DSHW-2011-003713 - 0901a0688020adb6

RECEIVED
28 February 2011 MAR 0 7 2011
8200-FY11-070 UTAH DIVISIUIM Uh
SOUD &HAZARDOUSWASTE
Mr. Scott T. Anderson, Executive Secretary jj^ 0Dhii7
State of Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 N. 1950 W.
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Attention: Jeff Vandel
Re: ATK Launch Systems Inc.-Promontory EPA ID number UTD009081357
Annual Report of the Promontory Thermal Treatment Areas Operation as required
by Hazardous Waste Storage Permit Module II.G.3
Dear Mr. Anderson:
This letter accompanies the annual report on the operation of the Promontory Thermal
Treatment Areas as required by ATK Launch Systems Inc.-Promontory EPA ID #
UTD009081357 Hazardous Waste Storage Permit Module II Condition G.3.
Please contact me if you have any questions conceming this report. My telephone
number is [phone] or you can contact Blair Palmer at [phone].
I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry
of the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fme and imprisonment for
knowing violations.
Sincerely
David P. Gosen, P.E., Director
Environmental Services
ATK Launch Systems Inc.-Promontory 2010 Annual Report of the Promontory
Thermal Treatment Areas Operation
Module II Condition G.3.a: requests an accounting of the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas.
Response: Table I and Table 2 shown below report the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas in 2010.
Table 1: 2010 M-136 Thermal Treatment Totals
Propellant Cla.ss Percent of Tptal-1 ,'Rcactivit> Group 1 la/ardou-s Waste
1.3 89.4% A .; . . 1043442
68
1777
G 6286
^^.^.j,,.,....... •V^^"7^2%;-" . >:;• •^79973
4915
(1.3) Flare -i-i*. .ii-.,i'3.4^ 39821
Table 2: 2010 M-225 Thermal Treatment Totals
-: 'ETpopeUaiatjIClasls-^ p*:e1•c^tlw^^t«^•ftoalvif•^
mi$m^7^:m77Mt7A
. H'azaFdoii»Me
1.3 34.5% 1019
B .•• • •0
•o-----
G 147
•-. '''' 1.1 ''' '* , .138- . ..
. . .. : 2042 .
r"7^(!.3)rFlare -g-^. E^- :
Module II Condition G.3.b: requests an estimated quantity of TCDD TEQs, or other
compounds as indentified 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.
Response: This condition cannot be completed since the air dispersion model protocol is
awaiting approval, and the emission rates from the dispersion model cannot be developed
until protocol approval.
Module II Condition G.3.c: requests an evaluation of the emission factors, identified in
Condition II.G.l .a, used in the human health risk assessment to determine whether these
factors are representative of the wastes treated and identified as directed by II.G.3.a, or if
the emission factors need to be updated.
Response: This condition cannot be completed since the human health risk assessment
protocol is awaiting approval, however; ATK considers the currently proposed emission
factors to be very representative of the wastes treated at the M-136 and M-225 Thermal
Treatment Areas.
Module II Condition G.S.d: requests a review of the human health risk assessment,
identified in Condition II.G.I.g., to evaluate whether the slope factors and reference dose
for carcinogenic and non-carcinogenic health effects related to chlorinated dioxin,
chlorinated fiiran and semi-volatile compounds have changed, and a review of the
potential human health risk scenarios that were evaluated in the risk assessment to assure
that these scenarios have not changed.
Response: This condition cannot be completed since the human health risk assessment
protocol is awaiting approval. Slope factors and reference dose for carcinogenic and non-
carcinogenic health effects related to chlorinated dioxin, chlorinated fiiran and semi-
volatile will be evaluated once the human health risk assessment protocol is approved and
the human health risk assessment is completed.