DSHW-2014-002006 - 0901a068803fa50a

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Division of
id and Hazardous Waste
January 21, 2014 JAN 2 2 20K
8200-FY14-068
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc. EPA ID number UTD009081357 V^"
ATK Launch Systems Inc. Promontory Facility Hazardous Waste Storage Permit Class 1
Modification
Dear Mr. Anderson:
As allowed under 40 CFR 270.42 (a), ATK Launch Systems Inc. (ATK) is requesting a
modification to the Promontory Facility's Hazardous Waste Storage Permit. The proposed
changes have been reviewed with your staff and were deemed to be a class 1 permit modification.
The updated pages are enclosed with this notification.
The following changes have been made due to change in personal, building improvements and
changes in operational practices.
o The emergency coordinator contact information associated with the Contingency Plan has
been updated allowing ATK to update the emergency personal contacts. The previous contact
list was outdated and emergency personal have changed.
o Figure 6A in Attachment 6 has been updated to reflect the addition of rollup doors to the M-
186 chemical waste storage facility.
o In Module V A.3 the language was updated to be consistent with the language in Attachment
10 and 40 CFR 262.34 allowing the waste to be managed either as a 90-day waste or under
satellite accumulation rules.
o The final update was the removal of the title "Executive Secretary" from all of the language
contained in the Hazardous Waste Storage Permit and to replace it with the correct title of
"Director." This change was requested by the UDSHW.
Please contact Blair Palmer at [phone] or myself at [phone] if you have any
questions concerning this submittal.
Sincerely,
George E. Gooch
Manager, Environmental Services
ATK Launch Systems Inc.
cc: JeffVandel
ATK Launch Systems Inc. - Promontory Modified January, 2014
Module I - Standard Permit Conditions UTD009081357
MODULE I - STANDARD PERMIT CONDITIONS
I.A. EFFECT OF PERMIT
I.A.I. The Permittee is allowed to store hazardous waste in containers, treat hydrazine, by
dilution, in containers and treat reactive hazardous waste by open burning or open
detonation at the ATK Launch Systems-Promontory (ATK) Facility, Box Elder County,
Utah in accordance with the conditions of this Permit. In addition, the Permittee is
allowed to store waste solid rocket motors at the facility in accordance with the
conditions of this Permit. Any treatment, storage, or disposal of hazardous waste not
authorized in this Permit, is prohibited.
I.A.2. Compliance with this Permit, during its term, constitutes compliance for purposes of
enforcement with applicable sections of Utah Administrative Code (UAC) R315 only
for those management practices specifically authorized by this Permit.
I.A.3. Issuance of this Permit does not convey property rights of any sort or any exclusive
privilege; nor does it authorize any injury to persons or property, any invasion of other
private rights, or any infringement of State or local law or regulations.
I.A.4. This Permit has been developed in accordance with the applicable requirements of UAC
R315-1 through 101 of the Utah Hazardous Waste Management Rules. All conditions
within this Permit will supercede conflicting statements, requirements, or procedures
found within UAC R315-1 through 101 or attachments to this Permit.
I.B. ENFORCEABILITY
I.B. 1 Violations documented through the enforcement process pursuant to Utah Code
Annotated (UCA) 19-6-112 may result in penalties assessed in accordance with UAC
R315-102, the Penalty Policy.
I.C. OTHER AUTHORITY
I.C. 1. The Director expressly reserves any right of entry provided by law and any authority to
order or perform emergency or other response activities as authorized by law.
I.D. PERMIT ACTIONS
I.D. 1. This Permit may be modified, revoked and reissued, or terminated for cause, as
specified in UAC R315-3-4. If the Director determines that cause exists to modify,
revoke, and reissue, or terminate this Permit, the action will proceed in accordance with
UAC R315-4-1.5. The filing of a request for a permit modification, revocation,
reissuance, termination, or the notification of planned changes or anticipated
noncompliance on the part of the Permittee does not stay the applicability or
enforceability of any permit condition.
I.D.2. The Director may modify this Permit, in accordance with UAC R315-3-4.2, when the
standards or regulations on which the Permit was based have been changed by statute,
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ATK Launch Systems Inc. - Promontory Module I - Standard Pennit Conditions Modified January, 2014 UTD009081357

through promulgation of new or amended standards or regulations, or by judicial decision after the effective date of this Permit.
LD.3. LD.4.
LD.5
LD.6.
I.E.
LE.I .
I.F.
LF.1.
LF.2.
I.G.
LG.I.
The Permit may be modified at the request of the Permittee according to the procedures of UAC R315-3-4.3. All Permit conditions supersede conflicting statements, requirements or procedures found in the Attachments to the Permit. Ifa conflict exists between conditions in this Permit, the most stringent condition, as determined by the Director, shall be met. In accordance with the Utah Solid and Hazardous Waste Act, UCA, 19-6-108(13), this Permit shall be reviewed no later than five (5) years from the date of issuance or renewal and subsequently modified, if necessary. SEVERABILITY The provisions of this Permit are severable and if any provision of this Permit, or the application of any provision of this Permit to any circumstance, is held invalid, the application of such provision to other circumstances and the remainder of this Permit shall not be affected thereby. Invalidation of any State or federal statutory or regulatory provision which forms the basis for any condition of this Permit does not affect the validity of any other state or federal statutory or regulatory basis for said condition. DUTIES TO COMPLY The Permittee shall comply with all conditions of this Permit, except to the extent and for the duration such noncompliance is authorized by an Emergency Permit issued in accordance with UAC R315-3-6.2. Any permit noncompliance, other than noncompliance authorized by an Emergency Permit, constitutes a violation of the Utah Solid and Hazardous Waste Act, and is grounds for enforcement action; for Permit termination, revocation and reissuance, or modification; or for denial of a Permit renewal application; or a combination of enforcement action and any of the other listed remedies. Compliance with the terms of this Permit does not constitute a defense to any order issued or any action brought under Sections 3007, 3008, 3013, or 7003 of RCRA (42 U.S.C. Sections 6927, 6928, 6934 and 6973), Section 106(a), 104, or 107 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9606(a), 9604, and 9607, commonly known as CERCLA) as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), or any other State or federal law providing for protection of human health or the environment from any imminent and substantial endangerment. DUTY TO REAPPLY
If the Permittee wishes, or is required by the Director, to continue an activity allowed by this Permit after the expiration date of this Permit, the Permittee shall submit a complete application for a new permit, in accordance with UAC R315-3- 2.l g and UAC R315-3-3.l (b), at least 180 days before this Permit expires.

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Module I - Standard Permit Conditions UTD009081357
I.H. PERMIT EXPIRATION
I.H. 1. This Permit shall be effective for ten years from the date it is issued.
I.I. CONTINUATION OF EXPIRING PERMIT
I.I. 1. This Permit and all conditions herein shall continue in force until the effective date of a
new permit, if the Permittee has submitted a timely and complete application, in
accordance with applicable requirements of UAC R315-3 and R315-4, and through no
fault of the Permittee, the Director has neither issued nor denied a new permit under
UAC R315-3-5.2 on or before the expiration date of this permit.
I.J. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE
I.J. 1. It shall not be a defense for the Permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the conditions of this Permit.
I.K. DUTY TO MITIGATE
I.K. 1. In the event of noncompliance with the Permit, the Permittee shall take all reasonable
steps to minimize releases of hazardous waste, hazardous waste constituents, and
perchlorate salts to the environment resulting from the noncompliance, and shall carry
out such measures as are reasonable to prevent significant adverse impacts on human
health or the environment.
LL. PROPER OPERATION AND MAINTENANCE
I.L. 1. The Permittee shall, at all times, properly operate and maintain all facilities and systems
of treatment and control (and related appurtenances) which are installed or used by the
Permittee to achieve compliance with the conditions of this Permit. Proper operation
and maintenance includes effective performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary equipment or similar systems only when necessary to achieve
compliance with the conditions of this Permit.
LM. DUTY TO PROVIDE INFORMATION
I.M.I. The Permittee shall furnish to the Director, within a reasonable time, any relevant
information which the Director may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this Permit, or to determine
compliance with this Permit. The Permittee shall also furnish to the Director upon
request, copies of records required to be kept by this Permit.
LN. INSPECTION AND ENTRY
I.N. 1. Pursuant to the UCA 19-6-109, the Permittee shall allow the Director, or an authorized
representative, upon the presentation of credentials and other documents, as may be
required by law, to:
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I.N. 1 .a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or
activity is located or conducted, or where records are kept as required by the conditions
of this Permit;
I.N.I.b. Have access to and copy, at reasonable times, any records that are kept as required by
the conditions of this Permit;
I.N. 1 .c. Inspect at reasonable times any portion of the Facility, equipment (including monitoring
and control equipment), practices, or operations regulated or required under this Permit;
I.N. 1 .d. Sample or monitor, at reasonable times, for the purposes of assuring permit compliance
or as otherwise authorized by the Utah Solid and Hazardous Waste Act, any substances
or parameters at any location; and
I.N. 1 .e. Make record of inspection by photographic, electronic, videotape, or any other
reasonable medium. No audio recording devices shall be used without notice to all
individuals in recording range prior to activation of the recording device. Photographic
and video recording shall comply with the safety and security requirements of the
Permittee.
1.0. MONITORING AND RECORDS
I.0.1. The Permittee shall retain records of all monitoring information, including all
calibration and maintenance records and, where applicable, all original strip chart
recordings (or equivalent recordings) for continuous monitoring instrumentation, copies
of all reports and records required by this Permit, the waste minimization certification
required by UAC R315-8-5.3. (40 CFR § 264.73(b)(9) incorporated by reference), and
records of all data used to comply with the conditions of this Permit, including any and
all data to support human health and ecological risk assessments for cleanup and closure
activities. All of the above referenced material shall be retained for a period of at least
three years from the date of the sample, measurement, report, certification, or recording
unless a longer retention period for certain information is required by other conditions
of this Permit. The three-year period may be extended by the Director at any time by
written notification to the Permittee. The retention times are automatically extended
during the course of any unresolved enforcement action regarding the facility to three
years beyond the conclusion of the enforcement action. Recordkeeping may be
accomplished using original documents, xerographic copies, document replicas, electronic
facsimiles, electronic disk, CD-ROM computer drive files, microfilm, microfiche, photograph,
magnetic tape or any other reasonable medium or similar recordkeeping technique. Any
recordkeeping system shall be capable of reproducing complete, accurate and legible records.
1.0.2. Pursuant to UAC R315-3-3.1 (j)(3), records of monitoring information shall specify at a
minimum:
I.0.2.a. The date(s), exact place, and times of sampling or measurements;
1.0.2.b. The name(s), title(s), and affiliation of individual(s) who performed the sampling or
measurements;
I.O.2.C. The date(s) analyses were performed;
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UTD009081357
I.0.2.d. The individual(s) who performed the analyses;
I.0.2.e. The analytical techniques or methods used; and
I.0.2.f. The results of such analyses.
1.0.3. Samples and measurements taken for the purpose of monitoring shall be representative
of the monitored activity. The method used to obtain a representative sample of the
waste to be analyzed shall be the appropriate method from UAC R315-50-6 or as
specified or modified by this Permit.. Laboratory methods shall be those specified in
"Test Methods for Evaluating Solid Waste; Physical/Chemical Methods SW-846 {Third
Edition, November 1986)" or most currently promulgated edition, "Standard Methods
for Examination of Water and Wastewater (/ 7th Edition, 1989) " or most currently
promulgated edition; or an equivalent method as approved by the Director. The
analysis of all samples shall be conducted by laboratories certified by the State of Utah.
I.O.4. When requesting substitute or additional analytical methods, the Permittee shall submit
to the Director a request for substitution of analytical methods which are equivalent to
the methods specifically approved for use in this permit, in accordance with UAC
R315-3-4.3. The request shall provide information demonstrating that the proposed
methods are equivalent or superior in terms of sensitivity, accuracy, and precision (i.e.
reproducibility).
LP. REPORTING PLANNED CHANGES
I.P.I. The Permittee shall give written notice to the Director 60 days prior to any planned
physical alterations or additions to any Hazardous Waste Management Unit (HWMU)
or system being permitted or previously permitted in accordance with UAC R315-3-
3.1(1) and R315-3-4.3. Planned physical alterations or additions shall include all
changes in any hazardous and solid waste activities, and to any non-waste underground
storage tanks regulated under UAC R315-202 (40 CFR 280). Construction or operation
of new or modified HWMUs shall not begin unless the provisions of UAC R315-4-1.5
are met.
I.Q. REPORTING ANTICIPATED NONCOMPLIANCE
I.Q. 1. The Permittee shall give written notice to the Director 30 days prior to any planned
changes in the permitted Facility or activity which may result in noncompliance with
requirements of this Permit. Advance notice shall not constitute a defense for any
noncompliance.
LR. CERTIFICATION OF CONSTRUCTION OR MODIFICATION
I.R. 1. The Permittee shall not commence storage, treatment, or disposal of hazardous waste in
a new hazardous waste management unit or in a modified portion of an existing
permitted hazardous waste management unit, except as provided in UAC R315-3-4.3,
until:
I.R. 1 .a. The Permittee has submitted to the Director by certified mail, express mail or hand
delivery:
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I.R. 1 .a.i. A letter signed by the Permittee and an independent, Utah registered professional
engineer qualified by experience and education in the appropriate engineering field
certifying that the unit has been constructed or modified in accordance with the
approved modification request and this Permit; and
I.R. 1 .a.ii. As-built engineering drawings and specifications as appropriate.
I.R. 1 .b.. The Director or designated representative has reviewed and inspected the modified or
newly constructed unit and has notified the Permittee in writing that the unit was found
in compliance with the conditions of this Permit.
I.R.2. If within fifteen (15) calendar days of the date of receipt of the letter required by Permit
Condition I.R. 1.a.i., the Permittee has not received notice from the Director, of the
intent to inspect, prior inspection is waived and the Permittee may commence treatment,
storage, or disposal of hazardous waste in the permitted unit, if certified in accordance
with Condition I.R.l.a.i.
LS. TRANSFER OF PERMIT
LS. 1. This Permit may be transferred to a new owner or operator only if it is modified or
revoked and reissued pursuant to UAC R315-3-4.1 and R315-3-4.2(b)(2). Prior to
transferring ownership or operation ofthe Facility during its operating life, the
Permittee shall notify the new owner or operator, in writing, of the applicable
requirements of UAC R315-1 through R315-101, and this Permit. Failure by the
Permittee to notify the new owner or operator of these requirements and this Permit in
no way relieves the new owner or operator of his obligation to comply with all
applicable requirements of the Rules and this Permit.
LT. TWENTY-FOUR HOUR REPORTING
I.T.I. In accordance with UAC R315-3-3.1 (l)(6)(i), the Permittee shall orally report to the
Director any noncompliance with this Permit which may endanger human health or the
environment. Any such information shall be reported as soon as possible, but not later
than twenty-four (24) hours from the time the Permittee becomes aware of the
noncompliance.
I.T.2. In accordance with UAC R315-9-1(b), the Permittee shall immediately report to the
Director any spill of any hazardous waste or material which, when spilled becomes a
hazardous waste, if the spilled quantity exceeds 100 kilograms or a lesser amount if
there is a potential for endangerment to human health or the environment, or exceeds 1
kilogram if the material is an acute hazardous waste as defined by UAC R315-9-1(b)(2).
I.T.3. The Permittee shall immediately report to the Director any spill that contains
perchlorate, if the spilled quantity exceeds 100 kilograms and the perchlorate
concentration of the spilled material is greater than 15 ug/L. Any such information
shall be reported as soon as possible, but not later than 24 hours from the spill
occurrence.
I.T.4. The non-compliance and spill reports shall include, but not be limited to, the following:
I.T.4.a. Information concerning the release of any hazardous waste which may endanger public
drinking water supplies; and
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UTD009081357
I.T.4.D. Any information of a release or discharge of hazardous waste, or of a fire, or explosion
at the Facility, which could threaten human health or the environment.
I.T.4.C. A description of the occurrence and its cause;
I.T.4.d. The name, title, and telephone number of the individual reporting;
I.T.4.e. The name, address, and telephone number of the owner or operator;
I.T.4.f. The name, address, and telephone number ofthe Facility;
I.T.4.g. The date, time, and type of the incident;
I.T.4.h. The location and cause of the incident;
I.T.4.i. The name and quantity of materials involved;
I.T.4.j. The extent of injuries, if any;
I.T.4.k. An assessment of actual or potential hazard to the environment and human health,
where this is applicable;
I.T.4.1. A description of any emergency action taken to minimize threat to human health and the
environment;
I.T.4.m. An estimated quantity and disposition of the recovered material that resulted from the
incident; and
I.T.4.n. Any other information necessary to fully evaluate the situation and to develop an
appropriate course of action.
I.T.5. Within 15 days of the time the Permittee is required to provide the reports specified in
Conditions I.T.I, through I.T.4., the Permittee shall submit to the Director a written
report.
I.T.6. The written report shall include, but not be limited to the following:
I.T.6.a. The name, title, address, and telephone number of the individual reporting;
I.T.6.b. A description including the date, time, location and nature of the reported incident;
I.T.6.C The extent of injuries, if any;
I.T.6.d. The name and quantity of material(s) involved in the spill;
I.T.6.e. An estimated quantity and disposition of the recovered material;
I.T.6.f. An assessment of actual or potential hazards to human health and the environment,
where this is applicable. The report shall also include whether or not the results of the
incident remain a threat to human health and the environment (whether the
noncompliance has been corrected and the release has been adequately cleaned up); and
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I.T.6.g. If the release or noncompliance has not been adequately corrected or cleaned up, the
anticipated time that the noncompliance or remediation is expected to continue; the
steps taken or planned to reduce, eliminate, and prevent recurrence of the
noncompliance; and/or the steps taken or planned to adequately remediate the release.
LU. MONITORING REPORTS
LU. 1. Monitoring information shall be recorded and maintained as specified in Condition 1.0.
I.V COMPLIANCE SCHEDULES
I. V. 1. Reports of compliance or noncompliance with, or any progress reports on, interim and
final requirements contained in any compliance schedule of this Permit shall be
submitted no later than 14 days following each scheduled date.
I.W. MANIFEST DISCREPANCY REPORT
I. W. 1. Manifest discrepancies shall be defined as differences between the quantity or type of
hazardous waste designated on the manifest or shipping paper, and the quantity or type
of hazardous waste the permittee actually receives. Significant discrepancies in
quantity are: (1) for batch waste, any variation in piece count, such as a discrepancy of
one drum in a truckload, and (2) for bulk waste, variations greater than 10 percent in
weight. Significant discrepancies in type are obvious differences which can be
discovered by inspection or waste analysis, such as waste solvent substituted for waste
acid, or toxic constituents not reported on the manifest or shipping paper. If a
significant discrepancy is discovered in a manifest, the Permittee shall attempt to
reconcile the discrepancy. If not resolved within 15 days, the Permittee shall submit a
written report, including a copy of the manifest and efforts to reconcile the discrepancy,
to the Director in accordance with UAC R315-8-5.4.
LX. UNMANIFESTED WASTE REPORT
I.X. 1. The Permittee shall submit to the Director an Unmanifested Waste Report within 15
days of receipt of unmanifested waste in accordance with UAC R315-8-5.7.
LY. BIENNIAL REPORT
I.Y.I. The Permittee shall submit to the Director a Biennial Report covering facility activities
during odd numbered calendar years. This report shall be submitted by March 1 of the
following even numbered year in accordance with UAC R315-8-5.6.
I.Z. OTHER NONCOMPLIANCE
I.Z. 1. The Permittee shall report all other instances of noncompliance with this Permit not
otherwise required to be reported in accordance with Condition I.T., within seven days
of discovering the noncompliance. The reports shall contain the information listed in
Condition LT. of this Permit. Reporting shall not constitute a defense for any
noncompliance.
I.AA. OTHER INFORMATION
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I.AA. 1. Whenever the Permittee becomes aware that it failed to submit any relevant facts in a
permit application, or submitted incorrect information in a permit modification, or in
any report submitted to the Director, the Permittee shall submit such facts or corrected
information within seven working days.
I.BB. SIGNATORY REQUIREMENT
I.BB. 1. All reports, notifications, submissions or other information required by this Permit,
requested by or submitted to the Director, shall be signed and certified in accordance
with UAC R315-3-2.2.
I.CC. CONFIDENTIAL INFORMATION
I.CC. 1. The Permittee may claim confidential any information required to be submitted by this
Permit in accordance with Utah Code Annotated 63-2-101 et seq. and Utah Code
Annotated 19-1-306.
I.DD. REPORTS. NOTIFICATIONS. AND SUBMISSIONS
I.DD. 1. All reports, notifications, or other submissions which are required by this Permit to be
transmitted to the Director should be sent by certified mail or other means of proof of
delivery to:
Director, Division of Solid and Hazardous Waste
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
Phone [phone]
Normal business hours are 7 am to 6 pm, Monday through Thursday, except Utah State
holidays. Required oral notifications shall be given only to the Director or an
authorized representative ofthe Director. Notifications made at other times shall be
made to the 24-hour answering service at [phone]. Notifications made to the
24-hour answering service shall include all applicable information required by this
Permit. The Permittee shall give oral notification to the Director or an authorized
representative ofthe Director on the first business day following notification to the 24-
hour answering service.
LEE. DOCUMENTS TO BE MAINTAINED AT THE FACILITY SITE
I.EE.l. The Permittee shall maintain at the facility, for the periods specified, current copies of
the following documents and amendments, revisions and modifications to these
documents:
LEE. 1 .a. A copy of the Permit until closure is certified in accordance with Condition II.O.;
LEE.l.b. Waste Analysis Plans (Attachment 1), and all associated analytical data, as required by
UAC R315-8-2.4. and this Permit until closure is certified in accordance with Condition
II.O.;
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I.EE. 1 .c. Inspection schedules and logs (Attachment 2), as required by UAC R315-8-2.6(b) and
this Permit for a period of three years in accordance with UAC R315-8.2.6(d);
I.EE. 1 .d. Personnel training documents (Attachment 3), and records, as required by UAC R315-
8-2.7(d) and this Permit until closure for current employees, or for a period of three
years for former employees in accordance with UAC R315-8.2.7(e);
I.EE. 1 .e. Contingency Plan (Attachment 4), as required by UAC R315-8-4 and this Permit until
closure is certified in accordance with Condition II.O;
I.EE.l.f. Operating record, as required by UAC R315-8-5.3, and this permit until closure is
certified in accordance with Condition II.O;
I.EE. 1 .g. Closure Plans (Attachment 5), as required by UAC R315-8-7 and this permit, until
closure is certified in accordance with Condition II.O;
I.EE. 1 .h. Cost estimates (Attachment 5) for the closure and post-closure of the Hazardous Waste
Management Units covered by this Permit, in accordance with UAC R315-8-8 and
Condition II.P. of this Permit;
I.EE. 1 .i. Manifest copies, as required by UAC R315-8-5 and this Permit for at least three years
from the date the waste shipment was accepted at the facility or shipped off-site to an
approved hazardous waste management facility; and
I.EE.l.j. A copy of the Permittee's waste minimization statement until closure is certified in
accordance with Condition II.O.
I.FF. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
I.FF.l. Pursuant to Section 3005(C)(3) of RCRA (Section 212 of HSWA) and UAC R315-3-
3.3(b)(2) [40 CFR 270.32(b)(2)], this Permit contains those terms and conditions
determined necessary to protect human health and the environment.
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Module II - General Facility Conditions UTD009081357
MODULE II - GENERAL FACILITY CONDITIONS
ILA. APPLICABILITY
II. A. 1. The requirements of this permit module pertain to all Hazardous Waste Management
Units (HWMUs) identified within Modules I, II, III, IV and V.
II.B. DESIGN AND OPERATION OF FACILITY
II.B. 1. The Permittee shall design, construct, maintain and operate all of the HWMUs and
surrounding areas to minimize the possibility of a fire, explosion, or any sudden or non-
sudden release of hazardous waste or hazardous waste constituents to the air, soil,
groundwater or surface water which could threaten human health or the environment.
II.B.2. Any construction changes associated with a permitted HWMU at the facility shall be
documented by as-built drawings and certified by a registered professional engineer in
accordance with Condition I.R.I, and UAC R315-3-3. l(l)(2)(i).
II.B.3. After review of the as-built drawings and field verification of the facility's HWMUs, the
Director will notify the Permittee in writing of any change which he concludes does not
satisfy the operating requirements specified in this permit.
II.C. REQUIRED NOTICE
II.C. 1. As required by UAC R315-8-2.3(a)(1), the Permittee shall notify the Director in writing
at least four weeks in advance of the date the Permittee expects to receive hazardous
waste from a foreign source. Notice of subsequent shipments of the same waste from
the same foreign source in the same calendar year is not required.
II.C.2. When the Permittee arranges to receive hazardous waste from an off-site source (except
where the Permittee is also the generator), the Permittee shall inform the generator in
writing that he has the appropriate permit(s) for, and will accept, the waste the generator
is shipping. The Permittee shall keep a copy of this written notice as part of the
operating record as required by UAC R315-8-2.3(b).
II.D. WASTE ANALYSIS PLAN
II.D. 1. The Permittee shall follow the procedures of the Waste Analysis Plan included as
Attachment 1 of this Permit. In addition, the Permittee shall comply with any other
conditions involving waste analysis in Modules I, II, III, IV and V.
II.D.2. The Permittee shall use the test methods described in the Waste Analysis Plan
(Attachment 1) or an equivalent procedure that satisfies Condition I.O.3. Changes in a
test method described in the Waste Analysis Plan, as a result of an improvement or
refinement of that method, may be adopted by the Permittee and incorporated into this
Permit, in accordance with UAC R315-4-1.5 and Condition I.D.
II.D.3. The Permittee shall characterize, using analytical techniques if necessary, all waste
streams generated on or off-site in accordance with UAC R315-8-2.4 and Attachment 1.
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The waste characterization profiles shall be kept in the operating record.
II.D.4. An annual evaluation of each waste stream shall be performed, as outlined in the waste
analysis plan, to verify that the waste characterization is still accurate. These
evaluations shall be kept in the operating record until the next annual evaluations are
completed. Characterization of waste streams shall also be done each time the process
generating the waste changes.
II.D.5. Any waste analysis used to evaluate off-site waste for acceptance by the Permittee shall
be accomplished using a laboratory that has been certified by the Utah State Division of
Laboratories.
II.D.6. At a minimum, the Permittee shall:
II.D.6.a. Maintain properly functioning sampling and analytical equipment;
II.D.6.b. Use approved sampling and analytical methods; and
II.D.6.C. Submit an updated list of parameters, analytical methods, and sample preparation
methods on an annual basis. The updated list shall be submitted to the Director on or
before January 15th of each calendar year.
II.D.7. Whenever the Director determines that the Permittee needs to update the analytical
methodologies or the version(s) of SW-846 that are being used by the Permittee's
analytical laboratory, the Director will submit written notification to the Permittee. The
Permittee shall notify the Utah Department of Health, Bureau of Laboratory
Improvement ofthe requested update within 30 days of receipt of the Director's
determination. The Permittee shall have 180 days from the receipt of the Director's
written notification to complete the requested update. If it is not possible to complete
the update within the prescribed time, the Permittee shall submit a written request for
extension to the Director for approval.
II.D.8. If the Permittee uses a contract laboratory to perform analyses, the laboratory must be
certified by the State of Utah to perform the contracted analyses. For parameters for
which certification is unavailable, the Permittee shall ensure that quality control/quality
assurance data provided by the laboratory is sufficient to assess the validity ofthe data.
The Permittee shall inform the laboratory in writing that it must operate under the
Waste Analysis Plan conditions set forth in this Permit.
ILE SECURITY
ILE. 1. The Permittee shall comply with the security conditions and procedures contained in
Attachment 7 of this Permit.
II.F. GENERAL INSPECTION REQUIREMENTS
II.F. 1. The Permittee shall conduct inspections in accordance with UAC R315-8-2.6 and shall
follow the inspection schedule found in Attachment 2.
II.F.2. The Permittee shall remedy any deterioration or malfunction as required by UAC R315-
8-2.6(c). If the remedy requires more than 72 hours to implement from the time that the
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problem is detected, the Permittee shall submit to the Director, before the expiration of
the 72 hour period, a proposed time schedule for correcting the problem.
II.F.3. Any problem which could endanger human health or the environment shall be corrected
as soon as possible after the problem is discovered. The Permittee shall make every
effort to eliminate the threat to human health or the environment within 24 hours.
II.F.4. If, upon determination by the Director or the Permittee, continued operation of the
waste management unit involved in the inspection could endanger human health or the
environment, the Permittee shall cease operation of the unit until the problem has been
corrected. The Permittee shall be allowed to undertake those operations which are part
of corrective activities.
II.F.5. Records of inspections shall be kept as required by UAC R315-8-2.6(d).
II.G. RISK THRESHOLDS
II.G. 1. The thermal treatment operations at the M-l36 and M-225 Thermal Treatment Areas shall be
conducted to minimize the risk to human health and the environment. The risk thresholds
identified in Condition II.G. and the operating conditions identified in Module TV for the
treatment areas shall be based on the information provided or referenced in Attachments to this
Permit and the following site specific documents available for review in the Department of
Environmental Quality, Division of Solid and Hazardous Waste files:
II.G. 1 .a. Sampling Results for Emissions Characterization of Open Burning Waste Propellant Materials,
October 2009;
II.G. 1 .b. The Waste Characterization and Air Dispersion Modeling Protocol for use in the Human Health
and Ecological Risk Assessments - ATK Launch Systems - Promontory, November 2009,
January 2010;
II.G. 1 .c. The response to the Division of Solid and Hazardous Waste comments on the Waste
Characterization and Air Dispersion Modeling Protocol for use in the Human Health and
Ecological Risk Assessments, July 2010;
II.G. 1 .d. The Waste Characterization and Air Dispersion Modeling Report, to be completed in
accordance with Condition IV.M.l.
II.G. 1 .e. The Human Health Risk Assessment Protocol for OB/OD Operations at the ATK Promontory
Facility, February 2010;
II.G. 1 .f. The response to the Division of Solid and Hazardous Waste comments on the Human Health
Risk Assessment Protocol for OB/OD Operations, August 2010; and
II.G. 1 .g. The Human Health Risk Assessment Report, to be completed in accordance with Condition
IV.M.2.
II.G.2. Based on the findings of the Human Health Risk Assessment which shall be completed in
accordance with Condition IV.M.2., the Permittee shall modify this section of the permit, in
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accordance with Condition IV.M.3., to establish annual risk thresholds that minimize the risk to
human health and the environment and ensure compliance with Permit Condition IV.C.5.
II.G.3. The Permittee shall submit to the Director by March 1st of each calendar year, an annual report
on the operation of the Promontory Thermal Treatment areas. This report shall at a minimum
include the following:
II.G.3.a. An accounting of the quantities and types of reactive hazardous waste treated at the M-136 and
M-225 thermal treatment areas, including all donor material and ignition compounds;
II.G.3.b. The estimated quantity of TCDD TEQs, or other compounds as identified 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 as identified in Condition JTV.M.l.
II.G.3.c. An evaluation of the emission factors, identified in Condition II.G. 1.a., used in the human
health risk assessment to determine whether these factors are representative of the wastes
treated and identified as directed by II.G.3.a., or if the emission factors need to be updated; and
II.G.3.d. A review of the of the human health risk assessment, identified in Condition II.G. 1 .g., to
evaluate whether the slope factors and reference doses for carcinogenic and non-carcinogenic
health effects related to the 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.
II.G.4. If the Director determines after reviewing this annual report that any component of the risk
assessment needs to be updated, he will inform the Permittee in writing which components of
the human health risk assessment to update.
II.G.5. If the Permittee is required to update the human health risk assessment for the
M-136 or M-225 Thermal Treatment areas, the Permit shall be modified in accordance with
Condition I.D. of this Permit.
II.H. PERSONNEL TRAINING
II.H. 1. The Permittee shall conduct personnel training as required by UAC R315-8-2.7. This
training program shall follow the outline found in Attachment 3. New personnel
working with or around hazardous waste shall complete the required personnel training
within six (6) months of their hire date, assignment to the facility or assignment to a
new position at the facility.
II.H.2. Facility personnel shall take part in an annual review of their initial training for
contingency and hazardous waste management procedures relevant to the positions in
which they are employed.
II.H.3. The Permittee shall maintain training documents and records as required by UAC R315-
8-2.7(d) and R315-8-2.7(e) [40 CFR 264.16(d) and 264.16(e)], in accordance with the
Training Plan in Attachment 3. These records shall indicate the type and amount of
training received.
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II.H.4. The Permittee shall maintain a copy of the Training Plan at the Facility until it is fully
closed and closure is certified.
II.H.5. Employees working at the M-136 and M-225 Thermal Treatment Areas shall receive
task specific on-the-job-training in addition to the training outlined in Attachment 3.
This training shall be documented and maintained in the operating record.
ILL GENERAL REQUIREMENTS FOR IGNITABLE, REACTIVE. OR
INCOMPATIBLE WASTE
11.1.1. The Permittee shall comply with the requirements of UAC R315-8-2.8.
11.1.2. In addition to the requirements of UAC R315-8-2.8., the Permittee shall comply with
the Conditions III.G and III.H pertaining to ignitable, reactive, or incompatible waste.
ILJ. LOCATION STANDARDS
II. J. 1. The Permittee shall comply with the location standards specified by UAC R315-8-2.9.
ILK. PREPAREDNESS AND PREVENTION
ILK. 1. The Permittee shall follow the Preparedness and Prevention Plan, Attachment 8.
II.K.2. At a minimum, the Permittee shall equip and maintain in good operating condition at
the facility the equipment set forth in Attachment 8, as required by UAC R315-8-3.3.
II.K.3. The Permittee shall test and maintain the equipment specified in Condition II.K.2 as
necessary to assure its proper operation in time of emergency.
ILKA The Permittee shall maintain records of the preventative maintenance and repair
activities specified in Condition II.K.3. and shall keep schedules, reflecting minimum
and planned frequency for the performance of preventative maintenance activities in the
Operating Record at the facility.
ILK.5. The Permittee shall maintain access to the communications or alarm system as required
by UAC R315-8-3.5.
ILKA At a minimum, the Permittee shall maintain 30 inches of aisle space between containers
or pallets of containers at storage areas M-l 86 and E-501.
II.K.7. The Permittee shall attempt to make arrangements (Coordination Agreements) with
State and local authorities as required by UAC R315-8-3.7. Copies of the Coordination
Agreements shall be kept in the Operating Record. The attempts to make such
agreements, any refusals and all final agreements shall be documented in the Operating
Record.
ILL. CONTINGENCY PLAN
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II.L.l. The Permittee shall immediately carry out the provisions of Attachment 4, and follow
the emergency procedures described by UAC R315-8-4.7 whenever there is a fire,
explosion, or release of hazardous waste or hazardous waste constituents which
threatens or could threaten human health or the environment. The Permittee shall
comply with Condition LT. in reporting releases to the Director.
II.L.2. The Permittee shall provide copies of the Contingency Plan to emergency agencies who
may be called in an emergency, shall maintain a copy of the Plan at the facility, and
shall provide a copy upon request in accordance with UAC R315-8-4.4.
II.L.3. The Permittee shall review the Contingency Plan, in accordance with UAC R315-8-4.5
and shall modify it in accordance with Condition I.D., if necessary.
II.L.4. A trained emergency coordinator shall be available at all times in case of an emergency,
in accordance with UAC R315-8-4.6 and identified in Attachment 4.
II.M. MANIFEST SYSTEM
II.M. 1. The Permittee shall comply with the manifest requirements of UAC R315-5-2 and UAC
R315-8-5. The manifest tracking number shall be recorded in the Operating Record
with each waste load that arrives or leaves the Permittee's facility.
II.N. RECORDKEEPING AND REPORTING
II.N. 1. The permittee shall maintain an accurate written Operating Record at the facility in
accordance with UAC R315-8-5.3 (40 CFR 264.73 incorporated by reference) and
R315-50-2 (Appendix I to Part 264 incorporated by reference).
II.N.2. The Permittee shall, by March 1 of each year, submit to the Director a certification
pursuant to UAC R315-8-5.3 [40 CFR 264.73(b)(9) incorporated by reference], signed
in accordance with UAC R315-3-2.2, that the Permittee has a program in place to
reduce the volume and toxicity of hazardous waste that he generates to the degree
determined by the Permittee to be economically practicable; and that the proposed
method of treatment, storage, or disposal is the most practicable method currently
available to the Permittee which minimizes the present and future threat to human
health or the environment.
II.N.3. The Permittee shall comply with the biennial report requirements of UAC R315-8-5.6,
by March 1 of each even-numbered reporting year. The report shall include wastes
generated, treated or stored at the Permittee's facility during the previous odd-numbered
year.
II.N.4. The Permittee shall submit additional reports to the Director in accordance with UAC
R315-8-5.8.
II.N.5. All reports, notifications, applications, or other materials required to be submitted to the
Director shall be submitted in accordance with Condition I.DD.
II.O. CLOSURE/POST-CLOSURE
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II.O.l. The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101
and Attachment 5.
II.0.2. For all HWMUs, minor deviations from the approved closure plan procedures,
necessary to accommodate proper closure, shall be described in narrative form with the
closure certification statements. The Permittee shall describe the rationale for
implementing minor changes as part of this narrative report. Within 60 days after
completion of closure of each HWMU, the Permittee shall submit the certification
statements and narrative reports to the Director.
II.0.3. The Permittee shall amend the closure/post-closure plan in accordance with UAC R315-
8-7 and Condition I.D. whenever necessary, or when required to do so by the Director.
II.0.4. The Permittee shall notify the Director in writing of the partial closure of any portion of
the facility in accordance with UAC R315-8-7. The Permittee shall notify the Director
at least 180 days prior to the commencement of final facility closure. The closure plan
contained in Attachment 5 will be reviewed before commencing partial or final facility
closure. If the closure plan requires modification, the plan shall be modified and
submitted to the Director for approval in accordance with Condition I.D.
H.O.5. After receiving the final volume of hazardous waste, the Permittee shall treat or remove
from the site all hazardous waste and complete closure activities in accordance with the
schedule specified in Attachment 5.
H.O.6. The Permittee shall decontaminate or dispose of all facility equipment, structures, soil
and rinsate as required by UAC R315-8-7, R315-8-9 and Attachment 5. Facility
equipment, structures and soil which have not been decontaminated shall be disposed of
only at a permitted hazardous waste treatment, storage or disposal facility.
II.0.7. The Permittee shall certify that the facility has been closed in accordance with the
specifications in Attachment 5 as required by UAC R315-8-7, and shall provide a
certification by an independent, Utah registered professional engineer qualified by
experience and education in the appropriate engineering field.
II.O.8. In the event that any of the hazardous waste management units covered by this permit
cannot be clean closed by decontaminating or removing contaminated structures or soil,
or releases have occurred which have impacted soil or groundwater, the Permittee shall
modify the Closure/Post-Closure Plan for that hazardous waste management unit in
accordance with Condition I.D. Within 30 days of the date that the Director approves
the modification, the Permittee shall close the unit in accordance with the applicable
provision of UAC R315-8-7 and R315-101.
II.0.9. If a HWMU can not be clean closed, the Permittee shall submit a survey plat and
property description for the HWMU with the submission of the certification of closure
for the HWMU, in accordance with UAC R315-8-7 and R315-101.
II.P. COST ESTIMATES FOR HWMU CLOSURE
II.P. 1. The Permittee's closure cost estimate for each HWMU shall be prepared and maintained
at the facility in accordance with UAC R315-8-8 (40 CFR 264.142 incorporated by
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reference) and Attachment 5.
II.P.2. On the one year anniversary date of Permit issuance, the Permittee shall submit to the
Director for approval updated closure plans and detailed closure cost estimates for each
HWMU at the ATK facility. The closure cost estimates shall identify the costs, in
current dollars, of the steps necessary to perform final closure for each HWMU in
accordance with UAC R315-8-9.9 and UAC R315-8-8 (40 CFR 264.142 incorporated
by reference).
II.P.3. On the five year anniversary date of the submittal of the closure cost estimates required
by Condition II.P.2. above, the Permittee shall conduct a detailed evaluation of the
closure cost estimates for each HWMU and determine whether the annual adjustments
for inflation have been adequate to update the closure cost estimates. The Permittee
shall submit a report on this assessment and if necessary, a modification of the Permit in
accordance with Condition I.D. to the Director 90 days after the report is submitted.
II.P.4. The Permittee shall revise the closure cost estimate within 30 days after the Director has
approved the request to modify the affected closure plan(s).
II.P.5. For each new HWMU placed into operation, an updated closure cost estimate to the
facility must be prepared which includes the new unit, 60 days prior to waste being
placed on or into the new unit.
II.Q. FINANCIAL ASSURANCE FOR FACILITY CLOSURE
II.Q. 1. The Permittee shall demonstrate continuous financial assurance compliance by
providing a third party financial assurance certification of at least the amount of the
closure/post-closure cost estimates established in Condition II.P. The Permittee may
substitute other instruments of financial assurance provided the method, funding and
wording requirements of UAC R315-8-8 are followed and approved by the Director.
II.Q.2. The financial assurance document shall be updated within 60 days of the annual
adjustment for inflation or within 60 days of the approval of a revised closure/post-
closure cost estimate in accordance with UAC R315-8-8.
II.R. LIABILITY REQUIREMENTS
II.R. 1. The Permittee shall demonstrate continuous compliance with the liability requirements
of UAC R315-8-8 (40 CFR 264.147(a) incorporated by reference). The Permittee shall
have and maintain hazardous waste liability coverage for sudden accidental occurrences
in the amount of at least one $1 million U.S. dollars per occurrence with an annual
aggregate of at least $2 million U.S. dollars, exclusive of legal defense costs. The
Permittee shall submit an approved certificate of hazardous waste liability insurance
worded as required by UAC R315-8-8.
II.R.2. The Permittee shall demonstrate continuous compliance with the requirements of UAC
R315-8-8 (40 CFR 264.147(b) incorporated by reference) to have and maintain liability
coverage for non-sudden accidental occurrences arising from operations of the two
Hazardous Waste Management Units, designated as the M-136 and M-225 Thermal Treatment
Areas.
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II.R.2. Changes in liability coverage mechanisms shall be approved by the Director 60 days
prior to such a change.
II.S. INCAPACITY OF OWNER OR OPERATORS. GUARANTORS. OR
FINANCIAL INSTITUTIONS
II.S. 1. The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (40 CFR 264.148 incorporated by reference).
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Module III - Storage in Containers UTD009081357
MODULE III - STORAGE IN CONTAINERS
IILA. APPLICABILITY
III. A. 1. The requirements of this permit Module pertain to the operation of hazardous waste
container storage areas at the facility. The Permittee shall comply with R315-8-9 and
all conditions of this Module.
III. A.2. The designated hazardous waste storage areas are the bays of Buildings M-705S, E-501,
M-47, M-603, M-186, the burn trays at M-136, Burn Station 14 at M-136, and Storage
Pad S-633. Drawings of these storage areas are presented in Attachment 6.
IILB. WASTE IDENTIFICATION
III.B. 1. The Permittee shall, subject to the terms of this Permit, store only the following
hazardous wastes, as listed by EPA hazardous waste code, in containers at storage areas
M-186, M-705S and E-501:
D001, D002, D003, D004, D005, D006, D007, D008, D009, D010 D011, D016, D018,
D019, D021, D022, D023, D024, D026, D027,D028, D029, D035, D036, D038, D039,
D040, D042, D043, F001, F002, F003, F004, F005, F006, F007, F008, F009, K044,
P003, P012, P022, P028, P029, P030, P047, P048, P064, P067, P077, P087, P092,
P093, P095, P098, P102, P105, P106, PI 12, PI 16, PI 19, U001, U002, U004,U006,
U008, U009, U019, U025, U028, U029, U031, U037, U041, U044, U048, U053, U056,
U057, U069, U070, U072, U077, U079, U080, U085, U088, U092, U093, U095, U098,
U101, U102, U103,U105, U108, U112, Ul 13, Ul 17, U118, U120, U121, U122, U123,
U131, U133, U134, U140, U147, U148, U149, U151, U154, U156, U159, U160, U161,
U162, U165, U168, U169, U170, U171, U185, U186, U188, U190, U196, U201, U209,
U210, U211, U218, U219, U220, U221, U223, U224, U225, U226, U228, U238, U239,
U240, U243, U244, U246, U253, U328, U353, U359, U404.
III.B.2. The Permittee may store solid reactive hazardous waste, EPA hazardous waste code
D003, in storage Buildings M-47 and M-603 subject to the terms of this Permit.
III.B.3. The Permittee may store solid reactive hazardous waste, EPA hazardous waste code
D003, received from off-site in burn trays at M-136 for up to 14 days prior to thermal
treatment. Waste stored in burn trays shall be containerized only in covered drums,
boxes, plastic bags, woven bags, US Department of Transportation (DOT) approved
shipping containers or containerized as described in Attachment 11. Containers shall be
labeled and managed as specified in Attachment 9.
III.B.4. The Permittee may store waste rocket motors, EPA hazardous waste code D003,
received from off-site that contain solid propellant, one at a time on the ground at
M-136, Burn Station 14 for up to 14 days prior to thermal treatment. The waste rocket
motors shall be labeled and managed as specified in Attachment 9.
III.B.5. The Permittee may store solid reactive hazardous waste, EPA hazardous waste code
D003, on Storage Pad S-633 subject to the terms of this Permit.
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ATK Launch Systems Inc. - Promontory
Module III - Storage in Containers
Modified January, 2014
UTD009081357
III.B.6. The Permittee is prohibited from storing hazardous waste that is not identified in
Section III.B. of this Module. Any addition of hazardous waste codes to Condition
III.B. 1. requires modification of the permit in accordance with Condition I.D.3.
III.C. CONDITION OF CONTAINERS
III.C. 1. If a container holding hazardous waste is not in good condition (e.g., severe rusting,
bulging, apparent structural defects) or it has begun to leak, the Permittee shall transfer
the hazardous waste, or the container itself, to a UN approved container in accordance
with Section 8-1-10 of Attachment 8. The transfer shall be completed as soon as
possible but not later than 24 hours from the time the problem was first discovered.
HLD. COMPATIBILITY OF WASTE WITH CONTAINERS
III.D.l. The Permittee shall assure that the waste is compatible with the containers as required
by R315-8-9.3. The Permittee shall follow the compatibility plan as indicated in
Section 9-2.1 and Table 9-2 of Attachment 9.
III.E. MANAGEMENT OF CONTAINERS
III.E. 1. The Permittee shall manage containers in accordance with this module of the Permit,
UAC R315-8-9.4 and the procedures identified in Attachment 9. A container holding
hazardous waste shall always be closed during storage except when the Permittee is
adding or removing waste from the container. The Permittee shall not open, handle, or
store containers in a manner which may cause the containers to leak.
III.E.2. The Permittee shall store liquid hazardous wastes in containers only at storage areas
M-186, E-501 and M-705S. Drawings of the container storage areas are shown in
Attachment 6. At capacity, the Permittee may store the following volumes of wastes:
III.E.2.a. E-501 - 8,800 gallons, which is 160 55-gallon containers or the equivalent;
III.E.2.b. M-l86 - 22,000 gallons, which is 400 55-gallon containers or the equivalent; and
III.E.2.C. M-705S - 1,760 gallons, which is 32 55-gallon containers or the equivalent.
III.E.3. The Permittee shall store solid reactive hazardous waste in containers at storage areas
M-47, M-603, M-136 and S-633. Drawings of the storage areas are shown in
Attachment 6. At capacity, the Permittee may store the following amounts of wastes:
III.E.3.a. M-47 - 300,000 lbs 1.3 or 21,000 lbs 1.1 solid propellant;
III.E.3.b. M-603 - 120,000 lbs 1.3 or 8,000 lbs 1.1 solid reactive hazardous waste;
III.E.3.c. M-136 - 106,500 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste, as
described in Condition III.B.3. or III.B.4., in burn trays or in a rocket case placed on the
ground; and
III.EJ.d S-633 - 75,000 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste.
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Module III - Storage in Containers UTD009081357
III.E.4. The Permittee shall maintain an aisle space of 30 inches minimum between containers
or pallets of containers at storage areas M-186 and E-501.
III.E.5. The Permittee shall store hazardous wastes at M-705S, M-47, M-603, S-633 and M-136
so that the container or waste rocket motor may be readily inspected and hazardous
waste labels are visible.
III.E.6. The Permittee may stack 55-gallon drums at a maximum of two high at storage areas
M-186 and E-501.
III.E.7. Hazardous waste containers shall not be stacked at storage areas M-705S, M-47,
M-603, S-633 and M-136 except as described in Attachment 9-2.3.
III.E.8. The Permittee shall unload any transport vehicle hauling containers of hazardous waste
for storage within 10 days following arrival at the site. Arrival for purposes of this
permit shall be the day the vehicle arrives at the facility.
III.E.9. The Permittee shall provide storage for and maintain on-site, 85 gallon over-pack drums
at areas where liquid hazardous waste is stored.
III.F. CONTAINMENT SYSTEMS
III.F. 1. The Permittee shall maintain the containment systems in accordance with the attached
plans and specifications contained in Attachment 9 and as specified in UAC R315-8-
9.6.
III.F.2. Container management areas shall be inspected for the presence of free liquids in
accordance with Attachment 2. If free liquids are discovered in the sumps or other
containment areas, the Permittee shall identify the location in the inspection log. Any
liquids discovered shall be removed immediately, but in no case later than twenty-four
hours after the liquid is discovered and managed according to the spill contingency plan
specified in Section 9-4.3 of Attachment 9.
III.F.3. For purposes of inspections, all containers stored in the liquid hazardous waste storage
area shall be considered full to their respective capacities with liquid hazardous waste.
Gondolas/roll-offs that are used only for the storage of solid hazardous waste need not
be considered in the calculations for containment. The area for storing solid waste shall
be identified.
III.F.4. The burn trays at M-l 36 are only permitted for the storage of solid reactive wastes in
containers received from off-site for no more than 14 days. However since some of the
containers contain small amounts of desensitizing fluid (e.g. diesel, shingle oil, etc.), the
containment requirements, as specified in Attachment 9, apply to the storage of wastes
in the burn trays. Inspection of the burn trays shall be conducted in accordance with
Attachment 2.
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r
ATK Launch Systems Inc. - Promontory Modified January, 2014
Module III - Storage in Containers UTD009081357
III.G. SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE
III.G. 1. The Permittee shall not locate containers holding ignitable or reactive waste within 15
meters (50 feet) of the facility boundary.
III.G.2. The Permittee shall take precautions to prevent accidental ignition or reaction of
ignitable or reactive waste and follow the procedures specified in Attachment 8, UAC
R315-8-2.8 and UAC R315-8-9.7.
IILH. SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTE
III.H. 1. The Permittee shall not place incompatible wastes, or incompatible wastes and
materials, in the same container, in accordance with UAC R315-8-2.8 and UAC R315-
8-9.8(a).
III.H.2. The Permittee shall not place hazardous waste or materials in an unwashed container
that previously held an incompatible waste or material in accordance with UAC R315-
8-2.8 and UAC R315-8-9.8(b).
III.H.3. A storage container holding a hazardous waste that is incompatible with any waste or
other materials stored nearby shall be separated from the other materials or protected
from them by means of a dike, berm, wall, or other device.
III.L INSPECTION SCHEDULES AND PROCEDURES
111.1.1. The Permittee shall inspect the hazardous waste storage and treatment facilities
identified in Condition III.B. of this Permit as specified in the Inspection Schedules
contained in Attachment 2. The purpose of this inspection shall be to detect leaking
containers, standing liquids, deterioration of containers, and to detect deterioration of,
or liquids in, the secondary containment system caused by corrosion and other factors as
specified in R315-8-9.5.
111.1.2. If problems are observed during the inspections, the Permittee shall correct the problem
in accordance with Module II, Section F.
IILJ. CLOSURE/POST-CLOSURE
HI.J. 1. The Permittee shall close the storage areas in accordance with UAC R315-8-7, UAC
R315-8-9.9, Condition II.O. and Attachment 5 of this Permit.
III.J.2. Closure plans for each individual hazardous waste management area shall be submitted
to the Director for approval no less than 180 days prior to the commencement of closure
activities. No closure activities shall take place that have not received prior approval
from the Director.
4
ATK Launch Systems Inc. - Promontory Modified January, 2014
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
MODULE D7 - THERMAL TREATMENT OF ENERGETIC WASTES
IV.A. APPLICABILITY
TV. A. 1. The requirements of this permit module apply to the thermal treatment of energetic or
reactive hazardous waste at the ATK Launch Systems - Promontory facility, Box Elder
County, Utah. The Permittee shall comply with UAC R315-8 and all conditions of this
module and Permit.
IV.A.2. The permit conditions of this module allow thermal treatment at the two Hazardous Waste
Management Units, designated as the M-136 and M-225 Thermal Treatment Areas, as
designed and described in the drawings and specifications in Attachments 6 and 11. The
M-136 Thermal Treatment Area consists of 14 burn stations and 2 open detonation areas.
The M-225 Thermal Treatment Area consists of 4 burn stations and 1 open detonation area.
IV.A.3. Thermal treatment at both of the Promontory Thermal Treatment Areas shall only be
accomplished by properly trained ATK personnel in accordance with ATK's Standard
Operating Procedures, the conditions of this Permit and its attachments.
IV.A.4. This Permit has been developed in accordance with the applicable requirements of UAC
R315-1 through 101. All conditions in this Permit shall supercede conflicting statements,
requirements, or procedures found in UAC R315-1 through 101 or attachments to this
Permit.
rV.B. PERMITTED AND PROHIBITED WASTE IDENTIFICATION
rV.B. 1. The Permittee may treat energetic or reactive hazardous waste at the two Promontory
Thermal Treatment Areas by open burning and detonation. These energetic and reactive
hazardous wastes are generated from the following sources:
IV.B.l.a. Class 1.1 and 1.3 propellants and explosives manufactured at the Promontory, Bacchus, and
other ATK facilities as well as Autoliv ASP, DOD, NASA or other government and private
facilities (e.g. cured and uncured propellants, excess propellants and propellant scraps);
IV.B. 1 .b. Production materials contaminated with class 1.1 and 1.3 propellants and explosives and
reactive residues (e.g., rags, gloves, other personal protective equipment, plastics, rubber
and paper that were contaminated with explosive materials during the manufacturing
process);
IV.B.l .c. Large and small class 1.1 and 1.3 rocket motors and initiating devices;
IV.B. 1 .d. Class 1.3 Pyrotechnic, Illuminants, Metal Powders, or Autoliv ASP Products
TV.B. 1 .e. Production materials contaminated with class 1.3 Pyrotechnic, Illuminants, Metal Powders,
or Autoliv ASP Products and other reactive residues (e.g., rags, gloves, other personal
protective equipment, plastics, rubber and paper that were contaminated with explosive
materials during the manufacturing process);
IV.B. 1 .f. Reactive laboratory wastes which may contain solvents;
Page 1
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
rv.B.i.g.
rV.B.Lh.
rv.B.i.i.
IV.B.2.
IV.B.3.
IV.B.4.
IV.B.5.
IV.B.6.
rv.c.
rv.c.i.
rv.c. 1.a.
rv.c. l.b.
rv.c.i.c.
rv.c.i.d.
rv.c. I.e.
rv.c.i.f.
Wastewater treatment sludge generated from the processing of explosive ingredients and
propellants defined in UAC R315-2 as a K044 listed hazardous waste;
Reactive bag house dust generated from the processing of explosive ingredients and
propellants; and
Waste developmental propellants, explosives and associated contaminated production
materials.
Only reactive hazardous waste as defined by UAC R315-2 may be treated at the
Promontory Thermal Treatment Areas. Reactive hazardous waste thermally treated at the
Promontory Thermal Treatment Areas may contain the follow EPA waste codes: D001,
D003, D005, D007, D008, D030, D038, F001, F002, F003, F004, F005 and K044.
The Permittee is prohibited from thermally treating reactive hazardous waste classes and
compositions not included in Conditions IV.B.l. and IV.B.2. including wholly inert items,
improvised explosive devices (e.g. homemade bombs) and chemical wastes.
The Permittee is prohibited from thermally treating, by open burning, energetic reactive
hazardous wastes that will detonate under open burning conditions.
The addition of hazardous waste codes to Condition IV.B.2. requires modification of the
permit as specified in UAC R315-4-1.5 and Condition I.D.
The Permittee shall comply with the waste compatibility requirements of Condition II.I.
GENERAL OPERATING CONDITIONS
The Permittee shall comply with the following treatment limits for the M-136 Thermal
Treatment Area:
The Permittee shall not treat more than a total of 106,500 pounds of reactive hazardous
waste in a calendar day;
The Permittee shall not treat more than a combined amount of 106,500 pounds of reactive
hazardous waste in a calendar day at burn stations 1,2,3,4,5,6,7,8,9,10,11,12;
The Permittee shall not treat more than 50,000 pounds of reactive hazardous waste in a
calendar day at burn station 13;
The Permittee shall not treat more than 106,500 pounds of reactive hazardous waste in a
calendar day at burn station 14;
The Permittee shall not treat more than 600 pounds of reactive hazardous waste by open
detonation per event;
The Permittee shall operate the M-136 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11 section 5; and
Page 2
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
rv.c.i.g.
rv.c.2.
rv.c.2.a.
rv.c.2.b.
IV.C.2.C.
rv.c.2.d.
rv.c.3.
rV.C3.a.
rv.c.3.b.
IV.C.3.C.
rv.c.3.d.
rV.C3.e.
The Permittee shall not treat more than 10,000,000 pounds of reactive hazardous waste at
the M-136 Thermal Treatment Area in a calendar year. This 10,000,000 pound limit shall
be established by adding the Net Explosive Weight (NEW) and all donor and initiator
materials. Donors shall include all pallets, cardboard, packaging material, absorbents and
diesel fuel.
The Permittee shall comply with the following treatment limits for the M-225 Thermal
Treatment Area:
The Permittee shall not treat more than 4,500 pounds of reactive hazardous waste per
calendar day;
The Permittee shall not treat more than 600 pounds of reactive hazardous waste by open
detonation per event;
The Permittee shall operate the M-225 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11 section 5; and
The Permittee shall not treat more than 55,000 pounds of reactive hazardous waste at the
M-225 Thermal Treatment Area in a calendar year. This limit shall be established by
adding the Net Explosive Weight (NEW) and all donor and initiator materials. Donors
shall include all pallets, cardboard, packaging material, absorbents and diesel fuel.
The Permittee shall maintain the integrity of the Promontory Thermal Treatment Areas to
ensure that they meet the performance standards of UAC R315-8-16 and minimize the
potential impacts to human health and the environment. The Permittee shall adhere to
applicable provisions of Attachments 2 and 11 and the following conditions:
The Permittee shall conduct all open burn operations within the secure areas designated as
the M-136 or M-225 Thermal Treatment Areas with controlled access as identified in
Attachment 11;
The Permittee shall post warning signs around both of the Thermal Treatment Areas to
keep unauthorized personnel out;
The Permittee shall maintain the egress paths for both of the Thermal Treatment Areas
identified in Attachment 4;
The Permittee shall disable the firing system whenever operators are in the QD for this
treatment unit. The firing system shall only be active or armed when operators are
conducting a pre-burn continuity check, as specified in Attachment 11, Section 8.2.3, or
when the firing system is being maintained and no waste is present in the treatment area, or
after all operators have exited the treatment unit and retreated to the firing control room in
preparation of initiating an ignition as specified in Condition TV.F.2.i;
The Permittee shall assess and monitor meteorological conditions to ensure operators are
not exposed to risks from lightning strikes or other adverse weather conditions that would
preclude the safe operation of the M-136 or M-225 Thermal Treatment Areas. The
Permittee shall record the temperature, wind speed, wind direction, sky conditions and
clearing index prior to each burn in the facility operating record;
Page 3
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
rv.c.3.f.
rv.c.3.g.
rv.c.3.h.
rv.c.3.i.
rv.c.3.j.
rv.c.3.k.
rv.c.4.
rv.c.5.
rV.C.5.a.
rv.c.5.b.
rv.c.6.
rV.C.6.a.
The Permittee shall comply with all requirements for pre-placement of waste, placement of
waste in treatment units, wiring and ignition and the post-burn inspection and clean up
activities identified in Condition IV.D, E, F, G, H and I;
The Permittee shall provide operators with access to a telephone that can be used to contact
support personnel, including security, safety and fire fighting units, whenever the operators
are inside the M-136 or M-225 Thermal Treatment Areas;
The Permittee shall maintain the integrity of the two Promontory Thermal Treatment Areas
and support equipment through regular inspections and in accordance with the inspection
plan in Attachment 2. Inspection records shall be maintained at the facility;
The Permittee shall train all operators of the Promontory Thermal Treatment Areas in
accordance with Condition II.H. and Attachment 3 of this Permit;
The Permittee shall not operate either of the Promontory Thermal Treatment Areas without
containment measures (e.g. firebreaks) to assure the confinement and control of any fire
resulting from the open burn and open detonation operations at the Promontory Thermal
Treatment Areas; and
The Permittee shall not treat propulsive items at the Promontory Thermal Treatment Areas,
unless the item has been rendered non-propulsive or is contained in accordance with
Attachment 11.
The Permittee shall operate the Promontory Thermal Treatment Areas to prevent
unacceptable risk of cancer and non-cancer effects to on-site workers and off-site residents
and to minimize significant effects to the ecosystem surrounding the Promontory Thermal
Treatment Areas. The Permittee shall maintain compliance with the environmental
performance standards listed in UAC R315-8-16 and comply with Permit Condition II.G.2.
The Permittee shall adhere to the following conditions to prevent unacceptable risk of
cancer and non-cancer effects due to exposure to emissions from the open burning
operations:
The cumulative carcinogenic risk to on-site workers shall not exceed an occurrence rate of
1.0 X 10"4 (one in ten thousand) for the closest potential receptors which are Promontory
facility workers. The risk shall be calculated in accordance with Section II.G.; and
The cumulative carcinogenic risk to actual or potential off-site receptors shall not exceed
1.0 X IO-6 (one in a million). The cumulative non-carcinogenic hazard to actual or
potential off-site receptors shall not exceed a hazard index of 1.0 for any 24-hour period
following initiation of a burn. The cumulative carcinogenic risk and non-carcinogenic
hazard to actual or potential off-site receptors shall be calculated in accordance with
Section II.G.
Based on the air dispersion and deposition modeling and the human health risk assessment
to be completed in accordance with Conditions IV.M.l. and IV.M.2. for the Promontory
Thermal Treatment Areas, the Permittee shall adhere to the following conditions:
ATK shall notify the Box Elder County Fire Marshall's Office and obtain a clearing index
before each treatment operation involving reactive material;
Page 4
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
rv.c.6.b.
IV.C.6.C.
IV.D.
rv.D.i.
rv.E.
rv.E.i.
rv.E. 1.a.
rv.E.i.b.
rv.E.i.c.
rv.E.i.d.
rV.E.l.e.
rv.E.i.f.
rv.F.
rv.F.i.
The Permittee shall only conduct burns when the surface wind speed is not greater than 15
miles per hour; and
The Permittee may conduct burns and open detonations only between the hours of 10:00
am and 6:00 pm.
WASTE TRACKING
The Permittee shall track all reactive hazardous waste in accordance with Attachment 11
and maintain this information in the operating record for both of the Promontory Thermal
Treatment Areas.
PRE-BURN ACTIVITIES
Prior to bringing any reactive hazardous waste into either of the Promontory Thermal
Treatment Areas for thermal treatment, The Permittee shall conduct pre-burn activities in
accordance with the requirements identified in Attachment 11, and the pre-burn inspection
requirements in accordance with the inspection schedule included in Attachment 2. The
Permittee shall also comply with the following conditions:
If the treatment units have not been inspected the same day the unit is loaded, the treatment
unit shall be inspected prior to placing reactive waste in the treatment unit;
Any treatment unit that fails one or more of the inspection criteria shall be removed from
service until the problem is corrected;
No treatment is permitted unless either radio or telephone communication with emergency
services is available;
No treatment is permitted if the emergency equipment listed in Attachment 2, Table II-B,
"Inspection Schedule for Thermal Treatment Area at M-136" or Table II-C, "Inspection
Schedule for Thermal Treatment Areas at M-225" is not available for use at each respective
location;
All leaks or spills of diesel fuel shall be cleaned up before the Promontory thermal
treatment areas can be operated; and
The loss of the flashing light will require that the unit be shut down until the problem is
corrected. If the Permittee must use the treatment unit when the flashing light is not
working, the supervisor shall visually inspect the area within the QD of the treatment unit
and assure that no unauthorized employees are present in the area. If any unauthorized
employees are found within this area, they will be escorted from the area. Treatment
operations can commence once the supervisor verifies in the operating record that the area
is clear.
PREPARING WASTE FOR THERMAL TREATMENT BURN
Prior to placing any reactive hazardous waste in a treatment unit, the Permittee shall
comply with all provisions Conditions IV.C, D and E of this Permit. The Permittee shall
also comply with the following conditions:
Page 5
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
rV.F. 1 .a. There shall be at least two operators present when a treatment unit is in the process of being
loaded with reactive hazardous wastes as defined in Condition IV.B.l;
rV.F. 1 .b. The treatment unit shall be loaded in accordance with internal safety procedures and the
ATK Hazardous Operation Standard 1-3 Handling & Disposal of Explosives & Other
Hazardous Wastes, an internal and confidential document which is part of the operating
record, and the provisions identified in Attachment 11.8.2.2;
rV.F.l .c. All cardboard, wood and diesel used as donor material to assure a complete burn shall be
counted towards the daily treatment limits, and recorded in the operating record;
rV.F. 1 .d. All reusable propellant buckets used as accumulation containers for reactive waste shall be
inspected after use. If there is any contamination in the containers they shall be cleaned or
decontaminated in accordance with the procedures identified in Attachment 11 before being
reused;
rV.F. 1 .e. The Permittee shall document in the operating record the burn station for each container of
reactive hazardous waste treated.
rV.F.2. Prior to beginning the final preparations for an open burn, the Permittee shall comply with
the following conditions:
IV.F.2.a. Reactive waste shall not be prepared for ignition, as described in Attachment 11.8.2.3, until
all non-essential personnel leave the treatment area;
IV.F.2.b. All wiring and ignition operations, described in Attachment 11.8.2.3, shall be conducted by
at least two employees;
JV.F.2.C. The Permittee may reactivate the firing system treatment areas only after all operators have
exited the QD for the treatment unit;
IV.F.2.d. As the operators leave the treatment area following operations described in Attachment 11,
Section 8.2.3, they shall close the gate to the treatment area;
IV.F.2.e. After all operators have exited the treatment area and retreated to the firing control room,
the operators may replace the firing system interlock in the firing system control console
and activate the firing system;
rV.F.2.f. After activating the firing system, the operators shall confirm that the flashing red light was
activated to alert all personnel that a treatment event is about to start and that they should
vacate the QD area for the treatment area. If the flashing light is not operational, the
Permittee shall comply with Condition IV.E.l.f. before initiating the thermal treatment;
rV.F.2.g. After the warning identified in Condition IV.F.2.f. has been completed, the Permittee shall
conduct a pre-ignition continuity check of the firing system to assure that the igniters have
been installed correctly into the hard-wired portion of the firing system. If any firing
circuit fails this test, the Permittee shall perform the following tasks:
IV.F.2.g.i. Remove the interlock for the firing control system, deactivating the firing control system;
IV.F.2.g.ii. At least two operators shall reenter the treatment area, and correct the problem;
Page 6
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
IV.F.2.g.iii. If the resistance problem cannot be immediately corrected, the operators may connect a
separate igniter wire to an adjacent stanchion; and
IV.F.2.g.iv. After the problem with the firing circuit has been corrected the operators shall repeat the
steps described in Conditions IV.F.2.g.
IV.F.2.h. The treatment units shall be fired in accordance with the provision of Attachment 11,
Section 8.2.3 of this Permit;
rV.F.2.i. All thermal treatment events shall be observed with a video camera from the firing control
room or immediately outside the firing control room;
rV.F.2.j. In the event that none of the treatment units ignite, the operators shall wait 30 minutes
before removing the firing system interlock and reentering the treatment area to correct the
problem. After correcting the problem, the operators shall repeat the steps described in
Conditions IV.F.2.C, d, e, f and g, and proceed with activating the firing system;
IV.F.2.k. If at least one treatment unit ignites, then the operators shall wait at least 16- hours before
reentering the treatment area, and correcting the problem. After the problem has been
corrected, the operators shall repeat the steps described in Conditions IV.F.2.C, d, e, f and g,
and proceed with activating the firing system;
1V.F.2.1. Prior to ignition, the area supervisor or designee, shall review the placement of the waste on
the treatment units; and
IV.F.2.m. All treatment data shall be maintained in accordance with the requirements of UAC R315-
8-5.3 and shall be entered into the operating record for the Promontory facility in
accordance with attachment 11.6.
IV.G. POST-BURN ACTUVTIES
rV.G. 1. Following treatment, the Permittee shall conduct the post-burn inspection activities
identified in Attachment 2, and clean up activities identified in Attachment 1 lof this
Permit, and shall comply with Conditions IV.C.l, 2 and 3, and shall have completed and
complied with all provisions of Conditions, IV.E and F.
IV.G.2. The post-burn inspection shall be conducted within 24 hours of completing a treatment
event, and perform the following unless one of the exceptions identified in IV.G.2.j or k
applies:
IV.G.2.a. Prior to entering the treatment area, the operators shall deactivate the firing control system
and remove the interlock;
IV.G.2.b. Document any treatment unit with an open flame, hot spot or smoldering residue;
IV.G.2.C. Document any treatment unit with unburned residue;
rv. G.2.d. Document any treatment unit with unburned reactive hazardous waste and identify if
possible in the operating record why the waste did not burn;
rV.G.2.e. Inspect for any unburned waste that was ejected from a treatment unit during the last
treatment event. Such waste shall be picked up and placed in a treatment unit;
Page 7
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
IV.G.2.f.
IV.G.2.g.
rV.G.2.h.
rV.G.2.i.
rv.G.2.j.
IV.G.3.
rV.G.3.a.
IV.G.3.b.
IV.G.3.C.
IV.G.4.
rV.G.4.a.
rV.G.4.b.
Record on the inspection form the date that the treatment units were cleaned, or the reason
why the units were not cleaned within 24 hours after completing the treatment event;
Identify the treatment unit where unburned waste is being stored;
Evaluate the condition of the safety equipment identified in Attachment 2, Table II-B and
Table II-C;
The Permittee may postpone post-burn activities if lightning strikes or adverse weather
conditions prohibit the safe operation of the treatment areas. Lightning strikes closer than
30 miles restrict attended operations at the Promontory Facility. The Permittee shall
document the reasons for the delay in the facility's operating record; and
The Permittee may delay the post-burn inspection for burns involving bulk propellant and
bulk explosives that occurred on a Friday. The post-burn inspection shall be conducted on
the following Monday, unless the meteorological conditions identified in Condition
IV.G.2.i. prohibit re-entry into the treatment area. The Permittee shall document the
reasons for the delay in the facility's operating record.
Within 24 hours of completing an open burn that generates a characteristic or listed ash or
residue, the Permittee shall remove all characteristic or listed residues from the treatment
area and manage the waste in accordance with R315-5 of the UAC. If meteorological
conditions exist, as identified in Condition J7V.G.2.i., that prohibit re-entry into the
treatment area within the 24 hour period, the Permittee shall document the following
information in the operating record:
The reason for the delay in doing the post-burn clean up;
The date when the treatment unit was cleaned; and
Except as delayed by the conditions described in Condition IV.G.2.i, the area supervisor, or
designee, shall review the Promontory Thermal Treatment Areas log and post-burn
inspection forms within 24 hours of completing a thermal treatment event. The review
shall assure that all of the recorded information is correct and identify any items that may
require corrective action including any treatment unit that failed to ignite, had an ignition
problem or misfired, had an unplanned detonation, where the burn did not propagate as
expected or any other unexpected event.
Open burn operations at the Promontory Thermal Treatment Areas may result in the
generation of untreated residue and unburned wastes. The Permittee shall manage these
residues and wastes in accordance with the following provisions:
Small amounts of untreated residue shall be considered newly generated waste and shall be
logged and tracked as such in the explosive waste tracking system. This small amount is
defined as less than 5% of the total volume placed treatment unit. The primary option for
managing this waste is to burn it by 6:00 pm of the following calendar day. If the untreated
residue cannot be treated by 6:00 pm of the following calendar day then it shall be managed
in accordance with UAC R315-5;
Unburned waste resulting from a misfire or an interrupted ignition shall be treated by 6:00
pm of the calendar day following the date of the first attempt to treat this waste. For the
purposes of this Permit, an interrupted ignition occurs when anything greater than 5% of
Page 8
ATK Launch Systems Inc. - Promontory Modified January, 2014
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
the waste placed on in a treatment unit or in a station fails to ignite. This unreacted waste
shall not be considered a newly generated residue. If the Permittee is unable treat the
unburned waste by 6:00 pm of the following calendar day, the Permitttee shall cover the
waste and manage the treatment unit or station in accordance with UAC R315-5. If the
cumulative storage time for the unburned waste both while in storage prior to treatment and
while on the treatment unit or in the burn station is greater than 90 days, the Permittee shall
request an emergency storage permit in accordance with UAC R315-3-6.2;
rV.GAc. For reactive hazardous wastes that have been in storage for greater than 90 days when they
are placed on in a treatment unit or in a burn station and which do not completely burn, the
Permittee shall treat all unburned or unreacted waste by 6:00 pm of the calendar day
following the date of the initial attempt to treat the waste. If the Permittee is unable to treat
the unburned or unreacted waste by 6:00 pm of the following calendar day, then the
Permittee shall request an emergency storage permit in accordance with UAC R315-3-6.2;
and
IV.G.5. The Permittee shall manage all treatment residues generated from the treatment of listed
and/or characteristic wastes during post-burn activities in accordance with this Permit and
UAC R315-5.
rV.H. STORMWATER MANAGEMENT AND RUN-ON AND RUN-OFF CONTROLS
rV.H. 1. The Permittee shall manage all stormwater collected from treatment units in accordance
with this Permit, Attachment 11, Section 11 and UAC R315-5.
IV.H.2. The Permittee shall maintain run-on diversion structures in accordance with this Permit and
UAC R315-8-16 which incorporates by reference 40 CFR 264.601. The Permittee shall
inspect the condition of those structures annually to assure that they are in good repair. The
annual inspection shall be documented in the operating record for Promontory Thermal
Treatment Areas.
IV.H.3. Run-off from precipitation that falls within the operating area of the Promontory Thermal
Treatment Areas shall be managed in accordance with UAC R315-8-16, which incorporates
by reference 40 CFR 264.601, using berms, and ground slope.
IV.H.4. The Permitee will submit a proposal for managing run-off precipitation within 180 days
from the issue date of this permit.
rV.I. TREATMENT RESIDUE AND ASH MANAGEMENT
IV.1.1. All treatment residue and ash generated from the Promontory Thermal Treatment
operations shall be managed in accordance with Condition IV.G.5. and the procedures
identified in Attachment 11.
IV.I.2. Sampling and analysis of treatment residues and ash generated during operations at the
thermal treatment areas shall be performed in accordance with Attachment 1 and 11.
rVJ. INSPECTION SCHEDULES AND PROCEDURES
rV.J. 1 The Permittee shall conduct inspections of the Promontory Thermal Treatment areas in
accordance with Attachment 2 and 11.
Page 9
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
IV.K.
rv.K.i.
rV.K.l.a.
rv.K.i.b.
IV.K.1.C.
IV.K.2.
rv.K.3.
IV.K.4.
rV.K.4.a.
IV.K.4.b.
rv.L.
rv.L.i.
ENIVRONMENTAL MONITORING REQUIREMENTS
Within 180 days of issuance of this Permit or completion of the Human Health Risk
Assessment, whichever occurs later, the Permittee shall submit a Soil Monitoring Plan to
the Director for approval. The Soil Monitoring Plan shall, at a minimum, address the
following:
The impact of thermal treatment operations on soils within the treatment zone as identified
by the air dispersion and deposition model contained in the human health risk assessment
identified in Condition II.G.l.;
Risks to human health from exposure to media impacted by emissions from the Promontory
Thermal Treatment Areas operations shall be assessed. Acceptable risks are specified in
Conditions Fv\C.5.a. and IV.C.5.b. The receptors to be evaluated are listed in the Human
Health Risk Assessment identified in Condition II.G.l. The risk assessment methodology
shall be consistent with UAC R315-101; and
The plan shall identify analytes, sampling protocols and data quality objectives for the soil
monitoring program.
If the Director does not approve the Soil Monitoring Plan, he shall provide written
comments to the Permittee identifying the deficiencies in Soil Monitoring Plan. The
Permittee shall address the comments and submit a revised Soil Monitoring Plan to the
Director for approval within 60 days of receipt of written comments.
Within 30 days of receipt of the Director's approval of the Soil Monitoring Plan, the
Permittee shall submit a request to modify the Permit in accordance with Condition I.D. to
incorporate the requirements of the Soil Monitoring Plan into this Permit.
Within 180 days of the issuance of this Permit, or completion of the Human Health Risk
Assessment, whichever occurs later, the Permittee shall submit a Groundwater Monitoring
Plan to the Director for approval. The Groundwater Monitoring Plan shall, at a minimum,
address the following:
The impact of thermal treatment operations on groundwater up and down gradient of the
M-136 and M-225 Thermal Treatment Areas; and
The plan shall identify analytes, sampling protocols and data quality objectives for the
groundwater monitoring program. In addition, the plan shall propose a statistical method
for determining if existing groundwater contamination concentrations increase due to
ongoing thermal treatment operations.
ECOLOGICAL RISK
Within 180 days of issuance of this Permit or completion of the human health risk
assessment, which ever occurs later, the Permittee shall submit an Ecological Risk
Assessment Protocol document for evaluating thermal treatment operations to the Director
for approval. If the Director does not approve the Ecological Risk Assessment Protocol
document, he shall provide written comments to the Permittee identifying the deficiencies
in Ecological Risk Assessment Protocol document.
Page 10
ATK. Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
IV.L.2.
IV.L.3.
rv.M.
rv.M.i.
rv.M.2.
rv.M.3.
rv.N.
rv.N.i.
rv.o.
rv.o.i.
The Permittee shall address the comments and submit a revised Ecological Risk
Assessment Protocol document to the Director for approval within 60 days of receipt of
written comments.
Within one year of receiving approval of the Ecological Risk Assessment Protocol
document, the Permittee shall submit an Ecological Risk Assessment for evaluating thermal
treatment operations to the Director for approval. If the Director does not approve the
Ecological Risk Assessment, he shall provide written comments to the Permittee
identifying the deficiencies in Ecological Risk Assessment. The Permittee shall address the
comments and submit a revised Ecological Risk Assessment to the Director for approval
within 60 days of receipt of written comments.
Within 30 days of receiving approval of the Ecological Risk Assessment, the Permittee
shall submit a request to modify Condition II.G. of this Permit in accordance with
Condition I.D. to add performance standards for the acceptable ecological risk associated
with the operation of both of the Promontory Thermal Treatment areas.
HUMAN HEALTH RISK
The Permittee shall submit the Waste Characterization and Air Dispersion Modeling
Report, which will be used in the Human Health Risk Assessment, within 120 days of
receiving approval for the Waste Characterization and Air Dispersion Modeling Protocol
from the Director. If the Director does not approve the Waste Characterization and Air
Dispersion Modeling Report, he shall provide written comments to the Permittee
identifying the deficiencies in the document. The Permittee shall address the comments
and submit a revised Waste Characterization and Air Dispersion Modeling Report to the
Director for approval within 60 days of receipt of written comments.
The Permittee shall submit the Human Health Risk Assessment Report within 90 days of
receiving approval for both the Human Health Risk Assessment Protocol and the Waste
Characterization and Air Dispersion Modeling Report. If the Director does not approve the
Human Health Risk Assessment Report, he shall provide written comments to the Permittee
identifying the deficiencies in the document. The Permittee shall address the comments
and submit a revised Human Health Risk Assessment Report to the Director for approval
within 60 days of receipt of written comments.
Within 30 days of receiving approval of the Human Health Risk Assessment, the Permittee
shall submit a request to modify Section II.G. of this Permit, in accordance with Condition
I.D., to establish annual risk thresholds that are based on the findings of the approved
human health risk assessment for operation of both of the Promontory Thermal Treatment
areas.
FACILITY MODIFICATION/EXPANSION
Modification of the design plans and specifications in Attachment 6 or construction of
additional treatment units shall be allowed only in accordance with UAC R315-4-1.5.
CLOSURE AND POST CLOSURE
The Permittee shall close the Promontory Thermal Treatment Areas in accordance with the
Closure Plan in Attachment 5.
Page 11
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified January, 2014
UTD009081357
rv.p.
IV.P.1.
rv.p. 1.a.
rv.p.i.b.
rv.p.i.c.
IV.P.1.d.
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PROMONTORY THERMAL TREATMENT AREAS OPERATING RECORD
The Permittee shall maintain an operating record at the Promontory facility that describes
the operation of the Thermal Treatment areas. The operating records for the M-136 and
M-225 Thermal Treatment Areas shall, at a minimum, include the following information:
All information required by UAC R315-8-5.3;
Copies of all inspections required by this module;
All waste tracking information maintained in the electronic Waste Tracking Record
identified in Attachment 11;
A description of the meteorological conditions described in Condition IV. C.3.e during
each burn;
Copies of all reports identified in Condition II.G.l. and required by Condition II.G.2. and
rV.K and IV.L; and
A running total of the type and quantity of reactive hazardous waste that has been treated at
both of the Promontory Thermal Treatment areas during the calendar year.
Page 12
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Module V - Treatment of Waste Hydrazine
Modified January, 2014
UTD009081357
MODULE V - TREATMENT OF WASTE HYDRAZINE
V.A. APPLICABILITY
V.A. 1. The Permittee may treat hydrazine, EPA hazardous waste code Ul33, by
dilution, at Building T-29B, for the sole purpose of safely shipping the
resultant waste to an off-site disposal facility in accordance with this
Module and Attachment 10.
V.A.2. The treatment process shall be conducted in a manner that will ensure
protection of human health and the environment.
V.A.3. Once the hydrazine is determined to be a hazardous waste it will be
managed in accordance with Attachment 10 and 40 CFR 262.34 until it is
shipped to an approved hazardous waste management facility for disposal
or transferred to the M-186 Hazardous Waste Storage Facility.
V.A.4. The Permittee shall comply with the requirements specified in the facility
Contingency Plan (Attachment 4), when there has been a release at
Building T-29B that threatens human health or the environment.
V.A.5. The Permittee shall take precautions to prevent accidental ignition or
reaction of the waste hydrazine and follow the procedures specified in
UAC R315-8-2.8.
V.A.6. The Permittee shall inspect Building T-29B in accordance with the
inspection schedule contained in Attachment 2.
V.B. RECORD KEEPING AND REPORTING
V.B. 1. The Permittee shall record in the operating record the following:
V.B. 1 .a. The date that waste hydrazine is received at T-29B;
V.B. 1 .b. The quantity of waste hydrazine received;
V.B. 1 .c. The date the waste hydrazine is treated by the dilution process;
V.B.I .d. The quantity of diluted hydrazine after the dilution process is complete;
and
V.B. 1 .e. The date the diluted hydrazine is shipped off-site or to the M-186 storage
facility.
ATK Launch Systems Inc. - Promontory
Module V - Treatment of Waste Hydrazine
Modified January, 2014
UTD009081357
V.C. CLOSURE
V.C. 1. The Permittee shall close Building T-29B in accordance with R315-8-7,
R315-8-9.9, Permit Condition II.O. and the designated Closure Plan in
Attachment 5 of this Permit.
HAZARDOUS WASTE MANAGEMENT
Contingency Plan and
Emergency Procedures
For Spills of
Hazardous Materials
January 2014
ATK Launch Systems
Promontory Plant
P.O. Box 707 Brigham City UT 84302-
[phone]
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
PREFACE
This document, HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES FOR SPILLS OF HAZARDOUS MATERIALS, (herein referred to as Contingency Plan), provides
written instructions on how to take care of spills of hazardous substances. It is intended to meet the requirements of
the Utah Hazardous Waste Rules and Subpart D of the EPA Resource Conservation and Recovery Act.
This CONTINGENCY PLAN does not replace, nor is it to be used instead of, the ATK Launch Systems -
Promontory EMERGENCY AND DISASTER RESPONSE PLAN, or any other plan which outlines procedures to
be followed during general emergencies, disasters, civil disturbances, riots, bomb threats, etc.
Most spills involving hazardous substances will not require use of the EMERGENCY AND DISASTER
RESPONSE PLAN. Spills that create an emergency situation involving possible injury to personnel or damage to
property will require use ofthe EMERGENCY AND DISASTER RESPONSE PLAN to take care ofthe emergency.
This CONTINGENCY PLAN applies to containment and cleanup of a hazardous waste spill.
Definitions in the HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES reflect EPA and State of Utah environmental language while those in the EMERGENCY AND
DISASTER RESPONSE PLAN reflect OSHA, UOSH, FEMA, and ATK Launch Systems language. The user must
be careful not to be confused by differences in language between these documents and must evaluate the
applicability of each document to the particular situation.
ATK Launch Systems - Promontory January, 2014
Attachment 4 - Contingency Plan UTD009081357
TABLE OF CONTENTS
I. INTRODUCTION
A. PURPOSE
B. SCOPE
C. NOTIFICATION
D. POSTING
E. REVISIONS AND UPDATING
F. DEFINITIONS 2
G. PLANT LOCATIONS AND SITE INFORMATION 5
H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES 7
II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION 7
A. EVACUATION CRITERIA 7
B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL 7
C. REPORTING OF EMERGENCY INCIDENTS 8
D. PERSONNEL RESPONSIBILITIES 8
E. ALARM SYSTEMS 19
F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND
HOSPITALS 15
III. SPILL CONTAINMENT AND CLEANUP 16
A. CONTROL PROCEDURES 16
B. SPILL CONTAINMENT AND CONTROL 16
C. SPILL CLEANUP 16
D. FOLLOWUP PROCEDURES 17
E. INCOMPATIBLE WASTE 18
F. CLEANUP MATERIAL AND EQUIPMENT 18
G. DECONTAMINATION EQUIPMENT AND PROCEDURES 20
H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT 20
IV. INSTALLATION RESPONSE TEAM TRAINING 21
A. TRAINING 21
B. SIMULATION 22
V. TRAINING PLAN 22
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN 22
B. REVIEW OF LEGAL REQUIREMENTS 22
C. LOCAL ATK CORPORATION REQUIREMENTS 22
D. CUSTOMER REQUIREMENTS 22
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER. 22
F. EMERGENCY COMMUNICATION SYSTEM 22
G. FIRE PLANS/FIRE DRILL 22
H. BOMB SEARCH TECHNIQUES 22
I. FIRE BARRICADE/CORDON AREAS 23
J. EMERGENCY MEDICAL TREATMENT 23
K. SECURITY OF SITE 23
L. INVESTIGATION 23
M. PUBLIC RELEASE OF INFORMATION 23
N. FACT-FINDING METHODS 23
O. SAFING THE AREA 24
P. CONTROL OF THE CURIOUS 24
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Attachment 4 - Contingency Plan
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UTD009081357 i - «
Q. HANDLING OF REMAINS 24
R. NOTIFICATION PROCEDURES 24
S. RESCUE EFFORTS 24
TABLES
TABLE I COMPATIBILITY INFORMATION 25
TABLE II EMERGENCY COORDINATOR CALL LIST 26
FIGURES
FIGURE 1. DECONTAMINATION/SPILL SCENE 27
FIGURE 2. DECONTAMINATION 28
APPENDIX I
NORTH PLANT SITE MAP 30
SOUTH PLANT SITE MAP 31
TEST AREA SITE MAP 32
PLANT 3 SITE MAP 33
M-136 BURNING GROUNDS FACILITY FUNCTION TABLE 34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE 34
M-136 SITE MAP AND EVACUATION PLAN 35
M-186 SITE MAP AND EVACUATION PLAN 36
E-501 STORAGE YARD FACILITY FUNCTION TABLE 37
E-501 SITE MAP AND EVACUATION PLAN 38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE 39
M-225 SITE MAP AND EVACUATION PLAN 40
T-29B SATELLITE ACCUMULATION AREA FUNCTION TABLE 41
T-29B SITE MAP AND EVACUATION PLAN 42
M-705 WASTEWATER TREATMENT FACILITY FUNCTION TABLE 43
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM 43
M-705 SITE MAP AND EVACUATION PLAN 44
M-47 PROPELLANT STORAGE FUNCTION TABLE 45
M-47 SITE MAP AND EVACUATION PLAN 46
M-603 PROPELLANT STORAGE FUNCTION TABLE 47
M-603 SITE MAP AND EVACUATION PLAN 48
S-633 PROPELLANT STORAGE FUNCTION TABLE 49
S-633 SITE MAP AND EVACUATION PLAN 50
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I . , Attachment 4 - Contingency Plan
January, 2014
UTD009081357
APPENDIX II
A. BULK FLAMMABLE LIQUID STORAGE AREAS 50
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE 51
APPENDIX III
ARRANGEMENTS WITH LOCAL AUTHORITIES 52
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I. INTRODUCTION
A. PURPOSE
This plan may be activated by requesting emergency response on phone number 2222 or 911.
The purpose of this Contingency Plan and Emergency Procedures is to set forth responsibilities,
establish organizational structure, and outline the procedures required to ensure effective warning,
response, and control to minimize hazards to human health or the environment from fires, explosions,
or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to
air, soil, or surface water.
B. SCOPE
This organizational plan is intended to meet requirements of the Utah Hazardous Waste Management
Rules and Subpart D of the Resource Conservation and Recovery Act.
The provisions of this plan will be carried out immediately whenever there is a fire, explosion, or
release of hazardous waste or hazardous waste constituents at one of the permitted facility that could
threaten human health or the environment. This plan specifically addresses company actions to be
initiated in the event of a spill or release of hazardous materials.
C. NOTIFICATION
Incidents covered by this contingency plan and which meet applicable State of Utah and U.S. EPA
reporting requirements will be reported to the appropriate agencies by Environmental Specialists. The
Environmental Specialist should confer with the Director or Manager of Environmental Services prior
to notification.
D. POSTING
Copies of the Contingency Plan and all revisions must be:
1. Maintained at the facility and the Fire Department's Spill Response vehicle.
2. Submitted to all local police departments, fire departments, hospitals, and State and local
emergency response teams that may be called upon to provide emergency services.
(Arrangements have been made between ATK Launch Systems - Promontory and the hospitals
located at Brigham City and Tremonton regarding emergency services that would be provided as
required. Letters of agreement are kept in the Environmental Services Central Files.)
E. REVISIONS AND UPDATING
This contingency plan will be reviewed and amended whenever:
1. Applicable regulations are revised.
2. The plan fails in an emergency.
3. The facility changes its design, construction, operations, maintenance, or other circumstances in
a way that materially increases the potential for fires, explosions, or release of hazardous waste
or hazardous waste constituents, or changes the response necessary in an emergency.
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UTD009081357
4. The list of emergency coordinators change.
5. The list of emergency equipment changes.
F. DEFINITIONS
1. Disaster - An event in which loss of life, serious and/or multiple injuries, major property or
environmental damage, or major disruption of normal operations has occurred. This includes
serious fires or major hazardous material spills, explosions, injuries to multiple people, and acts
of nature such as floods, violent storms, or earthquakes.
2. Discharge - The accidental or intentional spilling (see Spill), leaking, pumping, pouring,
emitting, emptying, or dumping of hazardous waste on or into the air, land, or water.
3. Emergency - A situation which, if not quickly controlled, can lead to death, serious and/or
multiple injuries, major loss or damage to property, significant damage to the environment, or
disruption of normal operations.
4. Emergency Command Unit - The group of personnel selected by the emergency commander to
assist in the full scope administration of the emergency.
5. Emergency Commander - The General Manager or his designee, as head of the Command
Unit, is responsible for the overall direction, coordination, and function of all units charged with
providing countermeasures to cope with conditions and/or events within the scope of this plan.
The Command Unit will consist of any and all persons selected by the Emergency Commander.
NOTE
The Emergency Commander will be the head of the Command
Unit for all civil disturbances, bomb threats, national
emergencies, and natural disasters.
The Command Unit will operate from a pre-designated Emergency Operations Center specified
by the Emergency Disaster Response Plan or the Emergency Commander.
6. Emergency Operations Center (E.O.C.) - The location of senior management where decisions
and incident specific policies are made.
7. Environmental Specialist - The Environmental Specialist is the Spill Team Leader from
Environmental Services. He or his designated alternate will assist the Incident Commander in
the evaluation ofthe impact on the environment resulting from any emergency, disaster, or
hazardous substance discharge.
NOTE
When required, notification of Federal, State, and/or local
environmental agencies shall be through the Environmental
Specialist. Company policy requires that the event be discussed
with the Vice President of the applicable division and ATK
Corporate Environmental.
8. Fire Brigade - A group of employees, generally from maintenance, who have received
HAZWOPER training and are called on as needed to assist the full-time fire department in
emergency response.
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Attachment 4 - Contingency Plan
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UTD009081357 x t
9. Fire Warden - A designated individual assigned in advance to assist the fire department in
evacuation procedures and give information on the building and surrounding area.
10. Hazardous Waste - Identified in 40 CFR 261 and in Utah Hazardous Waste Management Rules,
Section 2.1 on the basis of specific listed material and general characteristics. Specific listed
wastes are found in these documents. The EPA regulations provide detailed technical
specifications of four characteristics:
Ignitable (D001) - An ignitable compressed gas, an oxidizer, a liquid having a flashpoint <
140 F, or a non-liquid capable of causing fire, under standard temperature
and pressure, through friction, absorption, moisture, or spontaneous chemical
changes.
Corrosive (D002) - A solid waste that (1) is aqueous and has a pH < 2 or > 12.5; or (2) is a
liquid and has a corrosion rate > 0.25 inches/year on steel.
Reactive (D003) - A solid waste that:
a. Is unstable and readily undergoes violent change without detonating.
b. Reacts violently with water.
c. Forms potentially explosive mixtures with water.
d. Generates toxic gases, vapors or fumes in a quantity sufficient to present
a danger to human health or the environment when mixed with water.
e. Is a cyanide or sulfide bearing waste which can generate toxic gases,
vapors, or fumes in a quantity sufficient to present a danger to human
health or the environment when exposed to pH conditions between 2 and
12.5.
TCLP Toxicity - (as determined by Toxicity Characteristic Leachate Procedures) - Presence of
certain listed toxic materials at levels greater than those specified in the
regulation.
11. Chemical Safety Software EMS-E - a computer based system which contains a scanned image
of the MSDS, plus additional safety and disposal information.
12. Hazardous Waste Profile Data (HWPD) Sheet - An ATK document that lists all EPA, DOT,
and chemical information needed for marking, labeling, and identifying waste streams on plant.
13. Hazardous Waste Operations and Emergency Response (HAZWOPER) - Refers to specific
training requirement for handling hazardous materials and for emergency operations. These
requirements are found in 29 CFR 1910.120.
14. Human Resource Coordination - An intermediate between management and personnel who
deals with employee concerns and interests.
15. Incident Commander/Emergency Coordinator - The Incident Commander will be the on-duty
Assistant Fire Chief/Incident Commander.
The Incident Commander will direct the activities of all Field Units from a designated control
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point at the scene of the emergency, disaster, or other event.
The Security Manager will be the Incident Commander for countermeasures in situations caused
by hostile persons.
The Fire Prevention Captain will act as Incident Commander until relieved by an Assistant Fire
Chief.
The following items are identified as principles for the Emergency Commander and Incident
Commander to apply to the unique circumstances ofthe emergency or disaster:
a. Assist the injured.
b. Stabilize situation and site.
c. Assure evidence is not destroyed, lost, or moved.
d. Record situation through text, photographs, videos, and/or mapping.
e. Notify State and local officials.
f. Secure and admit only qualified essential personnel to the site.
g. Debrief participants.
16. Material Safety Data Sheet (MSDS) - Provides information on safe handling, proper PPE, and
disposal information for each chemical. This document is prepared by the chemical manufacture.
For additional information, contact your local Industrial Hygiene representative.
17. Non-sudden Release - The accidental discharging (see Discharge), spilling, leaking, pumping,
pouring, emitting, emptying, or dumping of hazardous wastes or materials which, when spilled
become hazardous wastes, into or on any land or water over an extended period of time. This
also includes spills onto asphalt or concrete pads.
18. Reportable Spill (Discharge) - A hazardous waste spill which must be reported to the Utah
Department of Environmental Response and Remediation, National Response Center and/or
other applicable Federal, State or local authorities. The Utah Hazardous Waste Management
Rules list reportable spill quantities as:
a. One kilogram (2.2 lb) of material in accordance with R315-9-1 (b)( 1). A spill of a lesser
quantity must be reported if there is a potential threat to human health or the environment.
b. One-hundred kilograms (220 lb) of hazardous waste or material which, when spilled,
becomes hazardous waste, in accordance with R315-9-1(b)(2). A spill of a lesser quantity
must be reported if there is a potential threat to human health or the environment.
c. Subpart J of 40 CFR Part 265 of the Resource Conservation and Recovery Act stipulates
that a spill of 1 lb from a leaking hazardous waste sump is a reportable quantity.
NOTE
For complete descriptions and listings, contact Environmental
Services or refer to R315-9 of the Utah Hazardous Waste
Management Rules.
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The following is a partial list of materials used at ATK and the quantities which, if spilled, would
require State or Federal notification:
EPA Utah
Material Quantity Quantity
Acetone 5000 lbs. 220 lbs.
Methanol 5000 lbs. 220 lbs.
Methylchloroform 1000 lbs. 220 lbs.
Methylene Chloride 1000 lbs. 220 lbs.
Methyl Ethyl Ketone 5000 lbs. 220 lbs.
Methyl Isobutyl Ketone 5000 lbs. 220 lbs.
Nitroglycerin 10 lbs. 2.2 lbs.
Propellants, reactive
materials (HMX)
oxidizers (AP) 100 lbs. 220 lbs.
Sodium Azide 1000 lbs. 2.2 lbs.
Toluene 1000 lbs. 220 lbs.
Xylene 100 lbs. 220 lbs.
19. Solid Waste - Any discarded material that is a solid, liquid, semi-solid or contained gaseous
material resulting from industrial, commercial, mining, or agricultural operations and is not
excluded under 40 CFR 261.4(a), 260.30, or 260.31.
20. Spill - The accidental discharging (see Discharge), spilling, leaking, pumping, pouring, emitting,
emptying, or dumping of hazardous wastes or materials which, when spilled become hazardous
wastes, into or on any land or water. This also includes spills onto asphalt or concrete pads.
21. Environmental Services - A department with expertise in the areas of hazardous waste, air and
water management, including environmental regulations in these areas.
G. PLANT LOCATIONS AND SITE INFORMATION
1. The ATK Launch Systems - Promontory (ATK) plant is located in Box Elder County
approximately 30 miles northwest of Brigham City. The 30-square mile plant site is
remote from any major population centers and is reasonably isolated from ranches
located at varying distances from the area boundaries. The plant site is composed of
four major areas in which manufacturing and testing activities take place: South Plant,
North Plant, Test Area, and Plant 3. There are approximately 675 buildings located on
the plant site, (See Appendix I for facility site maps).
ATK owns and operates these 4 areas. All of these areas are contiguous and waste
disposal is managed by one organization.
From the beginning of operations in 1956 to the present time, plant activities have
encompassed a wide range of programs requiring the production of solid rocket
propellants, rocket motor testing, and industrial support necessary to achieve each
program's objectives. Solid rocket motors manufactured during this period vary from
motors containing 7-9 lb of propellant to 1,100,000 lb. Programs have included Space
Shuttle SRM, Peacekeeper, Trident, SRAM, HARM, Standard, Genie, Minuteman,
Poseidon and a variety of ground and air launched flares.
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2. The plant site has nine hazardous waste treatment and storage facilities: Burning
Grounds at M-136, and M-225; Drum Storage areas at E-501 and M-186; the T-29B
Hydrazine Dilution Facility; the M-705 Wastewater Treatment Plant; the M-705S
Hazardous Waste Consolidation Room; the solid propellant waste storage facilities at
buildings M-47and M-603 and storage pad S-633.. The site maps and evacuation plans
for these facilities are shown in Appendix I.
These nine facilities serve as waste management units for the entire facility. Reactive
wastes treated at the burning grounds include waste propellants, waste explosives,
oxidizers, or solid waste contaminated with propellants, explosives, or oxidizers. No
propellants or explosives are ever stored in the drum storage areas; hazardous wastes
that are flammable, toxic, or corrosive are stored in these units. The Hydrazine Dilution
Facility at T-29B dilutes waste hydrazine to between 5 to 50 percent by volume for
shipment to an off-plant disposal site. The M-705 Wastewater Treatment Facility treats
hazardous and industrial waters from building sumps. Hazardous wastes are
consolidated and lab packed at the M-705S Hazardous Waste Consolidation Room.
3. Approved hazardous waste accumulation areas are described in Table I.
4. Fire hydrants are located as follows: 101 hydrants in the Administrative and
Manufacturing area, 95 at North Plant, 47 in the Test Area, and 9 in Plant 3. Static and
dynamic pressure heads have been measured for each hydrant and the Fire
Department maintains this information. The fire protection system at the plant site
meets the NFPA codes for fire protection. ATK owns and operates two pumper fire
engines and two brush trucks which are used for emergency response.
The following water tanks are interconnected:
Location
X-1
X-2
M-131
M-132
M-133
M-587 (North Plant)
M-696
T-59 (Test)
Capacity (gal)
200,000
20,000
50,000
50,000
100,000
1,000,000
20,000
1,000,000
The M-203 (Propellant Development Area) water tank with a 100,000 gallon capacity is
not interconnected to the other tanks.
Fire hydrants throughout the plant are color coded according to capacity.
Color Code Flow Capacity (gpm)
Green Fire Hydrant 1,000 or more
Orange Fire Hydrant 500 -1,000
Red Fire Hydrant 500 or less
5. Information depicting the capacity, location, and practical consequences of a
catastrophic failure of large hazardous material storage areas is found in Appendix II C,
p.67.
6. All buildings with 10 or more regular occupants have an evacuation plan posted at all
major exits of the building. (See Appendix I for the site maps and evacuation routes of
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UTD009081357
the hazardous waste treatment and storage facilities).
H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES
1. There are many steps that can be taken to prevent the recurrence and spread of fires,
explosions, or releases at the drum storage areas, burning grounds, and operating
buildings. These include limiting propellant quantities placed in the burning trays,
following safe handling procedures, personnel training, segregating incompatible and
reactive materials in the burning trays and in the drum storage areas, practicing good
housekeeping procedures, proper labeling, regular inspections, and separating the
burning trays by safe distances. These procedures are outlined in company operating
manuals.
2. Each fire, explosion, or release into the environment is unique. The Incident
Commander must be an experienced individual who will take all possible steps to
prevent a recurrence, to limit the extent of the damage, and to stop the discharge.
These steps may include:
a. Stopping processes and operations.
b. Collecting and containing released wastes.
c. Removing and isolating containers.
d. Preventing additional harm to the environment through knowledge of the potential
hazards associated with storage areas (found in Appendix II, A and B, pp. 65 and
66, their locations, capacities, and identification.
3. User organizations conduct regular inspections on items such as bulk storage
containers that store hazardous wastes or materials which, if released to the
environment, would become hazardous wastes. Audits are taken on volumes of stored
materials versus consumption to ensure that non-sudden releases are not occurring. If
a non-sudden release of materials is discovered, steps are taken immediately to
minimize the impact on the environment.
II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION
A. EVACUATION CRITERIA
1. A fire that is a threat to human safety.
2. A spill that is a threat to human safety.
B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL
1. The building personnel working the operation identify the material.
2. The Material Safety Data Sheet (MSDS) is referred to for chemical constituents, health
hazards and protective clothing.
3. The Hazardous Waste Profile Data sheet, Chemical Safety Software EMS-E, or MSDS
is referred to for proper disposal of the waste.
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C. REPORTING OF EMERGENCY INCIDENTS
1. Spilled material is reported to Security.
2. Security contacts the Environmental Service's Spill Advisory Team and Safety for
technical support and advice.
3. Environmental Services contacts the State and EPA to report the incident (if required).
4. Environmental Services obtains the log from Security to prepare the written report to the
State.
5. Within 15 days, Environmental Services submits the written report to the State and
maintains a permanent copy in the Environmental Services' Central File as required.
D. PERSONNEL RESPONSIBILITIES
1. EMERGENCY MANAGER
a. At all times, there shall be at least one employee either present on the facility
premises or on call with the responsibility for coordinating all emergency response
measures.
b. The facility emergency coordinator is thoroughly familiar with all aspects of the
facility's contingency plan, all operations and activities at the facility, the location
and characteristics of waste handled, the location of manifests and all other
records within the facility, and the facility layout, or has immediate access to
persons with this information.
c. This person shall have the authority to commit the resources needed to carry out
the contingency plan.
d. Arranges for and directs a spill contingency plan simulation.
2. EMPLOYEES, FIRST LINE SUPERVISORS AND FIRE WARDENS
a. Report all fires or emergencies by activating the fire alarm or calling the emergency
number.
b. Report from a safe telephone location:
Your name and phone number
Type of incident (fire, explosion, injury, spill, etc.)
Location of incident
c. Stay on the line when possible until released by the emergency operator.
d. Do not attempt to fight fires involving live or possibly toxic hazardous materials.
e. Do not attempt to contain spills that are beyond capability or training.
3. FIRST LINE SUPERVISORS
a. Ensure personnel evacuate buildings or areas to the assembly point indicated on
the Emergency/Evacuation Plan located in each building.
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NOTE
Handicapped personnel must be provided priority and
assistance during evacuation and assembly.
b. Advise the Fire Captain and the Incident Commander of conditions at the scene.
c. Account for all employees that were in or assigned to the affected building or area.
d. Report any injured or missing personnel to the Incident Commander.
e. Remain at the assembly point until released by the Incident Commander.
f. Notify appropriate Safety Department and fill out a Mishap Report.
4. INCIDENT COMMANDER
a. Initiate the first response actions.
b. Contact line supervision at the assembly point to determine the details of the
situation:
i. Nature of incident
ii. Number of personnel injured or not accounted for and the location of their last
known assignment.
iii. Location and type of hazardous materials that may be exposed to fire or
explosion (Quantity Distance Criteria).
c. Applicable Quantity Distance Criteria.
d. Assume control of emergency area.
e. Declare severity of event such as an emergency or disaster as appropriate.
f. Establish emergency scene, coordinate road blocks, cordon the site, and control
entry/exit from the area.
g. Make an initial assessment of situation.
h. Notify the Security Radio Dispatcher as appropriate, close the switchboard, if
absolutely necessary. The Environmental Specialists must be included if a building
deluge system has been activated and the building sump has overflowed or
another known spill of hazardous material has taken place.
i. Identify safe response routes for follow-on units,
j. Coordinate activities with other emergency units,
k. Commit rescue and first aid crews as necessary.
I. Obtain emergency rescue and ambulance as required.
m. Keep the Emergency Commander informed of the emergency situation.
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n. Request outside assistance from the EOC as needed.
p. Check with building's supervision to identify propellant ingredients and hazardous
constituents in any building or building sump which must be pumped by Water
Operations personnel. Evaluate what hazards, if any, exist which may hinder safe
access to the building.
q. Perform actions in accordance with 29 CFR 1910.120 (HAZWOPER).
5. SECURITY
a. Set up road blocks as directed by the Incident Commander to preclude
unauthorized entry of personnel and provide clear traffic flow for emergency
vehicles.
b. Coordinate with Incident Commander to ensure orderly evacuation of personnel.
c. Provide protection for classified information, valuable records, and special
equipment.
d. Ensure protection of Company and Government property from theft or sabotage.
e. Provide proper disposition, storage, and protection of classified material in
accordance with the Department of Defense Industrial Security Manual.
f. Establish perimeter boundary for emergency scene, set up road blocks, cordons,
etc.
g. Above actions must be consistent with HAZWOPER requirements.
6. SECURITY RADIO DISPATCHER
a. When directed by the Incident Commander, notify appropriate personnel in
accordance with the Emergency and Disaster Response Plan.
b. Monitor and record all emergency radio communications, and establish required
communications between radio units.
c. Upon direction of the Incident Commander, notifies appropriate ATK management.
7. TELEPHONE OPERATORS
a. When directed by the Incident Commander, refuse incoming and outgoing calls
unless directed otherwise by the Emergency Commander.
8. INDUSTRIAL HYGIENIST
a. Report to the Incident Commander at the assembly point or Field Command Post.
b. Advise the Incident Commander on emergencies involving toxic chemical or
radiation hazards.
c. Perform the following activities as necessary:
i. Sample air at the scene, including any sumps which have to be pumped, (if
determined to be necessary by the Industrial Hygienist (IH) on the scene)
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ii. Monitor radioactivity at the scene, (if determined to be necessary by the IH on
the scene)
iii. Advise Emergency Response Team concerning proper decontamination
controls.
iv. Notify Medical Services of personnel exposure to toxic chemicals or
radioactive materials.
v. Advise the Incident Commander to notify public health authorities,
d. Performs these duties in accordance with HAZWOPER requirements.
9. MAINTENANCE CRAFTS PERSONNEL
a. Respond to all alarms when notified by the Security Police Radio Dispatcher and
report to the Incident Commander at the command post.
b. Control distribution of air, water, steam, and electrical power as directed by the
Incident Commander.
c. Provide equipment, barricading, and shoring as necessary per direction of Incident
Commander.
d. As Fire Brigade, assist when needed.
e. Provide construction type materials and services for containment of hazardous
material spills.
f. Performs these duties per direction of Incident Commander.
10. ENVIRONMENTAL SERVICES PERSONNEL
a. Report to the Incident Commander at the command post, when notified by Security
Police Radio Dispatch.
b. Perform duties as directed by the Incident Commander after material to be
collected has been identified, any hazards associated with the material have been
identified, and safe procedures to handle the material have been established.
c. Perform these duties in accordance with HAZWOPER requirements.
d. Advise the Incident Commander on potential environmental hazards, safe handling,
and disposal options.
11. MEDICAL SERVICES PERSONNEL
a. Remain at or report to the Dispensary to receive and treat patients.
b. Report to the emergency area when requested by the Incident Commander.
c. Coordinate with surrounding community hospitals and doctors for the receipt and
treatment of injured.
d. Requisition supplemental medical supplies, equipment, and personnel as needed.
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May request helicopter transportation in life or death situations.
e. Conduct and supervise treatment for injured personnel.
f. Review MSDS and other relevant information, and transmit same to receiving
hospital.
12 TRANSPORTATION PERSONNEL (IN-PLANT TAXI SERVICE)
a. Coordinate with Incident Commander to ensure adequate transportation of plant
personnel.
13. EMERGENCY COMMANDER
a. Control and coordinate overall activities of the emergency situation. The
Emergency Commander will work from the Emergency Command Center, and will
assist and direct the On-Scene Incident Commander as needed.
b. Evaluate situation and determine need to convene the Emergency Command Unit.
c. Direct the Telephone Operators to open or close the switchboard according to the
nature of the emergency.
d. Open the Emergency Operations Center as necessary.
e. Identify the disaster potential posed by the emergency.
f. Make the disaster declaration when necessary (disaster responsibilities are listed in
Section III).
14. PHOTOGRAPHER
a. Report to the Incident Commander at the Command Post.
b. Advise the Incident Commander on photo coverage.
c. Photograph the scene as directed.
d. Expedite printing and delivery of the photographs.
e. Interpret the photographs as required.
15. HUMAN RESOURCES COORDINATOR
a. Provide food and assistance with personal needs for emergency team members
and those affected.
b. Notify next of kin of injured persons when advised by Emergency Commander.
(See Section IV, the Emergency and Disaster Response Plan for procedures).
16. ENVIRONMENTAL SPECIALIST
a. Assess possible environmental hazards resulting from the incident including
assessment of spills caused by the activation of a building deluge system which in
turn caused the building sump to overflow.
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b. Initiate reports required by the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) and Utah Solid and Hazardous Waste
Regulations.
c. Determine (along with the responding local emergency agency) whether the facility
has had a discharge, fire, or explosion which could threaten the environment
outside of the facility. Assure immediate implementation of emergency procedures.
d. Notify the State and Federal environmental agencies as required.
e. The Environmental Specialist contacts either the government official designated as
the on-scene coordinator or the National Response Center, [phone], and
Utah Dept. of Environmental Response and Remediation (DERR) at (801) 536-
4123 to relaying the following information:
i. Name and telephone number of reporter.
ii. Name and address of facility.
iii. Time and type of incident (such as discharge, fire, etc.).
iv. Name and quantity of material(s) involved, to the extent known.
v. The extent of injuries, if any.
vi. The possible hazards to human health or to the environment outside the
facility.
f. Notify the Corporate Environmental Engineer if the spill is reportable.
David Shead
[phone]
g. Utah Hazardous Waste Management Rules require that the Environmental
Specialist note in the operating record the time, date, and details of any incident
that requires implementing the contingency plan. Within 15 days after the incident,
he must submit a written report on the incident to the Executive Secretary of the
Solid and Hazardous Waste Control Board. The report must include:
i. Name, address, and telephone number of the owner or operator.
ii. Name, address, and telephone number of the facility.
iii. Date, time, and type of incident (such as fire, explosion, etc.).
iv. Name and quantity of material(s) involved.
v. The extent of injuries, if any.
vi. An assessment of actual or potential hazards to human health or the
environment where this is applicable.
vii. Estimated quantity and disposition of material recovered from the incident.
h. Notify the community emergency coordinator for the local emergency planning
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committee in compliance with requirements outlined in 40 CFR 355.40, where
applicable.
i. Immediately after an emergency, the Environmental Specialist must provide
direction for treating, storing, or disposing of recovered waste, contaminated soil or
surface water, or any other material that results from a discharge, fire, or explosion
at the facility.
j. The Environmental Specialist and the Incident Commander must ensure that, in the
affected area(s) of the facility:
i. A determination is made who will do the spill remediation work (Building
Personnel, ATK Spill Remediation Team, or Off-Site Contractor).
ii. No waste that may be incompatible with the discharged material is stored or
disposed of until cleanup procedures are completed; and
iii. All emergency equipment listed in the contingency plan is cleaned and ready
for its intended use before normal operations are resumed.
17. CORPORATE PUBLIC AFFAIRS
a. Establish liaison with representatives of public information media.
b. Prepare drafts of general/public information press releases relating to the
emergency.
c. Release information as directed by the Emergency Commander, according to ATK
Policy.
18. RECORDER
a. Record incoming and outgoing communications at the EOC.
b. Record all significant events and actions.
c. Initiate and maintain record information in a time line log.
d. Assist in the preparation of interim and final reports.
E. ALARM SYSTEMS
1. Alarm systems are available at ATK for fires or building evacuations if an emergency or
disaster situation exists:
Type People/Materials Sound
Fire and Building
Evacuation
People Fire Alarm
Hazardous Waste People Verbal Signal (or fire alarm, if
available)
Storage and
Thermal Treatment Materials
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horn, if available)
2. The hazardous waste storage facilities at M-186 and E-501 are located outdoors in open
areas, evacuation of personnel will be in any direction away from the problem. The assembly
area for E-501 is directly across the street (to the north) from the entrance gate. The
assembly point for M-186 is at the M-381 trailer.
3. The hazardous waste storage facility at the M-705 Consolidation Room is a single room
equipped with two exits, a single door on the west and a double door on the east. Both sets
of doors open directly to an open outdoor area where personnel are to evacuate to an area
near the intersection of the main in-plant road and the M-705 access road. The room is
equipped with a heat sensor alarm, a fire alarm and a carbon monoxide alarm on the
supplied air system.
4. M-47 is a storage building only, and is equipped with evacuation doors on the west side of
the building only. These exits are delineated in the evacuation plans in Appendix I.
5. M-603 is a storage building with multiple exits as outlined in the evacuation plan in
appendix I.
6. Tables and maps showing the function of the various hazardous waste sites and area
evacuation plans are found in Appendix I, p. 40.
F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND HOSPITALS
1. Local law-enforcement agencies, fire departments, and hospitals have been contacted
to respond to or treat any ATK emergency. The most recent copy of this Contingency
Plan is sent to each agency in order to familiarize them with the layout, description of
hazardous wastes handled, and evacuation plan for the plant. Copies of the letters sent
to each agency are kept in the Operating Record.
2. All emergency response units from off-plant will be escorted from the gate to the
fire/explosion/spill site by an ATK authorized agent. This will ensure the units reach the
location as quickly and efficiently as possible.
III. SPILL CONTAINMENT AND CLEANUP
A. CONTROL PROCEDURES
1. Detailed emergency response procedures whenever there is a fire, explosion, or release
(spill) are found in the current Emergency and Disaster Response Plan.
2. Specific directives for cleaning up spills are given in the Hazardous Waste Profile Data
(HWPD). There are over 1,000 chemical entries in the HPWD. Approximately 800 of
the chemicals in current use exhibit hazardous properties. The MHSI documents are
generated in-house to provide a standard format for easy use. Each entry contains
Material Safety Data Sheet (MSDS) information as well as other information. There are
approximately 100 sets of MHSI distributed throughout the facility. In addition, a
complete MHSI is accessible through over 1,000 computer terminals at the facility.
3. The Wastewater Treatment Facility (M-705) is designed to treat wastewater containing
hazardous waste constituents. The responsible building foreman or supervisor should
report to the M-705 facility personnel any spill or accidental discharge to a sump
suspected of containing chemicals at concentrations above the levels normally
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discharged. The report should include the incident location, name of person reporting,
chemical involved, and approximate quantity. The treatment facility personnel will then
be able to determine how best to handle the wastewater.
4. The propellant storage buildings will be inspected daily or weekly as required when in
use. While the propellants stored in these buildings are solid, occasionally a small
amount of nitro glycerin or similar material can ooze from the motor and drip to the floor.
These drips will be checked for during the inspections, and cleaned up using rags and
acetone within 24 hours of discovery or as soon as is practicable.
B. SPILL CONTAINMENT AND CONTROL
§265.56(e) of the Resource Conservation and Recovery Act (RCRA) states:
"During an emergency, the Emergency Commander must take all reasonable
measures to ensure that fires, explosions and releases do not occur, recur, or
spread to other hazardous waste at the facility. These measures must include
where applicable, stopping processes and operations, collecting and containing
released waste and removing or isolating containers."
Confine hazardous material spills to the affected area with dams, Quicksorb, or other
approved means. Hazardous material properties may be determined by consulting the
Hazardous Waste Profile Data Sheet, MHSI, or the DOT Emergency Response
Guidebook. No attempt will be made to contain a spill until the hazardous properties are
known. Secondary containment is provided for most storage tanks. For those tanks
without secondary containment, consult Appendix II for spill containment considerations.
C. SPILL CLEANUP
1. Waste Management and Environmental Services will be responsible for the coordination
of spill cleanup activities. Building personnel will clean up smaller sized spills, incidental
to the work process, that are deemed within the skills and level of training possessed by
available building personnel, where the spill occurred. All other spills will be cleaned up
by the Spill Remediation Team or a company contracted by ATK.
Proper procedures will be followed for every release of hazardous wastes. Because of
the extensive inventory of hazardous materials managed at ATK Corporation, each
release will require specific safety precautions, cleanup procedures, and/or disposal
methods. See Table II p. for chemical compatibility information.
WARNING
Do not attempt to contain or clean up any spill until hazards
associated with the material are known and proper safety
precautions are taken.
2. Response procedures to be used during container spills or leaks are as outlined:
a. Identify the material
• From the hazardous waste label
• From Waste Management and Environmental Services inventory records
• Through laboratory analysis
• From carrier manifest or placard DOT guide number
b. Protect personnel through the use of personal protective equipment specific to the
identified material (refer to MHSI or Material Safety Data Sheet, available from
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Industrial Hygiene.)
c. Stops the spill or leak
d. Contain the material
• Eliminate the source
• Use Quicksorb, or other approved methods
e. Clean up the material
• Re-drum
• Wipe up, use absorbent material, excavate soil
f. Dispose of the material (refer to Haz Com Web and Disposal Instructions for
Waste Materials, GM-3.1)
g. Decontaminate the site and clean the equipment
1. When the spill has been properly contained and stopped, appropriate equipment
will be used to remove the spilled material to a disposal site
2. Spills involving very large quantities of material caused by the failure of a large
storage tank should be dealt with as quickly as possible to minimize exposure to
the environment. The method of pickup generally will be pumping material into a
tank truck, the original tank after repairs, or into another tank. An alternative may
be to use the Environmental Waste Disposal sump truck to pump liquid hazardous
wastes and transfer them to a 5,000 gallon storage tank trailer at M-705. Contact
Waste Management and Environmental Services for use.
3. Proper steps will be taken to repair equipment and facilities and/or remove the
cause of the spill.
4. Operating procedures will be changed, if necessary, to prevent recurrence of a
spill.
5. Safety and Operational Training will be instigated, if required.
6. When possible, all reasonable effort will be made to salvage reusable material.
E. INCOMPATIBLE WASTE
The Environmental Coordinator and Incident Commander will ensure no waste is
incompatible with any material during the cleanup of a discharge. Table II, p. lists the
information and its available location to the Environmental Coordinator and Incident
Commander to make decisions regarding compatibility. All of these materials are available
for inspection at the plant site.
F. CLEANUP MATERIAL AND EQUIPMENT
The following is a partial list of safety equipment that may be used for cleanup as required
per Chemical Safety Software EMS-E. All items can be obtained from Stores or from a call
contract.
D. FOLLOWUP PROCEDURES
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Item
Coveralls
Smocks
Tyvek Suit (m)
Tyvek Suit (I)
Tyvek Suit (xl)
Tyvek Sack Suit
Tyvek Hood
Polyethylene-
Tyvek Suit
Saranex Tyvek Suit
Booties (Yellow)
Booties (Clear)
Boots (Rubber)
Glasses, Safety
Monogoggles
Ear Plugs
Gloves, Rubber (s)
Gloves, Rubber (m)
Gloves, Rubber (I)
Gloves, Leather
Gloves, Cotton
Gloves
Gloves, NBR (s)
Gloves, NBR (m)
Gloves, NBR (I)
Respirator, Half Mask
Air Purifying
Respirator,
Full-face Cart
Respirator, Fresh Air
Respirator, No. 8710
Filter S (Gray)
Filter H (Purple)
Filter GMA (Black)
Filter GMC (Yellow)
Filter GMD (Green)
Filter (Purple/Black)
GMA-H
Filter (Purple/
Yellow) GMC-H
Filter (Black/Olive)
GMP
Acetone
Rumple cloth
Chemliner bag
Stock No. Use
Live Operations
Manufacturing Area
Asbestos & Dust
Asbestos & Dust
Asbestos & Dust
Asbestos & Chemical Spills
Asbestos & Chemical Spills
Asbestos & Chemical Spills
Chemical Spills
Asbestos & Chemical Spills
Asbestos & Chemical Spills
Chemical Spills
Spills-Less than 1 quart
Spills-Greater than 1 quart
Noise-Greater than 90 B(A)
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Methyl Ethyl Ketone
General Use
General Use
Solvent Resistant
Methyl Chloroform
Methyl Chloroform
Methyl Chloroform
In 02 Sufficient Areas Only
In 02 Sufficient Areas Only
In 02 Deficient Areas Only
Dust, Single-use Only
Dusts, Mists, Fumes, Radon
Daughters, Asbestos
Dusts, Mists, Fumes, Radio-
nuclides, Asbestos
Organic Vapors
Organic Vapors, Acid Gases
Ammonia & Methylamine
Organic Vapors, Dusts, Mists,
Fumes, Radionuclides,
Asbestos
Organic Vapors, Acid Gases,
Dusts, Fumes, Mists,
Radionuclides, Asbestos
Pesticides
Propellant solvent
wipe
Contain solvent rags
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Velostat bag Conductive bag to contain chemiliner
In addition, the following materials are available if required:
Item Location Ext
Lumber M-90 2680/2757
Sawdust M-90 2680/2757
Pipe M-90 2680/2757
Quicksort) (27-200002) M-3 (Stores) 2757
Absorption Clay Landfill 2837
Hydrated Lime (54-426006) M-3 (Stores) 2757
Chemical Spill J. T. Baker
Neutralizer
Acids (General) M-53 2617
Bases (General) M-53 2617/7436
Flammable Solvents M-53 2617
Mercury Cleanup Kits M-53 2617
NG Spill and M-585 8446
Detector Kit
Bulldozer (Space/DLV) M-55/M-321 2837/2455
Front-end Loader M-55/M-321 2837/2455
Portable Lights and M-6 3431
Generator
Sump Tank M-136 2520
Portable Diaphragm Pumps M-55/M-321 2837/2455
General Trucks M-55/M-321 2837/2455
SCBA Respirators Fire Dept 2222
Water Ops. Equip M-705 2222
Spill Response Truck Fire Dept 2222
Description
Plywood, Lumbers
Bulk
All dimensions
50 lb Bag
Bulk
50 lb Bag
3.2 kg
1.2 kg
(1.1 kg) (18 kg)
0.9 kg
5 liter bottle
D-8
1 Vi and 3 yd bucket
2 Mercury Lamps
3,000 gal
172-5 Ton
30 Min. Tank
Sump Trucks, Etc.
Spill Response
and Rescue
DECONTAMINATION EQUIPMENT AND PROCEDURES
1. Equipment available for decontamination includes two disposable wading pools, a
wood-framed plastic pool carried on the spill truck for tool and spill team
decontamination, and fire trucks to supply wash down water. Decontamination
procedures outlined on Figures 1 and 2 will be followed to ensure spill containment and
to minimize the area of contamination.
2. The M-186 hazardous waste drum storage site is located near the burning grounds.
This area is serviced by the E-522 Fire Station which is located 3-5 minutes away. The
M-705 Hazardous Waste consolidation room and the E-501 drum storage yard are also
serviced by the E-522 Fire Station which is located 1-2 minutes away. Both the E-522
and M-11 Fire Stations are outfitted with quick-response spill control equipment (See
maps, Appendix I). In addition, spill response kits are available at the M-53 and M-585
Laboratories.
H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT
The Incident Commander, or his designee, will ensure all equipment has been properly
decontaminated, cleaned, and replaced before normal operations are resumed. The
following guidelines are to be used for decontamination of equipment after a discharge
has occurred. These steps are also supplemented by the information found in the
sources listed in Paragraph F.
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2. As much as possible, measures should be taken to prevent contamination of
equipment. Any delicate instrument which cannot be decontaminated easily should be
protected while it is being used. It should be bagged and the bag taped and secured
around the instrument. Openings can be made in the bag for sample intake.
a. Sampling Devices
Sampling devices require special cleaning. The instruction and care manuals
provide information on proper decontamination methods for each instrument used.
b. Tools and Equipment
Equipment and tools designated for spill response should be disposable; however,
some tools and equipment require decontamination.
Decontamination equipment, materials, and supplies are generally selected based
on availability. Soft-bristle scrub brushes or long-handle brushes are used to
remove contaminants. Water in buckets is used for rinsing. Large galvanized
wash tanks or stock tanks can hold wash and rinse solutions; children's wading
pools can also be used. Open top (55-gallon) drums or similar containers lined
with plastic bags can be used to store contaminated clothing and equipment.
Contaminated liquids can be stored temporarily in metal or plastic cans or drums.
Other supplies include paper or cloth towels for drying protective clothing and
equipment.
Personal protective equipment, sampling tools, and other equipment are usually
decontaminated by scrubbing with detergent-water using a soft-bristle brush
followed by rinsing with copious amounts of water. While this process may not be
fully effective in removing some contaminants, it is a relatively safe option
compared with using a chemical decontaminating solution. Occasionally, a
decontamination chemical is then needed to change the contaminant into a less
harmful substance during decontamination. The Environmental Coordinator and
Incident Commander, or his designee, may consult the information sources in
Table I, p. 33, to determine the necessity of using a chemical decontamination
solution.
All materials and equipment used for decontamination must comply with proper
disposal. Clothing, tools, buckets, brushes, and all other equipment that are
contaminated must be secured in drums or other containers and labeled. Clothing
not completely decontaminated onsite should be secured in plastic bags before
being removed from the site.
Contaminated wash and rinse solutions should be contained to hold spent
solutions. The spent solutions are transferred to drums which are labeled and
properly disposed of. The Environmental Specialist and Incident Commander, or
his designee, will ensure the disposal of these materials is done in an appropriate
manner.
c. Respirators
Certain parts of contaminated respirators, such as the harness assembly and
leather or cloth components, are difficult to decontaminate. If grossly
contaminated, they may have to be discarded with the other spill cleanup wastes.
Rubber components can be soaked in soap and water and scrubbed with a brush.
Regulators must be maintained according to manufacturer's recommendations.
20
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
Persons responsible for decontaminating respirators should be thoroughly trained
in respirator maintenance.
d. Heavy Equipment
Bulldozers, trucks, back-hoes, bulking chambers, and other heavy equipment are
difficult to decontaminate. The method generally used is to wash them with water
under high pressure and/or to scrub accessible parts with detergent/water solution
under pressure, if possible. Shovels, scoops, and lifts may be sandblasted or
steam cleaned. Particular care must be given to those components in direct
contact with contaminants such as tires and scoops. Wash water generated during
the decontamination process must be contained and disposed of in a proper
manner.
IV. INSTALLATION RESPONSE TEAM TRAINING
Building/area personnel responding to spills of hazardous materials incidental to the normal
processes within their building/area will not need training beyond that required by ATK's Hazard
Communication Program. Personnel responding to spills, who are not assigned to the building/area
where the spill occurred, are to be members of the Spill Remediation Team with the proper OSHA
training.
All personnel involved in cleanup operations will be trained. This training will include an
awareness of the locations of cleanup materials and equipment and the procedures for the
operation of such equipment.
B. SIMULATION
The Spill Contingency Plan will be simulated annually under the direction of the Emergency
Commander.
V. TRAINING PLAN
One of the most important objectives of the Contingency Plan is to ensure that the emergency
responders are properly trained. Training should include teaching, exercise and critique phases. Re-
training and review should be completed at least annually. The following is an outline of training plan
elements:
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN
B. REVIEW OF LEGAL REQUIREMENTS
1. Authority
2. OSHA requirements
3. State requirements
4. EPA requirements
5. State Fire Marshall requirements
21
NOTE
Hazard Communication Plus Program is a combination of
the HAZ-COM Program required by OSHA 29 CFR
1910.1200 and HAZWOPER first awareness level required
by OSHA 29 CFR 1910.120.
A. TRAINING
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
6. Law enforcement requirements
7. Medical Examiner/Coroner requirements
C. LOCAL ATK REQUIREMENTS
D. CUSTOMER REQUIREMENTS
Contract review
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER
F. EMERGENCY COMMUNICATION SYSTEM
1. Initial notification and follow-up
2. Verification of information
3. Radio discipline
4. Communication intercept
G. FIRE PLANS/FIRE DRILL
1. Use
2. Exercise
3. Evaluate
4. Evacuation
5. Assembly points
H. BOMB SEARCH TECHNIQUES
1. Outside to Inside
2. Left to right
3. Bottom to Top
4. Evacuation
5. Suspect items (Isolate; don't touch or disturb)
I. FIRE BARRICADE/CORDON AREAS
1. Function
2. Initiate/release
J. EMERGENCY MEDICAL TREATMENT
1. EMT training, equipment
2. First response first aid
K. SECURITY OF SITE
1. Purpose
2. Authority
3. Who authorizes access
L. INVESTIGATION
1. OSHA
2. EPA
3. Local Law enforcement
22
ATK Launch Systems - Promontory
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January, 2014
UTD009081357
4. Medical Examiner/Coroner
5. Customer
6. ATK
M. PUBLIC RELEASE OF INFORMATION
1. Who authorizes
2. Importance of controlling
3. Who releases
4. Who reviews
5. Next of kin
N. FACT-FINDING METHODS
1. Initial interview
2. Follow-up interview
3. Recordings
4. Photo Coverage
5. Mapping damage
a. Who?
b. How?
c. Why?
6. Personnel security checks
7. Drug and alcohol tests
8. Weather conditions
9. Product status
10. Operational status
11. Equipment records and history
12. Facility, tooling, modification and history
O. SAFING THE AREA
1. Electric Power
2. Water
3. Steam
4. Toxic chemicals
5. Falling hazards
6. Explosives
P. CONTROL OF THE CURIOUS
1. Outsider
2. Employees
3. Press
Q. HANDLING OF REMAINS
1. Notification
2. Photo
3. Movement (after authorization by Medical Examiner)
4. Release (after authorization by Medical Examiner)
R. NOTIFICATION PROCEDURES
1. When?
2. Who?
23
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
3. How?
4. Verification
S. RESCUE EFFORTS
1. When?
2. When not to
3. How to determine
24
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
TABLE I
COMPATIBILITY INFORMATION
Source of Compatibility Information Location
1. Hazardous Waste Compatibility Chart
Table 9-2 of Attachment 9
Available at
Environmental Services offices
2. Material Health and Safety
Information (example of informa-
tion found in plan)
Available in hard copy form at
approximately 100 locations through-
the plant; also available on 1,000 computer
terminals throughout the plant*
3. Material Safety and Data Sheets Located on the internal web Chemical Safety
Software EMS-E
4. Work Experience Knowledge of each member of the Response Team
when responding to a discharge
25
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
VI. EMERGENCY COORDINATOR
The Emergency Coordinator is the ATK Fire Department's Emergency Manager. The alternate
Emergency Coordinators are the ATK Fire Department Shift Supervisors. A primary or alternate
Emergency Coordinator is on plant or on call at all times. In this plan, the Emergency Coordinator
may be referred to as the Incident Commander (IC). The primary and alternate Emergency
Coordinators or ICs are identified in the Operating Record, which is maintained onsite at the
Promontory facility. ATK Promontory security headquarters/dispatch can be contacted 24/7 at
435-863-8545. ATK Promontory security headquarters/dispatch can contact the on plant
Emergency Coordinator or IC.
26
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
P
FIGURE 1. DECONTAMINATION/SPILL SCENE
Difficult Decontamination Situations
Some situations, such as a solvent spilled on tiles or large spills on unprotected ground require the
removal and disposal of the affected material. Other situations, such as contaminated equipment or
fixtures, require steam cleaning and the use of a detergent. Frequently, the rinse from steam cleaning is
best controlled with a wet/dry vacuum. Steam cleaners, detergents, and wet/dry vacuums can be
obtained from local rental companies. The rinse should be tested for the contaminant and managed
appropriately.
27
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
The Spill Scene
While each spill is unique, every spill shares common features best referred to as the "Spill
Scene." This allows a conceptual illustration of the work area which emphasizes the relationship
of the various components.
Complete decontamination of workers, tools, and the spill site must be performed before the spill
response is completed.
It is prudent to establish an area for worker decontamination through which all SPILL TEAM
members must pass prior to leaving the site. In this TEAM DECONTAMINATION SITE (TDS)
protective clothing can be thoroughly washed with detergent and rinsed with water, if necessary.
The soles of ALL WORKERS SHOES MUST BE RINSED before they leave the area. Outer
coveralls (Tyvek, etc.) must be removed in this area. These steps are necessary to prevent
spreading the contamination or introducing toxic substances into workers homes.
Tools can be rinsed with detergent and water prior to removal from the spill scene. All
rinses from these decontamination procedures must be treated as hazardous waste.
Dry decontamination may be used when appropriate.
It is frequently necessary to test the site for completeness of decontamination prior to declaring
the emergency resolved. Spills which contaminate soil, asphalt, concrete, or other absorbent
materials will require that samples be obtained and analyzed. After all residual contamination is
removed, asphalt and concrete areas must receive a thorough wash-down with fresh water.
Cold Zone N \
\ /
Warm Zone
Secure
Spill Area
lamination Corrijaor Dec
/ \
\ Suppl les
FIGURE 2. DECONTAMINATION
28
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
APPENDIX I
FACILITY FUNCTION TABLES, SITE MAPS, & EVACUATION PLANS
NORTH PLANT SITE MAP 30
MANUFACTURING AREA SITE MAP 31
TEST AREA SITE MAP 32
PLANT 3 SITE MAP 33
M-136 BURNING GROUNDS FACILITY FUNCTION TABLE 34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE 34
M-136 SITE MAP AND EVACUATION PLAN 35
M-186 SITE MAP AND EVACUATION PLAN 36
E-501 STORAGE YARD FACILITY FUNCTION TABLE 37
E-501 SITE MAP AND EVACUATION PLAN 38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE 39
M-225 SITE MAP AND EVACUATION PLAN 40
T-29B SATELLITE ACCUMULATION AREA FACILITY FUNCTION TABLE 41
T-29B SITE MAP AND EVACUATION PLAN 42
M-705 WASTEWATER TREATMENT FACILITY FUNCTION 43
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM 43
M-705 SITE MAP AND EVACUATION PLAN 44
M-47 PROPELLANT STORAGE FUNCTION TABLE 45
M-47 SITE MAP AND EVACUATION PLAN 46
M-603 PROPELLANT STORAGE FUNCTION TABLE 47
M-603 SITE MAP AND EVACUATION PLAN 48
S-633 PROPELLANT STORAGE FUNCTION TABLE 49
S-633 SITE MAP AND EVACUATION PLAN 50
29
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
mm... \ - iwm
7
L a 3 Tt i a a a
3
*-1
r
-
m—
J
HOHTHEHH UTAH FKUT7
RE ass: DU* Am* UASTER STTE tUP
NORTH PLANT SITE MAP
30
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
ad ->
!2
/
\
1 I
linn IBtta S •
MANUFACTURING AREA SITE MAP
(South Plant)
31
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
K.
\
5—I
NORTHERN UTAH FALUTT
IE5T ARLA
IUSTTI sm: IUP
TEST AREA SITE MAP
32
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
s~~
!
NDHTHLKH UTAH F AC Lin
HGH PtlfFOUWArJCE PROPELLANT „ 3EVELOPUEHT AREA (PUWT 3) *
UICTTE err utn " MUSTER SITE ««•
B5TCH WMM H
PLANT 3 SITE MAP
33
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
M-136 BURNING GROUNDS
FACILITY FUNCTION: Propellant, explosives, unstable and pyrotechnic waste disposal
Waste Products Into Area
Class 1.1 and 1.3 propellant
wastes, propellant con-
taminated wastes, and unstable
waste.
Method of
Disposal
Burning
Spill Cleanup/Handling
Flashing in waste propellant
disposal areas
M-186 HAZARDOUS WASTE AREA
FACILITY FUNCTION: Receive hazardous waste materials and store for shipment
Waste Products Into Area
Methyl Chloroform
Methyl Ethyl Ketone
Xylene
Toluene
Paint
Thinners
Oil
Lab Chemicals
Photographic Fixer Solution
Rags & debris
Method of
Disposal
Store for
off-plant
shipment
Store for
off-plant
shipment
Spill Cleanup/Handling
Six UN Drums
Quicksorb, 100 lb
Two shovels
One broom
One fire extinguisher
Emergency shower/eye wash
Two overpack drums
Saranex suit (level B)
34
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
EVACUATE AREA, THEN PROCEED TO ASSEMBLY POINT
200 FEET WEST ON APPROACH ROAD
NEW
POND
TANK 2 •
BURNING PIT 19
PIT 17
PIT 16
PIT 15
PIT 14
N
M-136
LEGEND:
• FIRE EXTINGUISHER
DETONATION PITS
D D D •
NO. 11 NO. 10 NO. 9 NO. 8
ULJl
r~
PIT 7
PIT 6
PIT 5
PIT 4
PIT 3
• •
PIT 1 PIT 2
PROPELLANT BED
M-136
AND BURNING PITS
35
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
EVACUATE, THEN PROCEED TO ASSEMBLY POINT,
SOUTHWEST AT M-381
-x x x X x X X
M-186A
GATE
X X X X
N
EYEWASH
SHOWER
WASTE
OIL
WASTE
OIL
WASTE
OIL
M-1S6G
STORAGE
SHED
M-186B
OFFICE
TUF
SHED
SUPPLY
SHED
M-186E
SAMPLE
SHED
M-186F
FIXER SHED
GATE
LEGEND:
• FIRE EXTINGUISHER
HAZARDOUS WASTE TREATMENT,
STORAGE, DISPOSAL, AND FACILITIES
M-186
36
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
BUILDING E-501 STORAGE YARD
FACILITY FUNCTION: Hazardous Waste Storage Yard
Waste Products Into Area
Various
Other assorted materials
that may be recycled
Method of
Disposal
Shipment
off-plant
for disposal
N/A
Spill Cleanup/Handling
Two fire extinguishers
Absorbent
Two repack drums
Electrical pump
Telephone/radio
Eyewash/shower
Safety gates
Safety flags
Six UN 55-gal drums
(empty)
Saranex suit (level B)
37
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
N
EVACUATE AREA, THEN PROCEED TO ASSEMBLY
POINT ON 200 STREET, 200 FEET EAST
DRUM
STORAGE
LEGEND:
• FIRE EXTINGUISHER
E-501
and
SALVAGE YARD
38
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
M-225 BURNING GROUNDS
FACILITY FUNCTION: Disposal of waste products from High Performance Propellant
Development Area and miscellaneous rocket motors, igniters, and
related materials
Waste Products Into Area
Composite propellant, uncured
from M-209
Composite propellant, cured Burn
from M-221
NG propellant, uncured from
M-208, M-241
NG propellant, cured from M-221
HMX from M-208, M-210
AP from M-210 (fine only)
Binder premix (NG or other
nitrate, etc.)
PEP contaminated waste (rags,
containers, etc.)
Miscellaneous (motor, igniters)
Method of
Disposal
Burn
Burn
Burn
Burn with
diesel
Burn with
propellant
Spill Cleanup/Handling
Dampened rags (wipes)
Pick up, soft brush or wet rags (wipes)
Solvent dampened rags followed by NG
detector to verify cleanliness
Pick up, soft brush and/or wet rags
Soft brush and/or water-damp rags.
If possible, wet HMX with water before handling
Sweep with soft brush. Wipe with
composite water-wet rag. Flush with water into
sump
Burn or Contain, absorb into sawdust or pulp,
detonate pick up with wipes, wet rags. Apply NG
depending detector to verify cleanliness
on materials
and/or condition
Burn with
respective
propellant
Bum or
detonate
depending
on materials
and/or con-
dition
Pick up, clean with method used for
respective propellant
or ingredient
Each case must be dealt with on an
individual basis
39
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
EVACUATE AREA TO M-22SA BUNKER
M-22SA BUNKER
/
//
/
/
/
/
/
//
//
//
/
itfiscmANEous ^
BURN TRAY s v
CONTAMINATED TRASH*
BURXTRAY v . WHOLE
^ MOTOR BURN M-225
/-DETONATI ENERGY
N TRAY V. PIT /
COM
M-225
40
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
T-29B SATELLITE ACCUMULATION AREA
BUILDING FUNCTION: Hydrazine Storage and Dilution Facility
Waste Product Method of disposal
From Building Disposal Spill Cleanup/Handling
Pure hydrazine
Hydrazine-citric
acid solution
5-50% dilute
hydrazine
contaminated
waste
Dilute with
water to 5-50%
solution by
volume. Waste
hydrazine is
shipped for
d isposal/Treatment.
Contaminated
waste is also
shipped for
disposal/treatment
All areas where normal operations are
performed have a drainage system which
culminates in a common sump. Spills
should be flushed thoroughly with large
amounts of water. The wash water is
then drummed and shipped for disposal
41
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
N
EVACUATE BUILDING, THEN PROCEED TO
ASSEMBLY POINT 300 FEET NORTH OF BUILDING
[
© Si
T-29B
42
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
M-705 WASTEWATER TREATMENT FACILITY
BUILDING FUNCTION: Removal of reactive wastes from sump water
Waste Products From Area
Lime Sludge (Heavy Metals)
Potassium Perchlorate
Classifier Decanter Solids
Method of
Disposal
Shipment
to off-
plant
disposal
company
Burning
Burning
Spill Cleanup/Handling
Two shovels
One broom
Plastic gloves
One bin
Saranex suit (level B)
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM
BUILDING FUNCTION: Consolidation and lab packing of hazardous wastes
Waste Products From Area
Consolidated hazardous wastes
Lab packed hazardous wastes
Method of
Disposal
Shipment to
M-186 for
eventual
off-plant
disposal
Spill Cleanup/Handling
Two shovels
One broom
Plastic Gloves
One Fire Extinguisher
Emergency shower/eyewash
Quicksort), 100 lb
Two overpack drums
Six UN drums
Saranex suit (level B)
43
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
EVACUATE BUILDING 300 FEET, THEN PROCEED TO
ASSEMBLY POINT ON R" AVENUE NEAR M-366
Pi . a. • •
I n n n
• •
HMX
• •
M-705B
c E3L M-705A
3_a_o ill. tj » i i i i
—3 N
LEGEND
• FIRE EXTINGUISHER
O MANUAL ALARM
H ALARM PANEL
HI EVACUATION HORN
S SMOKE DETECTOR
0 AUDIOVISUAL ALARM
6, SYSTEM RISER
• HEAT DETECTOR
? INSPECTORS TEST
© GASSHUTOFF
MAIN
PROCESS
AREA J
Q J ELECT^ ECXJK>ME
CONTRCH.
BE 3 S
r
10.000 Gallon
Fuel Oil Tank
Underground
W
M-705
44
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
M-47 PROPELLANT STORAGE FACILITY
BUILDING FUNCTION: Storage of waste and non-waste propellant and motors
Waste and non-waste Products
1.3C Propellant and Motors
Method of
Disposal
Burning/slurried
recovery/neutralization
Spill Cleanup Materials
Obtain clean up material as needed
1.1C Propellant and Motors Burning/slurried
explosives/AP
recovery/neutralization
Obtain clean up material as needed
45
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
EVACUATE BUILDING, THEN PROCEED
TO ASSEMBLY POINT 500 FEET SOUTH ON 6TH AVENUE
FIRE EXTINGUISHER
N
M-47
46
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
M-603 PROPELLANT STORAGE FACILITY
BUILDING FUNCTION: Storage and Disassembly of waste and non-waste propellant and motors
Method of
Waste and non-waste Products Disposal Spill Cleanup Materials
1.3C Propellant and Motors Burning/slurried
explosives/AP Obtain clean up material as needed
recovery/neutralization
1.1C Propellant and Motors Burning/slurried
explosives/AP Obtain clean up material as needed
recovery neutralization
47
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
EVACUATE BUILDING 500 FEET, THEN PROCEED
TO ASSEMBLY POINT AT BUILDING M-643
CALL HEADQUARTERS WITH HEADCOUNT
TRUCK
BAY
0
0
0
0
N
&
LEGEND:
FIRE EXTINGUISHER
MANUAL ALARM
ALARM RESET
QD EVACUATION HORN
A SYSTEM RISER
0 HEAT DETECTOR
§ INSPECTORS TEST
o
0
M-603
48
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
S-633 REACTIVE HAZARDOUS WASTE STORAGE PAD
STORAGE PAD FUNCTION: Storage of reactive hazardous waste propellant/propellant
contaminated materials and motors and non-waste propellant
Waste and non-waste Products
1.3C Propellant/propellant
contaminated materials
1.3C Rocket Motors
Method of
Disposal Spill Cleanup Materials
Thermal Treatment Obtain clean up material as needed
Thermal Treatment Obtain clean up material as needed
1.1C Propellant/propellant
contaminated materials
1.1C Rocket Motors
Thermal Treatment Obtain clean up material as needed
Thermal Treatment Obtain clean up material as needed
1.3C Donor Burn Propellant
1.3C Flares and Flare Material
Burn Enhancer Obtain clean up material as needed
Thermal Treatment Obtain clean up material as needed
49
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
50
v, sterns- Promontory
January, w UTD009081357
EVACUATE p AOr THEN PROCEED TO
ASSEMBLY POINT AT M-381
633
M-381
S-633
51
ATK Launch Systems - Promontory January, 2014
"* *• Attachment 4 - Contingency Plan UTD009081357
APPENDIX II
BULK STORAGE AREAS INFORMATION
A. BULK FLAMMABLE LIQUID STORAGE AREAS 50
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE 51
APPENDIX III
ARRANGEMENTS WITH LOCAL AUTHORITIES 57
52
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
A. BULK FLAMMABLE LIQUID STORAGE AREAS
Location
Type of
Flammable Liquid
M-4
M-53
M-55
M-66
1-10
M-585
M-711
E-510
E-512
E-517
Butanol
Ethanol
Isopropanol
Methanol
Methyl Ethyl Ketone
Paint
Paint Thinner
Acetone
Ethanol
Heptane
Methanol
Methyl Ethyl Ketone
Gasoline
Assorted
Methanol
Methyl Ethyl Ketone
Acetone
Ethyl Acetate
Methanol
Toluene
Gasoline
Ethanol
Isopropanol
Methanol
Acetone
Isopropanol
Paint Thinner
Polyester Resin
Toluene
Xylene
Isopropanol
Kerosene
Methyl Ethyl Ketone
Capacity
(Gallons)
40
60
530
500
400
500
120
60
10
10
50
60
17,000
80
15
50
50
15
10
30
10,000
100
1,660
35
100
50
50
160
50
160
170
50
450
Above/Below
Ground
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Below
Above
Above
Above
Above
Above
Above
Above
Below
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
Above
T-29B Hydrazine 100 Above
53
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Attachment 4 - Contingency Plan
January, 2014
UTD009081357
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE
Building
Number Location
1-10 Shed west of building
M-4" Building north of M-3
system
M-8" Two sheds west of
building
M-43B Shed south of building
M-53A Shed south of building
M-66 Shed southwest of
building
M-504 Shed south of building
M-585 Shed east of building
M-605 Waste dock north of
building
E-512 Shed west of building
E-517 Shed north of building
Direction of Flow*
Has self-containment concrete berm
Liquid would run west across asphalt into drain
Spill would drain down west hill
Self-contained storage building
Self-contained storage building
Spill would run into ditch (trench
or grading needed to keep surface runoff from
accumulating in containment area)
Spill would flow into ditch
Spill would drain into ditch
Spill would drain into ditch
Spill would drain into ditch
Spill would drain into ditch
All other storage areas have self-containment
Fire flows and/or spilled material from these buildings will flow into a gated spill
containment structure below M-2. The gates are hand operated.
54
ATK Launch Systems - Promontory
Attachment 4 - Contingency Plan
January, 2014
UTD009081357
APPENDIX III
Arrangements with Local Authorities
ATK has a well trained and full time Fire Department and Security Department onsite. ATK's roads and
grounds and Water Operations departments maintains a fleet of trucks, tractors, vacuum trucks and
other equipment that could be used during an emergency response. The facility also has a nursing staff
during normal business hour, and a 24/7 ambulance service operated by ATK firemen with EMT
certifications.
Due to these capabilities, the need for outside assistance is greatly reduced. The most likely need for
outside assistance would be that of hospital service. Arrangement will be made with both the Bear River
Valley Hospital and the Brigham City Community Hospital to accept employees that may have been
injured due to an explosion, chemical exposure or other accident. This arrangement will include
information on the types of chemicals used at ATK Promontory as well as explosive hazards and other
mechanical hazards associated with work performed at ATK.
The most likely scenario that would require assistance from a police agency would be the need to control
traffic on Highway 83. Arrangements for assistance in this area will be made with the Box Elder County
Sheriffs Department and the Utah Highway Patrol. All on plant traffic control will be handled by
ATK's security department.
ATK has established contracts with three different emergency response/remediation contractors for use
as needed. While we do not anticipate the need for emergency service assistance, these companies are on
call to provide service if needed.
All emergency response at the plant will be handled by the ATK Fire Department, who will act as the
primary emergency authority. Arrangements will also be made with the Box Elder County Fire
Department and the Tremonton Fire Department. We do not anticipate any need for assistance from the
Utah Department of Environmental Response and Remediation, although notification of emergencies will
be made to this department as required. In addition to those agencies listed above, ATK will also provide
a copy of the contingency plan to the Box Elder County Emergency Planning Committee for review and
comment.
Below is a summary list of those agencies/service providers for which service arrangements will be
sought:
Bear River Valley Hospital
Brigham City Community Hospital
Box Elder County Sheriffs Department
Utah Highway Patrol
Box Elder County Fire Department
Tremonton Fire Department
The most recent copy of the Contingency Plan will be sent to each of these agencies in order to
familiarize them with the layout, description of hazardous wastes handled, and evacuation plans for the
plant. All correspondence with these agencies, in regard to the Contingency Plan and service
arrangements will be kept in the Operating Record.
55
ATK Launch Systems Inc. - Promontory Modified January, 2014
Attachment 5 - Closure Plan UTD009081357
CLOSURE PLAN AND FINANCIAL REQUIREMENTS
This Closure Plan describes the steps that will be taken to close the hazardous waste
management units (HWMUs) at the ATK Launch Systems Inc. - Promontory (ATK) facility.
Estimates of the closure costs associated with these steps are also detailed in this Plan. HWMUs
included in this document are: M-186; M-705S; E-501; M-136; M-225; T-29B; M-47, M-603
and S-633.
The Closure Plan was developed to comply with R315-8-7 and R315-8-9.9 ofthe Utah
Administrative Code (UAC). UAC R315-8-7 incorporates by reference the requirements of 40
CFR 264 Subpart G. The closure cost estimates were made in accordance with UAC R315-8-8,
which incorporates by reference the requirements of 40 CFR 264
Subpart H.
All HWMUs in current operation are being managed in a manner that facilitates clean closure.
Historical sites, such as the LTT As do require post closure care, and are covered in our Post
Closure Permit.
1.0 Closure Plans [40 CFR 270.14(b)(13), 270.23(a)(2), and 264.112(a)(1) & (2) and UAC
R315-3, R315-8]
This Closure Plan identifies all of the steps needed to close storage and treatment facilities, as
identified above, at the end of their operating life. Copies of this plan will be maintained at the
Promontory Facility. The closure plans will be followed as written, unless modification to the
original plans have been submitted and approved by the Utah Department of Environmental
Quality, Division of Solid and Hazardous Waste (DSHW). Upon update/revision approval,
revised pages or complete documents will be sent to all plan addressees.
1.1 Closure Performance Standards [40 CFR 264.111 and UAC R315-8-7]
Closure standards specified under RCRA are designed to be protective of human health and the
environment. These goals will be achieved by one ofthe following closure methods:
• Clean closure - this method refers to residential risk based levels. Cleanup to
residential risk based levels, as outlined in UAC R315-101, will be considered clean
closure. Clean closure includes removal of all contaminants, or removal to the risk
based level.
• Site Management - closure where waste remains in place and specific post closure care
is required.
For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be "clean
closed". Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(l). All closures will
assess real and reasonably likely impacts to human and ecological exposures.
1
ATK Launch Systems Inc. - Promontory Modified January, 2014
Attachment 5 - Closure Plan UTD009081357
Preliminary remediation goals can be established prior to implementing any of the closure plans.
Screening levels published by USEPA or site-specific risk based levels based on UAC R315-
101-5.2 may be used.
If contamination from hazardous waste or constituents is discovered at a HWMU above risk
based goals, further investigation will be performed to determine the extent ofthe contamination.
Based on the results of this investigation, a Corrective Measure Study (CMS) may be prepared
for review and approval by the DEQ, prior to implementation.
If investigation suggests that clean closure is not a practicable approach, a Site Management Plan
will be prepared. Upon approval, the unit will be closed by implementing appropriate site
management or post closure requirements. If this approach is necessary, the Post Closure Permit
may be modified to provide post closure care for the sites that are not clean closed.
1.2 Partial Closure and Final Closure Activities [40 CFR 264.112(b)(1) through (b)(7)
and UAC R-315-8-7]
This plan is designed to accommodate both partial and final closure. The plan includes separate
steps to close storage, consolidation & disassembly areas, and open burning/open detonation
areas. Details for closing permitted facilities are provided in Tables 1 through 8.
Soil monitoring has been conducted at the M-136 and M-225 burn grounds since 1991. Semi-
annual groundwater monitoring is also conducted, in accordance with ATK's Post-Closure
Permit.
1.3 Maximum Waste Inventory and Disposal Method [40 CFR 264.112(b)(3) and UAC
R315-8-7]
The maximum inventory of hazardous waste onsite at any one time during the life of the
facilities is based on permit limitations for inert facilities, and Quantity/Distance(QD) limitations
for live materials, based on Department of Defense Explosive Safety Standard 4145.26M or a
lesser designated amount. If storage capacities change, the Permit will be modified. These
quantity limitations are listed below:
M-186 (inert) 400 ea. 55 gallon drum equivalent
M-705S (inert) 32 ea. 55 gallon drum equivalent
E-501 (inert) 160 ea. 55 gallon drum equivalent
M-136 (live) 106,500 lbs 1.3 / 20,000 lbs 1.1
M-225 (live) 55,000 lbs 1.3 / 1,500 lbs 1.1
T-29B (inert) 1 ea. 55 gallon drum (pure) equivalent
M-47 (live) 300,000 lbs 1.3 / 21,000 lbs 1.1
M-603 (live) 120,000 lbs 1.3 / 8,000 lbs 1.1
S-633 (live) 75,000 lbs 1.3/20,000 lbs 1.1
ATK treats reactive hazardous wastes on-site at the M-136 and M-225 open burning grounds.
Wastewater is collected and treated on site and discharged through one of two UPDES permitted
2
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
treatment facilities. All other hazardous wastes are transported by commercial carrier to fully
permitted disposal or recycling facilities.
1.4 Schedule for Closure [40 CFR 264.112(b)(6) and UAC R315-8-7]
Section 1.4.1 of this plan provides an estimated closure schedule for all activities associated with
implementation of this Closure Plan. If sample results indicate the need for additional
investigation or a CMS, the schedule will be modified to accommodate the changes. Final
closure will be certified by an independent professional engineer licensed in Utah.
1.4.1 Time Allowance for Closure [40 CFR 264.113(a) and (b) and UAC R315-8-7]
Final closure is expected to be initiated within 30 days following shipment of the final volume of
hazardous waste. If more time is required, a request will be submitted to the Director. All
hazardous wastes will be removed or treated within 90 days of (1) plan approval, or (2) after
receiving the final volume of hazardous waste, whichever is later. Final closure activities will be
completed within 180 days of (1) plan approval, or (2) after receiving the final volume of
hazardous waste, whichever is later.
1.4.2 Extensions for Closure time [40 CFR 264.113(a) and (b) and UAC R315-8-7]
If closure activities cannot be completed within the time designated in this Closure Plan, a permit
modification and request for additional time will be submitted to the DSHW. The request will
state the reason for needed additional time and the status of the closure underway. It will also
address any added measures that must be followed to minimize any threats to human health or
the environment during the extension period.
1.5 Closure Procedures [40 CFR 264.112 and 264.114 and UAC R315-8-7]
All permitted treatment and storage facilities have been designed and managed to minimize
possible contamination. This includes chemical resistant concrete coatings, blind containment
sumps, regular inspections, regular maintenance, and prompt clean up of any spilled materials.
These practices should greatly reduce the need for significant remediation efforts upon closure.
1.5.1 Soil and Groundwater Sampling
Groundwater sampling is not covered under this plan. A groundwater monitoring program is
currently in place as discussed above. Soil sampling should not be required for any ofthe
permitted facilities, except for the two burn ground areas (M-136 and M-225) and S-633.
Soil samples will be collected within the top 12" of the surface. Samples will first be collected at
locations most likely to have been affected by waste management practices - as approved by
DSHW personnel. Twenty soil samples will be collected at M-136, twelve soil samples will be
collected at M-225 and eight soil samples will be collected at S-633. These samples will be sent
to a State of Utah certified laboratory for analysis. Sample collection, preservation and handling
methods will follow those outlined in the Waste Analysis Plan of this permit, and will be in
3
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
compliance with all applicable SW-846 methods. All samples will be processed and analyzed by
a Utah Certified Laboratory in accordance with R444-14-3(2) UAC. Analytical and extraction
methods to be used are shown below.
Analytical and Extraction Methods
Parameter Analytical procedure Extraction Procedure
Volatiles SW-846; 8260B SW-846; 5030B(W), 5035S
Semi-Volatiles SW-846; 8270C SW-846; 3510C(W), 3550(S)
RCRA Metals SW-846; 601 OB SW-846; 3005A(W),7471A(S)
Mercury SW-846; 7470A/7471A SW-846;7470A(W), 7471A(S)
Explosives SW-846;8330 Modified SW-846; 8330 Modified
Perchlorate EPA 314.0 EPA 314.0
1.5.1.1 Sampling Equipment Decontamination Procedures
All field sampling equipment will arrive on site pre-cleaned, and will be decontaminated
following standard protocol and the waste analysis plan in this permit. A mobile
decontamination station will be used to clean all sampling equipment that could come in contact
with soil samples.
1.5.1.2 Sampling Waste Management
All waste generated from field sampling and decontamination operations will be managed in
accordance with the current UAC R315 rules. Water used in the decontamination process will be
sent to the M-705 wastewater treatment plant onsite, and discharged in accordance with UPDES
permit requirements. Soils will be stored in UN containers pending lab results. Any soil
determined to be hazardous waste will be managed appropriately.
All non-aqueous hazardous waste generated by the sampling operation will be transported by a
third party contractor off site to a fully permitted TSDF for disposal. Any waste determined not
to be hazardous under EPA regulations will be sent via third party to a non-hazardous landfill for
disposal.
A field log will be maintained to track and identify all samples. This log will include sample
numbers, dates, times, sample depth, samplers name, weather conditions, test methods and
constituents for which to analyze.
1.5.1.3 Health and Safety Procedures
Soil and water sampling will be performed by trained and qualified personnel. A determination
of appropriate personal protective equipment (PPE) to be used for this effort will be determined
at the time of closure. PPE selection will be based on potential hazards as determined at the time
of closure, and in consultation with Industrial Hygiene professionals.
4
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Soil sampling should only be required at the burn grounds, because of well maintained secondary
containment and waste management practices during the entire life of all other permitted
facilities. Protective clothing appropriate for the task will be used during removal of waste and
during decontamination of containment areas for the permitted storage and treatment units.
1.5.2 Determining Cleanup Goals
For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be clean
closed. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101 -6(c)(1). All closures will
assess real and reasonably anticipated potential impacts to human and ecological exposures. It is
anticipated that the HWMUs will be clean closed and will not require post-closure care.
1.5.3 Site Cleanup
1.5.3.1 Inventory Removal [40 CFR 264.112(b)(3) and UAC R315-8-7]
The maximum inventory of hazardous waste on hand at any given permitted facility is based on
the maximum allowed under this permit, or a quantity - distance limit for explosives, imposed by
the Department of Defense and ATK. These limitations are specified in Section 1.3 of this
Closure Plan.
Transportation and disposal costs of all hazardous waste during closure of a facility will be based
on hiring a third party. The transportation contractor will be licensed and insured, and the
disposal facility will be a permitted facility. Reactive hazardous wastes may be open burned on
site. Cost calculations for treatment, disposal and equipment decontamination will be based on
maintaining an ATK staff sufficient to complete these efforts.
1.5.3.2 Disposal or Decontamination of Equipment and Structures [40 CFR 264.112(b)(4),
264,112(e), and 264.114 and UAC R315-8-7]
Decontamination of equipment and structures at the Promontory facilities will follow one of two
plans. These plans cover the open burning units, and all other facilities.
The open burning facilities use burn trays, pipes, concrete vaults or rocket cases to contain the
waste to be treated. Most of the material burned is hazardous by characteristic only. Any waste
that may be contaminated with, or contains solvents or hazardous heavy metals is designated as a
derived waste, and the ash collected for offsite disposal. Therefore, except for the derived trays,
all ash in trays, vaults, cases, and on the ground around these units will be collected and disposed
on-site. The burn trays will then be high pressure water washed and the rinsate collected for
disposal. After the final rinse, a composite sample from the trays will be collected and analyzed
at a Utah certified lab to verify proper tray decontamination. Each sample will include rinsate
from 5 trays. Samples will be extracted and analyzed as described in 1.5.1.
All facilities except for M-136, M-225 and S-633 are designed with secondary containment. The
secondary containment includes a concrete pad with curbing and blind sump to simplify
5
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
cleaning. The containment pads and sumps are coated with a chemical resistant epoxy to prevent
liquid migration through the concrete. Secondary containments are inspected daily, when in use,
and maintained as needed. After removal of all containerized waste, the containment pads will
be high pressure water washed, and the rinsate will be collected for disposal. After the final
wash, rinse water samples will be collected from each sump and characterized for disposal.
Samples will be sent to a State certified laboratory for analysis.
1.5.3.3 Closure Containers [40 CFR 264.178,264.112(b)(3), and 270.14(b)(13) and UAC
R315-8-9.9, R315-807, and R315-3-5(b)(13)]
Non-reactive hazardous waste requiring off-site disposal will be placed in a UN or a bulk
USDOT authorized containers for offsite shipment to permitted disposal facilities. Empty
containers will be cleaned in compliance with 49 CFR, and sent for disposal.
2.0 Closure Certification [40 CFR 264.115 and UAC R315-8-7]
Within 60 days of completion of closure of each facility, ATK will submit a certification to the
DSHW by registered mail, that the hazardous waste management facility was closed in
compliance with this Closure Plan. This certification will be signed by ATK and an independent
registered professional engineer licensed in Utah. Documentation supporting the engineer's
registration will be provided upon request.
3.0 Closure Cost Estimate [40 CFR 264.142]
Closure costs are summarized in Table 9. A detailed breakdown of these costs is provided in
Tables 1 through 8. The entire estimate is based on hiring a third party, except for the thermal
treatment and disposal of reactive waste, which will be handled onsite.
4.0 Financial Assurance Mechanism for Closure [40 CFR 264.143 and R315-309]
ATK will maintain current financial assurance meeting the requirements outlined in the above
referenced Federal and State regulations. ATK will provide documentation to DSHW supporting
compliance with financial mechanism requirements.
5.0 Post Closure Plan
If it is determined that a HWMU can't be clean closed, contaminants may be left in place, and a
post closure or site management plan will be developed. Any proposal for post closure care or
site management will be developed in accordance with UAC R315-8-7, UAC R315-8-8 and 40
CFR 264 Subparts G and H, and will be submitted to the Director for approval. If this approach
is necessary, the Post Closure Plan may be modified to provide post closure care for the sites that
are not clean closed.
6
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 1
M-136 Closure Cost Estimate1
Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH)
2 Site prep (technician)
3 Treat remaining waste
4 Excavate contaminated soil
5 Load soil and burned waste
Haul waste and soil to Clean
6 Harbors
7 Landfill disposal, waste and soil
8 State disposal fee, waste and soil
9 Steam clean burn pans
10 Load rinsate
11 Haul rinsate to Clean Harbors3
12 Landfill disposal, rinsate3
13 State disposal fee, rinsate3
14 Demolish pans
15 Load pan debris
16 Haul pan debris to Clean Harbors
17 Landfill disposal, pan debris
18 State disposal fee, pan debris
19 Sample collection
20 Sample analyses, metals
21 Sample analyses, explosives
22 I Sample analyses, volatiles
33-22-0111 x 2
33-22-0112x2
ATK
17-03-0231
17-03-0222
33-19-0221
33-19-7214
Utah DEQ
33-17-0812
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
17-02-0105
17-03-0222
33-19-0221
33-19-7263
Utah DEQ
Site crew
Chemtech-Ford
Chemtech-Ford
Chemtech-Ford
hr
hr
lb
hr
hr
truck-mi
ton
ton
sf
drum
truck-mi
drum
ton
cf
hr
truck-mi
ton
ton
hr
ea
ea
ea
20
40
106,500
20
8
1,050
50
50
1,000
5
350
5
1
2,000
4
350
50
50
40
20
20
20
83.44
50.96
0.25
105.63
68.13
2.50
169.45
32.50
0.39
4.87
2.26
145.00
28.00
0.14
68.13
2.50
169.45
32.50
65.00
210.00
210.00
250.00
SUBTOTAL 75,196
INFLATION ADJUSTMENTS.2042 90,536
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5 %
10 %
10 %
10 %
4,527
9,054
9,054
9,054
TOTAL ESTIMATED COST 122,225
7
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 2
M-225 Closure Cost Estimate1
Item No. Description
Means
No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH)
2 Site prep (technician)
3 Treat remaining waste
4 Excavate contaminated soil
5 Load soil and burned waste
6 Haul waste and soil to Clean Harbors
7 Landfill disposal, waste and soil
8 State disposal fee, waste and soil
9 Steam clean burn pans
10 Load rinsate
11 Haul rinsate to Clean Harbors3
12 Landfill disposal, rinsate3
13 State disposal fee, rinsate3
14 Demolish pans
15 Load pan debris
16 Haul pan debris to Clean Harbors
17 Landfill disposal, pan debris
18 State disposal fee, pan debris
19 Sample collection
20 Sample analyses, metals
21 Sample analyses, explosives
22 | Sample analyses, volatiles
33-22-0111 x2
33-22-0112x2
ATK
17-03-0231
17-03-0222
33-19-0221
33-19-7214
Utah DEQ
33-17-0812
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
17-02-0105
17-03-0222
33-19-0221
33-19-7263
Utah DEQ
Site crew
Chemtech-Ford
Chemtech-Ford
Chemtech-Ford
hr
hr
lb
hr
hr
truck-mi
ton
ton
sf
drum
truck-mi
drum
ton
cf
hr
truck-mi
ton
ton
hr
ea
ea
ea
8
20
55,000
12
4
350
25
25
400
3
350
3
1
800
4
350
20
20
20
12
12
12
83.44
50.96
.025
105.63
68.13
2.50
169.45
32.50
0.39
4.87
2.26
145.00
28.00
0.14
68.13
2.50
169.45
32.50
65.00
210.00
210.00
250.00
668
1,019
13.750
1,268
273
875
4,236
813
156
15
791
435
28
112
273
875
3,389
650
1,300
2,520
2,520
2,520
SUBTOTAL 38,084
INFLATION ADJUSTMENT = 1.2042 45,853
Misc. costs as a percent of the inflation-adjusted
Subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5
10
10
10
2,293
4,585
4,585
4,585
TOTAL ESTIMATED COST 61,901
8
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 3
M-47 Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1 Materials prep (CIH)
2 Materials prep (technician)
3 Load waste motor (crane)
4 Haul motor to burning ground
5 Off-load motor
6 Handling evaluation/planning
9 Motor handling
10 Disposal at burning ground
11 Sweep area
12 Steam clean floor
13 Load rinsate/sweepings
14 Load drums
15 Haul to Clean Harbors
16 State disposal fee
17 Sample collection
18 I Sample analyses, metals/exp
33-22-0111 x 2
33-22-0112x2
Crew SIWSM
Crew COET2
Crew SIWSM
Site personnel
Site personnel
ATK
33-22-0112x2
33-17-0812
33-19-0103
33-19-0103
33-19-0243
Utah DEQ
33-22-0112x2
Chemtech-Ford
hr
hr
hr
hr
hr
hr
hr
lb
hr
sf
drum
ea
truck-mi
ton
hr
ea
12
20
8
16
8
80
40
300,000
8
5,680
10
10
350
1
4
2
83.44
31.58
393.57
93.31
393.57
65.00
65.00
0.25
31.58
0.39
4.87
3.05
2.26
28.00
31.58
210.00
1,001
632
3,149
1,493
3,149
5,200
2,600
75,000
253
2,215
49
31
791
28
126
420
SUBTOTAL 96,135
INFLATION ADJUSTMENT = 1.2042 115,747
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5
10
10
10
5,787
11,575
11,575
11,575
TOTAL ESTIMATED COST 156,258
9
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 4
M-603 Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1 Materials prep (CIH)
2 Materials prep (technician)
3 Load waste motor (crane)
4 Haul motor to burning ground
5 Off-load motor
6 Handling evaluation/planning
9 Motor handling
10 Disposal at burning ground
11 Sweep area
12 Steam clean floor
13 Load rinsate/sweepings
14 Load drums
15 Haul to Clean Harbors
16 State disposal fee
17 Sample collection
18 | Sample analyses, metals/exp
33-22-0111 x 2
33-22-0112x2
Crew SIWSM
Crew COET2
Crew SIWSM
Site personnel
Site personnel
ATK
33-22-0112x2
33-17-0812
33-19-0103
33-19-0103
33-19-0243
Utah DEQ
33-22-0112x2
Chemtech-Ford
hr
hr
hr
hr
hr
hr
hr
lb
hr
sf
drum
ea
truck-mi
ton
hr
ea
8
12
8
12
8
40
20
120,000
8
1,830
4
4
350
1
4
2
83.44
31.58
393.57
93.31
393.57
65.00
65.00
0.25
31.58
0.39
4.87
3.05
2.26
28.00
31.58
210.00
668
379
3,149
1,120
3,149
2,600
1,300
30,000
253
714
19
12
791
28
126
420
SUBTOTAL 44,727
INFLATION ADJUSTMENT = 1.2042 53,851
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5
10
10
10
2,693
5,385
5,385
5,385
TOTAL ESTIMATED COST 72,699
10
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 5
M-186A Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
1 Site prep (CIH)
2 Site prep (technician)
3 Load drums
4 Haul drums to Clean Harbors
5 Landfill disposal
6 State disposal fee
7 Truck washout/decon
8 Steam clean floor
9 Rinsate sample collection
10 Sample analyses, metals
11 j Sample analyses, explosives
33-22-0111 x2
33-22-0112x2
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
33-19-0311
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
8
24
400
1,750
400
100
1
1,930
4
1
1
83.44
31.58
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
SUBTOTAL 68,991
INFLATION ADJUSTMENT = 1.2042 83,065
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob 5 % 4,153
Engineering/permitting 10 % 8,307
DSHW oversight 10 % 8,307
Contingency 10 % 8,307
TOTAL ESTIMATED COST 112,138
11
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 6
M-705S Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1 Site prep (CIH)
2 Site prep (technician)
3 Load drums
4 Haul drums to Clean Harbors
5 Landfill disposal
6 State disposal fee
7 Truck washout/decon
8 Steam clean floor
9 Rinsate sample collection
10 Sample analyses, metals
11 I Sample analyses, explosives
33-22-0111 x2
33-22-0112x2
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
33-19-0311
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
4
8
32
350
32
8
1
1,850
4
1
1
83.44
31.58
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
334
253
98
791
4,640
224
158
722
260
210
210
SUBTOTAL 7,899
INFLATION ADJUSTMENT = 1.2042 9,510
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5
10
10
10
475
951
951
951
TOTAL ESTIMATED COST 12,838
12
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 7
E-501 Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1 Site prep (CIH)
2 Site prep (technician)
3 Load drums
4 Haul drums to Clean Harbors
5 Landfill disposal
6 State disposal fee
7 Truck washout/decon
8 Steam clean pad
9 Rinsate sample collection
10 Sample analyses, metals
11 Sample analyses, explosives
33-22-0111 x2
33-22-0112x2
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
33-19-0311
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
4
8
160
700
160
40
1
1,760
4
1
1
83.44
31.58
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
334
253
488
1,582
23,200
1,120
158
686
260
210
210
SUBTOTAL 28,501
INFLATION ADJUSTMENT = 1.2042 34,315
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5
10
10
10
%
1,716
3,431
3,431
3,431
TOTAL ESTIMATED COST 46,325
13
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 8
T-29B Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1 Site prep (CIH)
2 Site prep (technician)
3 Extra drum for dilution
4 Transfer and dilute hydrazine
5 Load drums
6 Haul drums to Clean Harbors
7 Landfill disposal
8 State disposal fee
9 Truck washout/decon
10 Steam clean floor
11 Rinsate sample collection
12 Sample analyses, metals
13 | Sample analyses, explosives
33-22-0111 x2
33-22-0112x2
33-19-0402
Site crew
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
33-19-0311
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
4
8
1
4
2
350
2
1
1
200
4
1
1
83.44
31.58
80.00
65.00
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
334
253
80
260
6
791
290
28
158
78
260
210
210
SUBTOTAL 2,958
INFLATION ADJUSTMENT = 1.2042 3,561
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob 5 % 178
Engineering/permitting 10 % 356
DSHW oversight 10 % 356
Contingency 10 % 356
TOTAL ESTIMATED COST 4,807
14
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified January, 2014
UTD009081357
Table 9
S-633 Closure Cost Estimate1
Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1
2
3
4
5
6
7
Site prep (CIH)
Site prep (technician)
Disposal at Burning Ground
Sample Collection
Sample analyses, metals
Sample analyses, explosives
Sample analyses, volatiles
33-22-0111 x2
33-22-0112x2
ATK
Site crew
Chemtech-Ford
Chemtech-Ford
Chemtech-Ford
hr
hr
hr
lb
ea
ea
ea
4
8
75,000
8
8
8
8
83.44
50.96
0.25
65.00
210.00
210.00
210.00
334
253
18,750
520
1,680
1,680
1,680
SUBTOTAL 24,897
INFLATION ADJUSTMENT = 1.2042 29,976
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/permitting
DSHW oversight
Contingency
5 %
10 %
10 %
10 %
1,499
2,997
2,997
2,997
TOTAL ESTIMATED COST 40,468
Closure Cost Estimate Footnotes:
1 All cost estimates were provided by EarthFax Engineering, Inc., using Means 2005
Remediation Cost Data adjusted for inflation except as otherwise noted. Cost estimates assume
using Level C PPE.
2 Subtotals multiplied by an inflation adjustment (1.204) based on July 2005 cost index of 151.6
from Means 2009 Heavy Construction Cost Data and July 2009 cost index of 182.5 from the
Means web site.
3 Closure cost estimates are based on rinsate from M-136 and M-225 being shipped off-site for
disposal. Rinsate from the other HWMUs will be treated on-site and discharged in accordance
with the UPDES permit.
15
ATK Launch Systems Inc. - Promontory Modified January, 2014
Attachment 5 - Closure Plan UTD009081357
Table 10
Summary of Closure Cost Estimates
Hazardous Waste Management Unit Estimated Cost ($)
M-136 122,225
M-225 61,901
M-47 156,258
M-603 72,699
M-186 112,138
M705S 12,838
E-501 46,325
T29B 4,807
S-633 40,468
Total 629,659
16
ATK Promontory Facility - Figure 6A
Figure 6B
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EL 99"-2 7/8"
TOP OF WALL
E-501 PLAN VIEW
SCALE 1* = 20'-0"±
EL 100'-0"
3-5 7/8"
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SECTION
SCALE: 3/8* = 1-0"
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SCALE: 3/8"" = V-O"
E-501 PAD LAYOUT
FIGURE B-1
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SCALE: 1/4" = T-O"
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SECTION
SCALE: 1/4" = f-0"
B
W.S. (TYP.)-\ 12' £2,
8
«. 1
CSJ
DOUBLE T
WALL PAN
SECTION
SCALE: 1/4" = T-0"
M-705S BUILDING LAYOUT
FIGURE C-1
r
r r
M-603'
4 # if ^
/
Figure 6D
2
RAIL STORAGE AREA STORAGE AREA
PIT
I i
73'-0
EXTERIOR WALL
PIT
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SECTION
SCALE: 3/32"
M-603 PLAN VIEW
SCALE: 1/16" = 1'-0"±
M-603 BUILDING LAYOUT
FIGURE D-1
N
o
Ik
o
M-186
I
Fieure 6E
JHT-B-
SECTION
SCALE: 1/4"= T-0"
ti" £
SECTION B
SCALE: 1/4"-1-0"
SECTION
SCALE: 1/4"= 1'-0"
r so-f—J" 1-6" SQ-»f Jf
>t-2,-6"^r
SECTION
SCALE: 1/4"=1'-0"
CHEMICAL RESISTANT
CONCRETE FLOOR
W/ CONTAINMENT
CURBS TYP.
Llfl T"
4>
•
my
•
n:7
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In
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-23-8'
-25-0'
M-186A BUILDING LAYOUT
FIGURE E-1 N
-136
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M-136 BURN GROUND
FACILITY LAYOUT
FIGURE F-1
SCALE: r = 60ff-0"
o
1 s
mo
ENCLOSED BLOC,
NO FLOOR COATING
OVER SLAB
14T-8-
16" CONC WALL;
SIDE AND BACK
51-0
PERMITTED AREA
6 CONC. SLAB
I I I I CO
ROLL-UP DOOR
M-47 PLAN VIEW
SCALE 1" = 30'-0"±
M-47 BUILDING LAYOUT
FIGURE G-1
N
n
T-29B
it?
Figure 6H
12' SQ. DRAIN PLATE
WITH 2" PPE UNDER
FLOOR TO EXTERIOR
SUMP
B
•
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14-8
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4
2x4 FRAMED WALL WIT
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ON EXT., 1/2" PLYWOi
WITH 16GA SST INT.
1
-7
SECTION
SCALE: 1/4* = 1'-0"
A
Ll CO
to
T-29B PLAN VIEW
SCALE: 1" - 10'-O"
SECTION /T
SCALE: 1/4" - 1'-0"
T-29B BUILDING LAYOUT
FIGURE H-1
N
o
225
Fie ure fil
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y 7
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M-225 BURN GROUND
FACILITY LAYOUT
FIGURE 1-1
SCALE: 1" = 200'-0,d
ATK Launch Systems Part B Operational Plan
Promontory Facility Process Information
UTD 009081357 January, 2014
ATTACHMENT 11
M-136 and M-225 Thermal Treatment Operations
11-1
ATK Launch Systems
Promontory Facility
Part B Operational Plan
Process Information
January, 2014 UTD 009081357
1L0 PROCESS INFORMATION
All reactive waste management operations at the facility are conducted and are under
the management of ATK. The reactive waste management process is described in
the following text.
The ATK Promontory facility is located in a remote area of west Box Elder County,
Utah, approximately 30 miles northwest of Brigham City, and approximately 11 miles
north of the Great Salt Lake. The facility was purchased by Thiokol in 1956, with the
exception of a 1,500-acre tract that was sold to the U.S. Air Force in 1958 and then
repurchased in 1995. The facility has been held in its entirety since purchase.
ATK Launch Systems conducts thermal treatment of reactive hazardous wastes at two
treatment units: (1) the main facility, M-l 36, located centrally to the two main
manufacturing sites; and (2) M-225 located in a remote development location called
M-l 36 is the primary treatment area for conducting open burning at the Promontory
facility. Open detonation is also conducted at M-136 which is a secured fenced facility
within the main facility fence.
The M-225 treatment area receives small amounts of the reactive hazardous waste
materials from the Plant III propellant development area. The M-225 treatment unit is
surrounded with an 8-foot high chain link fence. The waste materials are treated via
open burning or open detonation.
The M-136 and M-225 treatment areas are fenced and are located within a controlled and
fenced facility that is patrolled and maintained by a security department. The treatment
areas have warning signs posted around the perimeter. The vegetation is controlled within
the treatment areas through application of herbicide and putting in place loads of gravel
and road base. Surrounding both treatment areas are a large system of fire breaks that are
constructed using large equipment to till and cultivate a large strip of land removing any
vegetation. The system of fire breaks are designed to contain a fire within its boundaries.
Contained within the boundaries of the M-136 treatment area are twelve former surface
impoundments called Liquid Thermal Treatment Areas (LTTAs). These impoundments
were used for the disposal of hazardous waste and wastewater and then capped and closed.
The units are currently under post closure care and managed through a Post Closure Permit
which includes requirements for groundwater monitoring and corrective action. The Post-
Closure groundwater monitoring program includes all wells around the M-136 and M-225
treatment areas as part of the groundwater monitoring system. These wells are routinely
monitored thorough the permit requirements which includes the Sampling and Analysis
and Quality Assurance Plans.
The Promontory facility is located in the Blue Spring Valley which is bounded on the
east by the Blue Spring Hills and on the west by Engineer Mountain and the
Promontory Mountain ranges. Within the Blue Spring Valley, the terrain is
characterized by topography that slopes down from the mountain crest at an elevation
of approximately 6,050 feet above mean sea level (AMSL) toward the center of the
11.1 Facility Description
Plant III.
11-2
ATK Launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
January, 2014
Blue Creek Valley at an elevation of 4,250 feet AMSL. As a result, the surrounding
environment extending out to 6.2 miles (10 kilometers) from both treatment units can
be characterized as complex terrain.
GEOLOGY
The ATK facility is located in the Southern Blue Creek Valley, northwest of the Salt
Lake Valley, which is the eastern most structural valley of the Basin and Range
physiographic province, which includes parts of Utah, Idaho, Nevada, Arizona, and New
Mexico. The Basin and Range province consists of a number of north-south aligned
mountain ranges and valleys bounded by high-angle normal faults. The Blue Creek
Valley, in which ATK is located, is bounded on the east and west by the Blue Springs
Hills and the Engineer and Promontory Mountain ranges, respectively. Movement along
the faults has displaced the mountains upward relative to the adjacent valley. Likewise,
the mountains immediately west of ATK are bounded on their eastern margin by one or
more faults which are partly buried by recent deposits.
Bedrock, composed of Middle Paleozoic shale, sandstone, and limestone, is exposed in
the ranges adjacent to the site. The bedrock is highly fractured with some folding.
During the Mississippian and Permian Periods, marine sediments consisting of sand, clay,
and calcareous detritus were deposited in shallow marine environments. In the late
Cretaceous Period, compressional forces from the west resulted in folding and thrust
faulting in conjunction with uplift of the region into mountain ranges. Extensive jointing
and fracturing of the bedrock were caused by this folding and faulting episode. Tensional
stresses in the early to middle Tertiary Period resulted in north south trending normal
faults that formed a series of high linear mountain ranges with intervening basins which
received sediment from adjacent highlands. This activity was associated with volcanism
and ancient lake deposition.
In the late Tertiary Period, a series of geologic units tentatively identified as the Salt Lake
Group were formed from deposition of sediments in large lakes which developed within
the valleys. These lake deposits are composed primarily of silts and clays with minor
amounts of sand and gravel and are characterized by low to moderate permeabilities;
extensive deposits of volcanic ash are also present in the Salt Lake Group. The alluvial
fan deposits were overlapped by more recent lake sediments of Pleistocene Lake
Bonneville, the predecessor to the present Great Salt Lake. Lake Bonneville covered
much of western Utah and parts of Idaho and Nevada between about 23,000 and 12,000
years ago. Deposits associated with the lake consist of lakebed and alluvial materials
reworked by lake bottom and shoreline processes. Lake Bonneville sediments thicken
southward.
The most recent sedimentary deposits consist of stream alluvium and mud and debris
flows. The stream alluvium consists primarily of silty and clayey sand and gravel. The
mud and debris flow deposits are characterized by a broad gradation of sediments from
clay-size fines to boulders as large as 3 feet in diameter.
HYDROGEOLOGY
Ground water in Blue Creek Valley occurs under unconfined and confined conditions.
These two conditions exist in fractured and faulted bedrock, lake clays and gravels,
unconsolidated alluvium, gravel, and sandy deposits. Precipitation, surface water
infiltration, and plant discharges that infiltrate into sediments may migrate slowly,
11-3
ATK Launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
January, 2014
vertically, and horizontally to form perched water tables above the 50- 150-foot depth of
the regional water zone. The perched ground water may eventually migrate to the deeper
regional system. The regional system ranges from 50- 600 feet in depth depending on the
topographical location. Blue Creek may recharge shallow aquifers in the center of the
Blue Creek Valley. The direction of movement within the faulted and fractured bedrock
will be controlled by the connection of faults and fractures. Regionally, the ground water
flow trend is from north to south. Depth to groundwater at the M-136 treatment units is
an average 300 feet. Depth to groundwater at the M-225 treatment unit is 600 feet.
The ground water quality in Blue Creek Valley is generally poor due to naturally
occurring chlorides and total dissolved solids. Levels of dissolved solids range from 400
to over 12,000 mg/l. The quality of ground water depends upon the sediments, which it
has contacted. Quality is quite good in local, up gradient areas of water recharge, but
degrades rapidly as it moves from mountain to the valley axis. High levels of total
dissolved solids in lowland areas are probably due to slow migration through Tertiary
sediments. Down gradient from the ATK sites, quality deteriorates rapidly as it enters the
mudflats of the Great Salt Lake.
CLIMATE
ATK has a 10-meter meteorological tower and instruments to measure and record air
temperature, barometric pressure, relative humidity, solar radiation, precipitation, vertical
and horizontal wind speed, and direction.
The ATK plant site is classified as semiarid, with an average annual total precipitation of
14.88 inches at the ATK meteorology station. During the winter months, the average total
snowfall amounts to 24 inches. Precipitation typically occurs on 95 days out of the year
(includes trace precipitation). During the year, it would be expected that 35 percent of the
days would be clear, 30 percent of the days would be partly cloudy, 34 percent would be
cloudy, and fog would be expected to occur about 1 percent of the time. According to
interpreted weather data for the ATK facility, the 25-year storm with 24-hour duration
would result in 2.4 inches of precipitation.
Evaporation rates are high throughout the year, with the Great Salt Lake averaging 66 in.
a year. The average area evapotranspiration rate is 46.6 inches. The consistently low
precipitation and high evaporation allow little if any percolation into subsurface soils.
The average annual temperature in the ATK Promontory area is in the 45 to 50 degree
range, with generally hot, dry summers. Relative humidity averages between 20 and 30
percent during summer afternoons. Nights are usually cool, but daytime maximums
occasionally exceed 100 degrees F. On clear nights, cold air usually drains from the
slopes of the adjacent ranges and accumulates on the valley floor, while the foothills and
bench areas, such as at Thiokol, remain relatively warm. The average daily temperature
ranges from about 11 to 32 degrees F in January and from about 54 to 91 degrees F in
July.
On an annual basis, the winds for the valley tend to prevail from the north during the
earlier morning hours and south to southeast, averaging about 10 mph, during the
afternoon.
11-4
ATK Launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
January, 2014
Blue Creek is the only perennial stream in the valley drainage basin and is the closest
water body to the M-136 treatment unit. Blue Creek originates some 15 miles north of
the Promontory facility from a warm saline spring, which flows along the western
boundary of the facility.
The Promontory area is characterized as a very sparsely populated rural region, with
primarily dry farms and ranching activities. Low growing perennial grasses and shrubs
characterize the vegetation in the area. The ecological habitat found at the Promontory
facility includes many head of mule deer and large populations of various birds, rabbit,
and predator species.
11.2 WASTE CHARACTERIZATION
Wastes will be characterized to identify hazardous properties to ensure they are
properly managed. The Waste Analysis Plan (see Attachment 1) will be used to
characterize and classify reactive wastes.
11.3 REACTIVE WASTE DESCRIPTION
The primary products produced at the facility include solid rocket motors, military and
aviation flares, and high explosive/high energy compounds. Solid rocket motors are
typically cast with composite propellants. Composite propellants are classified as a
DOT 1.3 material, and typically contain a non-explosive liquid binder mixed with
aluminum powder and ammonium perchlorate. Flares are generally classified as a
DOT 1.3 material, and typically contain an inert binder, a metal powder, and an
oxidizer. High explosive compounds are generally classified as DOT 1.1 material and
are generally nitramine compounds developed for specific military requirements.
Reactive wastes are produced from the manufacturing process include, but are not
limited to the following: cured and uncured propellants; rocket motors; small initiating
devices; explosives articles, propellant scrap; and explosive ingredients such as HMX,
RDX, CL-20, explosive contaminated metal powders such as aluminum and
magnesium and oxidizers such as ammonium perchlorate and potassium perchlorate.
The facility also contains both quality assurance and research and development
laboratories. The quality assurance laboratories generate wastes similar to
manufacturing wastes. The Research and Development laboratories generate a small
quantity, but a wide variety of both explosive compounds and precursors to explosive
compounds.
Reactive wastes are characteristic hazardous wastes for reactivity (D003). Nearly all of
the reactive wastes are reactive due to the presence of propellants and explosives.
Some reactive wastes, such as those from laboratory operations, may contain solvents
which would also be a listed waste defined by R315-2 of the UAC. Wastewater
treatment sludge generated from the processing of explosives is a K044 listed
hazardous waste. Reactive wastes also include materials such as rags, gloves, other
personal protective equipment, plastics, rubber and paper contaminated with explosive
materials during the manufacturing process.
Reactive wastes may also be received from off-site sources. With one exception, off-
site wastes are rocket motors, propellants or explosives with similar formulations and
ingredients to those generated on site. The exception is wastes received from Autoliv
Automotive Safety Products Inc. (Autoliv) which are generally DOT Class 1.3
11-5
ATK Launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
January, 2014
materials containing compounds similar in nature to flare products. Ingredients include
oxidizers (e.g. ammonium nitrate, copper nitrate, potassium nitrate, strontium nitrate
and potassium perchlorate), reactive metal powders (e.g. boron, zirconium, aluminum
and magnesium), nitrogen rich fuels (e.g. tetrazole or triazole compounds) and
polyacrylimide binders. Many of the Autoliv products were initially developed at
Promontory when Thiokol Chemical Corporation operated the site. Autoliv and ATK
are co-located, and a working relationship continues between the two companies,
which includes open burning reactive wastes generated by Autoliv that can't be
commercially disposed.
11.4 REACTIVE WASTE GENERATION AND COLLECTION
ATK uses a variety of containers to store reactive wastes at the Facility. The standard
containers used at the Facility are described in this section. However, due to the nature
of our business, new types of containers may be required in the future, and can't be
described in this application. To ensure that all containers are safe to use, containers
will be selected using the DOD Contractor's Safety Manual for Ammunition and
Explosives (DOD 4145.26-M). All containers for reactive waste that are currently
used, or will be used in the future, will meet the DOD 4145.26-M requirements.
Operating buildings generating reactive wastes use a variety of collection containers as
described below:
• Conductive Containers -Electrically conductive containers are typically bags
made of opaque, volume-conductive carbon-impregnated polyolefin or
polypropylene. They can be grounded to prevent he build up of static electricity.
The bags are available in a variety of sizes from small containers to large than one
cubic yard. They are typically used to line other containers, but can be used
without an outside container. Typical conductive containers include Velostat®
bags, Velostat® sheet material, and conductive sling bag and Super Sack®
containers.
• Static Dissipative Containers -Static dissipative containers are typically bags
made of a polyethylene material. The material prevents the build-up of static
electricity by continually dissipating the charge. These bags are typically used to
line other containers, but may be used without an outside container. Typical static
dissipative containers include pink poly bags, pink poly sheet material and static
dissipative Cromhmiq™ sack containers.
• Fiberboard drums - Wastes may be collected directly into commercially available
30-gallon fiberboard drums. These drums have a removable lid that can be sealed
in place with a locking chime after the drum is filled. Fiberboard drums selected
for this application are approved by DOT for highway transportation of hazardous
materials and can be used to ship these wastes off-site for treatment and disposal.
• Sumps- Explosive contaminated wastewater is collected in sumps at the point of
generation. When appropriate, propellant "chips" and other suspended solids are
filtered out before the wastewater reaches the tank, and when the wastewater is
pumped out of the tanks. The wastewater is pumped into tanker trucks where it is
treated at M-705 and discharged under a UPDES permit. Filters containing "chips
11-6
ATK Launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
January, 2014
and other suspended solids are accumulated , and treated and disposed of in
accordance with the applicable hazardous waste management rules.
• Other Containers - Large blocks of cured propellant are containerized by wrapping
the waste in plastic and placing it on wood pallets. Ammunition cans are used to
hold initiating and ordnance items. Waste rocket motors are generally large
enough to be their own container. Plastic buckets are used to hold conductive and
static dissipative bags. The buckets are reused and become contaminated with
reactive material. The buckets are cleaned by removing the contaminated material
using a rag. The contaminated rag is then collected for disposal and managed as
directed in UAC 315-5. If a bucket cannot be cleaned, it is managed as a hazardous
waste and treated by open burning. Laboratory waste may come in a variety of
sizes and types of containers such as plastic, metal or glass. DOT containers for
Class 1.1 and 1.3 reactive materials may also be used. A plastic cover secured to a
tray may be used as a container for unburned residue or containers of off-site waste
stored in a tray for up to 14 days from its receipt to thermal treatment.
Operating personnel accumulate reactive waste in these containers as it is generated.
When a reactive waste container is full or at the end of an operating shift, it is closed
or sealed as applicable for the container. A hazardous waste label is filled out and
attached to the container. Operators at the buildings that generated the waste enter
pertinent information into the electronic waste tracking system described in Section
Most operating buildings that generate reactive waste have an explosive waste
collection area located approximately 50 feet from the operating building. Except as
described below, waste containers are placed in the collection area to facilitate removal
of waste propellant, explosive and reactive wastes from the operating buildings. The
collection sheds are constructed of wood or corrugated metal and are secured to a
concrete floor.
When managing reactive wastes, ATK building operators use the temporary collection
sheds as 90-day or satellite accumulation stations. Reactive wastes are placed in the
collection area either as they are generated or at the end of each operating shift. Waste
containers that are not full at the end of a shift are sealed, a hazardous waste label is
attached to the container and they are moved to the temporary collection area.
Containerized explosive wastes are picked up from the collection location using a
vehicle approved for the transport of explosive wastes. Extreme care is used when
handling all explosive wastes. Wastes are transported directly to either the M-136 or
M-225 burning ground. Reactive wastes generated at Plant 3 are transported to M-225.
All other reactive wastes are transported directly to M-136.
Propellant and explosive operating buildings at the facility, including explosive waste
90-day storage and satellite accumulation areas, are designed and constructed in
accordance with strict federal standards. These standards identify the criteria that must
be used to construct buildings where reactive material will be used and/or stored.
These standards also require that explosive buildings to be separated by sufficient
distance, or a quantity-distance relationship, to prevent an explosive event in one
building from propagating to another building. Quantity-distance rules also control the
location of propellant and explosive operating buildings with regard to public property
11.5.
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(highways, parks, etc,) and private property. All buildings used for temporary storage
of waste explosives, including the temporary storage sheds, are correctly sited with
respect to the applicable quantity-distance rules.
11.5 QUANTITY DISTANCE DETERMINATION
The facility uses the Department of Defense (DOD) guidance to calculate quantity
distance relationships. The evaluation was conducted according to NAVSEA OP5,
Volume 1, Revision 4, Paragraph 11-3.2. The method used to determine safe quantity
distance relationships for both Class 1.1 and 1.3 propellants is provided below.
The quantity distance relationship for Class 1.3 propellant is determined by the following
formula: D = 5Wlfl. Where W is the weight of Class 1.3 propellant and D is the safe
distance. The formula applies to Class 1.3 propellant and Class 1.3 propellant ingredients.
The safe distance is defined as the interline protection for mass fire for Class 1.3
propellant.
The quantity distance relationship for Class 1.1 propellant is determined by the
following formula: D = 18W1/3. Where W is the weight of a Class 1.1 explosive and D
is the safe distance. The formula applies to Class 1.1 propellant and Class 1.1 propellant
ingredients. The safe distance is defined as the unbarricaded interline protection for Class
1.1 propellant.
11.6 WASTE TRACKING
ATK maintains an electronic waste tracking record to collect and manage information
about reactive wastes generated at the facility. This tracking system uses a
combination of paper records and an electronic database.
Wastes being accumulated in containers at operating areas within the facility are
labeled and managed in accordance with R315-5 of the UAC for either a satellite
accumulation or less than 90-day hazardous waste storage area. The electronic tracking
system maintains the following information to monitor cradle to grave waste handling
practices:
• ID# - container identification number
• Date - accumulation date
• Building # - identifies where the waste was generated;
• RWDI# - identifies the reactive waste disposal instruction
• Profile # - identifies the profile
• Quantity of PEP - quantity of propellant, explosive or pyrotechnic material;
• Quantity of Contaminated waste - Explosive and total weight of the container;
• Material Description - description of the material
• Propellant name - describes the propellant by type, program other identifier
• Log Date - date logged into the system
The electronic tracking system maintains information on all containers of reactive
waste in 90- day storage at M-136 and M-225. It also tracks the total weight of waste
placed on each burn tray, and the total weight of waste burned on any given day.
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In the event reactive waste is shipped off-site for treatment, the system maintains the
following information: the manifest number, transporters, manifest ship date, and
manifest return date.
In the event the electronic tracking system is not operable, the information will be
tracked using paper copies until the electronic system is operable. In the event this
occurs, ATK will transfer all information to the electronic system within 72 hours of
the system becoming operational again.
11.7 REACTIVE WASTE STORAGE
ATK may store hazardous wastes prior to disposal. Reactive wastes are stored in
designated facilities as described in this section, and are segregated according to
compatibility requirements.
• M-47 - This building can be used to store any of the explosive wastes listed in
Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be
provided to permit proper container inspection; all containers will be labeled and
managed in accordance with R315-5 of the UAC. This building does not have water
immediately available, and relies on the Fire Department for any emergency action.
Employees are not permitted to fight fires inside an explosive storage building. This
building is totally enclosed, so there are no precipitation run-on or run-off concerns.
• M-603 - This building can be used to store any of the explosive wastes listed in
Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be
provided to permit proper container inspection. All containers will be labeled and
managed in accordance with R315-5 of the UAC. This building is equipped with a
fire sprinkler system, which is checked annually. Employees are not permitted to
fight fires inside an explosive storage building. This building is totally enclosed, so
there are no precipitation run-on or run-off concerns.
• M136- trays at M-136 can be used to store waste received from off-site for up to 14
days. All containers of waste must be closed, labeled and managed in accordance
with R315-5 ofthe UAC.
• S-633- This storage pad can be used to store any of the explosive wastes listed in
Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be
provided to permit proper container inspection. S-633 is approximately 100' x 100'
in size. It is secured by a perimeter fence, a vehicle access gate that can be locked,
and has the appropriate warning signs for a storage area. It has a road base surface,
and has lighting protection. All waste containers will be labeled, and managed in
accordance with R315-5 of the UAC. This area does not have water immediately
available, and relies on the Fire Department for any emergency action. Employees
are not permitted to fight fires inside a reactive waste storage area. Precipitation run-
on or run-off is prevented by a combination of diversion ditches, collection ditches
and trenches.
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11.8 TREATMENT OF REACTIVE WASTE
The facility utilizes thermal treatment methods to safely dispose reactive hazardous
wastes. Thermal treatment methods include both open burning and open detonation.
Reactive hazard wastes may also be shipped off-site and treated at other permitted
treatment storage and disposal facilities.
11.8.1 OFF-SITE TREATMENT OF REACTIVE WASTE
All hazardous reactive wastes treated off-site will comply with all applicable local,
State and Federal regulations.
11.8.2 ON-SITE TREATMENT
The M-136 and M-225 facilities are thermal treatment units designed to treat reactive
hazardous wastes using open burning or open detonation. Treatment by open burning
at M-136 is limited to a maximum of 106,500 pounds per day. Each burn station 1-12
and 14 may treat all or a portion of the 106,500 pounds. Burn station 13 can treat a
maximum of 50,000 pounds per day. Treatment by open detonation will be conducted
at burn stations 13 and 14 only, and is limited to 600 pounds per event. Figure 11-2
shows the security fence, control bunker, and vehicle access points for M-136.
Treatment by open burning at M-225 is limited to a maximum of 4,500 pounds per day.
Each burn station 1-4 may burn all or a portion of the 4,500 pound limit. Treatment by
open detonation is limited to the 600 pounds per day in the M-225 open detonation
area. Figure 11-2 shows the security fence and vehicle access points for M-225.
The process flow for open burning at both treatment areas is identified below:
1. Pre-planned Activities
2. Placement of Waste in Treatment Units, Wiring and Ignition
3. Post-burn Inspection and Cleanup
The following precautions are used to ensure operator safety while working at the M-
136 and M-225 burn grounds:
1. Emergency egress routes are always maintained while employees are working in
the treatment areas.
2. The firing systems are disabled using an interlock to prevent accidental ignition.
3. Weather conditions are monitored to assure operators are not exposed to risks from
lightning strikes.
11.8.2.1 PRE- PLACEMENT ACTIVITIES
OBOD operations at the facility are a continuous process. Wastes are transported from
the generation areas and brought into the treatment areas on a daily basis. Wastes are
off-loaded and placed in trays and managed under 90-day rules until treatment occurs.
When treatment is completed, the trays are cleaned, inspected and the loading process
begins again. Pre-placement inspections occur during the post-burn inspection and
clean-up phase of the treatment process.
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Prior to placing reactive waste for treatment at the OBOD facilities, operators visually
verify the following tasks were completed during post-burn inspection and cleanup
activity:
1. Any untreated waste and/or unburned residue has been identified, collected and is
being properly managed;
2. Storm water accumulated in the trays has been removed.
3. Trays which do not meet the inspection criteria have been removed from service.
11.8.2.2 PLACEMENT OF WASTE IN TREATMENT UNITS
Reactive hazardous waste is transported to the OBOD facilities using a vehicle which
meets explosive safety requirements. Reactive hazardous waste may be offloaded by
hand or mechanical means including a knuckle boom, forklift, crane, or other
appropriate equipment. Reactive hazardous waste is not collected, transported, or
unloaded during a lighting warning, which is defined as lightning within 30 miles of
the facility. If collection, transportation, or unloading operation has started, the
operation is brought to a safe halt.
Treatment units used to treat and contain waste are listed below but are not limited to,
the following:
• Burn Trays - Metal trays constructed in several different sizes including, 4'X10',
5'X16', 8'X8', and 8'X20'. Typical construction is out of steel plate A36 grade
steel ranging thicknesses of 3/8", VS", V", and 1 inch.
• Clamshell Disposal Trays- Used for the disposal of items that have the potential
to be propulsive. Typical construction is a square welded box 1-inch thick, A36
steel plate with a vented lid that enables treatment of potentially propulsive items,
while safely containing the propulsive energy.
• Restraining Trays are typically constructed of 1-inch thick A36 steel plate
welded into a square box that is filled with sand. There are several different
designs for restraining trays which include: (1) steel tubes sitting on end in the sand
are used to hold potentially propulsive items which are secured to the tube allowing
the exhaust to vent out of the open end of the steel tubes, and (2) used without steel
tubes where propulsive items are secured at the base for items where the exhaust
will vent from the side of the item.
• Small Motor Disposal Vaults- Constructed from a concrete 10x10 foot sump
filled with sand. Small rocket motors such are placed into the sand with the aft end
exposed perpendicular to the ground. Motors are treated with the propulsive force
directed into the concrete sump and the sand.
The vehicle containing hazardous waste is to be parked near the receiving tray with any
side rails lowered to facilitate offloading of the waste. Containers are transferred
directly from the truck and carefully placed into the burn tray. Items to be open
detonated are offloaded from the vehicle by hand, knuckle boom, or by forklift and
then placed on the ground for treatment
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Items that have the potential to be propulsive are off-loaded into the clamshell,
sandbox, or small motor disposal vault by hand, knuckle boom, or by forklift. After
offloading, items are restrained using engineered restraints allowing for safe treatment.
Potentially propulsive items (e.g. rocket motors) may also be off-loaded into station 14
using the knuckle boom, forklift, or crane. The case may be placed on the ground,
sand/dirt mounds, chocks, or other support media for treatment.
PEP waste which generates ash or residue which is listed or characteristic is segregated
from PEP waste which generates non-regulated ash. Ash and residue is managed as
described in 11.8.2.5.
11.8.2.3 WIRING AND IGNITION
After waste has been placed on a tray, the next step is to complete a resistance check on
the ignition system. As a safety precaution, a physical interlock (e.g. key) is used to
prevent the firing panel from being accidently engaged during the resistance check.
The key remains in under the control of the operators during the resistance check and
all subsequent operations until the operators return to the control bunker to complete
treatment. Each firing stanchion must have 10 ohms or less. A firing stanchion that
has a resistance of 10 ohms or greater must be tagged out until repairs are made.
Once the resistance check is completed igniter installation is performed. The igniter is
attached to the firing system by connecting the lead wire from the initiating device to
the firing stanchion. Igniter installation operations are performed by a minimum of two
operators. The types of igniters commonly used are listed below:
1. Burn Grounds Igniter -Propellant with a hot wire
2. Bag Igniters - Propellant, explosive, pyrotechnic with electric match or other
electric initiation device.
3. Blasting Caps - Small amount of primary explosive
4. Electric Matches - wire attached to small explosive device
5. Fuse - a tube, cord, or the like, filled or saturated with combustible matter
6. EBW - Exploding Bridge Wire, a wire that contacts explosives fired by a high
voltage electricity source
7. TBI - Through Bulkhead Initiator, shock initiation of an energetic material
provided through an integral barrier
Linear shaped charge may also be used to facilitate thermal treatment of potentially
propulsive wastes and items contaminated with reactive hazardous wastes.
Reactive hazardous wastes may be desensitized by adding one of the liquids listed
below. The addition of these liquids modifies the reactive nature of the waste making it
safer to store, handle and transport. It also slows the burning rate of the material during
treatment.
1. Oils
2. Water
3. Alcohol
4. Triacetin
5. Physical Media (e.g. Conductive and static dissipative packaging)
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When necessary, additional burn enhancers may be used to promote a more complete
burn. Additives include, but are not limited to, the following:
1. Diesel Fuel
2. Wood (e.g. Pallets)
3. Propellant
The burning ground operators verify the treatment area has been evacuated of all
personnel before proceeding with ignition. The burning ground operators retreat to the
control bunker and close the door. The lockout key is inserted into the control system
which allows power to the firing panel. Circuit continuity is checked at the firing panel
which verifies that igniters were properly installed. A flashing red light is activated
once the firing system is operational to alert personnel inside the area that a treatment
operation is about to begin. The appropriate stanchion is chosen and the igniter fired
by pressing the ignition buttons. Two operators are required for this operation.
In the event of a misfire, operators must wait a minimum period before reentering the
treatment area to correct the problem. If a misfire occurs on the first tray, being burned
the process stops, and personnel are required to stay in the bunker for at least 30
minutes. After 30 minutes, the igniter which failed is uninstalled. This process
requires two employees and is done by: (1) the two employees performing the task
remove the physical interlock and keep it in their possession, (2) the igniter wires are
removed from the stanchion where the misfire occurred then twisted together to short
the circuit. The igniter is not physically removed from its position. A new igniter is
installed, and the operators return to the control bunker and repeat the process.
If a misfire occurs and it is not the first tray in the burn sequence, the operators return
after 16 hours and repeat the process described above.
The Box Elder County Dispatch is notified prior to each treatment. This notification
can be made by telephone, fax or email, and may be made immediately prior to ignition
or an undefined number of hours prior to igniting the waste. Notification must be made
the same day as the waste is treated.
11.8.2.4 POST-BURN INSPECTION AND CLEANUP
Following an open burning treatment event, the area where the burn occurred cannot be
re-entered for at least 16 hours after completion of the burn without specific approval
from ATK management. A preliminary inspection is performed before the cleanup
begins. This inspection includes checking for hot spots and checking for unburned
reactive hazardous waste. Hot spots include visual indications of hot material (flame,
smoke, high temperature). If these conditions exist, post-burn clean is postponed until
the hot spots are gone.
All residues remaining on the burn trays are visually inspected to determine if there is
any unburned reactive material. Unburned reactive material will be reburned.
Depending on the nature of the material that did not burn, donor material or burn
enhancers such as diesel or wood may be used to ensure the material will completely
burn. Unburned waste ejected from the tray will be collected and placed on a bum tray,
and treated in the same manner.
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Small amounts of untreated residue will be considered as newly generated waste and
will be tracked as such in the tracking system. A small amount is defined as less than
or equal to 5% of the total volume placed on the tray or treatment area. The primary
option for managing this waste is to burn it by 6pm the following calendar day. If
untreated residue cannot be treated by 6pm the following calendar day then it will be
managed in accordance with R315-5 of the UAC.
Unburned waste that results from a misfire or an interrupted ignition can remain on a
burn tray. An interrupted ignition occurs when anything greater than 5% of the waste
on the tray fails to ignite. In this situation, the waste is considered unreacted waste
instead of newly generated residue. ATK will attempt to reburn the waste by 6 pm of
the following calendar day. If unforeseen circumstances prevent the burn from
occurring by 6pm of the following day, the waste will be covered and the burn tray will
be labeled and managed as a 90-day storage area in accordance with the requirements
of R315-5 of the UAC. The cumulative storage time for the waste both in storage prior
to burning and on the burn tray may not exceed 90-days. If it is necessary to storage
this waste for greater than 90-days, an emergency permit would be requested.
Typically, the post-burn and cleanup activities described in this section will be
conducted the next calendar day following treatment. The clean process begins after
the preliminary inspection is completed. Cleaning is accomplished using a variety of
tools and equipment such as rakes, shovels, a forklift and a tractor. Ash is classified
for disposal as described in 11.8.2.5. The majority of the waste treated is classified as
EPA waste number D003 reactive only. The ash resulting from treating D003 reactive
waste is collected, and transported to the on-site landfill where it is disposed.
Ash classified as hazardous is collected and managed in accordance with the
requirements of R315-5 of the UAC. Ash resulting from the treatment of K044 is
collected and disposed in the on-site landfill. After the tray is cleaned, it is inspected
for holes, weld cracks, and 6 inches of wall height. If a tray fails the inspection criteria,
it is removed from service. These inspections are maintained onsite in the operating
record. In the event a tray is not going to be used for an extended period, it is stored in
a manner to prevent stormwater accumulation (e.g. stored upside down or with a lid). If
accumulated liquid is present in a burn tray it is removed and delivered for treatment at
a UPDES permitted facility.
11.8.2.5 Ash Classification
A waste assessment is conducted prior to receiving waste for treatment. The waste
assessment is made using generator knowledge of the production process, the raw
materials used to produce the material, and the chemical composition of the materials.
If the assessment identifies that, at the point of generation, the waste meets any of the
following three criteria, all ash from the initial treatment is collected, and the ash is
sampled and analyzed using the protocol described in Attachment 1.
1. It could potentially contain 40 CFR 261.31 listed constituents.
2. It could potentially contain toxicity characteristic constituents above the 40
CFR 261.24 regulatory level.
3. It could potentially contain underlying hazardous constituents above the 40
CFR 268.48 treatment standards.
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Based on the analytical results, the ash is managed using the logic in Attachment 1
Figure 3-2. All ash classified as hazardous based on the above criteria is managed in
accordance with the requirements of R315-5 of the UAC.
11.9 RECEIVING HAZARDOUS WASTE FROM OFF-SITE
ATK periodically receives reactive hazardous waste from off-site sources. All
hazardous waste received from an off-site source will be managed at one of the
permitted storage units. All off-site generated hazardous waste will be reviewed and
approved prior to being accepted using the following criteria:
• EPA hazardous waste number(s);
• Physical description;
• Chemical description;
• Source of the waste;
• Sampling frequency;
• Parameter for analysis;
• Handling code;
• Tracking system number;
• DOT shipping description; and
• Safe handling instructions
Upon receipt, all off-site generated hazardous waste will be visually inspected to ensure
that it meets the acceptance criteria, the manifest is correct, and the containers are
labeled, closed, in good condition and compatible with the waste. All deficiencies will
be resolved with the generator before the waste is received. After the waste has been
accepted, it will be managed using the tracking systems described in Sections 11.6.
11.10 ENVIRONMENTAL PERFORMANCE STANDARDS
40 CFR 264.600 contains requirements for treatment, storage and disposal facilities to
meet environmental performance standards to ensure operations are conducted in a
manner that ensures protection of human health and the environment. The follow areas
of concern have been or are in the process of being addressed to ensure compliance
with the performance standard requirements.
Prevention of Releases Due to Migration of Waste Constituents in the Ground
Water or the Subsurface Environment - this standard requires actions to prevent
releases that may have adverse effects on human health or the environment due to
migration of waste constituents in the ground water or subsurface environment. Topics
that must be considered are:
• The volume and physical and chemical characteristics of the waste in the unit,
including its potential for migration through soil, liners, or other containing
structures;
• The hydrologic and geologic characteristics of the unit and the surrounding area;
• The existing quality of ground water, including other sources of contamination and
their cumulative impact on the ground water;
• The quantity and direction of ground-water flow;
• The proximity to and withdrawal rates of current and potential ground-water users;
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• The patterns of land use in the region;
• The potential for deposition or migration of waste constituents into subsurface
physical structures, and into the root zone of food-chain crops and other vegetation;
• The potential for health risks caused by human exposure to waste constituents; and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents;
Prevention of Releases Due to Migration of Waste Constituents in Surface Water,
Wetlands or on the Soil Surface -This standard requires actions to prevent releases
that may have adverse effects on human health or the environment due to migration of
waste constituents in surface water, or wetlands or on the soil surface. Topics that must
be considered are:
• The volume and physical and chemical characteristics of the waste in the unit;
• The effectiveness and reliability of containing, confining, and collecting systems'
and structures in preventing migration;
• The hydrologic characteristics of the unit and the surrounding area, including the
topography of the land around the unit;
• The patterns of precipitation in the region;
• The quantity, quality, and direction of ground-water flow;
• The proximity of the unit to surface waters;
• The current and potential uses of nearby surface waters and any water quality
standards established for those surface waters;
• The existing quality of surface waters and surface soils, including other sources
of contamination and their cumulative impact on surface waters and surface
soils;
• The patterns of land use in the region;
• The potential for health risks caused by human exposure to waste constituents;
and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents.
Prevention of Releases Due to Migration of Waste Constituents in the Air - this
standard requires actions to prevent releases that may have adverse effects on human
health or the environment due to migration of waste constituents in the air. Topics that
must be considered are:
• The volume and physical and chemical characteristics of the waste in the
unit, including its potential for the emission and dispersal of gases, aerosols
and particulates;
• The effectiveness and reliability of systems and structures to reduce or
prevent emissions of hazardous constituents to the air;
• The operating characteristics of the unit;
• The atmospheric, meteorologic, and topographic characteristics of the unit
and the surrounding area;
• The existing quality of the air, including other sources of contamination and
their cumulative impact on the air;
• The potential for health risks caused by human exposure to waste
constituents; and
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• The potential for damage to domestic animals, wildlife, crops, vegetation,
and physical structures caused by exposure to waste constituents.
11.10.1 Compliance With Environmental Performance Standard Requirements
All of these factors have been and will continue to be evaluated until closure of the
facility to ensure waste treatment methods are conservative and will not adversely affect
human health or the environment. Control measures include, but are not limited to the
following:
Human Health Risk Assessment - a Human Health Risk Assessment (HHRA) is being
conducted to evaluate the risk to the public from open burning and open detonation
operations at the facility. Tasks associated with the HHRA include developing an air
dispersion model, evaluating sources, source parameters, and waste materials, and
characterizing emissions. The HHRA will address the following environmental
performance related concerns:
• The volume and physical and chemical characteristics of the waste in the unit,
including its potential for the emission and dispersal of gases, aerosols and
particulates;
• The effectiveness and reliability of systems and structures to reduce or prevent
emissions of hazardous constituents to the air;
• The operating characteristics of the unit;
• The atmospheric, meterologic, and topographic characteristics of the unit and the
surrounding area; and
• The potential for health risks caused by human exposure to waste constituents.
The methods used in the HHRA are based on United States Environmental Protection
Agency (U.S. EPA) risk assessment guidance documents, and to the extent possible, the
dispersion modeling methodology within the Human Health Risk Assessment Protocol
(HHRAP) for Hazardous Waste Combustion Facilities (U.S. EPA, September 2005). The
completed HHRA Protocol and Report will be reviewed by the Utah Division of Solid
and Hazardous Waste. Limits on OBOD operations will be based on this assessment, as
appropriate, once approval of the HHRA Report is given by the Director of the Utah
Solid and Hazardous Waste Control Board.
Ecological Risk assessment - an Ecological Risk Assessment (ERA) will be conducted
to determine potential risks to ecological receptors that may be affected by OBOD
operations. It will evaluate the potential for damage to domestic animals, wildlife, crops,
vegetation, and physical structures. The completed ERA will be submitted to the Utah
Division of Solid and Hazardous Waste for review. Limits on the OBOD operations will
be based on this assessment, as appropriate, once approval of the ERA Report is given by
the Director of the Utah Solid and Hazardous Waste Control Board.
Soil Monitoring Plan - a Soil Monitoring Plan (SMP) will be developed to verify the
air dispersion and deposition models that were developed for the HHRA. The SMP will
be used to evaluate the existing quality of surface waters and surface soils, and to
determine what impact continued operations at the thermal treatment areas has on surface
soil and surface water quality. Risks to human health and the environment will be
evaluated using the data collected during implementation of the SMP.
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Groundwater Monitoring Plan - a groundwater monitoring program has been in place
at the facility since 1986 to monitor contaminants that were released from past disposal
practices. The sampling methods, constituents of concern, sampling frequency, sampling
results and analytical methods are closely reviewed and monitored by the DSHW.
The groundwater monitoring program addresses the following concerns:
• The hydrologic and geologic characteristics of the unit and the surrounding area
• The existing quality of groundwater, including other sources of contamination and
their cumulative impact on the groundwater;
• The quantity and direction of groundwater flow; and
• The proximity to and withdrawal rates of current and potential groundwater users.
A Groundwater Monitoring Plan will be developed to evaluate the impact of thermal
treatment operations on groundwater down gradient of the M-136 and M-225 Thermal
Treatment Areas. The plan will identify analytes, sampling protocols and data quality
objectives. In addition, the plan will propose a statistical method for determining if
existing groundwater contamination concentrations increase due to ongoing thermal
treatment operations.
Annual Review of Limits - the operating permit requires ATK to conduct an annual
review of emission factors established by the HHRA, the reference doses for selected
health effects, and to review the potential health risk scenarios to assure that the scenarios
have not changed. An annual accounting of the types and quantities of reactive waste
treated is also required.
Stormwater Management - Stormwater run-on and run-off is controlled by a
combination of soil grading and drainage ditches. The terrain around M-136 and M-225
has been graded and drainage ditches surround the areas in order to minimize stormwater
run-on and run-off. The topography is shown in Attachment 6, Figures F-l and 1-1.
Stormwater collection and drainage is shown in Attach 11 Figure 11-1 and Figure 11-2.
The combination of controlling run-on and run-off, containing waste in water-tight burn
trays, lack of precipitation, high evaporation rate and depth to groundwater prevents
waste constituents from being released to the groundwater and or subsurface
environment. Ongoing soil and groundwater monitoring are used to verify these controls
are effective in preventing adverse effects to human health and the environment.
Actions to Prevent Releases to the Environment - all spills of hazardous materials are
promptly cleaned up. Internal procedures require that chemicals be properly
containerized, labeled, stored, used and disposed. The workplace is routinely audited to
ensure compliance with procedures. When spills do occur, the released material is
promptly cleaned up and R315 reporting requirements are followed.
Open Burning is Conducted in Steel Containers - Open burning is conducted in
containers which minimizes the potential for waste constituents to migrate to the ground
water, surface water or related environments. The Operating Permit requires routine
inspections to ensure the containers are properly maintained. Containers requiring repair
are removed from service until repairs are completed.
11-18
ATK Launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
January, 2014
Ash Management - ash and residue from OBOD operations are promptly collected and
disposed. Ash is managed and classified as described in sections 8.2.4, and 8.2.5 of this
attachment.
Storage and Inspections - All PEP and residues from OBOD treatment are stored in
accordance with Section 4 of this attachment and R315-5 Hazardous Waste Generator
Requirements. Storage and treatment areas are inspected as required by Attachment 2,
and operated in accordance with Attachment 9 of this permit.
Regulatory Oversight- the facility is subject to strict regulatory oversight by the Utah
Division of Solid and Hazardous Waste. All aspects of hazardous waste management
described in this Attachment are subject to their review. When necessary, deficiencies
are identified and corrective action is taken by the permittee.
11-19