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Home My WebLink AboutDSHW-2011-008438 - 0901a06880274b44 (7)February 3, 2011 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 DSHW Comments on the Human Health Risk Assessment Protocol for OB/OD Operations ATK Launch Systems - Promontory Facility UTD009081357 Dear Mr. Gosen: The Division of Solid and Hazardous Waste has completed its review of ATK’s Response to Comments on the Human Health Risk Assessment (HHRA) Protocol. The requirement for conducting the HHRA for Open Burning/Open Detonation operations at the Promontory facility is outlined in Condition IV.M.2. of ATK’s Hazardous Waste Storage Permit. Most of the Division’s comments on the HHRA Protocol have been adequately addressed by ATK. However, there are a few issues that require additional clarification or information. These issues are discussed in the enclosed document. The Division requests that ATK submit its response to these additional comments and revised protocol documents by February 28, 2011. If you have any questions, please contact Jeff Vandel at (801) 536-0257. Sincerely, ORIGINAL DOCUMENT SIGNED BY SCOTT T. ANDERSON ON 2/3/2011 Scott T. Anderson, Director Utah Division of Solid and Hazardous Waste STA\JV\tjm Enclosure c: Paul Hancock, ATK Launch Systems Blair Palmer, ATK Launch Systems Lloyd Berentzen, Deputy Director, Bear River Health Department Cheryl Overstreet, Region 8, USEPA Review of ATK Responses to Division Comments on the Human Health Risk Assessment Protocol, August 10, 2010 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 OB/OD HHRA and that these receptor locations represent areas where most non-treatment related employees spend their time onsite. Please clarify the specific current and future receptors that will be evaluated at these two additional locations (i.e., the 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 exposure point concentrations from the maximum annual depositional area. Evaluation of the Response to Division 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 depositional locations 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 Refuge 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 and transport characteristics of the primary constituents: Describe how (and to what degree) game species may be exposed to site constituents. Do the primary constituents at issue have the capacity to bioaccumulate, bioconcentrate or biomagnify? Please evaluate the significance of these phenomena. Are any of these constituents preferentially sequestered in (edible) muscle tissue? What is the relative contribution (excess incremental lifetime cancer risk or hazard) of the 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 conservation areas should be included as discrete receptors to be 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 exposures pathways that are being evaluated at each receptor location, the response does not clarify if the two additional receptor locations noted in ATK’s response to Division Specific Comment 4 (i.e., the 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 (MEI). Future hypothetical adult and child residents/farmers should be evaluated at a location representative of the MEI. Please ensure that the OB/OD HHRA Protocol indicates that future hypothetical adult and child residents/farmers will be evaluated at a location representative of the MEI. 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 the values. This is acceptable; however, please ensure that Table 3 is updated to include parameter values from sources recommended by EPA’s 2005 Human Heath Risk Assessment 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. TN201100130 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4414 www.deq.utah.gov TN201100130 Printed on 100% recycled paper 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