DSHW-2013-002148 - 0901a06880353a23

.••vision of
''' '" ->•••:" Hazardous Waste
fE8 2 g 208
PO Box 98
Magna, Utah 84044
February 28, 2013
Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 North 1950 West
P.O. $ox 144880
Salt Lake City, Utah 84114-4880
Re: , Waste Minimization Certification; ATK Lauptcli Systems - NIROP
UTD3170027277; ATK Launch Systems ^Promontory Facility UTD009081357;
\ ATK Launch Systems - Bacchus Facility UTD001705029
Dear Mr. Anderson:
ATK Launch Systems Inc. ("ATK") is required by permit requirements to submit an
annual certification that there is a waste minimization program in place to reduce the
volume and toxicity of hazardous waste generated to the degree determined by the
permittee to be economically practicable; and that the proposed method of treatment,
storage or disposal is the practicable method currently available to the permittee which t
minimizes the present and future threat to human health and the environment.
ATK has a program in place to tracks the costs associated with generating and disposing
of hazardous waste. ATK also has an enterprise improvement system which encourages
process improvement projects which focus on waste reduction and pollution prevention.
Specific activities during Calendar Year 2012 are described below.
• i Historically propellant samples which were tested as part of our quality control
i program were open burned at the completion of the test cycle. The option to
j reclaim the ammonium perchlorate has been investigated with limited
implementation which will reduce future open burning requirements.
Additional effort has identified methods to further reduce the quantity of scrap
propellant produced when large motors are cast. This change will reduce future
open burning requirements.
February 28, 2013
Scott T. Anderson, Director
Utah Division of Solid and Hazardous Waste
• A mixing process was modified to recover course ammonium perchlorate
originally scrapped due to lost in equipment feed lines. This modification will
reduce the amount of scrap generated.
Other projects being investigated will allow the reuse of illuminant in flare
manufacturing, and reducing the mix size for inert propellant mixes. These
improvements will reduce the amount of waste material generated by each .
process.
In addition to these activities, ATK has an energy conservation program to minimize .
energy consumption while improving our operational efficiencies. The energy
conservation program includes the development of both wind turbine and solar
photovoltaic systems as alternate energy sources. Finally, we continue to work the
Division of Solid and Hazardous Waste to complete the open burning risk assessment for
our Promontory facility.
If you have any questions concerning this report, please contact George Gooch at (801)
699-0319.
/ 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 is, to the best of my knowledge
and belief true, accurate, and complete. Iam aware that there are significant penalties
for submitting false information, including the possibility offine and imprisonment for
knowing violations.
Sincerely,
i
Robert Ingersoll
Director, Environmental Services
ATK Launch Systems
cc: Jeff Vandel
I
Hoa Zhu