DSHW-2010-056122 - 0901a0688026d1ee (15)

October 13, 2010

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

RE: Response to ATK’s Comments on the Class 3 Hazardous Waste Permit Modification to Add Treatment by Open Burning and Open Detonation
Tracking Number 10.01569
UTD009081357

Dear Mr. Gosen:

On September 30, 2010, ATK’s permit modification request to add treatment of reactive hazardous waste by open burning/open detonation and other changes was approved. Two public comment
periods were held in conjunction with the permit modification. The second public comment period ended on September 17, 2010. The Division of Solid and Hazardous Waste received ATK’s
comments on the draft permit modification on September 16, 2010. Other comments were received from the public.

The Division has completed its review of ATK’s comments on the draft permit modification that was made available to the public during the second public comment period. Our responses
to ATK’s comments are enclosed with this letter. A number of changes to permit conditions have been made based on ATK’s comments. In addition, the Division made a few changes to the
draft document to clarify permit conditions. The Division considers these changes non-substantive and an additional comment period will not be held. All changes to the draft document
are shown with Division responses to ATK’s comments.

If you have any questions, please contact Jeff Vandel at [phone].

Sincerely,

ORIGINAL DOCUMENT SIGNED BY SCOTT T. ANDERSON ON 10/13/2010

Scott T. Anderson, Executive Secretary
Utah Solid and Hazardous Waste Control Board

STA\JV\tjm

Enclosure

c: George Gooch, ATK Launch Systems
Blair Palmer, ATK Launch Systems
Lloyd Berentzen, MBA, Health Officer, Bear River Health Department

ATK LAUNCH SYSTEMS INC. – PROMONTORY
PERMIT MODIFICATION

RESPONSE TO COMMENTS

The Division of Solid and Hazardous Waste conducted a 45-day public comment period from August 4, 2010 until September 17, 2010 to allow the public the opportunity to comment on the
Permit Modification request. In conjunction with this public comment period, the Division held a public hearing at the Brigham City Public Library on September 9, 2010.

On September 16, 2010, the permittee submitted 21 comments on the Permit Modification. The Division’s responses to these comments are shown below.

________________________________________________________________________

ATK Comment:

Module I
I.T.3. The State has included language regarding perchlorate and perchlorate
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.

Response to Comment:

The inclusion of perchlorate and perchlorate salts in this permit is within the rights of the Executive Secretary’s authority under R315-3-3.3(b)(2) of the Utah Administrative Code (UAC).
This provision of the UAC allows the Executive Secretary to incorporate conditions into the permit that are necessary to protect human health and the environment. The Executive Secretary
considered a number of issues before deciding to develop and incorporate permit conditions that are specific to perchlorate and perchlorate salts. The inclusion of the conditions that
specifically address perchlorate and perchlorate salts in this Permit is based on a number of issues that are present at the Promontory facility. The following conditions exist at the
Promontory facility:

1) Ammonium perchlorate is a primary ingredient in the formulation of solid propellants manufactured by ATK (the Permittee) at the Promontory facility;

2) Past disposal practices have resulted in the release of perchlorate to the environment. This release is documented by the Permittee’s groundwater monitoring program. Perchlorate
is one of the constituents that comprise the Groundwater Protection Standard in ATK’s Post-Closure Permit.

3) The operations at the Permittee’s facility periodically release perchlorate and perchlorate salts to the environment; and

4) The hazardous waste management rules do not adequately address the risks to human health or the environment associated with perchlorate and perchlorate salts.

While writing this Permit, the Executive Secretary developed two permit conditions specific to perchlorate and perchlorate salts to protect human health and the environment, and minimize
the further release of perchlorate to the environment. These conditions are I.K.1., and I.T.3.

Condition I.K.1. requires the Permittee to take all reasonable steps to minimize releases of solid and hazardous wastes, hazardous waste constituents, and perchlorate salts to the environment
and to carry out such measures as are reasonable to prevent significant adverse impacts on human health or the environment. All hazardous waste permits issued by the Executive Secretary
include a condition similar to this one. Perchlorate salts were included to minimize the potential introduction of additional perchlorate to the environment. The Executive Secretary
believes that this is an appropriate permit condition given the risks associated with perchlorate and the operational history of the Promontory facility.

In Condition I.T.3., the Executive Secretary defines when the Permittee needs to report a spill or release that contains perchlorate. This condition was developed to complement Condition
I.K.1. The reporting standard is based on the toxicity of perchlorate and the fact that perchlorate is not an acute toxin.

The commenter states that perchlorate and perchlorate salts are neither a hazardous waste nor a hazardous constituent. The current rules do not define perchlorate or perchlorate salts
as a hazardous waste constituent. However, while it is true that perchlorate and perchlorate salts are not a listed hazardous waste, they can be a characteristic hazardous waste for
ignitability (D001) and reactivity (D003). It should also be noted that the conditions in this permit, which address perchlorate and/or perchlorate salts, have not defined perchlorate
or perchlorate salts as a listed hazardous waste.

The commenter stated that a review of the public record pertaining to the facility failed to show any documented decision by the Executive Secretary or supporting technical or risk-based
information or determinations justifying the inclusion of perchlorate and perchlorate salts in this permit.

While there is no so-called “specific decision document” on perchlorate in the facility files, there are a number of documents that identify the Executive Secretary’s concerns with respect
to the perchlorate contamination and the desire to minimize the possibility of creating additional perchlorate source areas. The facility file for the Promontory facility includes the
following information: groundwater monitoring data; groundwater modeling reports; risk assessment reports; corrective action reports and pilot test reports.

The facility files document that the Permittee has reported releases of perchlorate at SWMUs at the Promontory facility. Perchlorate has been identified as a reactive waste that is
present as a contaminant at the facility in the RFI Phase I Workplan (April, 1993) and the RFI Phase I Report (August, 2000). In addition, ATK is currently conducting a pilot test at
the Promontory facility to evaluate a method for treating soil contaminated with perchlorate.

The groundwater monitoring program has been assessing the magnitude and extent of the groundwater contamination at the Promontory facility for many years. ATK has been analyzing groundwater
samples for perchlorate since 1987. In addition, groundwater flow and contaminant transport models have been developed for the Promontory facility which are currently being used to
predict the migration of perchlorate contamination in the groundwater.

The Executive Secretary has also developed a fact sheet for Perchlorate. This fact sheet was initially authored in 1999 and updated in 2005. The fact sheet describes the perchlorate
ion, the environmental fate and transport concerns, the known human health effects, the perchlorate contaminated sites in the State of Utah, the regulatory status and remediation guidance.
The fact sheet can be found on the Department website and hard copies can be obtained at the offices of the Division of Solid and Hazardous Waste.

In December, 2008, the EPA established an interim health advisory (HA) level for subchronic exposure to perchlorate. HAs establish non-regulatory concentrations of drinking water contaminants
at which adverse health effects are not anticipated to occur over specific exposure durations (one day, ten days, a subchronic period, several years, and a lifetime). HAs serve as informal
technical guidance to assist Federal, State and local officials, and managers of public or community water systems in protecting human health when emergency spills or contamination situations
occur. They are not legally enforceable federal standards and are subject to change as new information becomes available (Interim Drinking Water Health Advisory for Perchlorate, EPA,
Office of Water, December 2008).

The Interim Drinking Water Health Advisory level for perchlorate established by the EPA is 15 μg/l. This HA level is based on the recommendations of the National Research Council (NRC)
of the National Academies as reported in “Health Implications of Perchlorate Ingestion” (NRC, 2005). The NRC recommended and EPA adopted a Reference Dose (RfD) of 0.7 μg/kg/day. The
perchlorate HA level was calculated using this Reference Dose. It should be noted that the 15 ug/l concentration is protective for adults, children and a developing fetus. Further
information on the calculation of the HA level may be obtained from the EPA document referenced above.

The spill reporting limit for perchlorate releases identified in Condition I.T.3. is being changed to the HA level (15 µg/l). In accordance with R315-9 of the UAC, when a non-acute
material is released to the environment, the volume released must be greater that 100 kilograms to be a reportable quantity. Condition I.T.3 also requires that the perchlorate concentration
of the spilled material must be greater than 15 ug/l.

The Executive Secretary has considered this comment and determined that all requirements and references specific to perchlorate and perchlorate salts should be maintained in Permit Conditions
I.K.1 and I.T.3.

The edited Permit Condition I.T.3., as it appears in the final permit, is shown below:

I.T.3. The Permittee shall immediately report to the Executive Secretary any spill that contains perchlorate, if the spilled quantity exceeds 100 kilograms and the perchlorate concentration
of the spilled material is greater than15 ug/L. Any such information shall be reported as soon as possible, but not later than 24 hours from the spill occurrence.

________________________________________________________________________

ATK Comment:

I.T.6.c. Correct paragraph number error.

Response to Comment:
The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

I.T.6. The written report shall include, but not be limited to the following:

I.T.6.a. The name, title, address, and telephone number of the individual reporting;

I.T.6.b. A description including the date, time, location and nature of the reported incident;

I.T.6.c. The extent of injuries, if any;

I.T.6.d. The name and quantity of material(s) involved in the spill;

I.T.6.e. An estimated quantity and disposition of the recovered material;

I.T.6.f. An assessment of actual or potential hazards to human health and the environment, where this is applicable. The report shall also include whether or not the results of the
incident remain a threat to human health and the environment (whether the noncompliance has been corrected and the release has been adequately cleaned up); and

I.T.6.g. If the release or noncompliance has not been adequately corrected or cleaned up, the anticipated time that the noncompliance or remediation is expected to continue; the steps
taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance; and/or the steps taken or planned to adequately remediate the release.

________________________________________________________________________

ATK Comment:

I.DD.1. Update the DSHW telephone number.

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

I.DD.1. All reports, notifications, or other submissions which are required by this Permit to be transmitted to the Executive Secretary should be sent by certified mail or other means
of proof of delivery to:

Executive Secretary
Utah Solid and Hazardous Waste Control Board
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Phone [phone]

Normal business hours are 7 am to 6 pm, Monday through Thursday, except Utah State holidays. Required oral notifications shall be given only to the Executive Secretary or an authorized
representative of the Executive Secretary. Notifications made at other times shall be made to the 24-hour answering service at [phone]. Notifications made to the 24-hour answering
service shall include all applicable information required by this Permit. The Permittee shall give oral notification to the Executive Secretary or an authorized representative of the
Executive Secretary on the first business day following notification to the 24-hour answering service.

________________________________________________________________________

ATK Comment:

Module II
II.G.2. 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.

Response to Comment:

The Division agrees with the basis for ATK’s comment. The compounds and annual quantities that will comprise risk threshold limits should be based on the results of the HHRA. In accordance
with permit condition IV.M.3., ATK shall submit a request to modify Section II.G. of the permit to establish annual risk thresholds that are based on the findings of the approved HHRA.
Condition II.G.2 was changed to be consistent with Section II.G and Condition IV.M.3. The condition, as it appears in the final permit modification, is shown below:

II.G.2. Based on the findings of the Human Health Risk Assessment which shall be completed in accordance with Condition IV.M.2., the Permittee shall modify this section of the permit,
in accordance with Condition IV.M.3., to establish annual risk thresholds that minimize the risk to human health and the environment and ensure compliance with Permit Condition IV.C.5.

________________________________________________________________________

ATK Comment:

Module III
III.E.3.c. 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 III.BA in burn trays or
in a rocket case placed on the ground; and

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

III.E.3.c. M-136 – 106,500 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste, as described in Condition III.B.3 or III.B.4, in burn trays or in a rocket case placed on the
ground; and

________________________________________________________________________

ATK Comment:

III.E.7. 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.”

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

III.E.7. 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.

In addition, the following sentence was added to Attachment 9-2.3:

“Containers stored at S-633 that can be safely stacked, such as flare or munition boxes, may be stacked to a maximum height of 6 feet.”

________________________________________________________________________

ATK Comment:

Module IV
IV.B.3. Modify to read, “The Permittee is prohibited from thermally treating reactive hazardous waste classes and compositions not included in Condition IV.B.2.”

Response to Comment:

The intent of this condition is two-fold. First, the Permittee is prohibited from treating wastes not identified in Conditions IV.B.1 and IV.B.2. Second, the Permittee shall not treat
energetic reactive hazardous wastes by open burning that will detonate under open burning conditions. To clarify this condition, the Executive Secretary has separated the two parts
of it into two conditions. The two conditions that were modified are shown below as they appear in the final permit modification:

IV.B.3. The Permittee is prohibited from thermally treating reactive hazardous waste classes and compositions not included in Conditions IV.B.1 and IV.B.2, including wholly inert items,
improvised explosive devices (e.g. homemade bombs) and chemical wastes.

IV.B.4. The Permittee is prohibited from thermally treating, by open burning, energetic reactive hazardous wastes that will detonate under open burning conditions.

________________________________________________________________________

ATK Comment:

IV.C.3.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.

Response to Comment:

The federal Environmental Performance Standards for Miscellaneous Units (40 CFR §264.601), which are adopted and incorporated by reference in the Utah Administrative Code (R315-8-16),
state that miscellaneous units must be operated in a manner that will ensure protection of human health and the environment. Furthermore, “permits for miscellaneous units are to contain
such terms and provisions as necessary to protect human health and the environment, including, but not limited to…design and operating requirements.”

This provision of the UAC allows the Executive Secretary to incorporate conditions into the permit that are believed to be necessary to protect human health and the environment. The
intent of Condition IV.C.3.e is to ensure that the burn grounds are operated in a manner that is protective of human health. This condition will remain as it appears in the draft document.

________________________________________________________________________

ATK Comment:

IV.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.

Response to Comment:

The UAC Preparedness and Prevention Standards (R315-8-3.2) state that “facilities shall be designed, constructed, maintained, and operated to minimize the possibility of a fire, explosion,
or any unplanned sudden or non-sudden discharge of hazardous waste or hazardous waste constituents to air, soil, groundwater, or surface water which could threaten the environment or
human health.” In addition, as stated above, the federal Environmental Performance Standards for Miscellaneous Units (40 CFR §264.601), which are adopted and incorporated by reference
in the Utah Administrative Code (R315-8-16), state that miscellaneous units must be operated in a manner that will ensure protection of human health and the environment.

These provisions of the UAC allow the Executive Secretary to incorporate conditions into the permit that are necessary to protect human health and the environment. The Executive Secretary
has included the requirement for containment measures (e.g., firebreaks) to assure the confinement and control of any fire resulting from treatment operations at the burn grounds in
order to protect human health and the environment. The permit condition will remain as it appears in the draft document.

________________________________________________________________________

ATK Comment:

IV.C.6.a. Modify to say, “ATK shall notify Box Elder County Dispatch each day before treatment operations involving reactive material.”

Response to Comment:

Permit Condition IV.C.3.e requires the Permittee to record the temperature, wind speed, wind direction, sky conditions and clearing index prior to each burn in the facility operating
record. This data may be important for assessing the impact of treatment operations on the surrounding area. Since the clearing index is provided by the Box Elder County Dispatch (Fire
Marshall’s Office) and the clearing index may be updated during an eight-hour period, the Division believes it is still a good idea to notify them prior to each treatment operation.
The draft permit condition was edited to include a requirement to obtain the clearing index when notifying the Fire Marshall’s Office. The condition, as it appears in the final permit
modification, is shown below:

IV.C.6.a. ATK shall notify the Box Elder County Fire Marshall’s Office and obtain a clearing index before each treatment operation involving reactive material;

______________________________________________________________________________

ATK Comment:

IV.f.1.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.

Response to Comment:

As stated in Attachment 11, “plastic buckets are used to hold conductive and static dissipative bags. The buckets are reused and become contaminated with reactive material. The buckets
are cleaned by removing the contaminated material using a rag. The contaminated rag is then collected for disposal and managed as directed in UAC 315-5. If a bucket cannot be cleaned,
it is managed as a hazardous waste and treated by open burning.”

If the propellant buckets have the potential for being contaminated with reactive (hazardous) waste or containing hazardous waste after they are used, the Permittee must make a determination,
in accordance with UAC R315-2-7, on whether residues exist that are subject to regulation. If an inspection of the buckets indicates that cleaning is needed, then, as stated in the
Attachment, the rag that is used is managed as hazardous waste. This condition will remain as it appears in the draft document.

________________________________________________________________________

ATK Comment:

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.

Response to Comment:

The federal Environmental Performance Standards for Miscellaneous Units (40 CFR §264.601), which are adopted and incorporated by reference in the Utah Administrative Code (R315-8-16),
state that miscellaneous units must be operated in a manner that will ensure protection of human health and the environment. This provision of the UAC allows the Executive Secretary
to incorporate conditions into the permit that are necessary to protect human health and the environment. The intent of Condition IV.G.2.a is to ensure that the burn grounds are operated
in a manner that is protective of human health. This condition will remain as it appears in the draft document.

________________________________________________________________________

ATK Comment:

IV.G.2.j. Correct reference to Condition IV.G.2.i.

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

IV.G.2.j. The Permittee may delay the post-burn inspection for burns involving bulk propellant and bulk explosives that occurred on a Friday. The post-burn inspection shall be conducted
on the following Monday, unless the meteorological conditions identified in Condition IV.G.2.i prohibit re-entry into the treatment area. The Permittee shall document the reasons for
the delay in the facility’s operating record.

________________________________________________________________________

ATK Comment:

IV.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.”

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

IV.G.3. Within 24 hours of completing an open burn that generates a characteristic or listed ash or residue, the Permittee shall remove all characteristic or listed residues from the
treatment area and mange the waste in accordance with R315-5 of the UAC. If meteorological conditions exist, as identified in Condition IV.G.2.i., that prohibit re-entry into the treatment
area within the 24 hour period, the Permittee shall document the following information in the operating record:

______________________________________________________________________________

ATK Comment:

IV.K.4. Replace IV.K.4., IV.K.V.a. and IV.KA.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, which ever 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.”

Response to Comment:

A trend analysis may be an appropriate statistical method for assessing the impact of continued treatment operations on groundwater at the treatment areas. However, the Division prefers
to keep the condition more general in order not to limit what method may be used. In addition, the results of the statistical analysis will likely be compared to the results of the
risk assessment, but it is not necessary to include this proposed language in this condition. This condition will remain as it appears in the draft document.

________________________________________________________________________

ATK Comment:

IV.M.1. 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.

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

IV.M.1. 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.

ATK Comment:

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.

Response to Comment:

The Division agrees with ATK. The edited condition, as it appears in the final permit is shown below:

IV.M.2. 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.

________________________________________________________________________

ATK Comment:

Attachment 4
Page 49 ATK recommends adding flares and flare material to the material table for

S-633 REACTIVE HAZARDOUS WASTE STORAGE PAD.

Response to Comment:

The Division agrees with ATK. “Flares and Flare Material” was added to the S-633 Reactive Hazardous Waste Storage Pad Table on page 49 of Attachment 4.

________________________________________________________________________

ATK Comment:

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.

Response to Comment:

The Division agrees with ATK. The edited section of Attachment 7, as it appears in the final permit is shown below:

07.01.4 Signs

All hazardous waste management areas (i.e., E-501, M-136, S-633,
M-186, M-225, M-705S, M-47, M-603 and T29B) have warning signs placed at the access approaches. All signs are legible from a distance of at least 25 feet. All signs have a legend which
reads, “Danger - Unauthorized Personnel Keep Out.”

________________________________________________________________________

ATK Comment:

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.”

Response to Comment:

The Division agrees with ATK. The edited section of Attachment 9, as it appears in the final permit is shown below:

All solid reactive waste received from off-site and stored at M-136 will be stored in containers as described in Attachment 11.4. Storage of these containers is permitted in liquid
tight burn trays or on the ground at Burn Station 14 for intact rocket motors. All containers will be kept closed during storage.

________________________________________________________________________

ATK Comment:

Attachment 11
11.10.1. ATK recommends replacing the last paragraph in the Groundwater
Monitoring Plan section with, “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.”

Response to Comment:

Please see the Division’s response to the comment on Condition IV.K.4. above. The language in Section 11.10.1 of Attachment 11 will remain as it appears in the draft document.

________________________________________________________________________

Additional Changes to the Draft Permit Modification

In addition to the changes to the draft permit modification addressed above, the Division, upon further review of the draft document, has made a small number of changes to it. The Division
considers these changes, shown below, to be non-substantive. A second public comment period will not be held.

1. Condition II.R.2, shown below, was added to the Permit.

II.R.2. The Permittee shall demonstrate continuous compliance with the requirements of UAC R315-8-8 (40 CFR 264.147(b) incorporated by reference) to have and maintain liability coverage
for non-sudden accidental occurrences arising from operations of the two Hazardous Waste Management Units, designated as the M-136 and M-225 Thermal Treatment Areas.

Based on conversations with ATK, a few changes were made to the inspection schedules in Attachment 2. These changes were made to clarify when particular areas and equipment need to
be inspected. For all areas that require daily inspections – except for sumps and storage pads at M-186 and sumps, storage pads and portable secondary containment devices at M-705S
– the inspection schedules were clarified to read “Daily when in use (i.e. when loading or unloading operations occur at the facility).” For sumps and storage pads at M-186 and sumps,
storage pads and portable secondary containment devices at M-705S, the inspection schedules were revised to read “Daily except for weekends and holidays.”

3. Permit Condition II.G.3.b was changed slightly by adding “or other compounds as identified in accordance with Condition II.G.2” to account for the possibility of requiring ATK to
report estimated quantities of compounds other than, or in addition to, TCDD TEQs released annually (as determined by the findings of the risk assessment). The condition, as it appears
in the final permit modification, is shown below:

II.G.3.b. The estimated quantity of TCDD TEQs, or other compounds as identified in accordance with Condition II.G.2, released annually. The quantity shall be calculated based on emission
rates to be determined through approval of the air dispersion model as identified in Condition IV.M.1.

4. The language of Condition IV.M.3 was changed so that it is more consistent with the conditions referenced in Section II.G. of the Permit. The language “to add performance standards
in accordance with the approved human health risk” was replaced with “to establish annual risk thresholds that are based on the findings of the approved human health risk assessment.”
The condition, as it appears in the final permit modification, is shown below:

IV.M.3. Within 30 days of receiving approval of the Human Health Risk Assessment, the Permittee shall submit a request to modify Section II.G. of this Permit, in accordance with Condition
I.D., to establish annual risk thresholds that are based on the findings of the approved human health risk assessment for operation of both of the Promontory Thermal Treatment areas.

2
TN201000905

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
TN201000905 Printed on 100% recycled paper

State of Utah

GARY HERBERT
Governor

GREG BELL
Lieutenant Governor

Department of Environmental Quality

Amanda Smith
Executive Director

DIVISION OF SOLID AND HAZARDOUS WASTE
Scott T. Anderson
Director