DSHW-2012-012481 - 0901a0688030f827

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
April 2, 2012
Acting Director, Environmental Services
ATK Launch Systems-Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: EPA Region VIII Lead Compliance Evaluation Inspection
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
ATK Launch Systems-Promontory Facility, EPA I.D. #UTD009081357
Dear Mr. Gooch:
On January 31 through February 2, 2012, David Duster and Terry Brown of the EPA Region VIII
staff conducted a RCRA Compliance Evaluation Inspection (CEI) at the ATK Launch Systems -
Promontory.facility. Jeff Vandel of my staff accompanied them on the CEI. The inspection
report is enclosed with this letter.
If you have any questions regarding the content of this report, please contact Jeff Vandel at (801)
536-0257 or David Duster at [phone].
Sincerely,
~
Scott T. Anderson, Director
Utah Division of Solid and Hazardous Waste
STA/JV/tjm
Enclosure
c: David Duster, USEPA Region 8 (cover letter only)
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
DSW-2012-002225
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]
www.deq.utah.gov
Printed on 100% recycled paper
U.S. EPA Region 8
Enforcement Compliance & Environmental Justice Division
RCRA Compliance Evaluation Report
Date of Inspection:
Facilitv Name:
Location:
Mailing Address:
Facility Contact:
Facility Phone No.:
Email Address:
Notification Status:
EPA ID Number:
Applicable Regulations:
Type of Inspection:
Time of Arrival:
Time of Departure:
Participants:
January 31-February 2, 2012
ATK Launch Systems-Promontory Facility
30 miles north of Brigham City, Box Elder County
P.O. Box 707
Brigham City, UT 84302
George Gooch
Director, Environmental Services
801-251-2664
George. [e-mail]
LQG, TSD
UTD0090813 57
Utah Administrative Code, R315
Federal-40 CFR Parts 260-270
Compliance Evaluation Inspection (CEI)
09:30 hours on January 31, 2012
12:19 hours on February 2, 2012
David Duster, EPA Region 8
Terry Brown, EPA Region 8
JeffVandel, UDEQ
Dave Go sen, A TK
George Gooch, A TK
Blair Palmer, A TK
Troy Wadsworth, A TK
Paul Hancock, A TK
Rafia Ghatala, A TK
Dee Heyrend, A TK
A TK Launch Systems
Promontory, Utah
Introduction
ATK Launch Systems
Promontory, Utah
UTD009081357
RCRA Compliance Evaluation Inspection
On January 31 -February 2, 2012, Mr. Terry Brown and I performed an unannounced Resource
Conservation Recovery Act (RCRA) compliance evaluation inspection (CEI) at the A TK Launch
Systems Promontory facility located at 16700 W. Highway 83 in Brigham, Utah. The purpose ofthe
visit was to assess facility compliance with the conditions of A TK's RCRA Subtitle C permit allowing
the facility to store and open burn reactive (D003) hazardous waste. We were accompanied by Mr. Jeff
Vande! of the Utah Department of Environmental Quality, Division of Solid and Hazardous Waste.
Facility and Hazardous Waste Management Overview
A TK manufactures solid rocket motors for the Space Shuttle and Minuteman missiles, D-5 missile
components, commercial launch (or Castor) motors, advanced flares and pyrotechnics. A TK generates
reactive hazardous wastes, e.g., propellants, as part of manufacturing activities. ATK's operations
include propellant demilitarization and reclamation. In addition, A TK operates as a commercial
operation and is capable of storing and treating off-site generated reactive hazardous wastes.
The A TK Promontory facility is located in a remote area of west Box Elder County, Utah,
approximately 30 miles northwest of Brigham City, and approximately 11 miles north ofthe Great Salt
Lake. The facility was purchased by Thiokol in 1956, with the exception of a 1 ,500-acre tract that was
sold to the U.S. Air Force in 1958 and then repurchased by Thiokol in 1995. The facility has been held
in its entirety since the most recent purchase. Alliant Techsystems (ATK) purchased Thiokol in 2001. In
2001, the facility was renamed to ATK Launch Systems Inc.
On September 30, 2008, ATK was reissued a RCRA operating permit to store hazardous waste. This
permit was modified in September 2010. Under this modification, A TK was permitted to treat, through
open burning and open detonation, hazardous waste that exhibits the characteristics of reactivity
(reactive waste). This includes wastes generated both on-site and waste received from off-site sources.
The operating permit regulates the storage and the open burning of reactive wastes. Prior to permit
issuance, A TK was allowed to open burn reactive wastes through RCRA interim status provisions. In
September 2007, A TK was issued a RCRA Post-Closure Permit which provides the cleanup and
monitoring of hazardous waste management units and remediation of contaminated solid waste
management units through RCRA Corrective Action mechanisms.
ATK Launch Systems conducts thermal treatment of reactive hazardous wastes at two treatment units:
(1) the main facility, M-136, located centrally to the two main manufacturing sites; and (2) M-225
located in a remote development location called Plant III. M-136 is the primary treatment area for
conducting open burning at the Promontory facility. Open detonation is also conducted at M -13 6 which
is a secured fenced facility within the main facility fence. Nearly all of the reactive wastes are reactive
due the presence of propellants and explosives. Reactive wastes also include materials such as rags,
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A TK Launch Systems
Promontory, Utah
gloves and other personal protective equipment, plastics, rubber and paper contaminated with explosive
materials during the manufacturing process.
The M-225 treatment area receives small amounts of the reactive hazardous waste materials from the Plant Ill
propellant development area. The M-225 treatment unit is surrounded with an 8-foot high chain link fence. The
waste materials are treated via open burning.
Inspection Narrative
The EPA inspection team arrived at the facility, unannounced, at approximately 09:30 hours on January
31, 2012. We were met by ATK's Current Environmental Director, Mr. George Gooch, who served as
our point of contact during the inspection. Mr. Brown and I presented our credentials to Mr. Gooch. Mr.
Gooch notified ATK representatives Mr. Dave Gosen (Previous Director), Mr. Blair Palmer, Mr. Paul
Hancock, Mr. He Heyrend, Ms. Raia Ghatala, and Mr. Troy Wadsworth of our inspection. These
individuals also participated in the inspection. I informed the ATK representatives of the purpose and
scope of the inspection. Upon my request, the A TK representatives provided us with a brief background
on the type of activities conducted at the facility described above.
After breaking for lunch, Mr. Brown, Mr. Vandel and I were escorted on a general tour of the facility.
During the tour we visited the Test Area, Plant III, South Plant and the North Plant. At the Test Area, we
visited the two static test sites. At Plant III we visited the M-225 thermal treatment site. The M-225 site
receives wastes from the Plant III development area. Three 15-pound bags labeled as containing D003
reactive were stored at the site. According to plant operator, Mr. Dee Heyrend, the bags contain 2
pounds of propellant and 13 pounds of D003 contaminated debris such as rags, gloves, personal
protective equipment, plastics, rubber and paper. The current permit limits open burning at M-225 to
4,500 pounds per day. We returned to the Administration Building at approximately 15:00 hours. I
provided Mr. Gooch with a list of requested records and information tor review during the remainder of
the inspection. This list also included a request tor records of documentation required under the permit
related to open burning at M-136 for dates that the EPA Region 8 received complaints from a nearby
resident.
During the morning of February 1, 2012, I discussed with ATK personnel the specific conditions
required under their RCRA Subtitle C permit. In particular, we discussed facility compliance with the
specific conditions identified under Module IV (Thermal Treatment of Energetic Wastes), Attachment 1
(Waste Analysis Plan), Attachment 2 (Inspection Schedules and Procedure), Attachment 9 (Container
Management) and Attachment 11 (M-136 and M-225 Thermal Treatment Operations) of their permit.
In the afternoon, the EPA inspection team visited M-136 to observe facility compliance with open
burning and hazardous waste management requirements set forth in their permit. The facility recently
received a shipment of D003 reactive hazardous waste from the A TK Bacchus facility located near Salt
Lake City. The containers were properly labeled. Many of the drums were labeled as containing muslin
bags. According to Mr. Gooch, these bags might have been used to hold propellant. I also visited the
permitted hazardous waste storage area. All of the containers holding hazardous waste were closed, in
good condition and properly segregated. There was adequate aisle space separating the rows of
containers.
As part of this visit, we viewed a powerpoint presentation describing the reclamation and treatment of
propellant contained in the minuteman rocket motors. I also reviewed facility inspection and treatment
documentation. A TK utilizes an electronic bar scanning and recordkeeping system that tracks the
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A TK Launch Systems
Promontory, Utah
location of each container and identifies the container's contents. The facility also records the wind
direction and speed, clearing index and bum station where treatment occurred. No deficiencies were
noted. Following this review, the EPA inspection team observed the treatment of a rocket igniter. The
protocol is that once the waste is in place, an igniter is attached to the firing system by connecting the
lead wire from the initiating device to the firing stanchion. When necessary, additional burn enhancers
such as diesel, wood (pallets) or propellant are added. After ensuring that the treatment area has been
evacuated, the burning ground operators fire the igniter. Two operators are required for this operation.
The treatment of rocket motor igniter observed during our visit appeared to be consistent with the
requirements of ATK's permit.
The inspection concluded on the morning of Thursday, February 2, 2012. During this visit, we discussed
existing A TK contracts with the Air Force for refurbishing and demilitarization of the Minuteman III
missile, ODOBi (open detonation open burned improved) air emission testing used in the risk
assessment and recent ground water monitoring results.
Minuteman III Contracts. According to A TK personnel, A TK recently completed a ten-year contract
to refurbish the Minuteman III missile. This effort entails reclaiming ammonia perchlorate from the 1st -
and 2nd -stage motors and open burning the third stage motor. A TK is currently treating additional rocket
motors on a new contract that is in the initial stages.
ODOBi Air Emission Testing. Air emission factors developed for the facility risk assessment were
derived based on tests conducted using the ODOBi testing facility located on Dugway Proving Grounds.
Tests were run based on three scenarios of different types of waste mixtures: 100 percent propellant; 85
percent propellant and 15 percent contaminated debris; and 65 percent propellant and 35 percent
contaminated debris. These factors will be used in an air dispersion model that will estimate exposure to
workers and off-site residents.
Groundwater Corrective Action. Recent ground water monitoring results indicate that concentrations
of perchlorate are increasing in some of the monitoring wells installed downgradient ofthe M-136 area.
According to Mr. Hancock the increase in concentration levels may be attributed to a higher amount of
rainfall last year. He also stated that there is no evidence that current treatment activities contribute to
additional ground water contamination. The cause of the observed contamination is attributed to land
disposal in an unlined impoundment of perchlorate-contaminated wastewater prior to the enactment of
RCRA land ban restrictions.
At approximately 12:00 hours, I provided ATK representatives with the findings of my inspection
detailed in the Areas of Concern section below.
Areas of Concern
1. The facility appears to be conducting treatment of reactive wastes through open burning and
open detonation in compliance with the conditions of their permit.
2. A concerned citizen provided EPA with a photograph showing a plume of smoke. The date of
the photograph was November 25, 2011. The citizen was later treated for an injury to eyes and
lungs. The citizen resides east of the ATK facility. Information provided by ATK indicates that
approximately 11,476.5 pounds of waste was burned on November 25, 2011. The wind direction
for the burn was to the northeast. The potential exists that the smoke in the November 251h
photograph originated from the open burning at the M -136 facility during that same day. In
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A TK Launch Systems
Promontory, Utah
order to ensure no negative impacts on the surrounding community ATK needs to complete the
required risk assessment as well as evaluate operations at A TK that can minimize the migration
of constituents off-site.
3. ATK should consider conducting smaller, more frequent burns to reduce potential off-site
impact. A TK representatives agreed with this comment and are modeling potential impacts of
smaller burns in their risk assessment.
4. A TK should implement pollution prevention measures at the Promontory and Bacchus facilities
to reduce the amount of material burned at the facility. These measures could include changes in
propellant management or implementing decontamination procedures to reduce the amount of
contaminated material burned. Open burning should be viewed as the least preferable option to
source reduction, reuse or potentially some other decontamination or deactivation options.
Prepared by:
David Dus!Jdnspect(?~ Date
U.S. EPA Region VIII
RCRA Technical Enforcement Program
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