DSHW-2012-002209 - 0901a0688031f272

State of Utah
GARY HERBERT
Governor
GREG BELL
Lieutenant Governor
George E. Gooch
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
March 21,2012
Acting Director, Environmental Services
ATK Launch Systems -Promontory
P.O. Box 707
Brigham City, UT 84302-0707
Solid and Hazardous Waste Control Board
Kevin Murray, Chair
Kory Coleman, Vice-Chair
Brian E. Brower
Scott Bruce
Jeff Coombs, MPH, LEHS
R. Ryan Dupont, Ph.D.
Larry A. Ellertson
Brett Mickelson
Brad Mertz
Gary Mossor
Dennis Riding
Dwayne Woolley
Amanda Smith
Scott T. Anderson
Executive Secretary
RE: ATK's Response to Comments on the Air Dispersion Modeling Protocol Addendum
UTD009081357
Dear Mr. Gooch:
The Division of Solid and Hazardous Waste has completed its review of ATK's response to
comments (dated March 7, 2012) on the Air Dispersion Modeling Protocol Addendum that was
submitted to our office on February 2, 2012. The Division requested that ATK submit the
Protocol Addendum in order to outline the changes that will be made in the next iteration of the
Air Dispersion Model. Changes are being made to the model in order to reflect the modifications
that have been proposed for operations at the burn grounds and to generate more realistic
modeling results that will be used in the Human Health and Ecological Risk Assessments.
ATK's protocol addendum and the responses to the comments that were provided by the Division
and its contractor TechLaw Inc., collectively address our concerns on the next iteration ofthe air
dispersion modeling. However, there is one issue that the Division would like clarified in the
protocol addendum regarding the evaluation of particle-bound constituents. Please modify
Section 4.4.1.2 (Other Modeling Assumptions for M-136) and Section 4.4.2.2 (Other Modeling
Assumptions for M-225) by adding the following statement as was discussed with you on March
14, 2012:
"ATK does not plan to conduct model calculations for particle-bound analysis for M-136 (and M-
225) because OBODM does not contain an algorithm for particle-bound calculations. However,
A TK is proposing to assume that OBODM calculated particulate concentrations are equal to
particle-bound concentrations and modeled particulate gravitational deposition is equal to particle-
bound gravitational deposition. The values ofFv, fraction ofCOPC concentration in the vapor
DSHW -2012-002209
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
WUTW.deq.utah.gav
Printed on 100% recycled paper
phase, found in the HHRAP Companion Data Base will be used to determine the amount of
particle-bound constituent that behaves as a gas and (1-Fv) will be used to determine the amount
that behaves as particulate."
With the addition of this approach for evaluating particle-bound constituents, the Air Dispersion
Modeling Protocol Addendum is hereby approved. If you have any questions, please contact Jeff
Vandel at [phone].
~· -£)
Scott T. Anderson, Executive Secretary
Utah Solid and Hazardous Waste Control Board
STA/JV/tjm
c: Paul V. Hancock, ATK Launch Systems
Blair Palmer, ATK Launch Systems
Cheryl Overstreet, US EPA Region VIII
DSHW -2012-002209
2