DSHW-2013-001945 - 0901a0688034f980

WD
February 19,2013
8200-FY13-062
Division of
Solid and Hazardous Waste
Mr. Scott T. Anderson, Director
FEB 2 0 2013
M3
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 Inc. EPA ID number UTD009081357
Annual Report of the Promontory Thermal Treatment Areas Operation Hazardous
Waste Storage Permit Module II.G.3
Dear Mr. Anderson:
Attached is the 2012 Annual Report for the operation of the ATK Launch Systems
Inc.("ATK") Promontory Facility Thermal Treatment Areas as required by Hazardous
Waste Storage Permit Module II Condition G.3.
Please contact Blair Palmer at [phone] or myself at [phone], ifyou have
any questions concerning this report.
I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on
my inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate and complete. I am aware that there are significant
penalties for submitting false information, including the possibility offine and
imprisonment for knowing violations.
Sincerely,
Robert Ingersoll
Director, Environmental Services
ATK Launch Systems Inc.
cc: JeffVandel
ATK Launch Systems Inc.-Promontory 2012 Annual Report of the Promontory
Thermal Treatment Areas Operation
Module II Condition G.3.a: requires an accounting of the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas.
Response: Table 1 and Table 2 shown below report the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas in 2012.
Table 1: 2012 M-136 Thermal Treatment Totals
'ropell
1.3 50.2% 471,406
B 108
974
306
1.1 32.2% 293,427
D 10,193
(1»3) Flare 17.6% 165,602
Table 2: 2012 M-225 Thermal Treatment Totals
Propellant Class
1.3
Percent of Total
35.5%
Reactivity Croup
A 347
B
1.1 64.5% 29
D 601
(1.3) Flare 0.0% E
Module II Condition G.3.b: requires an estimated quantity of TCDD TEQs, or other
compounds as indentified in accordance with Condition H.G.2., released annually. The
quantity shall be calculated based on emission rates to be determined through approval of
the air dispersion model.
Response: This condition cannot be completed since the air dispersion modeling has not
been completed. The emission rates from the dispersion modeling are required to
complete this calculation.
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Module II Condition G.J.c: requires an evaluation of the emission factors, identified in
Condition II.G.l.a, used in the human health risk assessment to determine whether these
factors are representative ofthe wastes treated and identified as directed by II.G.3.a, or if
the emission factors need to be updated.
Response: This condition cannot be completed since the air dispersion modeling must be
completed prior to the human health risk assessment evaluation, however; A TK considers
the currently proposed emission factors to be representative of the wastes treated at the
M-136 and M-225 Thermal Treatment Areas.
Module II Condition G.3.d: requires a review of the human health risk assessment,
identified in Condition II.G.l.g., to evaluate whether the slope factors and reference dose
for carcinogenic and non-carcinogenic health effects related to chlorinated dioxin,
chlorinated furan and semi-volatile compounds have changed, and a review of the
potential human health risk scenarios that were evaluated in the risk assessment to assure
that these scenarios have not changed.
Response: This condition cannot be completed since the human health risk assessment
must be completed following the air dispersion modeling. Slope factors and reference
dose for carcinogenic and non-carcinogenic health effects related to chlorinated dioxin,
chlorinated furan and semi-volatile will be evaluated once the air dispersion modeling
and the human health risk assessment are completed.
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