DSHW-2012-001916 - 0901a068802b43ee

29 February 2012
8200-FYl 2-066
Mr. Scott T. Anderson, Executive Secretary
State ofUtah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 N. 1950 W.
P.O. Box 144880
Salt Lake City, Utah 84114-4880
RECEIVED
MAR 0 5 20t2
UTAH DIVISIUIM uh
SOLID & HAZARDOUS WASTf
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
ofthe 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
George E. Gooch, Acting Director
Environmental Services
cc: Jeff Vandel
ATK Launch Systems Inc.-Promontory 2011 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 1 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 2011. M-
136 donor and ignition material totaled 52,984 lb for 2011, M-225 donor and ignition
material totaled 2,617 lb for 2011. These totals are not included in Tables 1 and 2.
Table 1: 2011 M-136 Thermal Treatment Totals
Mrohfellant^la^^^^
1.3 55.2% :A . 400,491
B 1
F 656
G 2,523
;:i.T -,.r'3o;8%"-:': ; '^:v-c.'...:j • •222,348 '
D,..' ^: 3075 •
- ;-':;.(13)Flar;eL':,. .; .;: ri4'0%"^';?' ;. 102,134 : : i
Table 2: 2011 M-225 Thermal Treatment Totals
rf PinSpellantt^lass' ^^^'^'Pe^^^ HazarddusTWas'te t
, ^ 1 ;t 44?'--7 7, 'f-;r ^-?-f::^ ?T''#,i^^f t-'K^; .fV'T:*'*j; . 11-* vT > T i.Tr.eateaiCib,),-^],.
1.3 22.7% A 807
B Q
VF • 0
G 0
;74.6%.c:- --.. -c-' -1,677
•;•: >^".:\ V. :*U.3)i Flare*': ^-v: . i2.7yo-i--r cr: .i;.-.-E-. ••• ^
Module II Condition G.S.b: requests an estimated quantity of TCDD TEQs, or other
compounds as indentified in accordance with Condition ILG.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 modeling has not
been completed. The emission rates from the dispersion modeling are required to
complete this calculation.
Module II Condition G.3.c: requests an evaluation of the emission factors, identified in
Condition II.G.1.a, used in the human health risk assessment to determine whether these
factors are representative ofthe 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 air dispersion modeling must be
completed prior to the human health risk assessment evaluation, 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.3.d: requests a review of the human health risk assessment,
identified in Condition ILG.I.g., to evaluate whether the slope factors and reference dose
for carcinogenic and non-carcinogenic health effects related to chlorinated dioxin,
chlorinated furan 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
must be completed following the air dispersion modeling. Slope factors and reference
dose for carcinogenic and non-carcinogenic health effects related to chlorinated dioxin,
chlorinated furan and semi-volatile will be evaluated once the air dispersion modeling
and the human health risk assessment are completed.