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Home My WebLink AboutDSHW-2010-037670 - 0901a068801c831eSEP 2 1 2010 September 16, 2010 ,n^I^^?Sn^^^^^ 8200-FYl 1-042 SOLID & HAZARDOUS WAST[ 201D.031U, Scott T. Anderson Executive Secretary Division of Solid and Hazardous Waste P. O. Box 144880 Salt Lake City, UT 84114-4880 Subject: Comments on the ATK - Promontory Draft Permit Modiflcation Dear Mr. Anderson, ATK Launch Systems submits the attached comments as part of the public comment period for the draft permit modification. Please refer question regarding these comments to Blair Palmer at (435 863-2430 or blair.palmer(a),atk.com). Sincerely David P. Gosen, P.E. Director, Environmental Services cc: JeffVandel, DSHW George Gooch, ATK Paul Hancock, ATK Blair Palmer, ATK Module 1 I.T.3 LT.6.C L DD.l Module 2 ILG.2 Module 3 III. E.3.C IILE.7. Module 4 IV. B.3. SEP 2 1 2010 UTAH DIVISIUIM ui- SOLID & HAZARDOUS WASTt The State has included language regarding perchlorate and per^^ate^ ' ^-^'^^^^ salts within the text of the permit. These compounds are not a hazardous waste or a hazardous constituent nor is there a record of them being deemed dangerous to life or health by the Executive Secretary. ATK requests that all references to perchlorate and perchlorate salts be removed from the permit. Correct paragraph number error. update the DSHW telephone number. It is recommended that TCDD TEQ be replaced with .. " the most restrictive compound identified by the risk assessment." It is possible that compounds other than TCDD could be the limiting factor. Modify to read, "M-136- 106,500 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste as described in condition in.B.4 in bum trays or in a rocket case placed on the ground; and Modify to read, "Hazardous waste containers shall not be stacked at storage areas M-705S, M-47, M-603, S-633 and M-136 except as described in Attachment 9-2.3. Modify to read," The Permittee is prohibited from thermally treating reactive hazardous waste classes and compositions not included in Condition rV.B.2. rV.C.S.e ATK recommends deleting this requirement since it is an internal safety precaution, and should be managed by ATK safety requirements and not by the Division. rV.C.3.j ATK recommends deleting this requirement since it is an internal safety precaution, and should be managed by ATK safety requirements and not by the Division. rV.C.6.a Modify to say, "ATK shall notify Box Elder County Dispatch each day before treatment operations involving reactive material. rv.f I .d ATK recommends deleting this requirement since it is an internal safety precaution, and should be managed by ATK safety requirements and not by the Division. IV.G.2.a ATK recommends deleting this requirement since it is an internal safety precaution, and should be managed by ATK safety requirements and not by the Division. IV.G.2.j correct reference to condition IV.G.2.i. rV.G.3. Add the following exception to completing cleaning within 24 hours, "unless metrological conditions identified in condition IV.G.2.i. prohibit re-entry into the treatment area." IV.K.4 Replace IV.K.4., IV.K.V.a and IV.K.4.b with the following, " An existing groundwater monitoring program monitors groundwater at both treatment locations under a Post Closure Permit. The constituents of concern in the monitoring plan include the constituents thermally treated. A groundwater risk assessment is being conducted under the Post closure permit based on the results of the approved site specific groundwater model for contaminant fate and transport. Within 180 days of the issuance of this Permit, or completion of the Human Health Risk Assessment, whichever occurs later, the Permittee shall submit a plan for the long term trend analysis of groundwater contaminant levels at M-136 and M-225 using appropriate statistical methods. This trend will then be compared to results of the groundwater risk assessment. Based on this comparison, any significant increases in constituent concentrations that would affect the conclusion of the risk assessment will require a reevaluation of the risks and any corrective actions." rV.M.l Replace the existing module with : The Permittee shall submit the Waste Characterization and Air Dispersion Modeling Report, which will be used in the Human Health Risk Assessment, within 120 days of receiving approval for the Waste Characterization and Air Dispersion Modeling Protocol from the Executive Secretary. If the Executive Secretary does not approve the Waste Characterization and Air Dispersion Modeling Report, he shall provide written comments to the Permittee identifying the deficiencies in the document. The Permittee shall address the comments and submit a revised Waste Characterization and Air Dispersion Modeling Report to the Executive Secretary for approval within 60 days of receipt of written comments. IV.M.2. Replace the exiting module with: The Permittee shall submit the Human Health Risk Assessment Report within 90 days of receiving approval for both the Human Health Risk Assessment Protocol and the Waste Characterization and Air Dispersion Modeling Report. If the Executive Secretary does not approve the Human Health Risk Assessment Report, he shall provide written comments to the Permittee identifying the deficiencies in the document. The Permittee shall address the comments and submit a revised Human Health Risk Assessment Report to the Executive Secretary for approval within 60 days of receipt of written comments. Attachment 4 Page 49 ATK recommends adding flares and flare material to the material table for S-633 REACTIVE HAZARDOUS WASTE STORAGE PAD. Attachment 7 7.1.4 Due to the nature of our security requirements and controlled access to the facility, ATK recommends eliminating the requirement to provide signs in Spanish. Attachment 9 9-2.1 ATK recommends modifying the third paragraph to read, "All solid reactive waste received from off-site will be stored in containers as described in Attachment 11.4. All containers will be kept closed during storage. Attachment 11 11.10.1 ATK recommends replacing the last paragraph in the Groundwater Monitoring Plan section with the following, "This existing groundwater monitoring program monitors groundwater at both treatment locations. The constituents of concern in the monitoring plan include the constituents thermally treated. A separate groundwater risk assessment is being performed based on the results of the approved site specific groundwater model for contaminant fate and transport. Using monitoring results, a long-term trend analysis shall be conducted for groundwater at M-136 and M-225 using appropriate statistical methods. This trend will then be compared to results of the risk assessment. Based on this comparison, any significant increases in constituent concentrations that would affect the conclusion of the risk assessment will require a reevaluation of the risks and any corrective actions."