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Home My WebLink AboutDSHW-2012-013193 - 0901a068802d670aDepartment of Environmental Quality State of Utah Amanda Smith Executive Director GARY HERBERT Governor DIVISION OF SOLID AND HAZARDOUS WASTE GREG BELL Lieutenant Governor Robert Ingersoll, Director Environmental Services Scott T. Anderson Director ATK Launch Systems-Promontory P.O. Box 707 Brigham City, UT 84302-0707 May 29,2012 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 GaryMossor Dennis Riding Dwayne Woolley Amanda Smith Scott T. Anderson Executive Secretary RE: Preliminary Air Dispersion Modeling Draft Report for Open Bum and Open Detonation Treatment Units, March 23, 2012 ATK Launch Systems-Promontory Facility UTD009081357 Dear Mr. Ingersoll: The Division of Solid and Hazardous Waste, with the assistance ofTechLaw, Inc. and EPA Region VIII, has completed its review of ATK's Preliminary Air Dispersion Modeling Draft Report (dated March 23, 2012). Several significant problems were identified with how a portion of the modeling was conducted and in the calculations that were performed for determining contaminant concentrations. These problems, which have been discussed with A TK, have resulted in substantial errors in the modeling results. In addition, there are a number of other more minor issues with the modeling report that ATK needs to address. The comments that were generated from our review of the modeling report are enclosed with this letter. Please provide responses to these comments within 10 days ofthe date ofthis correspondence. If you have any questions, please contact JeffVandel at (801) 536-0257. cott . derson, Director Division of Solid and Hazardous Waste STA/JV/tjm Enclosure DSHW-2012-003358 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4414 www.deq.utah.goo Printed on I 00% recycled paper c: Paul V. Hancock, ATK Launch Systems Blair Palmer, ATK Launch Systems Cheryl Overstreet, US EPA Region VIII Grant Koford, EHS, Environmental Health Director, Bear River Health Department DSHIW-2012-003358 General Comments Utah Division of Solid ofHazardous Waste Comments Air Dispersion Modeling Assessment Draft Report Open Burn and Open Detonation Treatment Units A TK Launch Systems, Inc., Promontory Facility 1. ATK Launch Systems Revised Preliminary Air-Dispersion Modeling Assessment Draft Report for Open Burn and Open Detonation Treatment Units, Appendices D and E In reviewing the OBODM input files for annual averages at Adams Ranch, two issues were noted that impact the values that should be generated for comparison to annual NAAQS and used in the risk assessment. First, ATK did not generate the annual average of peak concentrations for use in the risk assessment. The files indicate that only the annual time average was generated. The Division prefers the more conservative annual average of peak concentrations be used in risk-based analyses. The second issue involves the specification of Concentration Averaging Time in OBODM's first Control/Print Options menu. ATK has specified this parameter as 8760 hours, presumably in reflection of the number of hours in a year. However, Appendix A, OBODM Menus, of Volume 1 of the OBODM Users Guide states that the Time-Average Concentration represents a concentration average over a user-specified time interval that should be less than or equal to 3600 seconds (i.e., 1 hour). In fact, when ATK's annual average input files are loaded into OBODM, the value of 8760 hours for Concentration Averaging Time is flagged by a dialog box that states: "Warning, data value 8760.0 is questionable." While the OBODM Users Guide recommends the value of this parameter be less than or equal to 3600 seconds, setting its value to 600 seconds, or ten minutes (the recommended value for the measurement time for the standard deviation of the wind direction angle entered by the user in OBODM's meteorologicaldata menus) results in annual time-average concentrations similar to the values obtained for annual average peak concentrations. This occurs because the measurement time parameter is considered in estimating the value of dispersion coefficients. Thus, many air dispersion modeling references recommend setting the value of the averaging time parameter equal to or close to the value of the measurement time for the standard __ deviation of the wind direction angle. Please revise the air modeling files for annual averages to ensure the annual average modeling runs generate annual average peak concentrations for use in subsequent risk-based analyses. The currently modeled annual time-average concentrations are too low for this application and were generated with a suspect parameter value. Further, the annual average air modeling should be repeated using an appropriate value for the Concentration Averaging Time. As discussed during a conference call on May 2, 2012, it is recommended that a value of 3600 seconds be entered for the Concentration Averaging Time in OBODM's first Control/Print Operations menu. DSHIW -2012-003358 2. ATK Launch Systems Revised Preliminary Air Dispersion Modeling Assessment Draft Report for Open Burn and Open Detonation Treatment Units, Section 3.0, Air Dispersion Modeling Results, and Appendices D, E, G, H, J, and L OBODM modeling was performed for unitized emissions so that a single modeling result can be applied to all constituents emitted from the modeled treatment process (i.e., open burning, open detonation). This is analogous to running the ISC model or AERMOD using a unit emission rate. One of the OBODM source menus allows the user to input either the pounds of constituent emitted and pounds of waste being treated or the fraction of the plume consisting of the constituent being modeled. Unitized results are obtained by specifying 1.0 as the fraction of the plume consisting of the constituent being modeled. This means that the unitized modeling results will represent the total mass ,of all constituents emitted during treatment per unit of plume volume (e.g., f!gwaste stream emissionslm3). Thus, to obtain the concentration of a specific constituent, the modeling result must be multiplied by the fraction of the total plume represented by the constituent of interest. This fraction is represented by the constituent- specific emission factor. Thus, the specific air concentration ofPM10 would be calculated as the product of the emission factor for PM10 (EFPMIO in micrograms ofPM10 per micrograms of waste stream treated) and the unitized air concentration dispersion factor for particulates (DFparticle in f!gwaste stream emissionsfm3): As discussed during a conference call on May 2, 2012, ATK used the following formula to calculate the concentration ofPM10 in air: :lMlO = EFPMlO (f!gPMIOemitted/) x Mass of Treated per hour (/hr) X DFparticle (f!gwastestream emissionsfm3). Thus, it appears that A TK' s approach results in incorrect units for constituent-specific air concentration (i.e., (f!gPMIO emitted·f!gwaste stream emissions)/(hr·m3)) and an overestimate of its magnitude by a factor equal to the assumed constituent emission rate. Please review the calculations of all constituent-specific air concentrations contained in the air modeling report to ensure that the correct value of air concentration has been compared to the appropriate NAAQS and TSLs. 3. ATK Launch Systems Revised Preliminary Air Dispersion Modeling Assessment Draft Report for Open Burn and Open Detonation Treatment Units, Tables 3-1 through 3-17 Tables 3-1 through 3-17 define one-hour CO NAAQS as 10,000 f!g/m3 and eight-hour CO NAAQS as 40,000 f!g/m3. These are reversed; 40 CFR 50.8 defines the one-hour CO NAAQS as "35 parts per million (40 milligrams per cubic meter) for a one-hour average" and the eight- hour NAAQS as "9 parts per million (10 milligrams per cubic meter) for an eight-hour average concentration." Some or all of the one-hour CO NAAQS exceedances identified in the tables and discussed in Section 3.2.1 probably are not predicted exceedances, but, they may have eight-hour predicted exceedances they missed because they used a level four times too high. A TK performed comparisons against the incorrect values and noted the results in the text DSHIW-2012-003358 when a constituent-specific air concentration exceeded its NAAQS. It will be necessary to revise Tables 3-1 through 3-17 to list the correct value for each CO standard, and repeat the comparisons. Any exceedances will need to be noted in Section 3.2.1, Compliance with NAAQS, of the text. Please ensure that the CO air concentrations compared against the standards have been calculated correctly. 4. ATK Launch Systems Revised Preliminary Air Dispersion Modeling Assessment Draft Report for Open Burn and Open Detonation Treatment Units, Appendix D, Gas Modeling Input and Output Files, and Appendix E, Particle Modeling Input and Output Files Appendices D and E contain most of the OBODM modeling files needed to verify the modeling methodology for gas and particle phase modeling, respectively. However, the hourly source strength files used in modeling annual average impacts have not been provided. Please provide these files as part of Appendices D and E. Specific Comments 5. Introduction, Page 1-2 The last paragraph on page 1-2 states that, "ATK typically treats three different waste type packages; one hundred percent pure propellant, 85 percent pure propellant with 15 percent waste materials, and 65 percent pure propellant with 35 percent waste materials." Please revise the text to clarify that most of the reactive waste that is treated by open burning is represented by the three pure propellant/waste material mixtures that are cited in this paragraph and that the three waste-stream classifications are based on an analysis of reactive wastes that have been generated at the facility in the past. 6. Section 2.12, Receptor Networks, Page 2-14 The second paragraph of Section 2.12 indicates that Universal Transverse Mercator (UTM) northing, easting, and terrain elevation data were obtained from United States Geological Survey (USGS) Digital Elevation Maps (DEM). This source of information is not referenced or listed in the Reference Section of the Air Modeling Report. Please revise the list of references to include a citation for the USGS DEMs used in the air modeling analysis so stakeholders can locate this information. In addition, please revise Section 2.12 to include a reference to the citation. 7. Section 2.13.1, Surface Data, Page 2-16 Section 2.13.1 states, "ATK operates the on-site monitoring station approximately 1.5 km southwest of the M-225 treatment unit at an elevation of about 5,000 feet amsl (see Figure 2- 1)." However, Figure 2-1 appears to indicate about 700meters between the two locations. Please review the locations depicted on Figure 2-1, the scale provided for Figure 2-1, and revise the figure and/or text to describe and illustrate the distance between M-225 and the on- site meteorological monitoring station (M-245) in an accurate and consistent manner. DSHIW-2012-003358 8. Section 2.14.1, Discrete Receptors, Page 2-19 Section 2.14.1 indicates, "A database ofthe 250 worst case 1-hour events for each discrete receptor and source is provided in Appendix B." A database containing the 250 worst-case one-hour events was not found in Appendix B. The hours producing the worst case events are contained in the five yearly meteorological data files submitted as part of Appendix B on the CD of air modeling files. However, no database was found. It is not known if ATK plans to present all worst case, one-hour events in a database once the air modeling results for the general receptor grid are submitted in May 2012. Ifa database of the 250 worst case, one-hour events will not be prepared and presented, please remove the reference to the database from the text. 9. Section 2.14.1, Discrete Receptors, Page 2-19 The last paragraph on page 2-19 begins, " ... M-136 Source 1 will conduct treatment twice daily, three times a week for 52 weeks, which is equivalent to 156 annual treatment events." However, the numbers provided in this sentence result in 312 separate treatment events over 156 days per year. Please revise this sentence to indicate that 312 treatment events are assumed for M-136 Source 1 in the air modeling analysis. 10. Section 3.2.1, Compliance with NAAQS, Pages 3-J and 3-4 Incomplete modeling results are reported for two discrete receptors in the air modeling report. For example, page 3-3 states: "Autoliv is a complex terrain receptor. As a result, only gas modeling results are available." Page 3-4 presents an identical description for the Boundary 1 discrete receptor. It appears that no comparison to particulate matter (PM, PM1 0, and PM2.5) emission standards was performed for these two discrete receptors. A conservative estimate of the air concentrations ofPM10 and PM2.5 can be estimated by multiplying the gas phase unitized dispersion factor by the emission factor for PM10, and PM2.5, respectively. Please revise the air modeling report to address compliance with the particle-based emission standards at these two discrete receptors by applying the approach outlined above. In addition, please discuss the inherent conservatism in this approach in Section 3.4.5, Uncertainty Due to OBODM of the Air Modeling Report. 11. Section 3.2.1, Compliance with NAAQS, Pages 3-3 and 3-4 As stated in Section 2.0 of the HHRA Protocol, criteria pollutants will be evaluated in the air dispersion modeling report by comparing modeled air concentrations to the NAAQS. The criteria pollutants will not be evaluated in the HHRA. As of June, 2010, the EPA has set primary one-hour averaging time standards for nitrogen dioxide and sulfur dioxide. Comparisons of modeled air concentrations to these specific NAAQS are not included in the air modeling report. Please calculate the appropriate air concentration values and revise the report to include comparisons to the following NAAQS: sulfur dioxide primary standard of one-hour averaging time and secondary standard of three-hour averaging time; nitrogen dioxide primary standard of one-hour averaging time and primary and secondary standard for annual averaging time. DSHIW-20 12-003358 12. Section 3.2.2,-Compliance with Utah 1-Hour Acute Gas TSLs, Page 3-8 The discussion entitled 1-Hour Acute Gas TSL Summary at the top of page 3-8 indicates formaldehyde was not detected in the ODOBi testing study. Further, the text states that formaldehyde is not believed to be an emission product associated with the OB and OD treatment processes at M-136 and M-225. However, Tables 2-5 and 2-6 as well as the tables in Appendix L indicate that formaldehyde was detected during testing. Please review the discussion in Section 3.2.2 and the table entries and revise the text and tables as necessary to provide accurate and consistent information regarding whether formaldehyde was detected during emissions testing. REFERENCES Bjorklund, J. R., J. F. Bowers, G.C. Dodd. and J.M. White, 1998a. Open Bum/Open Detonation Model (OBODM) User's Guide, Volume I, User's Instructions, DPG Document No. DPG-TR-96- 008a, February. Bjorklund, J. R., J. F. Bowers, G.C. Dodd. and J.M. White, 1998b. Open Bum/Open Detonation Model (OBODM) User's Guide, Volume II, Technical Description, DPG Document No. DPG-TR-96- 008b, April. Beychok, Milton R., 2012. Error Propagation in Air Dispersion Modeling. Newport Beach, CA., available on the web at: http://www.air-dispersion.com/feature.html. DSHIW-2012-003358