DSHW-2013-001346 - 0901a0688033ebf8

State of Utah
GARY HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
January 24, 2013
Robert Ingersoll, P.E., Director
Environmental Services
A TK Launch Systems-Promontory
P.O. Box 707
Brigham City, UT 84302-0707
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
RE: Air Dispersion Modeling Analysis for Open Bum and Open Detonation Treatment Units
ATK Launch Systems-Promontory Facility
UTD009081357
Dear Mr. Ingersoll:
This letter is in response to your correspondence dated December 20, 2012 regarding our
comments on the OBODM Air Dispersion Modeling Report (July, 2012), and ATK's proposal to
conduct a "hybrid" modeling analysis in order to obtain more refined results.
Based on your responses to our specific comments, numbers one and two, ATK and Tetra Tech
are working to confirm that peak concentrations were modeled in all necessary cases and that
annual gravitation deposition was calculated for the discrete receptors and the general grid. It is
understood that A TK and Tetra Tech are also working to verify that all of the appropriate data
files for these modeling efforts were submitted with the OBODM Modeling Report.
In regard to ATK's proposal to conduct a refined modeling analysis by using the emission and
source modules of OBODM and the dispersion and deposition portions of AERMOD, the
Division agrees that this hybrid modeling approach should produce more accurate or realistic
results rather than relying solely on the OBODM model. Please be aware that new versions of
AERMOD and AERMET were released on December 17,2012. These new versions, or the
commercially available equivalent, should be used for modeling that hasn't already been
completed.
As stated in your letter, the Division has reviewed draft protocol documents for the hybrid
modeling analysis that were prepared by ATK and Shaw Environmental beginning in July, 2012.
As stated above, the Division agrees that the hybrid modeling analysis is an appropriate approach
DSHW-2013-001346
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at this time. Please submit the revised addendum to the air dispersion modeling protocol, as
discussed in the January 16, 2013 conference call, for our review.
There is one point, in regard to the protocol addendum, that we would like to clarify before it is
submitted. It was stated in your December 20, 2012 letter (2nd page, 2nd paragraph) that peak one-
hour average concentrations will be calculated in the hybrid modeling analysis and will be used in
the HHRA. However, annual peak concentrations are not mentioned in your response. Please
clarify in the modeling protocol addendum that ATK intends to use the hybrid modeling analysis
results to represent the annual average air quality impacts in the HHRA.
Also, it is stated in your letter that once the Division has granted approval of the protocol, Shaw
Environmental can generate the final model data output package for Tetra Tech to use in the
HHRA. Please be aware that A TK needs to submit a report for the modeling analysis to the
Division for review once it is complete. If the modeling report is determined to be approvable by
the Division, ATK will have 90 days (in accordance with Permit Condition IV.M.2.) to submit the
HHRA Report.
If you have any questions, please call JeffVandel at [phone].
STA/JV/tjm
c: Blair Palmer, A TK, email
Paul V. Hancock, A TK, email
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Nancy Morlock, Region 8 EPA, email
Cheryl Overstreet, Region 8 EPA
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