DSHW-2013-001303 - 0901a0688033e0ad

January 15, 2013
Division of
Solid and Hazardous Waste
Mr. Scott T. Anderson, Director m 1S 20Q
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
Compliance Evaluation Inspection
Dear Mr. Anderson:
ATK Launch Systems Inc. (ATK) is responding to the Utah Division of Solid and Hazardous
Waste letter dated December 11, 2012 regarding the compliance evaluation inspection conducted
on September 25 and 26, 2012 at ATK's Promontory facility. The Division has expressed
concern about the ash disposal practice involving the M-136 landfill.
The Division has requested that ATK dispose of the burn ash/residue off-site. This request was
based on low concentrations of perchlorate in two samples (Lab Samples ID 1203017-01 and
1203017-02) of material that had been shipped off-site to a Subtitle C landfill for disposal. Lab
Sample ID 1203017-01 was from burn ash from laboratory material and is not representative of
normal burn ash/residue; this material was in fact identified for off-site disposal based on process
knowledge that the material might contain listed waste solvents. This was likely a small
laboratory sample which would not have contained enough reactive material to burn hot enough
for complete perchlorate oxidation.
Lab Sample ID 1203017-02 was from filter cake residue from the M-705 wastewater treatment
plant; this material was also identified for off-site disposal based on process knowledge that the
material might contain listed wastes. The filter cake residue from the wastewater treatment plant
is always shipped off-site for disposal.
The normal burn ash/residue is placed in the M-136 landfill. ATK has a data set (shown in Table
1) which indicates that the normal burn ash/residue has no residual perchlorate after burning.
This lack of perchlorate would be expected given the high temperature burning.
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Table 1: ATK Promontory Burn Ash/Residue Perchlorate Results
Sample Date Sample Description Perchlorate
(mg/kg)
MDL EQL
5/7/2003 M-136 Washout Ash U 0,1 mg/kg 0.4 mg/kg
5/7/2003 M-136 Washout Ash U 0.1 mg/kg 0.4 mg/kg
7/9/2003 M-136 Promontory General
Burn Ash
U 0.1 mg/kg 0.4 mg/kg
7/9/2003 M-136 Promontory General
Burn Ash
U 0.1 mg/kg 0.4 mg/kg
5/26/2010 M-136 Washout Ash :EQL 2.0 mg/kg 8.0 mg/kg
7/28/2011 M-136 Promontory General
Bum Ash
<EQL 1.0 mg/kg 4.0 mg/kg
9/2/2011 M-136 Bacchus Burn Ash U 0.1 mg/kg 0.4 mg/kg
9/7/2011 M-136 Flare Burn Ash U 0.1 mg/kg 0.4 mg/kg
6/11/2012 M-225 Burn Ash U 0.1 mg/kg 0.4 mg/kg
U Indicates that the analyte concentration is less than the MDL
MDL Method Detection Limit
EQL Estimated Quantitation Limit
Based on the analytical results showing no residual perchlorate, ATK does not believe that off-
site disposal ofthe normal non-hazardous burn ash/residue is warranted. Nonetheless, ATK is
open to further discussion with Division staff on this matter.
If you have any questions, please contact Blair Palmer at [phone] or me at (801) 251-
4643.
Sincerely,
Robert Ingersoll
Director
Environmental Services
ATK Launch Systems Inc.
cc: Brad Maulding
JeffVandel
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