DSHW-2010-056282 - 0901a06880274ad1 (9)

December 28, 2010

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

RE: ATK Responses to Division Comments
Waste Characterization and Air Dispersion Modeling Protocol
ATK Launch Systems - Promontory Facility
UTD009081357

Dear Mr. Gosen:

The Division of Solid and Hazardous Waste has completed its review of ATK’s responses to comments on the Waste Characterization and Air Dispersion Modeling Protocol documents. Most
of the comments have been adequately addressed. However, there are a few issues that require additional clarification or information from ATK. Additional comments are enclosed.

The Division requests that ATK submit its responses to these additional comments and revised protocol documents by February 7, 2011. If you have any questions, please contact Jeff Vandel
at [phone].

Sincerely,

ORIGINAL DOCUMENT SIGNED BY SCOTT T. ANDERSON ON 12/28/2010

Scott T. Anderson, Director
Division of Solid and Hazardous Waste

STA\JV\tjm

Enclosure

c: Paul Hancock, ATK Launch Systems
Blair Palmer, ATK Launch Systems
Cheryl Overstreet, Region 8, USEPA
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department

Review of ATK Responses to the Division’s Comments on the Waste Characterization and Air Dispersion Modeling Work Plan, July 27, 2010

Evaluation of the Response to General Comment 1: The ATK response partially addresses the original comment. While the information furnished in the facility response offers insights
into the procedures used to minimize impacts to soils surrounding the open burn units, the UDSHW General Comment 1 was not focused on this issue. Rather, General Comment 1 requested
information on the impact of the burn pan soil lining on the open burning process. Further, the comment requested that ATK provide the criteria used to determine if a burn pan should
have a soil lining. ATK’s response provided the criteria used to determine if a pan should be lined with soil. However, no information on the impact of the soil lining on the open
burn process (e.g., the potential for increased particulate emissions) was provided. ATK has indicated only one particle size distribution (PSD) will be used in the air modeling analysis
and the use of the single PSD will be addressed in the uncertainty discussion of the risk assessment. Because of the potential for increased particulate emissions and particulate emissions
with a unique PSD, the use of soil linings in some burn pans at M-136 should be specifically addressed in the planned uncertainty discussion. Please revise the Air Dispersion Model
Work Plan to discuss potential impacts of the soil lining in the burn trays on process emissions. Further, please indicate that the potential impacts from the soil lining will be addressed
in the uncertainty analysis of the risk assessment report.

Evaluation of the Response to Specific Comment 7: ATK has addressed the original comment by clarifying what model quantities, or daily quantity limits, will be used for modeling the
different sources. However, it still isn’t clear what emission factors will be used when the sources are modeled. For example, M-136 area Source 1 has a daily quantity limit of 106,500
pounds which may consist of all 1.1 pure propellant/contaminated material, all 1.3 pure propellant/contaminated material or a mixture of these waste categories that may contain up to
50,000 pounds of Category E waste materials. Does ATK plan to use three different sets of emission factors to represent the three different waste categories that may be included in
Source 1? This same issue exists for all four sources at M-136 and the two sources at M-225. Please revise the Air Dispersion Model Work Plan so that the specific emission factors
that will be used for these sources are identified.

Evaluation of the Response to Specific Comment 9: ATK replied to the original comment regarding the averaging of Class 1.3 Waste Material emission factors by proposing to use a “maximum
constituent emission factor measured over the three trial burns for each waste mix scenario.” These maximum constituent emission factors (for both the “conservative” and “corrected”
sets) are shown in Tables 3-5 and 3-6 of the revised work plan. However, the emission factors in the Tables don’t appear to match the maximum factors that are reported in Volume 1 of
the October, 2009 Sampling Results for Emission Characterization of Open Burning Waste Propellant Materials report. Please clarify ATK’s proposal for the Class 1.3 Waste Material emission
factors and explain how the factors presented in Tables 3-5 and 3-6 were calculated.

Evaluation of the Response to Specific Comment 10: ATK has provided additional information on the proposal to use the M816, 81-mm Infrared Illumination Cartridge as a surrogate for
the Category E wastes that are opened burned by ATK. Emission factors exist for this cartridge and are available from the EPA AP 42 Compilation of Air Pollutant Emission Factors website.
The ingredients of the cartridge are given on the MIDAS database. Due to the restrictions on reproducing the information in the MIDAS database, the Division acquired access to the
database and has communicated with ATK on the proposal to use the M816 cartridge emission factors to characterize the Category E wastes. There are a few issues with this proposal that
need clarification:

In the Ordnance Description section for the M816 Cartridge on the EPA 42 website (and in ATK’s response to our original comment) it is stated that the emission factors presented are
only associated with the detonation of the projectile. ATK has indicated that the Category E wastes are treated by open burning at the facility, not detonation and that the dispersion
of the emissions would be modeled as an open burn. What are the implications of using emission factors calculated from a detonation for modeling the dispersion of emissions from an
open burn? This issue should also be addressed in the uncertainty analysis section of the risk assessment report.
In the third paragraph of ATK’s response to the original comment10, it is stated that the M816 Cartridge presented the most conservative emission factors of the cartridges that were
reviewed from the MIDAS database. This statement is based on a comparison of the emission factors for the different cartridges that were reviewed. What were the compounds that were
given priority when the emission factors were compared (i.e. which compounds does ATK consider to be the likely “risk drivers” in the HHRA)?
The Category E wastes, as characterized by ATK, contain metals – most commonly magnesium, strontium, zirconium, boron, cesium and titanium. The M816 emission factors that ATK has proposed
to use as a surrogate for the Category E waste doesn’t contain any of these common metals. Is the absence of emission factors for these metals significant on the HHRA? This issue should
also be addressed in the uncertainty analysis section of the risk assessment report.

Evaluation of the Response to the Division’s Specific Comment 11: The ATK response partially addresses the original comment. ATK has proposed the following relationship for estimating
the gravitational settling of particulates in complex terrain:

Complex Terrain Dry Deposition (μg/m2·yr) = Annual Particulate dosage (μg·sec/m3) x Particulate Deposition Velocity (m/sec)

This relationship is similar in form to equation 2-49 from Section 2.5.2, Dry Deposition, of the Open Burn/Open Detonation Dispersion Model (OBODM) User’s Guide, Volume II, Technical
Description dated April 1998 (Volume II of the OBODM User’s Guide) which is recommended for estimating an upper bound on the dry deposition of gases and aerosols. However, Section 2.7,
Complex Terrain Screening Procedures, of Volume II of the OBODM User’s Guide states “When OBODM is applied in complex terrain, the receptor height…above ground level must be zero, and
the model cannot be used to calculate concentration, dosage, or deposition for particulates with appreciable settling velocities because the assumptions upon which [key equations] are
based are violated.” This statement raises concerns that the proposed relationship may not be appropriate as it is not clear from the response that OBODM is capable of modeling the
needed particulate dosage in complex terrain. Further, it appears the proposed value of particulate deposition velocity, 0.10 meters per second (m/sec), is “appreciable” though this
is not addressed in the ATK response.

The relationship proposed by ATK is also similar to equation 1-79, Section 1.3.1, General, of User’s Guide for the Industrial Source Complex (ISC3) Dispersion Models, Volume 2 – Description
of Model Algorithms, EPA-454/B-95-003b, dated September 1995 (Volume 2 of the ISC3 User’s Guide) for estimating total dry deposition flux. However, the proposed approach is based on
particulate dosage while equation 1-79 is based on particulate concentration. ATK has provided no details regarding the derivation of the proposed relationship or the associated deposition
velocity. Thus, the information furnished in the response does not demonstrate clearly that the relationship proposed by ATK can be applied successfully.

Please revise the Air Monitoring Work Plan to propose an approach for determining gravitation settling in complex terrain. Please ensure adequate detail is provided to demonstrate the
proposed approach will result in representative and conservative estimates of gravitation settling of particulates in complex terrain. Also, derivation of the proposed value of deposition
velocity should be detailed in the Air Modeling Work Plan. If an adequate demonstration can be provided, the proposed approach can be based on the currently proposed relationship.

Evaluation of the Response to the Division’s Specific Comment 13: The ATK response partially addresses the original comment. However, several aspects of the response require clarification:

The response indicates that the NASA-Lewis Thermochemical model was run for pure propellant, a mixture of 85% propellant and 15% decane to simulate PW85-15, and a mixture of 65% propellant
and 35% decane to represent PW65-35. Based on the information provided, the relationship between PW85-15 and PW65-35 as described in Section 3.2.1 and the propane/decane mixtures assumed
in the model runs is not clear. Please revise Section 4.4 to include a brief discussion to establish the relationship between PW85-15, PW65-35, and the propellant/decane mixtures assumed
in the NASA-Lewis Thermochemical model runs.
The Heats of Explosion listed in the table entitled Heat of Explosion for 1.3 Propellants, provided in both the ATK response and in Section 4.4 of the Air Modeling Work Plan, are referenced
to sample identification numbers J770812 and J956002. Please revise the Air Modeling Work Plan to identify the class 1.3 propellants (e.g., PW100, PW85:15, PW65:35) that comprised these
two samples.
The original comment requested that electronic copies of the input and output information for the model runs be provided to the Division. Please revise the Protocol to indicate if these
files will be submitted. If not, indicate why submission is not feasible.
Evaluation of the Response to the Division’s Specific Comment 19: The ATK response partially addresses the original comment. As requested in the original comment, the facility response
indicates the uncertainty associated with assuming the same PSD for open burning and open detonation will be addressed in the air modeling and risk assessment reports. However, given
that some open burning occurs in soil lined trays, the Division recommends that the planned uncertainty discussion be expanded to encompass the potential for a third, PSD unique to open
burning in soil lined trays.

Evaluation of the Response to the Division’s Specific Comment 25: The ATK response partially addresses the original comment. The response and information provided in the Air Modeling
Work Plan address concerns over the source of cloud cover and ceiling height information. However, the response does not address the confusion regarding the source of the surface temperature
observations. Based on the information furnished in Section 4.7, it was expected that surface temperature observations from the M-245 meteorological monitoring station would be used
to generate mixing heights. Please revise the Air Modeling Work Plan to indicate the source of the surface temperatures to be used. If surface temperature observations will not come
from the M-245 meteorological monitoring station, please explain why temperature data from Hill AFB must be used.

Evaluation of the Response to the Division’s Specific Comment 26: ATK has addressed the original comment regarding the delineation of background sources and OB/OD sources that contribute
to the emissions that will be compared to applicable standards and toxic screening levels. However, in ATK’s response, it is indicated that ATK will utilize historical air quality data
from Box Elder and Ogden as background concentrations for the comparative analysis. Due to the rural location of the ATK facility, and the urban nature of the Ogden area, it may not
be appropriate to use background data from the Ogden monitoring station in the comparative analysis. It is understood that a better option may not be available, although the appropriate
use of background data when comparing the calculated air concentrations to applicable standards and TSLs can be evaluated later as necessary (i.e. the appropriate use of background data
can be considered if the compound in question presents an unacceptable risk).

2
TN201001202

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
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Solid and Hazardous Waste Control Board
John D Newman, Chair
Michael D. Brehm, P.E., Vice-Chair
Scott Bruce
Carlton Christensen
Kory Coleman
Jeff Combs, MPH, LEHS
R. Ryan Dupont, Ph.D.
Larry A. Ellertson
Brad Mertz
Gary Mossor
Kevin Murray
Dennis Riding
Amanda Smith
Scott T. Anderson
Executive Secretary

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