DSHW-2011-003712 - 0901a0688020adb5

RtCElVED
8200!FYt7-07T MAR 0 7 Mil
UTAH Oiviisi^*'*
Mr. Scott T. Anderson, Executive Secretary SOLID & ^'^^^^P^Q'^
State of Utah Department of Environmental Quality 2-^^ ^ •
Division of Solid and Hazardous Waste
195 N. 1950 W.
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Attention: JeffVandel
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
ATK Response to Division Comments on the Human Health Risk Protocol for OB/OD
Operations
Dear Mr. Anderson:
This letter accompanies the response to comments from the Utah DEQ, Division of Solid
and Hazardous Waste, dated February 3, 2011. Also accompanying these documents are
newly created tables in response to comments number 3 and 8, and an update of Table 2.
Figure 1 has also been updated and is enclosed. This information is for use in the Subpart
X permitting of the open buming and open detonation operations at the ATK Launch
Systems Promontory Utah facility.
Please contact me if you have any questions conceming this report. My telephone
number is [phone] or you can contact Blair Palmer at [phone].
Sincerely
David P. Gosen, P.E., Director
Environmental Services
2/28/2011
RESPONSES TO DIVISION COMMENTS DATED FEBRUARY 3, 2011
ON THE ATK HUMAN HEALTH RISK ASSESSMENT PROTOCOL
Evaluation of the Response to Division Specific Comment 4: The response partially addresses the
original comment. The response indicates that additional onsite discrete receptors will be evaluated in
the OD/OD HHRR and that these receptor locations represent areas where most non-treatment related
employee spend their time onsite. Please clarify the specific current and future receptors that will be
evaluated at these two additional locations (i.e., North Plant Main Administration Building and Main
Manufacturing Area, and the South Plant Administration Building and Main Manufacturing Area).
Additionally, please clarify if these additional locations fall within the maximum annual depositional area,
and if not, indicate that (at a minimum) a future, hypothetical resident will be evaluated based on the
exposure point concentrations from the maximum annual deposition area.
ATK Response: The HHRA will address additional onsite discrete receptors to assess potential risk to
ATK workers that are not directly involved with the treatment activities at the M-136 and M-225 treatment
units. The additional 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.
These additional receptors are expected to not fall within the maximum annual depositional area
associated with either the M-136 or M-225 treatment units. As a result, a future, hypothetical resident and
farmer will be evaluated based on the exposure point concentrations calculated by OBODM from the
maximum annual deposition area.
Evaluation of the Response to Division Specific Comment 5: The Division accepts ATK's response
to this comment and, after further consideration, recognizes that a different approach to this issue is
warranted. The Division originally asked ATK to include the Salt Creek Waterfowl Management Area and
Bear River Migratory Bird Refuge as discrete receptors in the OB/OD HHRA in order to evaluate the
potential for hunters to be exposed to constituents of concern via ingestion of contaminated game birds.
This exposure pathway is not typically evaluated in HHRAs and standard default exposure assumptions
for this pathway do not exist. The Division expects the incremental risk associated with the ingestion of
game by hunters to be at least an order of magnitude less than other dietary exposure risk associated
with a resident farmer (adult and child) scenario modeled at the maximum deposition location for target
constituents. Instead of developing exposure assumptions for bird hunting for a quantitative assessment,
the Division prefers that ATK address this potential exposure pathway qualitatively within the uncertainty
analysis section of the risk assessment. In such a qualitative assessment, please address the following:
• The potential for the Salt Creek Waterfowl Management Area and Bear River Migratory Bird
Refugee to be impacted by open burning/open detonation operations at the two OB/OD sites at
the Promontory facility.
• Based on the nature and fate transport characteristics of the primary constituents:
o Describe how (and to what degree) game species may be exposed to site constituents,
o Do the primary constituents at issue have the capacity to bioaccumulate, bioconcentrate,
or biomagnify? Please evaluate the significance of these phenomena,
o Are any of these constituents preferentially sequestered in (edible) muscle tissue?
• What is the relative contribution (excess incremental lifetime cancer risk or hazard) of risk
associated with game species consumption by recreational hunters to the total residential human
health risk (e.g., potential for order-of-magnitude change)?
Please revise Section 3 of the HHRA Protocol as appropriate so that the qualitative assessment of this
potential exposure pathway is addressed. As stated in ATK's original response to this comment, these
2/28/2011
conservative areas should be included as discrete receptors to be evaluated in the ecological risk
assessment.
ATK Response: Agreed. The Salt Creek Waterfowl Management Area and Bear River Migratory Bird
Refugee will be listed as discrete receptors in Section 3.1 and included on the table being added as
requested in the original Specific Comment 4 which will list the receptors being evaluated at the individual
receptor locations. In addition, the text will be revised to discuss that a qualitative evaluation of risks will
be presented in the uncertainty analysis section as requested above. Also, these receptors will be
quantitatively evaluated in the ecological risk assessment.
Evaluation of the Response to Division Specific Comment 8: The response partially addresses the
original comment. While the response indicates that a table will be added that lists the receptors and
exposure pathways that are being evaluated at each receptor location, the response does not clarify if the
two additional receptors noted in ATK's response to Division Specific Comment 4 (i.e.. North Plant Main
Administration Building and Main Manufacturing Area, and the South Plant Administration Building and
Main Manufacturing Area) are representative of the maximally exposed individual (MEl). Future
hypothetical adult and child residents/farmers should be evaluated at a location representative ofthe MEl.
Please ensure that the OB/OD HHRA Protocol indicates that future hypothetical adult and child resident
farmers will be evaluated at a location representative ofthe MEl.
ATK Response: The two additional receptors (i.e.. North Plant Main Administration Building and Main
Manufacturing Area, and the South Plant Administration Building and Main Manufacturing Area) are not
expected to be representative of the maximally exposed individual (MEl). A general receptor network will
extend out to 10 km from each treatment units and identify the location of the MEl for short term and long-
term (annual) averaging periods. As a result, the future hypothetical adult and child residents/farmers will
be evaluated at the location of the maximum concentration receptor location determined by OBODM.
Evaluation of the Response to Division Specific Comment 15: The response addresses the original
comment. The response indicates that the values in Table 3 will be checked and adequate justification
will be provided for all values. This is acceptable; however, please ensure that Table 3 is updated to
include parameter values from sources recommended by EPA's 2005 Human Health Risk Protocol for
Hazardous Waste Combustion Facilities (HHRAP) (e.g., Baes et al. 1984), or from reliable site-specific
sources. At a minimum, it appears that the average annual irrigation parameter should be increased from
30.54 centimeters per year (cm/yr) to within the range of 55 to 70 cm/yr as recorded by Baes et al. (1984)
unless defensible site-specific data are available.
ATK Response: Agreed. Defensible justification will be provided for any site-specific value and all site-
specific values will be checked to ensure they fall within the range of default values recommended in the
HHRAP guidance.
TABLE 2
SUMMARY OF RECEPTORS AND EXPOSURE PATHWAYS
ATK PROMONTORY, UTAH
Exposure Pathway Ch
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Inhalation of Vapors and Particulates x<^' X(2) X(3) X
Incidental Ingestion of Soil x X x X X X
Ingestion of Drinking Water from Surface Water Sources (4) (4) (4) (4)
Ingestion of Homegrown Produce X X X X
Ingestion of Homegrown Beef X X
ingestion of Milk from Homegrown Cows X X
Ingestion of Homegrown Chickens X X
Ingestion of Eggs from Homegrown Chickens X X
Ingestion of Homegrown Pork X X
Ingestion of Fish (5) (5) (5) (5)
Ingestion of Breast Milk X(6) x'^> ^(6) ^(6)
Notes:
1 - Inhalation exposures will only be evaluated at off-site receptor locations.
2 - Evaluated for a worker at the AutoLiv facility, North Plant Main Administration Building and South Plant Main Administration Building.
3 - Evaluated for a worker at the location of the maximum on-site impact.
4 - Surface water in the area is not suitable for use as a drinking water source.
5 - Fishing does not occur in the area due to general poor surface water quality, intermittent surface water flow in the
vicinity of the treatment units, and lack of game fish in local water bodies.
6 - Ingestion of breast milk is evaluated only for dioxins/furans.
TABLE BEING ADDED IN RESPONSE TO COMMENT 3
TABLE X
EXPOSURE ASSUMPTIONS
ATK PROMONTORY, UTAH
RECEPTOR Resident
Adult
Resident
Child
Farmer
Adult
Farmer
Child
Industrial
Worker ~ Units
All Exposures
Averaging time for carcinogens 70 70 70 70 70 yr
Averaging time for noncarcincgens 30 6 30 6 25 yr
Exposure duration 30 6 30 6 25 yr
Exposure freguency 350 350 350 350 250 day/yr
Body weight 70 15 70 15 70 kg
Time period at the beginning of combustion 0 0 0 0 0 yr
Length of exposure duration 30 6 40 6 25 yr
Inhalation
Inhalation exposure duration 30 6 40 6 25 yr
Inhalation exposure freguency 350 350 350 350 250 day/yr
Inhalation exposure time 24 24 24 24 8 hr/day
Drinking Water
Fraction of contaminated drinking water 1 1 1 1 0 ~
Consumption rate of drinking water 1.4 0.67 1.4 0.67 0 Uday
Incidental Ingestion of Soil
Fraction of contaminated soil 1 1 1 1 0 —
Consumption rate of soil 0.0001 0.0002 0.0001 0.0002 0 kg/d
Ingestion of Poultry
Fraction of contaminated poultry 1 1 1 1 0 —
Consumption rate of poultry 0 0 0.00066 0.00045 0 kg/kg-day FW
Ingestion of Produce
Fraction of contaminated produce 1 1 1 1 0 —
Consumption rate of aboveground produce 0.00032 0.00077 0.00047 0.00113 0 kg/kg-day DW
Consumption rate of protected aboveground produce 0.00061 0.0015 0.00064 0.00157 0 kg/kg-day DW
Consumption rate of belowground produce 0.00014 0.00023 0.00017 0.00028 0 kg/kg-day DW
Ingestion of Beef
Fraction of contaminated beef 1 1 1 1 0 —
Consumption rate of beef 0 0 0.00122 0.00075 0 kg/kg-day FW
Ingestion of Eggs
Fraction of contaminated eggs 1 1 1 1 0 ~
Consumption rate of eggs 0 0 0.00075 0.00054 0 kg/kg-day FW
Ingestion of Milk
Fraction of contaminated milk 1 1 1 1 0 —
Consumption rate of milk 0 0 0.01367 0.02268 0 kg/kg-day FW
Ingestion of Pork
Fraction of contaminated pork 1 1 1 1 0 ~
Consumption rate of pork 0 0 0.00055 0.00042 0 kg/kg-day FW
DW - Dry weight of soil or plant/animal tissue.
FW - Fresh weight (or whole/wet weight) of plant or animal tissue.
TABLE BEING ADDED IN RESPONSE TO COMMENT 8
TABLE X
SUMMARY OF ON-SITE RECEPTORS
ATK PROMONTORY, UTAH
Receptor Boundary #1 Boundary #2 Boundary #3 Boundary #4
M-136
Maximum
On-site
M-136
Maximum
Off-site
M-225
Maximum
On-site
M-225
Maximum
Off-site
AutoLlv
Facility
North Plant Main
Administration
Building and Main
Manufacturing
Area
South Plant Main
Administration
Building and Main
Manufacturing
Area
On-Site Worker X X X X X
Child Resident X X X X X X X X X X X
Adult Resident X X X X X X X X X X X
Child Farmer X X X X X X X X X X X
Adult Farmer X X X X X X X X X X X
X - Indicates that the receptor will be quantitatively evaluated at this location.
Exposure pathways being evaluated for each receptor are listed on Table 2.
PCH P.dSirHlOKOLWXDVTReATWENT_UHIT3_BMXD Q2f20/U JEE
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Treatment Unit
O Discrate Receptoi
I I 10 km Radius
Q ^ Q Facility Boundary
DRAVm BY
J. ENGLISH
DATE
02^/11 TETRATECH CONTRACT NUMBER
01369
CTO NUMBER
CHECKED BY
J. ENGLISH
CMTE
02/28/11
APPROVED sr
SCALE
AS NOTED
LOCATION OF ATK PROMONTORY M-136 AND M-225 TREATMENT PLANTS
AND DISCRETE MODELING RECEPTORS
PROMONTORY. UTAH
APPROVED BY