of the surface area within 3 km of the source falls under an urban land
use type. Otherwise, the area is determined to be rural.
A radius of 3 km beyond each treatment unit was inspected to define whether the area within 3 km is rural
or urban according to Auer's definitions. This inspection resulted in a rural classification for both
treatment units. Next, the 3 km radius area was broken down into smaller areas (100 meters by
100 meters). Each small area was then classified either as rural or urban. The total count of rural areas
was greater than 50 percent surrounding each treatment unit. As a result, the land use classification of
ATK Promontory is rural.
Results of the land use analysis will be included in the air dispersion modeling report.
4.3 SURFACE ROUGHNESS HEIGHT
The surface roughness height (length) assumed for this modeling analysis is based on the methodology
given in Section 3,2.2.2 of the HHRAP guidance (U.S. EPA, 2005). The results of land use classification
and a five-year wind rose for the ATK M-245 on-site meteorological monitoring station were used to
calculate site-specific surface roughness heights for both treatment units. Using the HHRAP guidance
methodology, ail wind sectors were classified as desert shrub land.
Table 3-3 in the HHRAP guidance (U.S. EPA. 2005) presents seasonal values of surface roughness for
desert shrub land. An annual site-specific surface roughness height of 0.26 was calculated for ATK
based on the average of the four seasonal surface roughness coefficients.
4.4 OB/OD TREATMENT SCENARIOS
In order to calculate the air quality impact of OB and OD treatment operations. OBODM requires specific
information regarding the characteristics of the source of treatment emissions. For example, OBODM
requires input data indicating the type of energetic material being treated, how it is being treated (OB or
OD). the heat content, burn rate of the material, the amount of material being treated, the! size source,
and the release height.
The following treatment scenarios will be evaluated in the air dispersion modeling analysis for ATK
treatment operations:
090904/P 4-4
Rev 2
• OB treatment at M-136
• OB treatment at M-225
• OD treatment at M-136
• OD treatment at M-225
The M-136 Unit has 14 treatment stations. OB is conducted at stations 1-12. OB and OD is conducted at
stations 13 and 14. All OB treatment is conducted in pans with the exception of Burn Station 14. which
consists of a pad used for the OB of whole rocket motors. The OD hole or pit is not covered during OD
treatment. Based on quantity distance (QD) limitations, open detonation may be performed above ground
or underground in a hole or pit. depending on the item to be detonated.
The M-225 Unit has four burn stations and one detonation area. The OD hole or pit is not covered during
OD treatment. Based on QD limitations, open detonation may be performed above ground or
underground in a hole or pit, depending on the item to be detonated.
Although the OBODM model has the capability to model multiple source scenarios and locations in the
same model run (must have same heat content), the 100 receptor per run limitation inherent in the
OBODM software code necessitates numerous model runs to evaluate large receptor networks and
precludes the modeling of individual M-136 treatment stations.
ATK proposes to consolidate certain M-136 and M-225 OB treatment stations into a subset of source
areas representing either all or part of the treatment unit. USEPA guidance (USEPA. 1992) allows the
merging of multiple emission points that are located within 100 meters of each other, if the emission
points have similar release parameters. A similar type situation exists for the area comprised of burn
stations 1 through 12 at M-136 (see Figure 2-3). For example, burn stations 1-12 are all located within a
100-meter radius of the center point of the area comprised of burn stations 1-12. A center point for this
area can represent the treatment operations that are conducted at the burn stations 1-12. The burn
stations in this area treat similar materials and are assumed to have similar release parameters (e.g., pan
size, release height, and heat content). The proposed dimensions of the single emission point
representing the merger of BS 1-12 is discussed in Section 4.4.1.2 and shown in Table 4-1. ATK is
proposing to treat stations 13 and 14 as separate emission sources because of the large separation
distance (greater than 100 meters) from stations 1-12 and each other. The source parameters for all M-
136 sources are presented in Table 4-1.
The purposed heat content values for modeling emissions from treatment of 1.3, 1.1. and Category E
waste materials were determined using the NASA-Lewis Thermochemical model. NASA-Lewis
Themiochemical model runs were completed for three compositions burning 1.3 propellant at ambient
090904/P 4-5
Rev 2
pressure. The goal of the model calculations was to examine theoretical flame temperatures of the
propellant and the mixtures. The first composition was pure propellant (PWlOO); the second composition
was an 85:15 mixture of propellant and decane (to simulate PW85:15); the third was a 65:35 mixture of
propellant and decane (to simulate PW65:35). The results of the NASA-Lewis model runs are shown in
below.
1.3 Class Material
NASA-Lewis Model Output
Parameter PWlOO PW85:15
with Decane
PW65:35 with
Decane
Flame Temperature, °F 4976 2950 2260
Heat Content, cal/g 2058 1870 1471
The table given below lists the Heat of Explosion, which is the heat generated by the propellant when it is
burned in an inert gas atmosphere using a bomb calorimeter. This value would be conservative in
comparison to open burning since the testing was performed in an inert gas atmosphere (oxygen
deficient).
Heat of Explosion for 1.3 Propellants
Sample ID Heat of Explosion
cai/g
J770812 1464
J770812 1399
J770812 1492
Average 1452
J956002 1442
J956002 1365
J956002 1449
Average 1419
On June 3, 2009. ATK presented this data and information to the Utah Division of Solid and Hazardous
Waste. During this meeting, it was agreed that based on this data, a value in fourteen hiindreds was
I
appropriate for a 1.3 propellant heat content value. The 1.3 heat content value of 1471 cal/g|was chosen
since it was the most conservative value resulting from the NASA-Lewis Model output, and it
corresponded well with the test results from the bomb calorimeter. As a result, ATK is proposing to use a
heat content value of 1,471 cal/gm for 1.3 class materials.
090904/P 4-6
Rev 2
Heat content values for class 1.1 propellants and Category E were measured, again using a bomb
calorimeter in an inert gas atmosphere. The results from these tests are illustrated in separate tables
below for class 1.1 propellants and Category E materials.
Heat of Explosion for 1.1 Propellants
Sample ID Heat of Explosion
cal/g
Run #1 1395.0
Run #2 1372,6
Run #3 1438.5
Average 1402.0
As a result, ATK is proposing to use a conservative heat content value of 1372.6 cal/gm for 1,1 class
materials.
The DLQ152 Flare Illuminate, which is a similar illuminate to the M816, Infrared (IR) Illumination Cartridge
that is being used as a surrogate for the Category E wastes treated at ATK, was used for this heat
content testing.
Heat of Explosion for Reactive Category E (Flare Illuminate)
Sample ID Heat of Explosion
cai/g
Run#1 832.4
Run #2 821.3
Run #3 820.4
Average 824.7
As a result, ATK is proposing to use a conservative heat content value of 820.4 cal/gm for Category E
materials.
The objective of the OBODM modeling analysis will be to evaluate all potential daily operating hours on
an annual basis. ATK conducts only one treatment event per day at both M-136 and M-225. OBODM will
assume that one treatment event takes place each hour within the range of potential daily operating
hours, which is assumed to be between 1000 and 1800 hours. As a result, the frequency of treatment
events modeled will overestimate the expected operations at both M-136 and M-225 on an annual basis.
090904/P 4-7
Rev 2
Post-processing of the modeling results will account for the maximum daily per event treatment quantity
and the maximum annual treatment quantities proposed by ATK in Tables 2-1 and 2-2. The post-
processing step is discussed in Section 4.9.
A summary of the source parameters, treatment quantities and other assumptions that will be used in the
air dispersion modeling analysis for the M-136 and M-225 treatment units are presented in Sections 4.4.1
and 4.4.2, respectively.
4.4.1 M-136 Treatment Unit
M-136 is the primary open burning treatment unit at ATK. The M-136 treatment unit will conduct treatment
of 1.1 and 1,3 class waste and Category E wastes. Based on the maximum annual treatment quantities
proposed in Tables 2-1 and 2-2, the M-136 units will treat 99 percent of the total ATK annual waste in
comparison to M-225.
4.4.1.1 M-136 Source Parameters
The air dispersion modeling analysis for the M-136 treatment unit will include the following four (4)
sources groups:
• Source 1 - OB of 1.1,1.3, and Category E waste at stations 1 through 12
• Source 2 - OB of 1.1,1.3. and Category E waste at Station 13
• Source 3 - OB of 1.1 and 1.3 waste (including rocket motors) at Station 14
• Source 4- OD of 1.1 and 1.3 waste at Stations 13 and 14 in a single area.
The proposed source parameters for the M-136 sources are given in Table 4-1. Table 4-1 also shows the
proposed per event treatment quantities that will be used in OBODM for each M-136 source, as well as
the proposed maximum annual treatment quantity for each M-136 source.
4.4.1.2 Other Modeling Assumptions for M-136
OBODM will be setup to assume the following about treatment activities at M-136:
• Assume that all M-136 sources are at the same base elevation as BS 1-12. Elevation = 4.587 feet in
order to consolidate gravitational settling modeling due to the limited number of receptors that can be
evaluated per run of OBODM. The actual net elevation difference between the three M-136 treatment
locations is only 36 feet (11 meters). Therefore, this assumption is not expected to affect the
modeling results for M-136,
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Rev 2
• Include all four M-136 sources groups in single OBODM run. Each source will have a separate
coordinate (x,y) location reflecting its relative position within M-136 and each source will be assign to
a source group to give the individual contribution from each source to a receptor and waste type (1.1.
1.3. and Category E).
• The four source groups for M-136 will include the following:
> Source 1 - Burn Stations 1. 2. 3, 4, 5, 6, 7, 8. 9, 10, 11, and 12 OB treatment
> Source 2 - Burn Station 13 OB treatment
> Source 3 - Burn Station 14 OB treatment
> Source 4 - Burn Station 14 OD treatment
• The burn pans used at M-136 Burn Stations 1-12 burn stations (Source 1) are not all the same size.
Because source group 1 represents a merger of Burn Stations 1-12, an average pan size has been
was calculated for based on the existing burn pans sizes and the normal configuration of burn pans.
The typical pan sizes used at M-136 are 5'x 16'. 8'x 20', and 8'x 8'. Currently, seventy percent of the
trays are 5'x16'. When they burn the trays at Source 1 (BS 1-12), they are usually placed in a long
row of 12 - 14 trays in the row. When they burn the trays at Source 2 (BS 13), they typically use 3
small trays, 3'x 7', and an 8'x 8' and then a 6'x 6' that are essentially arranged in a rectangular
configuration. There are no burn pans at Source 3 (BS-14) or Source 4 (BS-14).
Based on the bum pan configurations describe above, ATK is proposing the following revised
dimensions for each M-136 source:
> Source 1 - 224' x 5' (14, 5' x 16' trays in a row which is the maximum bum scenario for
Source 1)
> Source 2 - 17' x 7' (an area that includes 3 small trays, 3'x 7', and an 8'x 8' and then a 6'x 6',
which is the maximum burn scenario for Source 2)
• Release height for OB treatment at all M-136 source groups is 1.0 meter.
• OBODM will assume one treatment event per hour during the hours 1000 to 1800. The total annual
treatment hours modeled for each M-136 source will be = 9 hours/day x 365 days/year =
3,285 hours/year.
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Rev 2
• OB source release quasi-continuous (volume source).
• OD source release instantaneous (volume source).
• OBODM will assume that treatment days include all days of the year in order to calculate the worst-
case 1-hour air dispersion factors at each receptor for each annual period.
• Dispersion modeling types for M-136 will include the following:
> Gas phase air concentrations
> Particle phase air concentrations
> Particle-bound air concentrations
> Particle phase gravitational deposition
> Particle-bound phase gravitational deposition
> Gas phase deposition
• Gas and particulate phase modeling will utilize a unit emission rate of 1.0 Ib/hr as recommended by
the HHRAP (USEPA. 2005).
• Particulate phase modeling will include particle size information to include gravitational settling (see
Section 4.5) as recommended by HHRAP guidance (USEPA. 2005).
4.4.2 M-225 Treatment Unit Sources
The M-225 Unit will treat small amounts of 1.1 and 1.3 class waste and Category E waste, OB will be
conducted in burn pans. OD treatment of pure propellant will be conducted at one OD pit. OD treatment
consists of placing the waste material in a small, excavated pit that has a diameter of 1.5 meters. The
treatment pit is not covered with soil and is considered as a surface detonation. Based on QD limitations,
open detonation may be perfonned above ground or underground in a hole or pit, depending on the item
to be detonated.
As shown in Figure 2-6. the M-225 burn pans and OD pit are located within a 200 foot x 500 foot
rectangular area. All M-225 treatment locations are within 60 meters of the center of this treatment area
and there are no significant changes in elevation. M-225 treatment activities at Source Groups 1 and 2
will be modeled separately for OB and OD treatment, respectively. The source parameters for M-225 OB
and OD treatment sources are summarized in Table 4-2,
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Rev 2
4.4.2.1 M-225 Source Parameters
The air dispersion modeling analysis for the M-225 treatment unit will include the following two sources
groups:
• Source Group 1 - OB of 1,1.1.3, and Category E wastes.
• Source Group 2 - OD of 1.1 and 1.3.wastes.
The proposed source parameters for the M-225 sources are given in Table 4-2. Table 4-2 also shows the
proposed per event treatment quantities that will be used in OBODM for each M-225 source, as well as
the proposed maximum annual treatment quantity for each M-225 source.
4.4.2.2 Other Modeling Assumptions for M-225
OBODM will be setup to assume the following about treatment activities at M-225:
• Both sources (OB and OD) have the same coordinate and elevation; elevation = 4,597 feet above
mean sea level to consolidate gravitational settling modeling for both sources in a single model run.
• Include two M-225 sources groups in single OBODM run. Each source group will have a separate
coordinate (x.y) location reflecting its relative position within M-225 and each source will be assign to
a source group to give the individual contribution from each source to a receptor.
• The two source groups for M-225 will include the following:
> Source 1 - M-225 Burn Stations 1, 2. 3. 4. and 5 for OB treatment
> Source 2 - Single OD treatment pit
• Each source configuration is based on historical treatment information:
> For OB at M225 Source 1, assume 5.18 m x 1.83
> For OD at M225 Source 2, assume 1.5 meter diameter pit
• Release height for OB = 1.0 meters
• Release height for OD = 0 meters (ground level)
• OB source release quasi-continuous (volume source)
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Rev 2
• OD source release instantaneous (volume source)
• Dispersion modeling types for M-136 will include the following:
> Gas phase air concentrations
> Particle phase air concentrations
> Particle-bound air concentrations
> Particle phase gravitational deposition
> Particle-bound phase gravitational deposition
> Gas phase deposition
> Gas and particulate phase modeling will be conducted using a unit emission rate of 1.0 Ib/hr as
recommended by HHRA guidance (USEPA. 2005).
> Assume 1 treatment event per hour
> Assume treatment window runs from 1000 to 1800. The total annual treatment hours modeled will
be = 9 X 365 = 3.285 hours/year.
> Treatment days include all days of the year in order to calculate the worst-case 1-hour air dispersion
factor for each source in each annual period.
> Particulate phase modeling will include particle size information to include gravitational settling (see
Section 4.5) as recommended by HHRAP guidance (USEPA, 2005).
4.5 TYPES OF DISPERSION MODELING
As indicated above in Sections 4.4.1.1 and 4,4.1.2, several types of dispersion modeling will be
conducted for M-136 and M-225 in support of the HHRA. These include model calculations of air
concentrations and deposition associated with gas phase, particle phase, and particle-bound air
emissions.
The air dispersion modeling and HHRA will not address wet deposition because ATK does not conduct
treatment operations during precipitation events. The HHRA will address the dry deposition of particulate
phase (gravitational settling) and gas phase (non-gravitational settling) pollutants from treatment
operations at M-136 and M-225. The sum of these two deposition mechanisms is assumed to represent
total dry deposition. Therefore, the total annual dry deposition will be computed as follows:
090904/P 4-12
Rev 2
Total Dry Deposition (ug/m /yr) = gravitational settling + Non-gravitational settling (pg/m%r)
Further information regarding each type of dispersion modeling is presented below in Sections 4.5.1
through 4.5.4.
4.5.1 Gas Phase and Particulate Air Concentrations
OBODM will be used to calculate air concentrations for treatment emissions in vapor phase. OBODM will
calculate peak concentrations, time-mean concentrations, and dosage (time-integrated )concentrations.
4.5.2 Particle and Particle- Bound Phase Air Concentrations
OBODM will be used to calculate concentrations for treatment emissions in particle phase. OBODM will
calculate peak concentrations, time-mean concentrations, dosage (time-integrated) concentrations. All
particle phase modeling runs will use a particle size distribution.
ATK has not conducted particle size distribution testing of OB and OD emissions. In addition, other
representative particle size distribution data for OB and OD of energetic materials cannot be identified at
this time. As a result. ATK feels there is no representative available test data to determine separate
particle size distributions for OB and OD treatment. ATK will utilize a single particle size distribution that
will be generated by OBODM. OBODM requires the user to enter the number of particle-size categories,
mass-median diameter, and geometric standard deviation ofthe particle distribution.
A study conducted by the National Aeronautics and Space Administration (NASA. 1973) investigated the
particle size distribution (but no standard deviation) for aluminum oxide particles from rocket propellants.
Aluminum oxides particles are a combustion product of the materials treated at M-136 and M-225 based
on Bang-box testing results. The results of the NASA study indicate a mean mass aluminum oxide
particle size of 12.3 micrometers (\m\). However, it is important to note that ATK also treats contaminated
waste materials. The combustion of these materials is expected to result in larger particle size diameters
and a higher mean mass particle size. ATK is assuming that the mass mean-median diameter for both
OB and OB treatment is approximately 30 microns.
As indicated in Section 3.2, 1.3 class waste materials constitute about 96 percent of the wastes treated
annually at ATK. The results of the ODOBi emissions testing of 1.3 class waste materials determined that
the most abundant metal (particulate) in 1.3 emissions is aluminum. Aluminum has a density of 2.7
g/cm^.
090904/P 4-13
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Based on this available particle information, ATK is proposing the following assumptions for particulate
deposition modeling with OBODM:
• A density of 2.7 g/cm^ will be assumed for particulates, which is based on ODOBi test results and is
comparable to the DOE study (DOE, 1984).
• A mass median particle diameter of 30.0 pm.
• A particle size standard deviation of 2.0 jim in order to account for a reasonable measure of size
distribution variability.
• OBODM will generate a particle size distribution based on 10 particle size categories. This is the
OBODM model default.
• For the particle phase, OB and OD emissions will be modeled using the fraction of total mass for the
assumed particle size distribution. Particle-bound deposition modeling will utilize the assumed
particle size distribution generated by OBODM and the calculated fraction of total surface area for
each of the 10 particle size categories, which is shown in Table 4-4.
4.5.3 Gas Phase Dry Deposition
OBODM does not calculate the dry deposition of gaseous emissions. However. OBODM modeling
results (dosage) for the gas phase will be used to determine the dry deposition rate of gas phase
pollutants. This approach is consistent with HHRAP guidance (USEPA. 2005) and OBODM guidance,
and is also considered to be a conservative approach because the air concentration is non-depleted (e.g.,
no mass has been removed for the treatment plume).
Gas phase dry deposition will be calculated as follows:
Gas Phase Dry Deposition (pg/m^-yr) = Annual Gas Dosage (pg-sec/m'') x Deposition Velocity (m/sec)
The deposition velocity assumed for this protocol is 0.03 meters/second (m/sec), which is the default
value specified in the HHRAP guidance (USEPA, 2005),
Table 4-3 provides a summary of the gravitational settling parameters that will be used to evaluate
particulate phase and gas phase dry deposition in the OBODM,
090904/P 4-14
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4.5.4 Complex Terrain Particulate Deposition
OBODM contains a screening-level algorithm for estimating air quality impacts in complex terrain.
However, this algorithm is restricted to predicting air concentrations. In an effort to address particulate
deposition at complex terrain receptors. ATK is proposing to use the OBODM modeling results for
particulate dosage to calculate particulate deposition for complex terrain receptors. As indicated in Table
4-3. ATK is assuming that the emission surrogate for OBODM particulate phase model runs is aluminum,
which has the density of aluminum is of 2.7 g/cm^. and the mean particle diameter has been revised to 30
micrometers, which is consistent with the particulate size distribution used by OBODM. Based on these
assumptions for particulate emissions, a dry deposition velocity for a spherical particulate has been
estimated from data presented by Hanna (Hanna. et al.. 1982) to be approximately 0,10 meters/second.
As a result, the particulate phase dry deposition at complex terrain receptors only will be calculated as
follows using the ).10 meters/second deposition velocity:
Complex Terrain Dry Deposition (pg/m^-yr) = Annual Particulate dosage (pg-sec/m^) x Particulate
Deposition Velocity (m/sec)
4.6 RECEPTOR NETWORKS
All receptors used in the ATK dispersion modeling analysis will be based on a Cartesian grid system.
ATK is proposing to use two types of receptor networks will be used in the analysis: general and discrete.
A general receptor network will extend out to 10 km from each treatment units and will be used for
locating the maximum short term and long-term (annual) receptor locations. The discrete receptor
network will consist of special receptors that will support the human health and ecological risk
assessments. The general and discrete receptor networks are discussed in Sections 4.6.1 and 4.6.2,
respectively.
The Universal Transverse Medcator (UTM) coordinates and terrain elevations for all receptors and
treatment units will be based on United States Geological Service (USGS) Digital Elevation Map (DEM)
grids of 1:24,000 at a resolution of 1 meter. The website to access DEM files from the USGS is
httD://data.aeocomm.com/dem/demdownload,html. The GeoCommunity website has a partnership with
USGS to provide the DEM data.
4.6.1 Discrete Receptor Grid
Discrete receptors are defined as special receptors that exist within, on, or beyond the ATK boundary and
represent human and ecological exposure points. These locations include onsite areas occupied by ATK
090904/P 4-15
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employees, the facility boundary, nearby residential dwellings, the closest population center or town,
worker exposure at an offsite commercial businesses, and ecological receptor exposure points.
The following is a list of discrete receptors that will be evaluated each treatment unit in the dispersion
modeling analysis:
• The Adam's Ranch, which is the closest domestic dwelling to M-136. is located approximately 3 km
south-southwest of M-136.
• The Holmgren Ranch and Pond, which is the closest domestic dwelling to the M-225, is located
approximately 2 km east-southeast of M-225.
• Four facility boundary receptors that are selected based on the annual prevailing wind direction
measured over a five-year period (1997 through 2001) at the M-245 meteorological monitoring
station.
• AutoLiv Facility. This is an off-site commercial business located between the M-136 and M-225
treatment units.
• Christensen Residence. This residential dwelling is located due north of ATK.
• Blue Creek perennial stream, which runs along the western boundary of M-136.
• The Bear River Migratory Bird Refuge located about 10.5 km south-southwest of M-225 ,
• The Salt Creek Waterfowl Management Area located 13 km east of ATK; and
• The Thiokol Ranch Pond, which is located approximately 14 km southwest of M-225.
• The Howell Dairy Farm just north of the ATK northern property boundary.
• Two onsite discrete receptors to assess potential risk to ATK workers that are not directly involved
with the activities at the M-136 and M-225 treatment units. The proposed new onsite receptors
represent areas where most non-treatment related employees spend their time onsite. The new
onsite discrete receptors include the following:
090904/P 4-16
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> North Plant Main Administration Building and Main Manufacturing Area- 2.5 miles north of M-136
and 6.7 miles north-northwest of M-225
> South Plant Main Administration Building and Main Manufacturing area - 1,8 miles south of M-
136 and 3.9 miles west-northwest of M-225.
All discrete receptors listed above are shown in Figure 4-1.
4.6.2 General Receptor Grid
ATK is proposing to use a general receptor grid extending out 10 km from each treatment unit. The
general receptor grid will include receptors spaced at 100-meter intervals from each treatment unit out to
3 km and receptors spaced at 500-meter intervals beyond 3 km out to 10 km. ATK believes the 10 km
general grid extends far enough out from the treatment units to identify the location of maximum short-
term and long-term receptor locations associated with each treatment unit. Due to the large separation
distance between the M-136 and M-225 treatment units, separate general grid systems are proposed for
each treatment unit. The proposed general grid networks for the M-136 and M-225 treatment units are
shown in Figures 4-2 through 4-5, respectively.
The general grid extending from the M-136 M-225 treatment areas out to 3 km includes on-site receptors.
At the request of UDSHW. these receptors will be used to evaluate on-site for OB/OD treatment unit
workers. The on-site receptors extend from beyond the M-136 quantity-distance (Q-D) arcs out to the
facility boundary in all directions.
4.7 METEOROLOGICAL DATA
The meteorological data requirements for OBODM are historical houriy averages of wind speed and wind
direction, atmospheric stability class, air temperature, and urban or rural mixing height. These
meteorological parameters represent a combination of surface and upper air data and are available from
several different sources including the National Weather Service (NWS), military installations or as part of
an on-site measurement program. The meteorological data used in an air dispersion modeling analysis
should be selected based on spatial and climatological representativeness, as well as. the ability of the
data to characterize the transport and dispersion in the area of concern. Spatial and geographical
representativeness is best achieved by using on-site meteorological data. As a result, site-specific
measured data is therefore preferred as modeling input (U.S. EPA September 2000), provided
appropriate instrumentation and quality assurance procedures are followed and the data is compatible
with the requirements of the dispersion model.
0g0904/P 4-17
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4.7.1 Surface Data
ATK is proposing to use five-years (1997 through 2001) of on-site meteorological data collected at the
M-245 meteorological monitoring station. ATK operates the on-site monitoring station approximately
1.5 km southwest of the M-225 treatment unit at an elevation of about 5,000 feet above mean sea level
(amsl). The monitoring station is operated in accordance with the U.S. EPA monitoring guidance for the
collection of onsite meteorological data (U S EPA, 2000). Table 4-5 shows the frequency distribution of
16 wind direction sectors for each individual year and the average of all 5 years.
The monitoring station consists of a 10-meter tower that collects the following data at the 10-meter level:
Wind speed
Wind direction
Standard deviation of the horizontal wind (sigma theta)
Temperature
Relative humidity
Barometric pressure
The wind speed, wind direction and air temperature are considered critical parameters for input into
OBODM. However, the M-245 station does not collect all required meteorological data for preparing the
meteorological input file necessary to run OBODM. The data recovery percentage for all variables
monitored at Station M-245 during the five-year period is shown in Table 4-6. The percentages shown in
Table 4-6 represent data recovery after validation. The data recovery percentage for all critical model
variables was greater than 90 percent, which is recommended (U.S. EPA, February 2000) in order to use
on-site meteorological data in a regulatory modeling anailysis. With the exception of wind ; speed, wind
direction, and temperature in 1999, the amount of missing data in each annual period was in the range of
one to six percent or less. As a result, substitute meteorological data does not constitute a significant
portion of the meteorological database for the most critical variables.
The monitoring plan for the M-245 station includes quality assurance/quality control (QA/QC) procedures
to ensure that the data collected meets the standards of reliability and accuracy as required by U.S. EPA
(U.S. EPA, February 2000). The QA/QC procedures implemented by ATK at this station include semi-
annual audits and calibrations of instruments, periodic site inspections, data validation, and preventive
maintenance. Meteorological data collected at this on-site station has been approved by the Utah
Department of Environmental Quality (UDEQ) for use in prior modeling analyses to evaluate the air
quality impact of ATK OB and OD treatment operations.
090904/P 4-18
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The meteorological data collected at the M-245 station is recommended to be appropriate for use in this
modeling analysis for the following reasons:
1. Data recovery statistics for the 1997 to 2001 on-site meteorological database exceed U.S. EPA
minimum requirements for on-site data recovery.
2. Each annual period of data has been validated by an independent consultant.
3. ATK is located in a remote area of northern Utah. As a result, the potential for finding local sources of
houriy, climatological data that depict local climatology and satisfy the requirements of OBODM is
extremely low. The nearest available source of validated houriy surface observation data (including
sky condition) is located at Hill Air Force Base (AFB) in Hill, Utah. Hill is located approximately 30
miles southeast of ATK. The M-245 meteorological monitoring station is located 5 miles and 1 mile,
respectively, from M-136 and M-225 treatment units and has been approved by UDEQ for use in prior
ATK modeling analyses.
4. Because previous air dispersion modeling has not been conducted for treatment operations at M-136
and M-225, Hill AFB has not been used as a surrogate for missing meteorological data. In addition to
the meteorological parameters measured at the M-245 monitoring station, the meteorological
preprocessor used to prepare the meteorological input file for OBODM requires houriy values of
opaque cloud cover and ceiling height. These parameters are not measured at M-245. Houriy values
of opaque cloud cover and ceiling height are only available from 1*' class NWS reporting stations.
The closest 1^ class reporting station to ATK is located at Hill AFB. In addition to being the closest l"
reporting station to ATK, Hill AFB and M-245 have climatological and topographical similarities that
support of the selection of Hill AFB as a source of substitute data based on elevation, alignment of
the terrain and valley at both locations and other conditions described in Section 4.7.1. The use of
surface data from Hill AFB will be addressed as a source of uncertainty in the air modeling report.
5. The M-245 monitoring station is located on a hilltop southwest of M-225. This station has been sited
in accordance with Prevention of Significant Deterioration (PSD) monitoring guidance (USEPA, 1987)
and is considered representative of the free stream wind flow that transports emissions from the M-
136 and M-225 treatment units. This station is also representative of the diurnal variations in wind
patterns that are characteristic of mountain valley winds in the western United States (AMS 2002),
In addition to the meteorological parameters measured at the M-245 monitoring station, hourly values of
opaque cloud cover and ceiling height are needed in order to preprocess the meteorological data for input
into OBODM, Hourly values of opaque cloud cover and ceiling height are only available from 1^ class
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NWS reporting stations. These stations are usually operated by the NWS or the military. The closest 1^'
class reporting station to ATK is located at Hill AFB. Hill AFB houriy observation data for opaque cloud
cover and ceiling height are available from the National Climatic Data Center (NCDC) for the same 5-year
period as the ATK on-site data. ATK is proposing to merge hourly observations of cloud cover and ceiling
height from Hill AFB with M-245 station hourly data to develop the required surface data for input a
meteorological data preprocessing program (PCRAMMET - see Section 4.7.3).
As indicated in Table 4-7, there are varying percentages of missing data the M-245 five-year database.
The meteorological preprocessor program that will be used to prepare input files for OBODM requires a
complete dataset for an entire year. In other words, missing data values must be filled in with substitute
data. The substitute data is normally obtained from a nearby location that has similar climatological
characteristics.
ATK is proposing to follow the guidance recommended by USEPA (USEPA, 2000) for the substitution of
missing data. Missing 1-hour periods of surface data will be substituted by interpolation of the previous
and following hour's values. For periods greater than 1-hour, data will be substituted from the nearest,
representative houriy reporting station, which is Hill AFB. In addition to reporting hourly cloud cover and
ceiling height, this station also reports houriy values of wind speed, wind direction and temperature. Due
to its same geographical location and similar topography setting, Hill AFB has been selected as a source
of representative substitute data for missing data.
In addition to being the closest 1** reporting station to ATK. Hill AFB and ATK have climatological and
topographical similarities that support of the selection of Hill AFB as a source of substitute data:
• Hill AFB is located at the base of a valley similar to ATK.
• The alignment of the complex terrain and valley at both monitoring locations is primarily north to
south.
• Hill AFB is bounded by higher terrain (Wasatch Mountains). The ATK site is bounded by higher
terrain (Spring Hills).
• Both ATK and Hill AFB are located between 25 to 30 miles northeast of the Great Salt Lake. Any
influence from the Great Salt Lake is expected to be similar at both locations.
090904/P 4-20
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• The amount of missing data from the M-245 station in each annual period was in the range of one to
six percent. As a result, substitute wind speed, wind direction and temperature data from Hill AFB will
not constitute a significant portion of missing meteorological database for the most critical variables.
4.7.2 Upper Air Observations (Mixing Height Data^
Upper air data, also known as mixing height data, is required to run OBODM. Twice daily mixing heights
available from upper air sounding stations are used by the meteorological preprocessor program to
calculate houriy rural or urban mixing height data for input into OBODM. Upper air sounding data is
normally obtained from National Weather Service upper air reporting stations. The number of upper air
reporting stations in the western United States is very limited due to operational requirements and
budgetary constraints, which play a key role in the determining where and how many stations are
operated. As a result, this condition limits the availability of upper air reporting stations near to a source.
The closest NWS upper station to ATK is located in Salt Lake City, which is about 80 miles south of ATK.
The next closest NWS upper air reporting station is located in Lander, Wyoming, which is about 190 miles
northeast of ATK. Although considerable site-to-site variability is expected for measurements taken close
to the surface compared to upper air measurements. ATK believes the upper air sounding measurements
from Salt Lake City are generally representative of a much larger spatial domain, which includes the
northern Utah valley.
It is important to note that the PCRAMMET preprocessor program uses the Holzworth Method (USEPA
1996) to calculate twice-daily mixing heights. With this method, the morning mixing height is calculated
using the morning minimum surface temperature, which occurs between 0200 and 0600 hours. The
afternoon mixing height is calculated using the maximum temperature observed from 1200 to 1600 hours.
As a result, the surface temperature is an important factor in the mixing height computation routine. ATK
will use a combination of upper air data from Salt Lake City and surface temperature observations from
Hill AFB to produce twice-daily mixing heights.
Other critical meteorological parameters used by PCRAMMET to calculate mixing height include cloud
cover and ceiling height, which are only available from 1^ class NWS stations. As indicated previously,
the M-245 station does not collect cloud cover and cloud ceiling height data. As a result, it is necessary
to obtain these parameters from another nearby location that is most representative of meteorological
conditions at ATK,
Based on a review of 1°' class NWS stations near ATK, it is assumed that Hill AFB is a suitable choice for
houriy meteorological parameters that are not available at M-245, in comparison to other nearby NWS
stations such as Salt Lake City for several reasons. Hill AFB is geographically much closer to ATK and is
090904/P 4-21
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assumed to be located beyond the urban heat flux influence of Salt Lake City. In addition, the NWS Salt
Lake City reporting station is located only 10 miles from the Great Salt Lake, which is known to influence
local climate. Depending on the time of the year, the temperature of the Great Salt Lake can moderate
local temperatures and affect the lake/valley wind system. As a result, the use of cloud cover and ceiling
height observations from Hill AFB is expected to be more representative of conditions at M-245 and will
provide consistency in the calculation of stability class in the meteorological preprocessor.
4.7.3 Meteorological Preprocessor
The surface observation and mixing height data files for each annual period will be preprocessed for input
into OBODM using PCRAMMET (U.S.EPA. 1995b) as recommended in the HHRAP guidance (USEPA.
July 1998 and August 1999). The format of the PCRAMMET output file is compatible for use with
OBODM.
The input requirements for PCRAMMET include houriy surface observations of year, month day, hour,
ceiling height, wind speed, wind direction, dry bulb temperature, and opaque cloud cover in CD144
fomiat. The resulting output file from PCRAMMET contains houriy values of wind speed, wind direction,
ambient temperature, stability category, rural mixing height, and urban mixing height. The rural mixing
heights will be used in this modeling analysis.
As stated in Section 4.7,1, data recovery for the M-245 five-year database is greater than 90 percent to
100 percent for all input variables, with the exception of cloud ceiling height and opaque cloud cover,
which is not collected at M-245. Substitute hourly cloud ceiling height and opaque cloud cover, for the
corresponding annual periods, will be obtained from Odgen AFB and inserted into the hourly onsite data
files to develop a complete input file for PCRAMMET.
In the case of missing surface observations at the M-245 station, current USEPA data substitution
guidance (on-site guidance reference) using interpolation will be followed In the case of one-hour gaps.
In the case of lengthy (greater than 1 hour missing) missing data periods, surface observations from the
Hill Air Force base will be used as substitute data. The Hill AFB surface data is considered to be the most
representative site for providing substitute data based on its location relative to ATK, climatology, location
relative to higher surrounding terrain, and similar land use. In the case of missing mixing height data,
missing data will be substituted in accordance with USEPA guidance (USEPA 1992).
4.8 COMPARISON TO AIR QUALITY STANDARDS AND EXPOSURE CRITERIA
As described in Section 4.9, OBODM modeling results with be post-processed in conjunction with 1.1.
1.3, and Category E emission factors presented in Section 3 to determine the impact of emissions from all
090904/P 4-22
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sources at M-136 and M-225. The post-processing activities will determine the maximum air
concentrations and deposition rates at the maximum onsite and offsite receptors and all discrete
receptors for 1-hour, 3-hour. 8-hour. 24-hour, and annual averaging periods. The calculated air
concentrations will then be compared to all applicable air quality standards, occupational exposure criteria
concentrations, and Utah Toxic Screening Levels (TSLs), and serve as input for the HHRA. The
comparative analysis to applicable standards and TSLs will also consider the impact from background
sources and delineate the contribution from background sources and the contribution from ATK OB and
OD sources.
Generally, the ambient impacts from background sources can be represented by air quality data collected
in the vicinity of the source. ATK no longer collects PMIO air quality in Box Elder County. In addition,
UDAQ has limited air quality monitoring data for in Box Elder County. The closest Utah air quality
monitoring station (AQS# 49-003-0003) to the ATK facility is located in Brigham City, Box Elder County.
Utah. The Brigham City monitoring station is part of the USEPA's ambient air quality monitoring program,
which is carried out by State and local agencies and consists of three major categories of monitoring
stations. State and Local Air Monitoring Stations (SLAMS). Currently, this station only monitors PM2.5
and ozone parameters.
UDAQ has also recommended Ogden, Utah as a potential alternate source of background air quality
data. Unless directed othenwise, ATK will utilize historical air quality data from the Utah Air Pollution Data
Archive from Box Elder and Ogden as background air quality concentrations for the comparative analysis.
It is important to note that background values may not be available for all criteria pollutants because of
limited sampling conducted by the State.
The applicable air quality standards/exposure criteria will include the criteria pollutants (National Ambient
Air Quality Standards [NAAQS]) and Utah Toxic Screening Levels (TSLs). The State of Utah has
adopted the NAAQS. In the case of on-site air concentrations, 2008 Occupational Safety and Health
Administration (OSHA) time-weighted-average (TWA) exposure concentration values will be used to
evaluate ATK worker exposure at each treatment unit. These TWA values are based on an 8-hour
exposure period. ^
The comparative analysis, applicable standards and TSLs, will clearly delineate the contribution from
background sources and the contribution from ATK OB and OD sources.
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4.9 POST-PROCESSING ACTIVITIES
The output from OBODM output files will require post-processing in order to calculate receptor
concentrations and deposition values for ali target analytes identified in Section 3 for 1.1, 1.3, and
Category E waste materials. The post-process activities to be used are summarized below.
Post-processing of OBODM output files will involve the following activities:
• Determine the location and value of the maximum, 1-hour and annual average air dispersion factors
for on-site and off-site receptors in flat terrain and complex terrain from the general receptor grids,
and all discrete receptors for each type of dispersion modeling and year of meteorological data.
Summarize the results in an Excel workbook.
• Calculate the 1-hour and annual average pollutant concentrations and deposition values. The
individual pollutant air concentrations will be calculated by multiplying the maximum 1-hour or annual
air dispersion factor (pg/m^-lb/hr) x the pollutant specific emission factor (Ib/Ib) x treatment quantity
per hour (Ib/hr) = pg/m^ or pg/m^. Vapor deposition (pg/m^) will be calculated by multiply the OBODM
gas dosage ( pg-sec/m^) x the assumed settling velocity (m/sec) dosage value x In the case of vapor
deposition, individual pollutant. In the case of particle and particle-bound deposition in complex
terrain, deposition (pg/m^) will be calculated by multiplying the particle/particle bound dosage x the
assumed settling velocity.
• Adjust where necessary the short term and long term unit emission rate concentrations and
deposition values based on the modeled treatment quantity daily and/or annual allowable treatment
quantities given in Tables 2-1 and 2-2. For example, in the case of Category E waste treated at M-
136. the modeled treatment quantity for Source 2 OB is 50.000 pounds. However, the treatment
quantity for Category E waste is only 5.000 pounds. If the modeled 1-hour concentration for pollutant
PMIO is 1.0 pg/m^ based a treatment quantity of 50.000 pounds and the actual Category E treatment
limit is 5.000 pounds of materials, then the maximum 1-hour PMIO concentration for treating
5,000 pounds of material is 1.0 x (5000/50.000) = 0.10 pg/m^.
• Convert 1-hour concentrations into 8-hour and 24-hour concentrations for comparison analysis to
National Ambient Air Quality Standards (NAAQS) short-term standards, OSHA exposure criteria, and
Toxic Screening Levels (TSLs) that have been established by Utah Department of Air Quality. The 1-
hour air concentrations will be converted to longer averaging periods using USEPA guidance
identified in the document Screening Procedures for Estimating the Air Quality Impact of Stationary
Sources (USEPA, 1995), Where available, add background concentrations to the air concentrations
to determine compliance with NAAQS and UTAQ TSLs.
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• Format OBODM modeling results for input into the IRAP-h and EcoView risk assessment models.
4.10 OBODM MODELING FILES
At the conclusion of the air dispersion modeling analysis and human health risk assessment, copies of
the OBODM input and output files and model-ready meteorological data files will be provided to DSHW in
electronic format on compact disc (CD) for review of modeling analysis.
090904/P 4-25
TABLE 4-1
M-136 SOURCE PARAMETERS
ATK PROMONTORY, UTAH
Source Parameter Source 1 - OB Source 2 - OB Source 3 - OB Source 4 - OD
Treatment Operations OB in Pans
Burn Stations 1-12
OB in Pans
Burn Station 13
OB
Burn Stations 14
OB
Burn Stations 14
Location Center of Burn
Station
Center of Burn
Station
Center of Burn
Station
Center of Burn
Station
Number of sources 1 1 1 1
Source Dimensions
(length,widfh,depth) 68 m, 1.5 m, GL 5.1 m. 2.13 m. GL 15.24 m, 1.52 m.GL 1.5 m diameter
Source Release Type Quasi-continuous Quasi-continuous Quasi-continuous Instantaneous
Burn/Release Duration
(OBODM calculated based
on source type)
300 seconds 300 seconds 300 seconds Instantaneous
Source Configuration Volume Volume Volume Volume
Effective Release Height
(m) 1 meter 1 meter 1 meter Calculated by
OBODM
1.3 waste heat content 1,471 cal/g 1.471 cal/g 1,471 cal/g 1.471 cal/g
1.1 waste heat content 1,372.6 cal/q 1,372,6 cal/g 1,372.6 cal/g 1.372,6 cal/g
Category E waste heat
content 820.4 cal/g 820.4 cal/g NA NA
Number of treatment
events (per day)
1 per hour between
1000 and 1800
hours
1 per hour between
1000 and 1800
hours
1 per hour between
1000 and 1800 hours
1 per hour between
1000 and 1800
hours
Number of treatment days
assumed by OBODM (per
vear)
365 days 365 days 365 days 365 days
Unit emission factor 1.0 1.0 1.0 1.0
OBODM Modeled
Treatment Quantity/Event
106,500 pounds 50,000 pounds 106,500 pounds 600 pounds
ATK Annual Maximum
Treatment Quantity
7.500.000 pounds 496,400 pounds 2.000,000 pounds 3,600 pounds
NA - Not applicable. Category E wastes are not treated at BS-14 (Sources 3 and 4).
GL - ground level
TABLE 4-2
M-225 SOURCE PARAMETERS
ATK PROMONTORY, UTAH
Source Parameter Source 1 - OB Source 2 - OD
Treatment Operations OB OD (Uncovered)
Location Center of M-225 Unit Center of M-225 Unit
Number of sources 1 1
Source Release Type Quasi-continuous Instantaneous
Burn/Release Duration
(OBODM calculated based
on source type)
300 seconds Instantaneous
Source Configuration Volume Volume
Source Dimensions
(length.wide, depth)
5.18 m X 1.83 m 1.5 m diameter buried
uncovered
Effective Release Height (m) 1 meter Calculated by OBODM
Source Diameter NA 1.5 meters
1.3 waste heat content 1,471 cal/g 1,471 cal/g
1.1 waste heat content 1.372.6 cal/g cal/g
Category E waste heat
content 820.4 cal/g NA
Number of treatment events
(per day)
1 per hour between
1000 and 1800 hours
1 per hour between
1000 and 1800 hours
Number of treatment days
assumed by OBODM (per
year)
365 365
Unit emission factor 1.0 1.0
OBODM Modeled Treatment
Quantity/Event
4,500 pounds 600 pounds
ATK Annual Maximum
Treatment Quantity
52,500 pounds 2,500 pounds
NA - Not applicable. Category E waste not treated at Source 2.
TABLE 4-3
SUMMARY OF DEPOSITION MODELING PARAMETERS
ATK PROMONTORY, UTAH
Parameter Gas Phase OBODM Run Particulate Phase OBODM Run
Emission Surrogate CO2 Aluminum (density of 2,7 g/cm^)
Emission Factor 1.0 1.0
Non-gravitational dry deposition Yes (computed in post-
processing step)
No
Gravitational settling No Yes
Mean particle diameter -30 um
Particle size standard deviation -2.0
Number of particle size classes -10
Cloud depletion No Yes
OBODM Output Air concentration (pg/m^) Deposition rate (pg/m^)
TABLE 4-4
ATK ASSUMED PARTICLE SIZE DISTRIBUTION INFORMATION FOR
OPEN BURN AND OPEN DETONATION OBODM DISPERSION MODELING
Proportion Fraction of
Upper Bound Limit Lower Bound Limit Mean Particle Particle ^ Surface Fraction of Total Available Surface Total Surface
Size Group (H) M Diameter (\i) Radius (|i) Area/Volume (n'') Mass Area Area)
1 60.57 44.04 50.69 25.34 0,12 0.02 0.003 0.00
2 44.04 32.01 36.97 18.48 0.16 0,05 0.008 0.01
3 32.01 23.27 26.96 13.48 0.22 0.10 0.022 0.04
4 23.27 16.92 19.66 9.83 0.31 0.15 0.045 0.07
5 16.92 12.3 14.34 7.17 0.42 0.18 0.076 0.13
6 12.3 8.94 10.46 5.23 0.57 0.18 0.104 0.17
7 8.94 6.5 7.63 3.81 0.79 0.15 0,116 0.19
8 6.5 4.73 5.56 2.78 1,08 0.10 0.105 0.17
9 4.73 3.44 4.06 2.03 1.48 0.05 0.077 0.13
10 3.44 2,5 2,96 1.48 2.03 0.02 0.046 0,08
TABLE 4-5
5-YEAR WIND ROSE SUMMARY FOR THE
M-245 METEOROLOGICAL MONITORING STATION
THIOKOL PROPULSION
BRIGHAM CITY, UTAH
Direction Frequency/Wind Speed Group (m/sec) 5-Year
Averaiae DIRECTION 1997 1998 1999 2000 2001
5-Year
Averaiae
NNE 0.08 0.08 0.10 0.09 0.10 0.09
NE 0.07 0.10 0.09 0.12 0.11 0.10
ENE 0.04 0.04 0.05 0.05 0.05 0.05
E 0.04 0.05 0.04 0.04 0.05 0.04'
ESE 0.03 0.04 0.05 0.05 0.04 0.04
SE 0.05 0.05 0.06 0.04 0.05 0.051
SSE 0.05 0,06 0.04 0.06 0.05 0.051
S 0.03 0.03 0.04 0.07 0.02 0.04;
SSW 0.02 0.01 0.01 0.02 0.01 0.01!
SW 0.04 0.02 0.01 0.01 0.03 0.02i
WSW 0.07 0.05 0.04 0.05 0.06 0.05 i
W 0.10 0.11 0.08 0.10 0.11 o.io;
WNW 0.07 0.07 0.06 0.06 0.07 0.07*
NW 0,11 0.08 0.09 0.07 0.07 0.08'
NNW 0.11 0.10 0.11 0.08 0.08 0.10:
N 0.10 0.11 0.13 0.09 0.10 0.11 !
1
TOTAL 1.00 1.00 1.00 1.00 1.00 1.0 ,
TABLE 4-6
DATA RECOVERY PERCENTAGES* FOR
CRITICAL VARIABLES MONITORED AT THE M-245
METEOROLOGICAL MONITORING STATION
THIOKOL PROPULSION
BRIGHAM CITY, UTAH
PARAMETER 1997 1998 1999 2000 2001
Wind Speed 95 99 91 99 98 i
Wind Direction 95 96 91 99 94 i
Temperature 94 99 91 99 94 i
- After validation.
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LOCATION OF ATK PROMONTORY M-136 AND M-225 TREATMENT UNITS
AND DISCRETE hK>DELIN6 RECEPTORS
PROMONTORY, UTAH
(WW MO
LOCATION OF ATK PROMONTORY M-136 AND M-225 TREATMENT UNITS
AND DISCRETE hK>DELIN6 RECEPTORS
PROMONTORY, UTAH
AS NOTED
LOCATION OF ATK PROMONTORY M-136 AND M-225 TREATMENT UNITS
AND DISCRETE hK>DELIN6 RECEPTORS
PROMONTORY, UTAH F10URE4-1 0