DSHW-2012-013248 - 0901a068803000cb

HAZARDOUS WASTE COMPLIANCE
INSPECTION REPORT
Date of Inspection:
Facility:
Facility Contact:
Applicable Regulations:
Type of Inspection:
Report Prepared by:
8/24/2012
ATK Launch Systems Bacchus
P.O. Box 98
Magna, UT 84044
UTD001705029
ATK Launch Systems Promontory
P.O. Box 707
Brigham City, UT 84302
UTD009081357
George Gooch, Facility Contact
Phone: [phone]
Part "B" Permits, Closure and Post-Closure,
Utah Administrative Code (UAC) R315,
Federal Rule 40 CFR 264 Subpart H
Financial Assurance Evaluation
David McCleary
An evaluation of the financial assurance documents (DSHW log #s 2012-003332, 2012-
003333, 2011.02382, 2012-003540, 2012-003541, 2012-003881, and 2012.003882) for
ATK facilities for Bacchus (UTD001705029) and Promontory (UTD009081357) has
been performed.
This financial assurance evaluation looked at the compliance status of the A TK permitted
facilities in the State of Utah subject to financial assurance requirements specified by
R315-8-8 [40 CFR 264.140 through 264.151].
The evaluation covered the required sudden and non-sudden insurance liability
requirements, closure and post-closure care cost estimates, and the financial assurance
mechanisms required under R315-8-8 (the Rules). The liability coverage's and costs
associated with closure and post-closure were determined to be proper and appropriate
for both facilities.
EPAIDNo. Closure Cost Post Closure Sudden I Non-
Cost Sudden Liability
UTD001705029 $408,272. $0 $8,000,000.00
UTD009081357 $649,007. $647,009 Annual aggregate
Liability Coverage
ATK is insured (see 264.147(a)), through Chartis Specialty Insurance Company for
sudden liability insurance coverage (see documents 2012-003332 and 2012-003333. The
amount of the insurance for Bacchus and Promontory is the maximum amount to meet
the requirements of the Rules (see 264.147(a)). The wording of the "HAZARDOUS
WASTE FACILITY CERTIFCATE OF LIABILITY INSURANCE" meets the
requirements and the wording of the Rules (264.151 (j).
ATK, Promontory is required by its Permit to maintain non-sudden liability coverage (see
264.147(b)). The insurance coverage is issued through Great American Insurance (see
document 2011.023820 for the non-sudden liability coverage in the maximum amount to
meet the requirements of the Rules (see 264.147(b)). The wording of the
"HAZARDOUS WASTE FACILITY CERTIFCATE OF LIABILITY INSURANCE"
meets the requirements and the wording ofthe Rules (264.151(j).
Closure/Post-Closure Cost Estimates and Financial Assurance Coverage
ATK provided cost estimates identified in the above table (see documents 2012-003540,
and 2012-003541). ATK has chosen to use insurance coverage issued by Great American
Insurance Group with Insurance Policy Number CPC 3762254 01 with an effective date
of June 28, 2012 (see documents 2012-003881, and 2012-003882), (see 264.143/145(e))
as the financial assurance mechanism for closure and post-closure at a multiple facilities
(see 264.146) in Utah. The amount of the insurance policy is $1,704,288 which equals
the amount necessary for the closure and post-closure at the two facilities. The wording
ofthe insurance policy and "CERTIFCATE OF INSURANCE FOR CLOSURE AND
POST -CLOSURE CARE" meets the requirements and the wording of the Rules
(264.151(e). The ATK financial assurance review indicates that the two Utah facilities
have met the requirements under R315-8-8 for closure and post-closure care
requirements.
Date: 8" /J I/ 2o .' '(_
l I
c: Brad Maulding, Manager, Hazardous Waste Facility Section