DSHW-2012-001281 - 0901a068802a7d92

1 February 2012
8200-FY12-053
Mr. Scott T. Anderson, Executive Secretary
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
HAND DELIVERED
FEB 0 2 2012
UTAH DIVISION OF
SOLID & HAZARDOUS WASTE
Attention: JeffVandel
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
Response to Comments on ATK Preliminary Air Dispersion Modeling Report,
and Addendum to Waste Characterization and Air Dispersion Modeling Protocol
For Use in the Human Health and Ecological Risk Assessments
Dear Mr. Anderson:
ATK has completed a response to the comments provided by the Utah Division of Solid
and Hazardous Waste (UDSHW) regarding the Preliminary Air Dispersion Modeling
Report. Also included is an Addendum to the Waste Characterization and Air Dispersion
Modeling Protocol. This information is necessary to conduct the Human Health and
Ecological Risk Assessments for our OB/OD operations.
Please contact me if you have any questions concerning this report. My telephone
number is [phone] or you can contact Blair Palmer at [phone].
Sincerely
David P. Gosen, P.E., Director
Environmental Services
ATK ALLIANT TECH FINAL RESPONSES TO TECH LAW REVIEW
COMMENTS ON ATK PRELIMINARY AIR DISPERSION MODELING REPORT
Tech Law review comments are shown in regular font. ATK responses to Tech Law Comments
are shown in italic font. The proposed modeling protocol changes discussed in the ATK
responses have been incorporated into an Addendum to the "ATK Launch Systems Waste
Characterization and Air Dispersion Modeling Protocol for Use in Human Health and Ecological
Risk Assessments" document, which was approved by UDSHW in June 2011. The Addendum is
being issued separately from these responses.
Technical Review Comment 1: Section 2.0, Air Dispersion Modeling Protocol, indicates that
complex and flat terrain modeling was performed as part of the air modeling analysis. This
approach was not proposed in ATK's air modeling protocol. Further, the need to perform both flat
and complex terrain modeling was not established in the Draft Modeling Report. Revise the Draft
Modeling Report to provide additional details on flat terrain modeling. The additional information
should establish the need for performing both flat terrain and complex terrain modeling. When
modeling results are discussed, ensure the text indicates whether the results were obtained
under the flat terrain or complex terrain assumption (this is done in Section 3.2.1.2, M-225
Treatment Unit). In addition, the sensitivity of Gaussian air dispersion models to elevation heights
and the impact of the flat terrain assumption on air modeling results should be addressed in
Section 3.6, Uncertainty Analysis.
ATK Response: It is agreed that the modeling protocol discussion in Section 2.0 did not contain
sufficient information to establish the need for flat and complex terrain modeling. A new section
will be added to the modeling protocol document in Section 4.0 entitled "4.5.4 Flat and Complex
Terrain Modeling" that will discuss the need to perform flat and complex terrain modeling.
The presentation of modeling results in Section 3 of the new modeling assessment will include
distinctions between flat and complex terrain modeling results. In addition, the sensitivity of
Gaussian model and flat terrain assumptions will be addressed in Section 3.6, Uncertainty
Analysis.
Technical Review Comment 2: To promote clarity and transparency in the air modeling report,
the column entitled Model Quantity in Tables 2-1 and 2-1 should re-titled Modeled Quantity per
Event.
ATK Response: The column entitled "Model Quantity" in Tables 2-1 and 2-2 will be re-titled to
read "Modeled Quantity per Event". In addition. Modeled Quantity per Event for each source in
Tables 2-1 and 2-2 will be revised to address Tech Law's recommendation to "reduce the amount
of waste treated per event". Also, a new section has been added to Section 4.4 entitled "Modeling
Analysis Objective and Methodology" which explains a revised protocol for assessing the worst
case impact from both treatment units using a "screening" procedure in order to provide ATK with
the flexibility needed to conduct treatment operations.
Technical Review Comment 3: Figure 2-6 depicts the discrete receptors of interest and labels
them with a descriptor but does not specify their UTM coordinates. Thus, the figure illustrates the
spatial relationship among the discrete receptors, sources, and other points of interest but does
not establish their exact location by specifying their UTM coordinates. It appears the Draft
Modeling Report does not include a description of the discrete receptors of interest that matches
their location with their name. Please label each discrete receptor of interest with its UTM
coordinates.
ATK Response: A description of discrete receptors was provided in Section 2.12.2 of the draft
report. This discussion will be Section 2.12.1 of the new modeling report will be revised so that
discrete receptors are properly matched by location and name. Also, the labels for all discrete
receptors identified in Figure 2-6 will also include UTM coordinates. In addition, a table will be
included in Section 2 of the modeling report providing the receptor name, elevation, and UTM
coordinates.
1/19/2012 Page 1
ATK ALLIANT TECH FINAL RESPONSES TO TECH LAW REVIEW
COMMENTS ON ATK PRELIMINARY AIR DISPERSION MODELING REPORT
Technical Review Comment 4: The majority of the tables in Section 3.0 list the Universal
Transverse Mercator (UTM) coordinates for the modeled receptor locations but do not list a
descriptor for the on-site and off-site discrete receptors of interest. Thus, it appears the report
does not include a description of the discrete receptors of interest that matches their location with
their name. It is recommended that a comments column be added to these tables so that a
descriptor could be provided for discrete receptors of interest.
ATK Response: The tables in Section 3.0 of the new modeling report will be revised to include a
new column labels "Comments" that will contain a descriptor for the receptor location, including if
it is located in flat or complex terrain. In addition, the Figures 3-1 to 3-7 will be revised to include
new labels that will match the descriptor given in the Section 3 tables for easy identification.
Technical Review Comment 5: Table 3-5 identifies the discrete receptors of interest by their
name but does not list their location in UTM coordinates. Thus, it appears the Draft Modeling
Report does not include a description of the discrete receptors of interest that matches their UTM
coordinates (location) with their description (name). It is recommended that columns be added to
Table 3-5 so the UTM coordinates of the discrete receptors of interest can listed.
ATK Response: Tables 3-5 and 3-6 will be revised to include a new column which will identify
the UTM coordinates of each discrete receptor
Technical Review Comment 6: Section 3.5.1 raises concerns regarding the inclusion of non-
detected constituents in the suite of constituents addressed in the risk assessment. In
conjunction with this concern. Tables 2-5 and 2-6 should be modified to identify those
constituents that were not detected during testing. Consideration should also be given to
identifying non-detected constituents in the results tables presented in Section 3.0.
ATK Response: Tables 2-5 and 2-6 (Corrected and Conservative Emission Factors) will be
revised to identify that analytes that were not detected during the ODOBi testing program. The
results tables in Section 3.0 will also identify the target analytes that were not detected during the
ODOBi testing program.
Technical Review Comment 7: No plots of the air modeling results were found in the report.
Important air modeling results should be presented graphically as contour lines overlaying a
figure that illustrates the source locations, facility boundaries, and both on-site and off-site
discrete receptors of interest.
ATK Response: ATK is proposing to present new figures showing iso-contour plots of air
dispersion factors (ADFs) associated with gas modeling (pg/m ^-Ib/hr), particulate modeling (pg/m
^-Ib/hr), and deposition modeling (pg/m^-lb/hr) in flat and complex terrain for the general receptor
grid. Separate figures will be presented for 1-hour and annual ADFs. The new figures showing
the contour plots with include source locations, facility boundaries, and both on-site and off-site
discrete receptors. If possible, the results for both flat and complex terrain will be placed on the
same figure. The new figures will be placed in Section 3 and will be discussed in a new section.
ADF contour plots will be presented for the following modeling scenarios and averaging periods:
Model Scenario Flat Terrain Complex Terrain
Gases 1-hour and annual 1-hour and annual
Particulate 1-hour and annual NA
Deposition Annual NA
NA - Not available with OBODM
1/19/2012 Page 2
ATK ALLIANT TECH FINAL RESPONSES TO TECH LAW REVIEW
COMMENTS ON ATK PRELIMINARY AIR DISPERSION MODELING REPORT
Technical Review Comment 8: The graphical depictions of air modeling results should
differentiate between results obtained under the complex terrain assumption and those obtained
assuming flat terrain. Present the results on the same figure if possible. If not, provide separate
figures.
ATK Response: ATK is proposing to present new figures showing iso-contour plots of air
dispersion factors (ADFs) associated with gas modeling (pg/m ^-Ib/hr), particulate modeling
(pg/m^-lb/hr), and deposition modeling (pg/m -Ib/hr) in flat and complex terrain. Separate figures
will be presented for 1-hour and annual ADFs. The new figures showing the contour plots with
include source locations, facility boundaries, and both on-site and off-site discrete receptors. If
possible, the results for both flat and complex terrain will be placed on the same figure.
Technical Review Comment 9: A spot check of the OBODM output files in Appendix D, Gas
Modeling Results, indicates that elevations were specified for the modeled receptor locations in
both the complex and flat terrain modeling runs. In flat terrain modeling runs, OBODM treats
elevations as flagpole receptor heights (i.e., heights above the ground surface). Further, the flat
terrain runs specify a source elevation of 0 meters while the complex terrain runs for M225
specify a source elevation of 1401 meters. In addition, all flat terrain runs examined in the spot
check specified flag pole receptor heights well in excess of the elevation of the sources. It is not
clear why this is done as Section 2.1, Air Dispersion Modeling Protocol, indicates that receptor
locations at or below the elevation of the treatment unit are considered as flat terrain receptors.
Review all flat terrain air modeling files and ensure the flat terrain modeling was performed
correctly. Further, ensure the flat terrain assumption was applied to modeled receptor locations
that do not vary significantly in height with the modeled sources. In addition, justify the use of
flagpole receptor heights in the flat terrain modeling and discuss the impact of using flagpole
heights on the air modeling results.
ATK Response: The modeling analysis was not intended to include flag pole receptors for flat
terrain modeling. The receptors identified as being in flat terrain do not vary greatly in elevation
from the source location. This will be re-valuated in the next modeling analysis to verify this
assumption. All source locations and flat terrain receptors will be assigned a value of zero
elevation in the flat terrain model runs. Complex terrain modeling runs will continue to include the
source elevation and the receptor elevation.
Technical Review Comment 10: It appears that the OBODM output files (Appendices D
through F) and the model-ready meteorological data files (Appendix B) have been submitted.
However, the OBODM input files were not found. Please ensure the OBODM input files
corresponding to the submitted output files are also submitted to UDEQ HWB.
ATK Response: A new appendix will be included in the modeling report that will include all
OBODM input files.
Technical Review Comment 11: A review of the OBODM output files indicates that the number
of hours addressed in the evaluation of the annual average air quality impacts (concentration and
deposition factors) have been limited to hours in which treatment occurred. Thus, the resulting
annual averages represent the annual average of the number of hours OB and OD operations
were performed rather than the total number of hours in a year. This approach results in higher
annual average impacts than would be realized if all hours in which emissions were zero were
included in the calculation of the annual average.
ATK Response: ATK intends to follow the recommendation made by Tech Law to use "Hourly
Source Strength" files for all sources associated with M-136 and M-225, which will correspond
with the new ATK treatment schedule. The current model assumption limiting treatment events to
the hours between 1000 and 1800 will now be assumed to include the hours between 0600 and
1800, as recently approved by UDSHW.
1/19/2012 Page 3
ATK ALLIANT TECH FINAL RESPONSES TO TECH LAW REVIEW
COMMENTS ON ATK PRELIMINARY AIR DISPERSION MODELING REPORT
Due to the change in the proposed ATK treatment quantities and treatment schedule, the new
modeling assessment will utilized worst case meteorological events to estimate the maximum
impact from all sources based on the proposed number of ATK treatment events per year The
current protocol assumption limiting treatment events to the hours between 1000 and 1800 will
now be assumed to include the hours between 0600 and 1800, as recently approved by UDSHW.
The annual average concentrations at all receptors will be based on the amount of waste treated
at each source over each hour in the worst case event meteorological data file Thus, hourly
source strength files and worst case meteorological input files will be developed for each
treatment unit and model type (gas, particulate, deposition).
A new section has been added to Section 4.4 entitled "Modeling Analysis Objective and
Methodology" which explains a revised protocol for assessing the worst case impact from both
treatment units using a "screening" procedure in order to provide ATK with the flexibility needed
to conduct treatment operations.
1/19/2012 Page 4
Revision 1
ADDENDUIVI
ATK LAUNCH SYSTEMS
WASTE CHARACTERIZATION AND
AIR DISPERSION MODELING PROTOCOL
FOR USE IN THE HUMAN HEALTH
AND ECOLOGICAL RISK ASSESSMENTS
ATK LAUNCH SYSTEMS
PROMONTORY, UTAH
JANUARY 2012
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 1.0
JANUARY 2012
1.0 INTRODUCTION
In April, 2011 (Tetra Tech, 2011a), ATK Launch Systems (ATK) submitted an air dispersion modeling
protocol to the Utah Department of Environmental Quality Division of Solid and Hazardous Waste
(UDSHW). The protocol was prepared to evaluate the air quality impact of treatment operations that are
conducted at ATK's M-136 and M-225 treatment units in support of 40 CFR 264 Subpart X permitting.
The protocol was approved by UDSHW and the air dispersion modeling assessment was completed in
October 2011 (Tetra Tech, 2011 b).
The USDHW asked Tech Law to conduct a technical review of the October 2011 air dispersion modeling
assessment report and to prepare comments regarding any deficiencies in the report or modeling
assessment. Tech Law provided comments on November 22, 2011 that addressed recommendations for
changes to the next modeling assessment report. Based on the Tech Law recommendations, a protocol
addendum has been prepared for conducting a revised modeling assessment for treatment units M-136
and M-225. The Tech Law recommended changes to the ATK modeling protocol include the following:
• Revise the protocol treatment quantity Tables 2-1 and 2-2 in Section 2 (Thiokol Propulsion Facility
Descnption) such that the column entitled "Model Quantity" is re-titled to read "Modeled Quantity per
Event". In addition, ATK will "reduce the amount of waste treated per event" at each source listed in
Tables 2-1 and 2-2 and revised Sections 2.3.1 and 2.3.2 as needed.
• Revise Section 3.2.1 and Tables 3-5 and 3-6 (Corrected and Conservative Emission Factors) of the
protocol to identify that analytes that were not detected during the Bang Box testing program.
• Revise protocol Section 4.4 (OB/OD Treatment Scenarios) to follow the recommendation made by
Tech Law to use Hourly Source Strength files for all sources associated with M-136 and M-225
treatment operations. The hourly source strength assumptions will be presented in revised versions
of Sections 4.4.1 (M-136 Treatment Unit) and 4.4.2 (M-225 Treatment Unit). A new section has been
added to Section 4.4 entitled "Modeling Analysis Objective and Methodology" which explains a
revised protocol for assessing the worst case impact from both treatment units using a "screening"
procedure in order to provide ATK with the flexibility needed to conduct treatment operations. The
screening procedure is a highly conservative technique that is designed to calculate the maximum,
worst case air concentrations at a receptor location.
• A new section (4.5.4 Flat and Complex Terrain Modeling) will be added to Section 4.5 to include
sufficient information establishing the need for flat and complex terrain modeling.
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ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 1.0
JANUARY 2012
• Revise Section 4.9 (Post-Processing Activities) of the protocol to Indicate that the modeling report will
include figures showing iso-contour plots of air dispersion factors (ADFs) associated with gas
modeling (|jg/m ^-Ib/hr), particulate modeling (|jg/m ^-Ib/hr), and deposition modeling (|jg/m^-lb/hr) in
flat and complex terrain for the general network receptor grid.
This Addendum presents only the revised sections of the document ATK Launch Systems Waste
Characterization and Air Dispersion Modeling Protocol for Use in the Human Health and Ecological Risk
Assessments (Tetra Tech, 2011).
041108/P 1-2
I
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.1
JANUARY 2012
2.3.1 M-136 Treatment Activities
M-136 is the primary treatment unit for conducting open burning at the Promontory facility. Open
detonation is also conducted at M-136 which is a secured fenced facility within the main facility fence.
The layout of the M-136 treatment unit (showing all burn stations) is provided in Figures 2-2 through 2-4
of this protocol.
Typical reactive waste treatment at M-136 includes but is not limited to 1.1 propellant, 1.3 propellant,
propellant contaminated waste, reactive laboratory waste, waste solid rocket motors, propellant
ingredients such as nitroglycerin, ammonium perchlorate, aluminum, cyclotetraethylenetetranitramine
(HMX), and similar propellant, explosive and pyrotechnic ingredients. Similar wastes are also received
from Autoliv, other ATK locations, and on rare occasion from other Department of Defense/government
facilities. All wastes received from off-site sources such as Autoliv and other ATK sites are burned within
14 days. Except for EPA waste numbers exempted by rule, reactive wastes with listed EPA waste
numbers are identified, and isolated from other material enabling the ash to be collected and shipped
offsite for disposal.
The M-136 Burn Grounds is comprised of 14 burn stations. Open burn treatment is conducted at all burn
stations. However, open detonation treatment is only conducted at Stations 13 and 14. The burn stations
are located in three general areas and are aligned in an east-west direction across the treatment unit.
The change in elevation between the three general areas is relatively minor (less than 20 feet per area).
Burn Stations 1 through 12 are located in one treatment area that measures approximately 820 feet x
574 feet. All Burn Stations are located within a 394-foot radius of the center of the area represented by
the active burn stations. Burn Station 13 is located approximately 820 feet due east of Burn Stations 1
through 12. Burn Station 14 is located approximately 820 feet due east of Burn Station 13.
Open burning is conducted at ground level in burn trays. Burning trays are constructed in several different
sizes including, 4'X10', 5'X16', 8'X8', and 8'X20'. These trays are constructed to contain the propellant
and withstand the intense heat from the open burning process. They are made from steel plate A36 grade
steel ranging thicknesses of 3/8", Vi\ YA", and 1 inch.
Lids for the burn trays may be used during the wet weather months to keep moisture out of the trays. If
the trays are empty, they may also be turned upside down to avoid the collection of moisture in the empty
trays. If excess water exists in the burn trays, a sump truck is used to remove the water and it is taken to
the M-705 wastewater treatment facility. The trays may be lined with soil to facilitate burning operations;
however, most trays do not contain soil. The number of trays at each burn station varies. Burn stations 1
through 12 typically have 15 burn trays. Burn Station 13 typically has six trays. Burn station 14 is used to
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ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.1
JANUARY 2012
open burn motors. Operation of station 14 is described below. Trays may be moved between stations as
needed.
Open detonation is conducted at either Burn Station 13 or 14. Based on Quantity Distance (QD)
limitations, open detonation may be performed aboveground or underground in a hole or pit, depending
on the item to be detonated.
The M-136 Burn Grounds also has three specially designed disposal units that are used to handle the
disposal of rocket motor igniters, small rocket motors, and other items that have the potential to become
propulsive. These disposal units are the Clamshell Disposal tray, Sandbox Disposal tray, and Small Motor
Disposal vaults, which are used to contain the propulsive force of the igniters and small rocket motors, but
allow for safe disposal.
The Clamshell Disposal tray is used for the disposal of closed end rocket motor igniters, and other items
that have the potential to be propulsive. The Clamshell Disposal tray is a square welded box 1-inch thick,
A36 steel plate with a vented lid that enables the potentially propulsive items to be burned, while safely
containing the propulsive energy. The Clamshell Disposal tray is portable and can be used at several
burn stations ranging from 1 through 13.
The Sandbox Disposal tray is used for the disposal of open-end rocket motor igniters, and other items
that have the potential to be propulsive. It is constructed of 1-inch thick A36 steel plate welded into a
square box that is filled with sand, and has four 1-inch thick steel tubes sitting on end in the sand. The
potentially propulsive items are placed in the tubes allowing the exhaust to vent out of the open end of the
steel tubes. Steel bars are then slid into the end of the exposed tubes to contain the igniters. The
Sandbox Disposal tray is portable and can be used at several burn stations ranging from 1 through 13.
The two Small Motor Disposal vaults are constructed from a concrete 10x10 foot sump filled with sand.
The small rocket motors such as the STAR motor are placed into the sand with the aft end exposed
perpendicular to the ground. The motors are then burned with the propulsive force directed into the
concrete sump and the sand. These small motor disposal vaults are located at Burn Station 9.
Large-scale obsolete rocket motors are open burned at Burn Station 14. The rocket motor is positioned
near Station 14 and is offloaded by a mobile crane. The obsolete motor is placed on sand or wooden
blocks in Station 14. Systems of Linear Shaped Charges (LSC) are then placed on the rocket motor to
split the rocket motor case, rendering it non-propulsive allowing Jthe open burning of the rocket motor
while it is still being burned within the existing rocket motor case. This also allows the rocket motor case
to act as the "burn tray" for the burning propellant.
041108/P 2.3.1-2
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.1
JANUARY 2012
The firing stanchions electrical circuits for each burn station are buried underground throughout the
Burning Grounds. Burn Stations 1 through 12 contain a multiple firing stanchions (firing posts) for each
burn station. Burn Stations 13 and 14 have a single firing stanchion for each burn station. The electrical
components for the relays, power supply, etc. are located in Bunker M-136. A heavy steel pylon is
located in each firing stanchion containing the ignition wire. This steel pylon is to protect the electrical
equipment from the intense heat generated during the open burning event. An electrical igniter is placed
in a minimum of one tray for each firing stanchion for the burn event.
Several safety interlocks are in place at M-136 to prevent inadvertent ignition of the system while
operators are in the Burning Grounds. Ignition of all the burning pans is completely remote and controlled
by a system of switches in the M-136 control bunker. Before initiating a burn, the resistance of each
circuit is tested to ensure all of the connections have been made properly. Pressing the system activation
button initiates a warning siren. A siren will sound for approximately 40 seconds and the ignition system is
then armed and ready to fire. The ignition switches located in the control bunker can then ignite the rows
and stanchions that are selected. Generally, all firing stanchions that contain waste to be burned are
ignited consecutively with a delay between ignitions of firing stanchions. The burn is observed and
recorded in the control bunker via a closed circuit television system.
No entrance is allowed into the M-136 Burn Grounds during the burning process. After a burn, a 16-hour
waiting period is normally required prior to entering the area in the Burnings Grounds where the burn was
conducted. Entrance is then permitted and a thorough check for abnormalities that may have occurred
during the burn is done. This check involves looking for reactive material that was not completely treated
and may have left the burn trays during the burn event, or resulted from an unplanned detonation. Any
unburned reactive material is collected and placed in the nearest tray to be re-burned. A forklift is then
used to carry and dump the trays containing the burn ash to the Industrial Waste Trench (IWT) located in
the far eastern end of the M-136 Burn Grounds. If a burn event occurs at the end of the working week
such as Thursday, the ash generally is not transported to the IWT until the beginning of the next
workweek. A forklift or a backhoe is used to carry the large-scale obsolete rocket motor cases for
disposal in the IWT.
2.3.1.1 M-136 Treatment Quantities
Table 2-1 presents a list of the M-136 treatment sources to be included in the dispersion modeling, the
burn stations associated with each M-136 source, the reactive wastes treated by the each M-136 source,
the modeled quantity per treatment event in pounds (lbs.) to be used for each M-136 source in the
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ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.1
JANUARY 2012
dispersion modeling, the annual treatment quantity for each source, and the emission factors to be used
for each M-136 source.
The modeled quantity per treatment event at M-136 Burn Stations 1 through 12 (Source 1) is 12,000 lbs.
Treatment at M-136 Source 1 will be conducted twice daily, three times per week, for a total annual
treatment quantity of 3,744,000 lbs. The modeled quantity per treatment event at M-136 Burn Station 13
(Source 2) is 10,000 lbs. Treatment at Source 2 will be conducted 52 times per year for a total annual
treatment quantity of 520,000 lbs. The modeled quantity per treatment event at M-136 Burn Station 14
(Source 3) is 10,000 lbs. Treatment at Source 3 will be conducted 52 times a year for a total annual
treatment quantity of 520,000 lbs. In addition, ATK will conduct treatment of small and large rocket
motors at Station 14 (Source 3). The modeled quantity per treatment event for these events will be
26,000 lbs, which is the assumed quantity for large rocket motors. The treatment of large rocket motors at
Station 14 will be conducted only 3 times per year and result [n a total annual treatment quantity of 78,000
lbs. Open detonation treatment will be conducted at Burn Station 14 (Source 4) once every two months,
six times per year for a total annual treatment quantity of 3,600 lbs.
Waste material is delivered to the Burn Grounds and packaged in a variety of containers and sizes
including, but not limited to super sacks, conductive/static dissipative bags, and buckets. The Bacchus
waste is received in conductive/static dissipative bags and cardboard/wood containers. Autoliv waste is
received in high-density polyethylene bags and cardboard containers.
Some waste materials are desensitized with shingle oil, diesel fuel, or triacetin prior to transporting to the
M-136 Burn Grounds. The requirement to desensitize is identified in the waste profile system. This is
done to ensure the safe handling of static sensitive materials.
Material delivered to M-136 may be offloaded from the vehicle into the burn trays by hand, knuckle-boom-
crane, or by forklift. During tray loading, the vehicle is parked next to the receiving tray, then the
appropriate side rails on the trailer are lowered and the web belts are removed, if necessary, allowing the
material to be offloaded and placed into the burn tray.
The burn trays are inspected prior to loading. The burn tray inspection criteria includes: (1) holes in the
tray; (2) weld cracks; and (3) a minimum of 6-inches depth or wall height. The inspection is documented
in the Daily Propellant Log. Trays that fail the inspection are removed from service. The trays are also
checked for hot spots from the previous burns.
Open burning of reactive waste at M-136 can be conducted at Burn Stations 1 through 13. However,
ATK's operating convention is to open burn reactive laboratory waste at Burn Station 13, although some
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ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.1
JANUARY 2012
laboratory wastes, such as propellant test loaves may be burned at Stations 1 through 12. The amount of
laboratory wastes treated at Burn Station 13 constitutes less than 1 percent of the total waste treated
annually at M-136. Operation of Burn Station 14 has been described previously.
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ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.2
JANUARY 2012
2.3.2 M-225 Treatment Unit
The M-225 treatment unit receives small amounts of the reactive waste materials from the Plant III
propellant development area. The waste containers are labeled and the material is stored in 90-day
storage on the wastes docks and then transferred to M-225 for treatment. The M-225 treatment unit is
surrounded with an 8-foot high chain link fence. The waste materials are treated via open burning or
open detonation. Open detonation is conducted no more than once per day and generally occurs once
every three weeks. The layout of M-225 is shown in Figures 2-5 and 2-6.
2.3.2.1 M-225 Treatment Quantities
Table 2-2 presents a list of the M-225 treatment sources to be included in the dispersion modeling, the
burn stations associated with each M-225 source, the reactive wastes treated by the each M-136 source,
the modeled quantity per treatment event in pounds (lbs.) to be used for each M-136 source in the
dispersion modeling, the annual treatment quantity for each source, and the emission factors to be used
for each M-136 source.
The modeled quantity per treatment event at M-225 Burn Station 1 (Source 1) is 2,000 lbs. Treatment at
Source 1 will be conducted twice per month, 12 months per year daily, which is equivalent to a total
annual treatment quantity of 48,000 lbs. The modeled quantity per treatment event at M-225 Burn Station
2 (Source 2) is 400 lbs. Treatment at Source 2 will be conducted once every 2 months, six times per year
which equals a total annual treatment quantity of 2,400 lbs.
The burn trays at M-225 are inspected once a week. The burn tray inspection criteria includes: (1) holes
in the tray; (2) weld cracks; and (3) a minimum of 6-inches depth or wall height. The inspection is
documented in the Daily Propellant Log. Trays that fail the inspection are removed from service. The
trays are also checked for hot spots from the previous burns. The M-225 treatment unit has the capability
of using the sump truck to remove the excess water from the trays and have it treated at the M-705
hazardous wastewater treatment plant.
Within the M-225 Burn Grounds are four burn stations with one burn stanchion in each station, and one
tray per station. Unlike M-136 operations, the trays at M-225 are not moved from one burn station to
another. Burn tray construction is comparable to those used at the M-136 Burn Grounds. The trays may
be lined with soil to facilitate burning operations; however, most of the trays do not contain soil.
The M-225 treatment activities are very similar to the operations at M-136 with only a few differences. At
M-225, treatment typically occurs less frequently, and involves smaller quantities of waste material
041108/P 2.3.2-1
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 2.3.2
JANUARY 2012
(600 lbs or less). During a burn event, a burn tray is ignited and allowed to burn down, and then the next
tray is ignited. This routine is followed until all the trays have completed burning. The re-entry waiting
time following a burn event at M-225 is 16 hours. Open detonation is conducted at a designated location
within the M-225 fenced area (See Figure 2-6). Based on QD limitations, open detonation may be
performed aboveground or underground in a hole or pit, depending on the item to be detonated.
The M-225A building is the control bunker that contains the system for firing the igniters that are placed in
the burn trays. The firing system functions in the same manner as the M-136 treatment unit, which has
been described previously.
The reactive wastes treated by open burning at M-225 include neat double base (1.1) propellants and
composite propellants (1.3), as well as, reactive contaminated materials such as cloth and paper wipes,
metal containers, plastics, and propellant ingredients. Reactive wastes are collected in a variety of
containers and sizes including but not limited to super sacks and buckets lined with conductive/static
dissipative bags that may contain desensitized ingredients that are the same as those used for wastes at
M-136.
With the exception of U.S. EPA, waste numbers exempted by rule, the ash resulting from the treatment of
reactive wastes at M-225, with listed EPA waste numbers, is collected and shipped for offsite disposal.
All other ash is sent for disposal in the M-136 IWT. A sump truck is used to remove excess water in the
burn trays. The collected water is then taken to the M-705 wastewater treatment facility.
041108/P 2.3.2-2
ATK DISPERSION MODEL PROTOCOL ADDENDUM
TABLE 2-1
JANUARY 2012
TABLE 2-1
M-136 TREATMENT UNIT
SOURCES, WASTES TREATED, MODELED TREATMENT QUANTITES PER EVENT,
TREATMENT SCHEDULE AND APPLICABLE EMISSION FACTORS
Modeled
Sources
Burn
Station(s)
Treated
Reactive
Waste
Categories
Modeled
Per Event
Treatment
Quantity
Treatment
Events Per
Day Per
Month or
Year
Total
Treatment
Events Per
Year
Total
Annual
Burn Limit
(lbs.)
Applicable Emission
Factors For Wastes
Treated At Each
Source*
Source 1
Open Burn
1,2,3,4,5,6,7,
8,9,10,11,12
A, B,C, D,
E, F,G, H 12,000 lbs. 2 events per
day, 3 days 312 3,744,000 1.3 - see Tables 3-5 and
3-6
Source 2
Open Burn 13 A, B, C. D,
E, F,G, H 10,000 lbs. Once per
week 52 520,000 1.3 - see Tables 3-5 and
3-6
Source 3
Open Burn 14 A, B, C, D 10,000 lbs. Once per
week 52 520,000 1.3 - see Tables 3-5 and
3-6
Source 3
Open Burn 14
Large
Rocket
Motors
26,000 lbs. 3 per year 3 78,000 1.3 - see Tables 3-5 and
3-6
Source 4
Open
Detonation
13&14 C, D, G, H 600 lbs. Once every 2
months 6 3,600 1.3 - see Tables 3-5 and
3-6
* - ATK has agreed to use 1.3 OBODi emission factors for all M-136 modeled sources.
ATK DISPERSION MODEL PROTOCOL ADDENDUM
TABLE 2-2
JANUARY 2012
TABLE 2-2
M-225 TREATMENT UNIT
SOURCES, WASTES TREATED, MODELED TREATMENT QUANTITES PER EVENT,
TREATMENT SCHEDULE AND APPLICABLE EMISSION FACTORS
Treated Modeled Treatment Total Total Applicable Emission
Modeled Burn Reactive Per Event Events Per Treatment Annual Factors For Wastes
Sources Station(s) Waste Treatment Month Events Per Burn Limit Treated At Each
Categories Quantity Year (lbs.) Source*
Source 1
Open Burn 1,2,3,4 A, B, C, D,
E, F, G, H 2,000 lbs. 2 events per
month 24 48,000 1.3 - see Tables 3-5 and
3-6
Source 2
Open
Detonation
1 C, D, G, H 400 lbs. Once every
two months 6 2,400 1.3 - see Tables 3-5 and
3-6
ATK has agreed to use 1.3 OBODi emission factors for all M-225 modeled sources.
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 3.2.1
JANUARY 2012
3.2.1 Class 1.3 Waste Emission Factors
Although the waste materials treated at M-136 and M-225 includes 1.1 and 1.3 class materials, the
majority (96 percent) of wastes treated by ATK are 1.3 class wastes. In 2006, ATK conducted emissions
testing at the DPG to obtained emission factors for Class 1.3 materials. The ODOBi test chamber was
used to determine emission factors for airborne compounds from three different compositions of Class 1.3
process waste (PW) materials. The tests were conducted from June 7 to 15, 2006. Test results are
presented in the report titled Sampling Results for Emission Characterization of Open Burning Waste
Propellant Materials (U.S. Army, 2009).
Emissions were measured from simulated OB events of the following three waste scenarios that are
considered representative of 1.3 class propellant waste:
e PW100: 100% ammonium perchlorate (AP) propellant
• PW85-15: 85% AP propellant + 15% trash
• PW65-35: 65% AP propellant + 35% trash
The first material (PW100) was 100% Class 1.3 propellant. The other two test materials (PW85-15 and
PW65-15) consisted of a mixture of Class 1.3 propellant blended with different percentages of materials
such as cloth, paper, paper wipes, plastics, and cleaning items. The PW85-15 trash sample was
determined by conducting a 2-week-long survey of the types and quantities of contaminated waste
coming from each live-area waste dock. The 15% trash ration was based on an analysis of daily
treatment data for the past 3 years. This sample is intended to be representative of most of the Class 1.3
contaminated waste streams treated at the ATK. The PW65-35 trash sample was determined in a similar
manner.
It is important to note that the 1.3 waste testing resulted in numerous analytical results being reported as
"non-detect" or "below background". Based on a re-evaluation of key aspects of the test, including non-
detects, blank corrections and how background values were used, the UDSHW has determined that the
inherent uncertainty associated with the emissions test and calculation of 1.3 emission factors needs to
evaluated using two data sets that reflect the range of possible emissions; based on the available data.
The first emission factor data set consists of a more "conservative" data set uses the full method detection
limit (MDL) for non-detected compounds and background and blank values have not been subtracted out
from the test results. Table 3-5 shows the "conservative" emission factor data set, which represents the
maximum emission factor for all three test scenarios (PW100, PW85-15, and PW65-35). Table 3-5 also
identifies the analytes that were not detected during the Bang Box testing program.
041108/P 3.2.1-1
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 3.2.1
JANUARY 2012
The second set of emissions data represents a "corrected" (less conservative) set proposed by ATK in
which all non-detects are replaced with Vi MDL (or Vz EDL) and background/blank correction has been
performed. Table 3-6 shows the "corrected" emission factor data set for all three test scenarios (PW100,
PW85-15, and PW65-35). Table 3-6 also identifies the analytes that were not detected during the Bang
Box testing program.
Using the two sets of emissions data to assess risk will permit evaluation of the potential range in impacts
of some of the uncertainties in the emissions data. This proposal assumes that the risk results of the
conservative, or uncorrected data set will be evaluated and if emissions are acceptable, no further
analysis is required. If some of the emission factors in the conservative data set produce an
unacceptable risk and the "corrected" data set does not, the risk results will be reviewed to determine if
using the less conservative estimate of emissions is justified.
The "conservative" and "corrected" emission factors presented in Tables 3-5 and 3-6, respectively, have
been approved by the UDSHW for use in the ATK evaluation of Class 1.3 materials.
041108/P 3.2.1-2
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 1 OF 7
Analyte Maxiinum Emission Factor (ibs/lb)
Particulates
TSP 1.5E-01
PM10 1.2E-01
PM2.5 6.0E-02
Metals
Aluminum 4.0E-02
Antimony 2.9E-05
Arsenic 5.5E-07
Barium 9.SE-06
Cadmium 6.1E-07
Chromium 2.0E-05
Cobalt 6.1E-07
Copper 2.5E-05
Lead 4.1E-05
Magnesium 8.2E-05
Manganese 9.4E-05
Mercury 7.4E-08
Nickel 5.8E-05
Phosphorus l.lE-04
Selenium 1.6E-06
Silver 1.2E-06
Thallium 4.3E-06
Zinc 3.5E-05
Perchlorate 4.9E-07
SVOCs
1,2,4,5-Tetrachlorobenzene 5.5E-07
1,2,4-Trichlorobenzene 6.5E-07
1,2-Dichlorobenzene 5.6E-07
1,3,5-Trinitrobenzene 5.5E-07
1,3-Dichlorobenzene 6.2E-07
1,3-Dinitrobenzene 5.7E-07
1,4-Dichlorobenzene 5.8E-07
1 -Chloronaphthalene 5.5E-07
1-Naphthylamine l.lE-05
2,3,4,6-Tetrachlorophenol 7.1E-07
2,4,5-Trichlorophenol 1.4E-06
2,4,6-Trichlorophenol 1.3E-06
2,4-Dichlorophenol 9.3E-07
2,4-Dimethylphenol 6.9E-06
2,4-Dinitrophenol 2.4E-05
2,4-Dinitrotoluene 5.5E-07
2,6-Dichlorophenol 5.5E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 2 OF 7
Analyte Maximum Emission Factor (lbs/lb)
2,6-Dinitrotoluene 5.6E-07
2-Acetylaminofluorene 5.5E-07
2-Chloronaphthalene 5.5E-07
2-Chlorophenol 1.9E-06
2-Methylnaphthalene 3.6E-06
2-Methylphenol 3.3E-06
2-Naphthylamine l.lE-05
2-Nitroaniline — 5.5E-07
2-Nitrophenol 5.5E-07
3,3'-Dichlorobenzidine 8.1E-06
3,3'-Dimethylbenzidine 5.5E-05
3-Methylcholanthrene 5.5E-07
3-Methylphenol & 4-Methylphenol 2.2E-06
3-Nitroaniline 2.2E-06
4,6-Dinitro-2-methylphenol 9.5E-06
4-Aminobiphenyl l.lE-05
4-Bromophenyl phenyl ether 5.5E-07
4-Chloro-3-methylphenol 6.8E-07
4-Chloroaniline 6.6E-06
4-Nitroaniline 2.2E-06
4-Nitrophenol 3.6E-06
7,12-Dimethylbenz(a)anthracene 5.6E-07
Acenaphthene 5.5E-07
Acenaphthylene 5.5E-07
Acetophenone 2.7E-06
Aniline 8.0E-06
Anthracene 5.5E-07
Benzidine 5.6E-05
Benzo(a)anthracene 6.4E-07
Benzo(a)pyrene 5.5E-07
Benzo(b)fluoranthene 1.2E-06
Benzo(ghi)perylene 6.8E-07
Benzo(k)fluoranthene 1.8E-06
Benzoic acid 6.2E-05
Benzyl alcohol 3.8E-05
bis(2-Chloroethoxy)methane 5.5E-07
bisf2-Chloroethvn ether 6.1E-07
bis(2-Chloroisopropyl) ether '8.3E-07
bis(2-Ethylhexyl) phthalate l.lE-05
Butyl benzyl phthalate 6.7E-07
Carbazole 7.0E-07
Chrysene 7.0E-07
Dibenz(a,h)anthracene 6.6E-07
Dibenzofuran 5.5E-07
Diethyl phthalate 8.0E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 3 OF 7
Analyte Maximum Emission Factor (Ibs/lb)
Dimethyl phthalate 5.5E-07
Di-n-butyl phthalate l.lE-05
Di-n-octyl phthalate 3.7E-06
Diphenylamine 5.5E-07
Ethyl methanesulfonate 5.5E-07
Fluoranthene 5.9E-07
Fluorene 5.5E-07
Hexachlorobenzene 4.7E-06
Hexachlorobutadiene 8.1E-07
Hexachlorocyclopentadiene l.lE-05
Hexachloroethane 5.9E-07
Hexachloropropene 7.9E-07
lndeno(1,2,3-cd)pyrene 5.9E-07
Isophorone 5.5E-07
Methyl methanesulfonate 6.0E-07
Naphthalene 1.4E-05
Nitrobenzene 6.2E-07
N-Nitro-o-toluidine 8.8E-06
N-Nitrosodiethylamine 5.5E-07
N-Nitrosodimethylamine 5.5E-07
N-Nitrosodi-n-butyiamine 5.5E-07
N-Nitrosodi-n-propylamine 5.5E-07
N-Nitrosodiphenylamine 9.5E-07
N-Nitrosomethylethylamine 9.1E-07
N-Nitrosomorpholine 5.5E7G7
o-Toluidine 7.0E-06
p-Dimethyiaminoazobenzene 5.5E-07
Pentachlorobenzene 5.5E-07
Pentachloroethane 5.5E-07
Pentachloronitrobenzene 5.5E-07
Pentachlorophenol 2.7E-05
Phenanthrene 7.0E-07
Phenol 2.4E-06
Pyrene 5.8E-07
Pyridine 8.1E-07
Dioxins/Furans
2,3,7,8-TCDD 2.3E-12
1,2,3,7,8-PeCDD 6.7E-12
1,2,3,4,7,8-HxCDD 3.5E-12
1,2,3,6,7,8-HxCDD 8.9E-12
1,2,3,7,8,9-HxCDD 6.1E-12
1,2,3,4,6,7,8-HpCDD 2.9E-11
OCDD 3.7E-11
2,3,7,8-TCDF 4.0E-11
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 4 OF 7
Analyte Maximum Emission Factor (Ibs/lb)
1,2,3,7,8-PeCDF 8.0E-11
2,3,4,7,8-PeCDF 1.6E-10
1,2,3,4,7,8-HxCDF 2.6E-10
1,2,3,6,7,8-HxCDF 1.6E-10
2,3,4,6,7,8-HxCDF 1.9E-10
1,2,3,7,8,9-HxCDF 1.2E-10
1,2,3,4,6,7,8-HpCDF 7.3E-10
1,2,3,4,7,8,9-HpCDF 1.9E-10
OCDF 5.3E-10
Carbonyls
2,5-Dimethylbenzaldehyde 2.7E-05
Acetaldehyde 9.3E-05
Acetone 3.1E-05
Benzaldehyde 1.4E-05
Crotonaldehyde 1.4E-05
Formaldehyde 4.7E-05
Hexanal 1.4E-05
Isopentanal 1.4E-05
m,p-Tolualdehyde 1.4E-05
MEK/Butyraldehydes 1.4E-05
o-Tolualdehyde 4.0E-05
Pentanal 1.7E-05
Propanal 5.2E-05
HCI/CI2/NH3
HCI 1.8E-02
: CI2 1.2E-02
NHS 3.2E-05
HCN 2.2E-05
VOCs
TNMOC 9.4E-04
1,1,1-Trichloroethane 8.9E-07
1,1,2,2-Tetrachloroethane 4.2E-07
1,1.2-Trichloroethane 7.3E-07
1,1-Dichloroethane 3.2E-07
1,1-Dichloroethene 4.3E-07
1,2,3-Trimethylbenzene 4.2E-07
1,2,4-Trichlorobenzene 1.3E-06
1,2,4-Trimethylbenzene 5.2E-06
1,2-Dibromomethane (EDB) 8.9E-07
1,2-Dichlorobenzene 4.8E-07
1,2-Dichloroethane 5.4E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 5 OF 7
Analyte Maximum Emission Factor (Ibs/lb)
1,2-Dichloropropane 3.7E-07
1,3,5-Trimethylbenzene 2.0E-06
1,3-Butadiene 2.4E-05
1,3-Dichlorobenzene 4.4E-07
1,3-Diethylbenzene 5.0E-07
1,4-Dichlorobenzene 7.3E-07
1,4-Diethylbenzene 6.7E-07
1,4-Dioxane 6.4E-07
1 -Butene 2.2E-05
1-Hexene 2.0E-05
1-Pentene 1.2E-05
2,2,4-Trimethylpentane 2.3E-06
2,2-Dimethylbutane 8.8E-07
2,3,4-Trimethylpentane 2.8E-07
2,3-Dimethylbutane 2.9E-06
2,3-Dimethylpentane 2.7E-06
2,4-Dimethylpentane l.lE-06
2-Butanone (MEK) 3.9E-06
2-Ethyltoluene 4.5E-07
2-Hexanone 8.7E-07
2-Methylheptane 2.7E-06
2-Methylhexane 4.4E-06
2-Methylpentane l.lE-05
2-Nitropropane 2.8E-06
2-Propanol 3.0E-07
3-Chloropropene 4.7E-06
3-Ethyltoiuene 4.8E-06
3-Methylheptane 3.5E-06
3-Methylhexane 5.2E-06
3-Methylpentane 7.1E-06
4-Ethyltoluene 5.3E-06
4-Methyl-2-pentanone .7.0E-07 . - -
Acetone 2.4E-05
Acetonitrile 1.9E-05
Acetylene 9.4E-05
Acrylonitrile 1.6E-05
alpha-Chlorotoluene 5.7E-07
Benzene 4.7E-05
Bromodichloromethane 7.8E-07
Bromoform 1.3E-06
Bromomethane 6.2E-07
Butane 1.8E-05
Carbon Disulfide 9.8E-06
Carbon Tetrachloride 1.5E-05
Chloroacetonitrile l.lE-06
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 6 OF 7
Analyte Maximum Emission Factor (Ibs/lb)
Chlorobenzene 2.5E-06
Chloroethane 2.6E-07
Chloroform 6.1E-06
Chloromethane 1.4E-05
cis-1,2-Dichloroethene 4.6E-07
cis-1,3-Dichloropropene 1.3E-06
cis-2-Butene 1.7E-06
cis-2-Pentene ^ 3.3E-07 -
Cumene 4,2E-07
Cyclohexane 2.5E-06
Cyclopentane 1.8E-06
Decane 1.7E-05
Dibromochloromethane 8.8E-07
Ethane 2.1E-05
Ethanol 1.6E-06
Ethene 1.8E-04
Ethyl benzene 2.8E-06
Ethyl ether 2.5E-06
Ethyl Methacrylate 1.6E-06
Heptane 7.2E-06
Hexachlorobutadiene 1.7E-06
Hexane 9.8E-06
Isobutane 2.8E-06
Isopentane 2.0E-05
m,p-Xylene l.lE-05
Methacrylonitrile 4.9E-06
Methyl Acrylate 1.2E-06
Methyl Methacrylate 1.6E-06
Methyl tert-butyl ether 4.2E-07
Methylcyclohexane 6.1E-06
Methylcyclopentane 5.6E-06
Methylene chloride 7.1E-06
n-Butylchloride 1.2E-05
Nonane 1.3E-05
Octane 7.5E-06
o-Xylene 3.5E-06
Pentane 1.9E-05
Propane 8.7E-06
Propylbenzene l.OE-06
Propylene 4.9E-05
Styrene 9.9E-07
Tetrachloroethene 2.5E-06
Tetrahydrofuran 9.0E-07
Toluene 1.9E-05
trans-1,2-Dichloroethene 7.2E-07
TABLE 3-5
1.3 CLASS WASTE MATERIAL
"CONSERVATIVE" MAXIMUM EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 7 OF 7
Analyte Maximum Emission Factor (Ibs/lb)
trans-1,3-Dichloropropene 6.1E-07
trans-2-butene 7.7E-06
trans-2-Pentene 1.7E-06
Trichloroethene 9.4E-07
Undecane 1.2E-05
Vinyl chloride 7.6E-06
CEM
C02 7.20E-01
CO 6.40E-03
NOX 6.40E-03
S02 5.00E-04
Highlighted analytes were not detected during the Bang Box testing program
HCN - hydrogen cyanide
SVOCs - semi-volatile organic compounds
VOCs - volatile organic compounds
HCL - hydrogen chloride
NOX - nitrogen oxide
S02 - sulfur dioxide
CO - carbon monoxide
C02 - carbon dioxide
TNMOC - total non-methane organic carbon
OCDD - 1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin
OCDF - l,2,3,4,6,7,8,9-Octach!orodibenzo-p-furan
CL2 - chlorine
NHS - ammonia
TSP - Total suspended particulates
PMIO - particulate matter less than 10 microns in aerodynamic diameter
PM2.5 - particulate matter less than 2.5 microns in aerodynamic diameter
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 1 OF 7
Analyte Emission Factoi' (Ibs/lb)
Particulates
TSP 1.4E-01
PMIO 8.6E-02
PM2.5 5.9E-02
Metals
Aluminum 4.0E-02
Antimony 2.9E-05
Arsenic 3.0E-07
Barium 4.9E-06
Cadmium 3.1E-07
Chromium 2.0E-05
Cobalt 3.1E-07
Copper 2.5E-05
Lead 3.4E-05
Magnesium 2.9E-05
Manganese 9.3E-05
Mercury 3.7E-08
Nickel 5.8E-05
Phosphorus 1 .OE-04
Selenium 1.7E-06
Silver 9.5E-07
Thallium 2.1E-06
Zinc 3.5E-05
Perchlorate 2.5E-07
SVOCs
1,2,4,5-Tetrachlorobenzene 2.7E-07
1,2,4-Trichlorobenzene 3.2E-07
1,2-Dichlorobenzene 2.8E-07
1,3,5-Trinitrobenzene 2.7E-07
1,3-Dichlorobenzene 3.1E-07
1,3-Dinitrobenzene 2.8E-07
1,4-Dichlorobenzene 2.9E-07
1 -Chloronaphthalene 2.7E-07
1-Naphthylamine 5.5E-06
2,3,4,6-Tetrachlorophenol 3.6E-07
2,4,5-Trichlorophenol 7.1E-07
2,4,6-Trichlorophenol #REF!
2,4-Dichlorophenol 9.3E-07
2,4-Dimethylphenol 3.5E-06
2,4-Dinitrophenol 1.2E-05
2,4-Dinitrotoluene 3.1E-07
2,6-Dichlorophenol 4.0E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 2 OF 7
Analyte Emission Factor (Ibs/lb)
2,6-Dinitrotoluene 5.6E-07
2-Acetylaminofluorene 2.7E-07
2-Chloronaphthalene 2.7E-07
2-Chlorophenol 1.9E-06
2-Methylnaphthalene 3.6E-06
2-Methylphenol 1.6E-06
2-Naphthylamine 5.5E-06
2-Nitroaniline 2.7E-07
2-Nitrophenol 3.9E-07
3,3'-Dichlorobenzidine 4.1E-06
3,3'-Dimethylbenzidine 2.7E-05
3-Methylcholanthrene 2.7E-07
3-Methylphenol & 4-Methylphenol 1.1E-06
3-Nitroaniline 1.1E-06
4,6-Dinitro-2-methylphenol 4.8E-06
4-Aminobiphenyl 5.5E-06
4-Bromophenyl phenyl ether 2.7E-07
4-Chloro-3-methylphenol 3.4E-07
4-Chloroaniline 3.3E-06
4-Nitroaniline 1.1E-06
4-Nitrophenol 1.8E-06
7,12-Dimethylbenz(a)anthracene 2.8E-07
Acenaphthene 2.7E-07
Acenaphthylene 2.7E-07
Acetophenone 2.7E-06
Aniline 4.0E-06
Anthracene 2.7E-07
Benzidine 2.8E-05
Benzo(a)anthracene 3.2E-07
Benzo(a)pyrene 2.7E-07
Benzo(b)fluoranthene 6.0E-07
Benzo(ghi)perylene 3.4E-07
Benzo(k)fluoranthene 8.8E-07
Benzoic acid 6.2E-05
Benzyl alcohol 1.9E-05
bis(2-Chloroethoxy)methane 2.7E-07
bis(2-Chloroethyl) ether 3.1E-07
bis(2-Chloroisopropyl) ether 4.2E-07
bis(2-Ethylhexyl) phthalate 5.5E-06
Butyl benzyl phthalate 3.3E-07
Carbazole 3.5E-07
Chrysene 3.5E-07
Dibenz(a,h)anthracene 3.3E-07
Dibenzofuran 2.7E-07
Diethyl phthalate 4.0E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 3 OF 7
Analyte Emission Factor (Ibs/lb)
Dimethyl phthalate 2.7E-07
Di-n-butyl phthalate 5.5E-06
Di-n-octyl phthalate 3.7E-06
Diphenylamine 2.7E-07
Ethyl methanesulfonate 2.7E-07
Fluoranthene 4.0E-07
Fluorene 4.2E-07
Hexachlorobenzene 4.7E-06
Hexachlorobutadiene 4.1E-07
Hexachlorocyclopentadiene 5.5E-06
Hexachloroethane 3.0E-07
Hexachloropropene 3.9E-07
lndeno(1,2,3-cd)pyrene 3.0E-07
Isophorone' 2.7E-07
Methyl methanesulfonate 3.0E-07
Naphthalene 1.3E-05
Nitrobenzene 3.1E-07
N-Nitro-o-toluidine 4.4E-06
N-Nitrosodiethylamine 2.7E-07
N-Nitrosodimethylamine 2.7E-07
N-Nitrosodi-n-butylamine 2.7E-07
N-Nitrosodi-n-propylamine 2.7E-07
N-Nitrosodiphenylamine 4.8E-07
N-Nitrosomethylethylamine 4.5E-07
N-Nitrosomorpholine 2.7E-07
o-Toluidine 3.5E-06
p-Dimethylaminoazobenzene 2.7E-07
Pentachlorobenzene 3.0E-07
Pentachloroethane 2.7E-07
Pentachloronitrobenzene 2.7E-07
Pentachlorophenol 1.4E-05
Phenanthrene 7.0E-07
Phenol 2.1E-06
Pyrene 2.9E-07
Pyridine 4.1E-07
Dioxins/Furans
2,3,7,8-TCDD 1.3E-12
1,2,3,7,8-PeCDD 6.7E-12
1,2,3,4,7,8-HxCDD 3.4E-12
1,2,3,6,7,8-HxCDD 8.9E-12
1,2,3,7,8,9-HxCDD 6.1E-12
1,2,3,4,6,7,8-HpCDD 2.9E-11
OCDD 3.7E-11
2,3,7,8-TCDF 4.0E-11
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 4 OF 7
Analyte Emission Factor (Ibs/lb)
1,2,3,7,8-PeCDF 8.0E-11
2,3,4,7,8-PeCDF 1.6E-10
1,2,3,4,7,8-HxCDF 2.6E-10
1,2,3,6,7,8-HxCDF 1.6E-10
2,3,4,6,7,8-HxCDF 1.9E-10
1,2,3,7,8,9-HxCDF 1.2E-10
1,2,3,4,6,7,8-HpCDF 7.3E-10
1,2,3,4,7,8,9-HpCDF 1.9E-10
OCDF 5.2E-10
Carbonyls
2,5-Dimethylbenzaldehyde 1.4E-05
Acetaldehyde 7.5E-05
Acetone 1.5E-05
Benzaldehyde 7.3E-06
Crotonaldehyde 6.8E-06
Formaldehyde 4.0E-05
Hexanal 8.2E-06
Isopentanal 6.8E-06
m,p-Tolualdehyde 6.8E-06
M EK/Butyraldehydes 1.2E-05
o-Tolualdehyde 2.3E-05
Pentanal 1.2E-05
Propanal 3.8E-05
HCI/CI2/NH3
HCI 1.8E-02
CI2 1.5E-03
NH3 2.2E-05
HCN 1.2E-05
VOCs
TNMOC 8.1E-04
1,1,1 -Trichloroethane 4.5E-07
1,1,2,2-Tetrachloroethane 2.1E-07
1,1,2-Trichloroethane 3.6E-07
1,1-Dichloroethane 1.6E-07
1,1-Dichloroethene 2.2E-07
1,2,3-Trimethylbenzene 2.1E-07
1,2,4-Trichlorobenzene 6.3E-07
1,2,4-Trimethylbenzene 5.2E-06
1,2-Dibromoethane (EDB) 4.4E-07
1,2-Dichlorobenzene 2.4E-07
1,2-Dichloroethane 2.7E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 5 OF 7
Analyte Emission Factor (Ibs/lb)
1,2-Dichloropropane 1.8E-07
1,3,5-Trimethylbenzene 2.0E-06
1,3-Butadiene 2.0E-05
1,3-Dichlorobenzene 2.2E-07
1,3-Diethylbenzene 2.5E-07
1,4-Dichlorobenzene 3.7E-07,
1,4-Diethylbenzene 3.3E-07
1,4-Dioxane 3.2E-07
1-Butene 2.1E-05
1-Hexene 2.0E-05
1-Pentene 1.2E-05
2,2,4-Trimethylpentane 2.3E-06
2,2-Dimethylbutane 4.4E-07
2,3,4-Trimethylpentane 1.4E-07
2,3-Dimethylbutane 2.9E-06
2,3-Dimethylpentane 2.7E-06
2,4-Dimethylpentane 5.5E-07
2-Butanone (MEK) 3.9E-06
2-Ethyltoluene 2.2E-07
2-Hexanone 4.4E-07
2-Methylheptane 2.7E-06
2-Methylhexane 4.4E-06
2-Methylpentane 5.3E-06
2-Nitropropane 2.8E-06
2-Propanol 1.5E-07
3-Chloropropene 4.7E-06
3-Ethyltoluene 4.8E-06
3-Methylheptane 3.5E-06
3-Methylhexane 5.2E-06
3-Methylpentane 7.1E-06
4-Ethyltoluene 5.3E-06
4-Methyl-2-pentanone 3.5E-07
Acetone 2.3E-05
Acetonitrile 9.2E-06
Acetylene 7.4E-05
Acrylonitrile 1 .OE-05
alpha-Chlorotoluene 2.8E-07
Benzene 4.4E-05
Bromodichloromethane 3.9E-07
Bromoform 6.3E-07
Bromomethane 3.1E-07
Butane 1.8E-05
Carbon Disulfide 9.4E-06
Carbon Tetrachloride 1.5E-05
Chloroacetonitrile 5.6E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 6 OF 7
Analyte Emission Factor (Ibs/lb)
Chlorobenzene 2.5E-06
Chloroethane 1.3E-07
Chloroform 6.1E-06
Chloromethane 1.4E-05
cis-1,2-Dichloroethene 2.3E-07
cis-1,3-Dichloropropene 1.3E-06
cis-2-Butene 1.4E-06
cis-2-Pentene 1.7E-07
Cumene 2.1E-07
Cyclohexane 2.5E-06
Cyclopentane 1.8E-06
Decane 1.7E-05
Dibromochloromethane 4.4E-07
Ethane 1.7E-05
Ethanol 1.6E-06
Ethene 1.5E-04
Ethyl Benzene 2.8E-06
Ethyl Ether 1.2E-06
Ethyl Methacrylate 7.8E-07
Heptane 7.2E-06
Hexachlorobutadiene 8.5E-07
Hexane 9.8E-06
Isobutane 2.8E-06
Isopentane 2.0E-05
m,p-Xylene 1 .OE-05
Methacrylonitrile 4.9E-06
Methyl Acrylate 5.9E-07
Methyl Methacrylate 8.1E-07
Methyl tert-butyl ether 2.1E-07
Methylcyclohexane 6.1E-06
Methylcyclopentane 5.6E-06
Methylene Chloride 7.1E-06
n-Butylchloride 5.8E-06
Nonane 1.3E-05
Octane 7.5E-06
o-Xylene 3.5E-06
Pentane 1.9E-05
Propane 8.7E-06
Propylbenzene 1 .OE-06
Propylene 4.3E-05
Styrene 9.9E-07
Tetrachloroethene 2.5E-06
Tetrahydrofuran 6.4E-07
Toluene 1.8E-05
trans-1,2-Dichloroethene 3.6E-07
TABLE 3-6
1.3 CLASS WASTE MATERIAL
"CORRECTED" EMISSION FACTORS (LBS/LB)
ATK PROMONTORY, UTAH
PAGE 7 OF 7
Analyte Emission Factor (Ibs/lb)
trans-1,3-Dichloropropene 3.0E-07
trans-2-butene 7.7E-06
trans-2-Pentene 1.7E-06
Trichloroethene 9.4E-07
Undecane 1.2E-05
Vinyl Chloride 7.6E-06
CEM
C02 6.9E-01
CO 4.7E-03
NOX 5.8E-03
S02 4.1E-04
[Highlighted analytes were not detected during the Bang Box testing program
HCN - hydrogen cyanide
SVOCs - semi-volatile organic compounds
VOCs - volatile organic compounds
HCL - hydrogen chloride
NOX - nitrogen oxide
S02 - sulfur dioxide
CO - carbon monoxide
C02 - carbon dioxide
TNMOC - total non-methane organic carbon
OCDD - 1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin
OCDF -1,2,3,4,6,7,8,9-Octachlorodibenzo-p-furan
CL2 - chlorine
NHS - ammonia
TSP - Total suspended particulates
PMIO - particulate matter less than 10 microns in aerodynamic diameter
PM2.5 - particulate matter less than 2.5 microns in aerodynamic diameter
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
4.4 OB/OD TREATMENT SCENARIOS
In order to calculate the air quality impact of OB and OD treatment operations, OBODM requires specific
information regarding the characteristics of the source of treatment emissions. For example, OBODM
requires input data indicating the type of energetic material being treated, how it is being treated (OB or
OD), the heat content, burn rate of the material, the amount of material being treated, the size source,
and the release height.
The following treatment scenarios will be evaluated in the air dispersion modeling analysis for ATK OB
and OD treatment operations:
• OB treatment at M-136
• OB treatment at M-225
o OD treatment at M-136
• OD treatment at M-225
The M-136 Unit has 14 treatment stations. OB is conducted at stations 1-14. OD is conducted at stations
13 and 14. All OB treatment is conducted in pans with the exception of Burn Station 14, which consists of
a pad used for the OB of whole rocket motors. The OD hole or pit is not covered during OD treatment.
Based on quantity distance (QD) limitations, open detonation may be performed above ground or
underground in a hole or pit, depending on the item to be detonated.
The M-225 Unit has four burn stations and one detonation area. The OD hole or pit is not covered during
OD treatment. Based on QD limitations, open detonation may be performed above ground or
underground in a hole or pit, depending on the item to be detonated.
Although the OBODM model has the capability to model multiple source scenarios and locations in the
same model run (must have same heat content), the model has a 100 receptor limitation per model run
which necessitates numerous model runs to evaluate large receptor networks and precludes the
modeling of individual M-136 treatment stations.
ATK will consolidate certain M-136 and M-225 OB treatment stations into a subset of source areas
representing either all or part of the treatment unit. USEPA guidance (USEPA, 1992) allows the merging
of multiple emission points that are located within 100 meters of each other, if the emission points have
similar release parameters. A similar type situation exists for the area comprised of burn stations 1
through 12 at M-136 (see Figure 2-3). For example, burn stations 1-12 are all located within a 100-meter
radius of the center point of the area comprised of burn stations 1-12. A center point for this area can
041108/P 4.4-1
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
represent the treatment operations that are conducted at the burn stations 1-12. The burn stations in this
area treat similar materials and are assumed to have similar release parameters (e.g., pan size, release
height, and heat content). The proposed dimensions of the single emission point representing the merger
of BS 1-12 is discussed in Section 4.4.1.2 and shown in Table 4-1. ATK will treat stations 13 and 14 as
separate emission sources because of the large separation distance (greater than 100 meters) from
stations 1-12 and each other. The source parameters for all M-136 sources are presented in Table 4-1.
The proposed heat content values for modeling emissions from the treatment of reactive waste materials
was determined using the NASA-Lewis Thermochemical model. NASA-Lewis Thermochemical model
runs were completed for three compositions to simulate treatment scenarios; one composition burning
pure 1.3 propellants; and two compositions burning pure propellant and different percentages of waste
materials (PW85-15 and PW65-35.) at ambient pressure as described in Section 3.2.1. Decane was
chosen as a substitute material in the model for the different percentages of trash mixtures since most
waste materials would be carbon- and hydrogen- containing materials (diesel desensitizer, paper, wipes,
polystyrene plastics, support materials, etc.), whose exact composition could vary. Decane contributes no
oxidative species (has no oxygen in the molecule) that would aid in better combustion, so it can be
considered as a worst case representation. The goal of the model calculations was to examine
theoretical flame temperatures of the propellant and the mixtures. The NASA Lewis model calculations
are presented in Appendix A. The first composition was pure propellant (PW100); the second
composition was an 85:15 mixture of propellant and Decane (to simulate PW85:15); the third was a 65:35
mixture of propellant and Decane (to simulate PW65:35). The results of the NASA-Lewis model runs are
shown in below.
1.3 Class Material
NASA-Lewis Model Output
Parameter PW100 PW85:15
with Decane
PW65:35
with Decane
Flanne Temperature, "F 4976 2950 2260
Heat Content, cal/g 2058 1870 1471
The table given below lists the Heat of Explosion, which is the heat generated by the propellant when it is
burned in an inert gas atmosphere using a bomb calorimeter. This value would be conservative in
comparison to open burning since the testing was performed in an inert gas atmosphere (oxygen
deficient).
•
041108/P 4.4-2
ATK DISPERSION MODEL PROTOCOL ADDENDUM
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JANUARY 2012
Heat of Explosion for 1.3 Propellants
Sample ID Sample
Description
Heat of Explosion
cal/g
J770812 PW100 1,464
J770812 PW100 1,399
J770812 PW100 1,492
Average 1,452
J956002 PW100 1,442
J956002 PW100 1,365
J956002 PW100 1,449
Average 1,419
On June 3, 2009, ATK presented this data and information to the UDSHW. During this meeting, it was
agreed that based on this data, a value of approximately 1400 was appropriate for a 1.3 propellant heat
content value. The 1.3 heat content value of 1,471 calories/gram was chosen since it was the most
conservative value resulting from the NASA-Lewis Model output, and it corresponded well with the test
results from the bomb calorimeter. As a result, ATK is proposing to use a heat content value of
1,471 calories/gram for all M-136 and M-225 emission sources. As indicated in Section 3.3, ATK will use
the 1.3 reactive propellant emission factors given in Tables 3-5 and 3-6 for all emissions sources at
M-136 and M-225 (see Tables 2-1 and 2-2),
MODELING ANALYSIS OBJECTIVE AND METHODOLOGY
ATK completed a preliminary modeling assessment for M-136 and M-225 in October 2011 (Tt, 2011). In
this assessment, the modeling focused on determining the worst case short term and long term impact
based on treatment operating hours between 1000 and 1800 hours. Restricting treatment operations can
be problematic for ATK due to local climatological conditions which are not always conducive to good
dispersion. For example, the Cleanng Index (CI) is an air quality/smoke dispersal index used to regulate
open burning in Utah to ensure better air quality. The CI is determined on the basis of information
obtained from meteorological soundings which includes the Mixing Depth (depth of the mixed layer in
100s of feet above ground level) and (the average wind in the mixed layer in knots). CI values below 500
are considered poor ventilation and open burning is restricted under these conditions.
CI values for the ATK air basin are frequently below 500 due to the impact from complex terrain in
northern Utah. The complex terrain is responsible for trapping air masses and producing thermal
inversions. Thermal inversions are usually most pronounced in valleys and low-lying areas where cool
air is trapped by warm air, resulting in low mixing depths and an extremely stagnant wind conditions at
041108/P 4.4-3
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
the earth's surface. As a result, ATK experiences a large number of prohibited burn day when treatment
cannot be conducted and cannot rely on a regular treatment schedule.
The revised modeling methodology presented in this protocol is intended to give ATK the flexibility they
need to conduct treatment at variable times due to the restrictive climatological conditions. Rather than
designating specific treatment hours in the OBODM model, the revised protocol will evaluate the impact
of M-136 and M-225 treatment units on the basis of "worst case" events that were identified in a
preliminary modeling assessment conducted in October, 2011 (Tt, 2011). Applying this type of
methodology is typically referred to as a "screening" assessment and is designed to determine the worst
case impact at all receptors of interest regardless of the time of day. The screening procedure is a highly
conservative technique that is designed to calculate the maximum, worst case air concentrations at a
receptor location.
The 2011 preliminary modeling assessment identified the maximum impact from each treatment unit
source, for each model type (gas, particulate, and deposition) for the discrete receptors and general grid
receptors based on five years of onsite meteorological data. The OBODM output files from the
preliminary assessment identified the maximum air dispersion factor, associated meteorological
conditions, Julian Day and hour for the maximum impacted receptor. The worst case event
meteorological data identified for each treatment source, discrete receptor, and maximum general grid
receptor in the 2011 preliminary assessment will be used to compile the number of required worst case
meteorological events based on the revised ATK treatment schedules identified in Tables 2-1 and 2-2.
The worst case meteorological events will be selected from the new daily treatment time period 0600 to
1800, which was recently approved by the UDSHW.
> Discrete Receptor Assessment
In the case of discrete receptors, OBODM will be used to model the individual impact from each treatment
source to each discrete receptor using the revised treatment quantities shown in Tables 2-1 and 2-2 for
each year of meteorological data. OBODM will produce a table of the 50 highest 1-hour ADFs and events
for each source at a specific receptor. The 50 highest ADFs for each year of meteorological data will be
used to compile a master list of 250 worst case events for each receptor and source. The master list will
then be used to compile the required number of worst case annual treatment events for each source
based on the annual treatment schedules shown in Tables 2-1 and 2-2 in order to calculate annual
average ADFs. The maximum ADF for each source and discrete receptor will be used to determine
compliance with short term air quality criteria for the hours 0600 to 1800. New meteorological data files
will be created for each discrete receptor and will be used in conjunction with "hourly source strength"
files to limit source treatment to the number of events in Tables 2-1 and 2-2.
041108/P 4.4-4
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
For example, M-136 Source 1 will conduct treatment twice daily, three times a week for 52 weeks, which
is equivalent to 156 annual treatment events. The first treatment event conducted each day of the week
will result in 156 annual treatment events as will the second daily treatment event for a total of 312
treatment events at Source 1. The master list of worst case events will be used to compile a total of 156
individual worst case meteorological events that will be used for both daily treatment events at Source 1.
Likewise, 52 individual worst case meteorological events will be identified for M-136 Sources 2 and 3.
Source 3 will also be evaluated for the treatment of large rocket motors that will be conducted only 3
times per year and therefore, only requires 3 worst case meteorological events, which will be chosen from
the list of 52 events for standard OB treatment at Source 3. Source 4 will conduct OD 6 times a year and
will require 6 worst case meteorological events. The OBODM "houdy source file" option will be used to
calculate annual average ADFs on the basis of worst case meteorological conditions for each source and
model type. The same procedure will be used for M-225 source impacts to discrete receptors.
> General Grid Receptor Assessment
The 2011 preliminary model assessment utilized a general receptor grid extending out to 10 km to
determine the maximum onsite and offsite impact from each source at M-136 and M-225. Due to the
OBODM limit of 100 receptors per model run, 350 individual receptor grids were required to cover the
10 km general grid. The results of the preliminary assessment for M-136 and M-225 indicated that the
maximum short term impact from all four M-136 sources, for each model type (gas, particulate, and
deposition) occurred within the 3 km grid network (see Figures 3-1, 3-2, 3-3, 3-4, 3-6 and 3-7). The offsite
maximum impact locations were primarily located near or along the boundary of ATK property. Using the
lower treatment quantities shown in Table 2-1 and 2-2 in the revised protocol will result in lower plume
heights and maximum impacts close to the ATK boundary once again and not expected to extend out
beyond 3 km.
ATK is proposing to utilize the general grid maximum onsite and offsite receptor locations associated with
each treatment source for conducting the general grid analysis on the basis of worst case events to
duplicate the process used in the discrete receptor analysis discussed above. The general grid maximum
impact onsite and offsite locations (UTM coordinates and Grid Sector) for M-136 and M-225 sources and
each model type are summarized in Tables 4-1A And 4-2A, respectively.
In the case of the maximum onsite and offsite general grid receptors identified in Tables 4-1A and 4-2A,
OBODM will be used to model the individual impact from each treatment source to each general grid
sector using the revised treatment quantities shown in Tables 2-1 and 2-2 for each year of meteorological
data. OBODM will produce a table of the 50 highest 1-hour ADFs and events for each source within each
041108/P 4.4-5
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
sector at the maximum receptor. The 50 highest ADFs for each year of meteorological data will be used
to compile a master list of 250 worst case events for each sector and source. The maximum 1-hour ADF
for each source in each sector will be used to determine compliance with short term air quality criteria for
the hours 0600 to 1800 for the general grid.
The master list will then be used to compile the required number of worst case annual treatment events
for each source based on the annual treatment schedules shown in Tables 2-1 and 2-2 in order to
calculate annual average ADFs. The annual average modeling will then include the maximum impact
sector plus all adjacent sectors out to a distance of 1 km distance from the maximum impact receptor
sector. This methodology will facilitate the preparation of ADF contours for these general grid maximum
impact areas. The proposed adjacent sectors for each treatment source and model type are presented in
Tables 4-1A and 4-2A.
For example, the preliminary gas modeling assessment determined the general grid maximum impact
sector for M-136 Source 1 to occur within the 3 km sector 36C3A. This sector will be used to model the
individual impact from each treatment source to compile a list of 50 worst case events for each year of
meteorological data. The worst case events will be based on the operating hours 0600 to 1800 for each
year of meteorological data. The 50 highest 1-hour ADFs for each year of meteorological data within
sector 36C3A will then be used to compile a master list of 250 worst case events for the purpose of
calculating annual average impacts.
In the case of maximum impact receptor 36C3A, the annual average modeling will include sector 36C3A,
plus the sectors 36C3b, 36F3D, 36F3A, 36F30, 36F10B, and 36F10H. It is important to note the
selection of adjacent sectors will include adjacent 10 km sectors when the maximum 3 km sector occurs
on the outer boundary of the 3 km general grid. The OBODM "hourly source file" option will be used to
calculate annual average ADFs on the basis of worst case meteorological conditions for each source and
model type. The same procedure will be used for M-225 source impacts to general grid receptors.
A summary of the source parameters, treatment quantities and other assumptions that will be used in the
air dispersion modeling analysis for the M-136 and M-225 treatment units are presented in Sections 4.4.1
and 4.4.2, respectively.
4.4.1 M-136 Treatment Unit
M-136 is the primary open burning treatment unit at ATK. The M-136 treatment unit will conduct treatment
of 1.1 and 1.3 class waste and Category E wastes. Based on the maximum annual treatment quantities
041108/P 4.4-6
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
proposed in Tables 2-1 and 2-2, the M-136 units will treat 99 percent of the total ATK annual waste in
comparison to M-225.
4.4.1.1 M-136 Source Parameters
The air dispersion modeling analysis for the M-136 treatment unit will include the following four (4) source
groups:
• Source 1 - OB of 1.1, 1.3, and Category E waste at stations 1 through 12
• Source 2 - OB of 1.1, 1.3, and Category E waste at Station 13
• Source 3 - OB of 1.1 and 1.3 waste (including rocket motors) at Station 14
• Source 4 - OD of 1.1 and 1.3 waste at Stations 13 and 14 in a single area.
The proposed source parameters for the M-136 sources are given in Table 4-1.
4.4.1.2 Other Modeling Assumptions for M-136
OBODM will be setup to assume the following treatment activities at M-136:
• Modeled per event treatment quantities will be based on the quantities given in Table 2-1.
• Only one M-136 source will conduct treatment in a given hour.
• Modeling for each M-136 source will be based on worst-case meteorological conditions for all discrete
and maximum impact general grid receptors. The OBODM "hourly source file" option will be used to
process worst case meteorological conditions for each source and model type. The worst case
meteorological events will be selected from then new daily treatment time period 0600 to 1800, which
was recently approved by the UDSHW.
• Assume that all M-136 sources are at the same base elevation as BS 1-12, Elevation = 4,587 feet in
order to consolidate gravitational settling modeling due to the limited number of receptors that can be
evaluated per run of OBODM. The actual net elevation difference between the three M-136 treatment
locations is only 36 feet (11 meters). Therefore, this assumption is not expected to affect the
modeling results for M-136.
041108/P 4.4-7
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
Include all M-136 source groups in single OBODM run. Each source will have a separate coordinate
(x,y) location reflecting its relative position within M-136 and each source will be assigned to a source
group to give the individual contribution from each source to a receptor.
The four source groups for M-136 will include the following:
- Source 1 - Burn Stations 1, 2, 3, 4, 5, 6, 7, 8. 9, 10, 11, and 12 OB treatment
Source 2 - Burn Station 13 OB treatment
Source 3 - Burn Station 14 OB treatment
Source 4 - Burn Station 14 OD treatment
The burn pans used at M-136 Burn Stations 1-12 (Source 1) are not all the same size. Because
source group 1 represents a merger of Burn Stations 1-12, an average pan size was calculated
based on the existing burn pans sizes and the normal configuration of burn pans. The typical pan
sizes used at M-136 are 5'x 16', 8'x 20', and 8'x 8'. Currently, seventy percent of the trays are
5'x 16'. When they burn the trays at Source 1 (BS 1-12), they are usually placed in a long row of 12 -
14 trays in the row. When they burn the trays at Source 2 (BS 13), they typically use 3 small trays,
3'x 7', and an 8'x 8' and then a 6'x 6' that are essentially arranged in a rectangular configuration.
There are no burn pans at Source 3 (BS-14) or Source 4 (BS-14).
Based on the burn pan configurations describe above, ATK is proposing the following revised
dimensions for each M-136 source:
Source 1 - 224' x 5' (14, 5' x 16' trays in a row which is the maximum burn scenario for Source 1)
Source 2 - 17' x 7' (an area that includes 3 small trays, 3'x 7', and an 8'x 8' and then a 6'x 6',
which is the maximum burn scenario for Source 2)
Release height for OB treatment at all M-136 source groups is 1.0 meter.
OB source release quasi-continuous (volume source).
OD source release instantaneous (volume source).
041108/P 4.4-8
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
• Dispersion modeling types for M-136 will include the following:
Gas phase air concentrations
Particle phase air concentrations
Particle phase gravitational deposition
• Gas and particulate phase modeling will utilize a unit emission rate of 1.0 Ib./hr as recommended by
the HHRAP (USEPA, 2005).
• Particulate phase modeling will include particle size information to include gravitational settling (see
Section 4.5) as recommended by HHRAP guidance (USEPA, 2005).
4.4.2 M-225 Treatment Unit
The M-225 Unit will treat small amounts of 1.1 and 1.3 class waste and Category E waste. OB will be
conducted in burn pans. OD treatment of pure propellant will be conducted at one OD pit. OD treatment
consists of placing the waste material in a small, excavated pit that has a diameter of 1.5 meters. The
treatment pit is not covered with soil and is considered a surface detonation. Based on QD limitations,
open detonation may be performed above ground or underground in a hole or pit, depending on the item
to be detonated.
As shown in Figure 2-6, the M-225 burn pans and OD pit are located within a 200 foot x 500 foot
rectangular area. All M-225 treatment locations are within 60 meters of the center of this treatment area
and there are no significant changes in elevation. M-225 treatment activities at Source Groups 1 and 2
will be modeled separately for OB and OD treatment, respectively. The source parameters for M-225 OB
and OD treatment sources are summarized in Table 4-2.
4.4.2.1 M-225 Source Parameters
The air dispersion modeling analysis for the M-225 treatment unit will include the following two source
groups and waste categories:
• Source Group 1 - OB of 1.1, 1.3, and Category E wastes.
• Source Group 2 - OD of 1.1 and 1.3.wastes.
The proposed source parameters for the M-225 sources are given in Table 4-2.
041108/P 4.4-9
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
4.4.2.2 Other Modeling Assumptions for M-225
OBODM will be setup to assume the following about treatment activities at M-225:
• Modeled per event treatment quantities will be based on the quantities given in Table 2-2.
• Only one M-136 source will conduct treatment in a given hour.
• Modeling for each M-225 source will be based on worst-case meteorological conditions for all discrete
and maximum impact general grid receptors. The OBODM "hourly source file" option will be used to
process worst case meteorological conditions for each source and model type. The worst case
meteorological events will be selected from the new daily treatment time period 0600 to 1800, which
was recently approved by the UDSHW.
• Both sources (OB and OD) have the same coordinate and elevation; elevation = 4,597 feet above
mean sea level to consolidate gravitational settling modeling for both sources in a single model run.
• Include two M-225 source groups in single OBODM run. Each source group will have a separate
coordinate (x,y) location reflecting its relative position within M-225 and each source will be assigned
to a source group to give the individual contribution from each source to a receptor.
• The two source groups for M-225 will include the following:
- Source 1 - M-225 Burn Stations 1, 2, 3, 4, and 5 for OB treatment
Source 2 - Single OD treatment pit
• Each source configuration is based on historical treatment information:
- For OB at M225 Source 1, assume 5.18 m X 1.83 m
For OD at M225 Source 2, assume 1.5 meter diameter pit
• Release height for OB = 1.0 meter
• Release height for OD = 0 meters (ground level)
• OB source release quasi-continuous (volume source)
041108/P 4.4-10
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.4
JANUARY 2012
• OD source release instantaneous (volume source)
• Dispersion modeling types for M-225 will include the following:
Gas phase air concentrations
Particle phase air concentrations
Particle phase gravitational deposition
• Gas and particulate phase modeling will be conducted using a unit emission rate of 1.0 Ib./hr as
recommended by HHRA guidance (USEPA, 2005).
041108/P 4.4-11
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.5.4
JANUARY 2012
4.5.4 Flat and Complex Terrain Modeling
The Promontory facility is located in the Blue Spring Valley which is bounded on the east by the Blue
Spring Hills and on the west by Engineer Mountain and the Promontory Mountain ranges, respectively.
Within a 10 kilometer radius of the ATK facility, the terrain is characterized by topography that slopes
down from peak mountain elevations of approximately 6,900 feet above mean sea level (AMSL) to flat
terrain elevations of approximately 4,200 feet amsl. The M-136 and M-225 treatment units are located at
elevations of approximately 4,587 feet amsl and 4,597 feet amsl respectively.
OBODM will be used to assess the impact from ATK treatment operation to receptor locations in both flat
and complex terrain. A receptor location is defined as a flat terrain receptor if the receptor elevation is
equal to or less than the source elevation. A receptor location is defined as complex if the receptor
elevation is greater than the source elevation. As a result, the surrounding environment extending out to
10 kilometers from the ATK facility can be characterized by a combination of flat and complex terrain
relative to the elevation of the M-136 and M-225 treatment units.
OBODM has the capability to calculate downwind concentrations for both flat and complex terrain
receptors. However, in complex terrain mode, the model cannot be used when calculating concentration
with gravitational deposition occurring or gravitational deposition for particulates with appreciable settling
velocities. In this assessment, a particle size distribution has been assumed for the particulate and
deposition calculations. As a result, the OBODM complex terrain model will be used only to calculate gas
phase concentrations in this assessment.
041108/P 4.5.4-1
ATK DISPERSION MODEL PROTOCOL ADDENDUM
SECTION 4.9
JANUARY 2012
4.9 POST-PROCESSING ACTIVITIES
The output from OBODM output files will require post-processing in order to calculate receptor
concentrations and deposition values for all target analytes identified in Tables 3-5 and 3-6. The post-
process activities to be used are summarized below.
Determine the location and value of the maximum. 1-hour and annual average air dispersion factors
for on-site and off-site receptors in flat terrain and complex terrain from the general receptor grids,
and all discrete receptors for each type of dispersion modeling and year of meteorological data.
Summarize the results in an Excel workbook.
Calculate the 1-hour and annual average pollutant concentrations and deposition values. The
individual pollutant air concentrations will be calculated by multiplying the maximum 1-hour or annual
air dispersion factor (pg/m^-lb/hr) x the pollutant specific emission factor (Ib./lb.) x treatment quantity
per hour (Ib./hr) = pg/m^. Dry deposition (|jg/m^) will be calculated by multiply the OBODM
concentration (|jg/m^) x the assumed settling velocity (m/sec).
Convert 1-hour concentrations into 8-hour and 24-hour concentrations for comparison analysis to
National Ambient Air Quality Standards (NAAQS) short-term standards, OSHA exposure criteria, and
Toxic Screening Levels (TSLs) that have been established by Utah Department of Air Quality. The
1-hour air concentrations will be converted to longer averaging periods using USEPA guidance
identified in the document Screening Procedures for Estimating the Air Quality impact of Stationary
Sources (USEPA, 1995).
Format OBODM modeling results for input Into the IRAP-h and EcoView risk assessment models.
The modeling report will include figures showing iso-contour plots of air dispersion factors (ADFs)
associated with gas modeling (|jg/m ^-Ib/hr), particulate modeling (|jg/m ^-Ib/hr), and deposition
modeling (|jg/m^-lb/hr) in flat and complex terrain for the general network receptor grid.
041108/P 4.9-1
ATK DISPERSION MODEL PROTOCOL ADDENWM
TABLE 4-1
JANUARY 2012
TABLE 4-1
M-136 SOURCE PARAMETERS
ATK PROMONTORY, UTAH
Source Parameter Source 1 - OB Source 2 - OB Source 3 - OB Source 3 - OB Source 4 - OD
Treatment Operations OB in Pans
Burn Stations 1-12
OB in Pans
Burn Station 13
OB in Pans
Burn Station 14
OB in Pans
Burn Station 14
OD (Uncovered)
Burn Station 14
Location Center of Burn
Station
Center of Burn
Station
Center of Burn
Station
Center of Burn
Station
Center of Burn
Station
Number of sources 1 1 1 1 1
Source Release Type Quasi-continuous Quasi-continuous Quasi-continuous Quasi-continuous Instantaneous
Burn/Release Duration
(OBODM calculated based
on source type)
300 seconds 300 seconds 300 seconds 300 seconds Instantaneous
Source Configuration Volume Volume Volume Volume Volume
Effective Release Height
(m) 1 meter 1 meter 1 meter 1 meter Ground level
1.3 waste heat content* 1,471 calories/gram 1,471 calories/gram 1,471 calories/gram 1,471 calories/gram 1,471 calories/gram
Number of treatment
events per year See Table 2-1 See Table 2-1 See Table 2-1 See Table 2-1 See Table 2-1
Unit emission factor 1.0 1.0 1.0 1.0 1.0
Modeled Per Event
Treatment Quantity See Table 2-1 See Table 2-1 See Table 2-1 See Table 2-1 See Table 2-1
Annual Maximum
Treatment Quantity See Table 2-1 See Table 2-1 See Table 2-1 See Table 2-1 See Table 2-1
• ATK has agreed to use 1.3 OBODi emission factors and 1.3 heat content values for all M-136 modeled sources.
ATK DISPERSION MODEL PROTOCOL ADDENUUM
TABLE 4-1
JANUARY 2012
TABLE 4-2
M-225 SOURCE PARAMETERS
ATK PROMONTORY, UTAH
Source Parameter Source 1 - OB Source 2 - OD
Treatment Operations OB in Pans OD (Uncovered)
Location Center of M-225 Unit Center of M-225 Unit
Number of sources 1 1
Source Release Type Quasi-continuous Instantaneous,
Burn/Release Duration
(OBODM calculated based
on source type)
300 seconds Instantaneous
Source Configuration Volume Volume
Effective Release Height (m) 1 meter Ground level
Source Diameter NA 1.5 meters
1.3 waste heat content 1,471 cal/g 1,471 cal/g
Number of treatment events
(per day) See Table 2-2 See Table 2-2
Unit emission factor 1.0 1.0
Modeled Per Event
Treatment Quantity See Table 2-2 See Table 2-2
Annual Maximum
Treatment Quantity See Table 2-2 See Table 2-2
• ATK has agreed to use 1.3 OBODi emission factors and 1.3 heat content values for all M-225 modeled sources.
TABLE 4-1A
M-136 MAXIMUM GENERAL GRID ONSITE/OFFSITE RECEPTORS AND GRID SECTORS
Maximum Short Term Impact Offsite Receptor Maximum Short Term Impact Onsite Receptor
Source Easting Northing Sector Surrounding Sectors
Within 1 KM of Max Source Easting Northing Sector Surrounding Sectors
Within 1 KM of Max
1 - Gas 378172 4618166 36G3A 36C3B, 36F3D, 36F3A,
36F30, 36F10B, 36F10H 1 - Gas 380472 4615766 36F3H
36F3F, 36F3G, 36C3M,
36C30
2 - Gas 378772 4617766 36C3A 36C3B, 36F3D, 36F3A,
36F30, 36F10B 2 - Gas 380772 4615766 36F3H
36F3F, 36F36, 36C3M,
36C30
3 - Gas 378472 4618366 36C3A 36C3B, 36F3D, 36F3A,
36F30, 36F10B, 36F10H 3 - Gas 380772 4615766 36F3H
36F3F, 36F3G, 36C3M,
36C30
4 - Gas 378772 4616666 36C3C 36C3B, 36F3D, 36F3E,
36F3P, 36C3D, 36C3E 4 - Gas 380672 4615866 36F3H
36F3F, 36F3G, 36C3M,
36C30
1 - Part 379872 4615966 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F
1 - Part 380472 4615766 36F3H
36F3F, 36F3G, 36C3M,
36C30
2- Part 379872 4615666 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F, 36F3I
2 - Part 380772 4615766 36F3H
36F3F, 36F3G, 36C3M,
36C30
3- Part 379872 4616066 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F, 36C3WW
3 - Part 380772 4615766 36F3H
36F3F, 36F3G, 36C3M,
36C30
4 - Part 379872 4616166 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F
4 - Part 380672 4615866 36F3H
36F3F, 36F3G, 36C3M,
36C30
1 - Dep 379572 4616366 36F3F
36F3G, 36F3H, 36F3E,
36C3WW, 36C3C, 36C3D,
36C3E, 36C3F
1 - Dep 380472 4615066 36F3H
36F3F, 36F3H, 36C3M,
36C30,36F3E
2 - Dep 379572 4615060 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F
2 - Dep 380672 4615266 36F3G
36F3F, 36F3G, 36C3M,
36C30
3 - Dep 379572 4616066 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F, 36C3WW
3 - Dep 380772 4615466 36F3G
36F3F, 36F3G, 36C3M,
36C30
4 - Dep 379572 4615060 36F3F
36F3G, 36F3H, 36F3E,
36F3P, 36C3D, 36C3E,
36C3F
4 - Dep 380672 4615066 36F3H
36F3F, 36F3G, 36C3M,
36C30
' The maximum offsite and onsite receptors in this table represent the maximum Impact location determine with the general grid receptor networl<.
TABLE 4-2A
M-225
MAXIMUM GENEFIAL GRID ONSITE/OFFSITE RECEPTORS AND GRID SECTORS
Maximum Short Term Impact Offsite Receptor* Maximum Short Term Impact Onsite Receptor*
Source Easting Northing Sector Surrounding Sectors Within
1 KM of Max Source Easting Northing Sector Surrounding Sectors Within
1 KM of Max
1 - Gas 395669 4604980 25010 E 25C10I, 25F10H 1 - Gas 385669 4610080 25C3I 25C3G, 25C3F,25C3E, 25C3J,
25C3H
2 - Gas 387169 4612480 25C30 25C3D, 25C3L,
25C3C,25C10D, 25C10B 2 - Gas 385669 4610080 25C3I 25C3G, 25C3F,25C3E, 25C3J,
25C3H
1 - Part 387469 4610080 25F3H
25C3M, 25F3I, 25F3G,
25F3E, 25F3F, 25C3I,
25C3H
1 - Part 386669 4609680 25F3F 25C3H, 25C3I, 25C3J, 25C3K,
25F3D, 25F3E, 25F3H
2- Part 387669 4608580 25F3M 25F3L, 25F3N, 25F10J,
25F10I 2-Part 386669 4609680 25F3F 25C3H, 25C3I, 25C3J, 25C3K,
25F3D, 25F3E, 25F3H
1 - Dep 367469 4610080 25F3H
25C3M, 25F3I, 25F3G,
25F3E, 25F3F, 25C3I,
25C3H
1 - Dep 386769 4609480 25F3E
25F3G, 25F3H, 25F3F,
25C3I,25C3J, 25C3K, 25F3D,
25F3E
2 - Dep 387469 4610080 25F3H
25C3M, 25F3I, 25F3G,
25F3E, 25F3F, 25C3I,
25C3H
2-Dep 386889 4609480 25F3E
25F36, 25F3H, 25F3F,
25C3I,25C3J, 25C3K, 25F3D,
25F3E
' The maximum offsite and onsite receptors In this table represent the maximum impact location determine with the general grid receptor network.
ATK DISPERSION MODEL PROTOCOL ADDENDUM
REFERENCES
JANUARY 2012
REFERENCES
Auer. 1978. "Correlation of Land Use and Cover with Meteorological Anomalies." Journal of Applied
Meteorology, Volume 17, May 1978.
Bulletin of the American Meteorological Society (AMS). 2002. "A Climatological Study of Thermally
Driven Wind Systems of the U.S. Intermountain West". Jebb Q. Stewart, C. David Whiteman,
W. James Steenburgh, and Xindi Bian. Volume 83, Number 5, Pages 699-708, May 2002.
DOE, 1984. The Toxicological Effects of Non-nuclear Pollutants, Section 17-17, Particulates, Department
of Energy Publication "Atmospheric Science and Power Production, Office of Scientific and Technical
Information, United States Department of Energy.
Hanna, S.R., and P.J. Davis (1987): Guidelines for Use of Vapor Cloud Dispersion Models, New York:
Center for Chemical Process Safety, American Society of Chemical Engineers.
Lakes Environmental, 2003a. "IRAP-h View Industrial Risk Assessment Program for Human Health,
Lakes Environmental, Ontario, Canada.
Lakes Environmental, 2003b. "EcoRisk View Ecological Risk Assessment Program". Lakes
Environmental, Ontario, Canada.
NASA, 1973. "NAS/VMSFC Multilayer Diffusion Models and Computer Program for Operational
Prediction of Toxic Fuel Hazards", Dumbald, R.K., Bjorklund, J.R., H.E. Cramer Company for the National
Aeronautics and Space Administration, Marshall Space Flight Center, Alabama.
Kramer, H. E., 1997. "Open Burn/Open Detonation Dispersion Model (OBODM) User's Guide", H. E.
Cramer Company, Sandy, Utah 84091-0411, and West Desert Test Center, U.S. Army Dugway Proving
Ground, Dugway, Utah, DPG Document No. DPG-TR-96-008a, July 1997.
Radian International LLC, 1998. Draft Sampling Results for Alliant "Slum" Emission Characterization,
Volumes 1, 2, and 3; Prepared for U.S. Army Dugway Proving Ground Dugway, Utah, March 1998.
041108/P R-1
ATK DISPERSION MODEL PROTOCOL ADDENDUM
REFERENCES
JANUARY 2012
Stewart, J. Q., el al. "A Climatological Study of Thermally Driven Wind Systems of the United States
Intermountain West", Bulletin of the American Meteorological Society, Volume 83, Number 5, Page 669,
May 2002.
Tetra Tech (Tt), 2011. "Preliminary Air Dispersion Modeling Report for Open Burn and Open Detonation
Treatment Units at ATK Launch Systems, Brigham City, Utah, October, 2011.
URS Corporation, 2005. "Human Health Risk Assessment in Support of Alliant Techsystems' Bacchus
Works, RCRA Subpart X Activities", Magna, Utah, Final Report, September 2005.
URS, 2008. Sampling Results for USAEC Phase IX Emission Characterization of Exploding Ordnance
and Smoke/Pyrotechnics, URS Group, Inc., Oak Ridge, Tennessee, June 2008.
U.S. Army. Munitions Items Disposition Action System (MIDAS) Database System, website,
https://midas.dac.army.mil/, U.S. Army Defense Ammunition Center, McAlester, Oklahoma.
U.S. Army, January 1992. "Development of Methodology and Technology for Identifying and Quantifying
Emission Products from Open Burning and Open Detonation Thermal Treatment Methods". U.S. Army
Armament, Munitions and Chemicals Command, Rock Island, Illinois.
U.S. Army, 2006. Detailed Test Plan for Phase IX Emission Characterization of Burning
Smoke/Pyrotechnics and Propellants, West Desert Test Center, U.S. Army Dugway Proving Ground,
Utah, April 2006.
U.S. Army, 2009. Sampling Results for Emission Characterization of Open Burning Waste Propellant
Materials, Volume I - Summary Report, Prepared for ATK Launch Systems, Promontory, Utah, Prepared
by U.S. Army Dugway Proving Ground, U.S. Army, 2009.
U.S. Army Defense Ammunition Center (DAC), 2009. Munitions Items Disposition Action System
(MIDAS) database; DAC McAlester, OK.
USEPA, 1987. "Ambient Monitoring Guidance for Prevention of Significant Deterioration (PSD), Office of
Air Quality Planning and Standards, Research Triangle Park, N.C. EPA-450/4-87-007, May, 1987,
041108/P R-2
ATK DISPERSION MODEL PROTOCOL ADDENDUM
REFERENCES
JANUARY 2012
USEPA, 1992. Technical Memorandum: "Procedures for Substituting Values for Missing NWS
Meteorological Data for Use in Regulatory Air Quality Models". Office of Air Quality Planning, and
Standards, Research Triangle Park, North Carolina, July 7, 1992.
USEPA, 1995a. "User's Guide for The Industrial Source Complex Dispersion Models, Volumes I and H".
Office of Air Quality Planning, and Standards. Emissions, Monitoring, and Analysis Division, Research
Triangle Park, North Carolina. EPA-454/B-95-00Sa.
USEPA, 1995b. "PCRAMMET User's Guide." Office of Air Quality Planning and Standards. Emissions,
Monitoring, and Analysis Division, Research Triangle Park, North Carolina. October 1995.
USEPA, 1997. "Procedures for Preparing Emission Factor Documents", Office of Air Quality Planning
and Standards, Research Triangle Park, North Carolina. EPA-454/R-95-015, November 1997.
USEPA, 2000. "Meteorological Monitoring Guidance for Regulatory Modeling Applications". EPA-454/R-
99-005, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina.
USEPA, 2005. "Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities",
Office of Solid Waste and Emergency Response, EPA530-D-98-001 A, September 2005.
USEPA, 2005. "Guideline on Air Quality Models", Title 40, Code of Federal Regulations Part 51,
Appendix W. November 2005.
USEPA, 2009. AP 42, Fifth Edition, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary
Point and Area Sources, Volume I, Chapter 15: Ordnance Detonation, Section 15.3.22, Pages 15.3-99 to
15.3-102.
041108/P R-3