DSHW-2014-005529 - 0901a0688041d108

Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISIONOF SOLIDAND
HAZARDOUS WASTE
Scott T. Anderson
Director
Solid and Hazardous Waste Control Board
KevinMunay, Chair
Dennis Riding, Yice-Chair
Eugene Cole, DrPH
JeffCoombs, MPH, LEHS
Mark Franc
Brett Mickelson
Amanda Smith
Shane Whihey
Dwayne Woolley
Scott T. Anderson
Execiltive kc:retan
GARYR. HERBERT
Govemor
SPENCERJ. COX
Lieutenant Governor
Aprll23,2014
George Gooch, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham city, UT 84302-0707
RE: Revised Human Health Risk Assessment Protocol (Red Line/Strike Out Version)
Evaluation of the Open Burning and Open Detonation Units
ATK Launch Systems - Promontory Facility
uTD009081357
Dear Mr. Gooch:
The Division of Solid and Hazardous Waste has completed its review of the referenced document' ATK's request
to revise the Human Health Risk Assessment (HHRA) Protocol was approved in June 201 l, in order to amend the
Constituents of Potential Concern (COPC) section of the document. The process of selecting constituents of
concern that was followed is outlined in the 2005 EPA docum ent Human Health Risk Assessment Protocol for
Hazardous Waste Combustion Facilities. The Division determined that an amendment of the COPC selection
process was appropriate after close examination of the EPA guidance document and the 201I HHRA Protocol.
'The revised pioto*t document (redline/strikeout version) and previous conespondence with the Division on this
issue were rubtnitt"d informally by email. These informal documents will be scanned and added to the public
record.
Enclosed are general and specific comments based on the review of the revised HHRA Protocol. All comments
must be addreised in a complete draft final HHRA Protocol document (i.e., revision of the Approved HHRA
protocol) and submitted to the Division for approval. Please submit.the draft final document no later than
May 30,2014.
Ifyou have any questions, please call JeffVandel at [phone] '
Division of Solid and Hazardous Waste
STA/Mtjm
Enclosure:DSHW-20 I 4 -005 5 42; DSHW-2O I 4-005 543,
195 North 1950 West ' Salt Lake City, UT
Mailing Address: P.O. Box 1,14880 ' Salt Lake City, Ln 84114'4880
Telephone (S0l) 536-0200'Fax [phone] 'T.D'D. (801) 5364414
zutuw.ileq.utah.gn
Printed on l00oZ recYcled PaPerDSHW-2014-005529
(Over)
c: Blair Palmer, ATK Launch Systems
Paul Hancock, ATK Launch Systems
Lloyd C. Berentzen, MBA, Health Officer, Bear RiverHealth Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Nancy Morlock, USEPA Region 8
DSHW-2014-005529
Division of Solid and Hazardous Waste
HumanHearth#'f
t^:::1*ilil"n-#iT!"d""tionorthe
Open Burning and Open Detonation Units
ATK Launch Systems - Promontory Facility
The following comments are based on a technical review of the ATK Launch Systems Human
Health Risk Assessment Protocol for Evaluation of the Open Burning and Open Detonation
Units dated February 2014 (redline/strikeout version of the HHRA Protocol).
INTRODUCTION
In general, the constituents proposed to be addressed in the risk assessment and listed in Table 2-
I and Table 2-2 of the redline/strikeout version of the HHRA Protocol represent a robust list.
However, they are not as robust as the list provided in Table I of the older, approved 201I
version of the Human Health Risk Assessment Protocol (Approved HHRA Protocol). The lists
presented in Table 2-l and Table 2-2 are in general agreement with the constituents listed in
Table I as well as the constituents present in the emissions for aluminized ammonium
perchlorate (AP) and surrogate aluminized AP manufacturer's waste (with diesel) and waste
streams that are similar to the Class 1.3 waste materials treated by OB at ATK Promontory and
tested during the initial Bang Box studies summarized by Mitchell and Suggs (August 1998,
EPA/600/R-98/103). There remain, however, a number of constituents identified as constituents
of potential concern (COPCs) in the Approved HHRA Protocol that have not been addressed in
the redline/strikeout version of the document.
In addition, there are several other issues that should be addressed before the identification of
COPCs for the human health risk assessment is finalized:
o Table I has been eliminated from the protocol document. Thus, ATK must establish the
relationship between previous descriptions and listings of the COPCs to be addressed in
the HHRA and the descriptions and listings presented in the redline/strikeout version of
the document;o ATK must ensure that an emission factor is available for all identified COPCs; ando ATK must ensure that the identification of COPCs accounts for chemicals that are found
in or could potentially be emitted from (including products of incomplete combustion) all
waste categories subjected to treatment by OBOD at the facility. This more
comprehensive approach is needed due to recent changes in the percentage of total waste
treated for each waste category burned and detonated at M-l36 and M-255.
These issues, as well as other issues related to the redline/strikeout document, are addressed
below in the general and specific comments.
All issues raised herein must be addressed in a draft final HHRA Protocol document (i.e.,
revision of the Approved HHRA Protocol) and submitted to the Division of Solid and Hazardous
DSHW-2o14405543
Waste with all figures, tables, and literature references used to justiff deviations from the human
health risk assessment (HHRA).
I. GENERAL COMMENTS
l. In June 2011, ATK Promontory's May 20ll Human Health Risk Assessment Protocol
(Approved HHRA Protocol) was approved. The approved HHRA Protocol contained
Table l, Chemicals of Potential Concem Evaluated in Human Health Risk Assessment,
and referred to Section 3 of the Air Modeling Protocol. The majority of the chemicals
identified in Table I as constituents of potential concem (COPCs) have been addressed in
the redline/strikeout document. However, sorne chemicals have not been addressed
making it unclear how they will be handled in the HHRA. These chemicals include:
o Perchlorate.o SVOCS: 2-chlorophenol,4-chlorophenyl phenyl ether, diallate, kepone,2-methyl
furan, 3 -methylcholantrene, 2-methylheptane, 5 -nitro-o-toluidine, 4-
nitroquinoline-l -oxide, 2-picoline, and p-toluidine.o Carbonyls: furfrual
o VOCs: bromoform, l-(butylene), l-(ethylethylene), cis-2-butene, trans-2-burtene,
chlorobromomethane, dichlorotetrafluoroethane,2,2-dimethylheptane, 2,3-
dimethylhexane,2,4-dimethylhexane, 2,5-dimethylhexane,2,2-dimethylpropane,
ethylcyclohexane, ethylene, 3-ethylhexane, o-ethyltoluene, 2-heptanone,
methacrolein, methyl tert-butyl ether, methylcyclohexane, 3-methylhexane,
nitromethane, n-pentan e, 2-pentanone, phenylacetylene, propene, I,2,4-
trimethyberuene & sec-butylbenzene.
Please revise Section 2.0 and Tables 2-l and2-2 as necessary to indicate if these
chemicals will be included as COPCs and subjected to quantitative evaluation in the
HHRA or eliminated from the analysis. Justification for elimination must be provided for
all chemicals dropped from evaluation in the HHRA.
2. ATK's 2012 Annual OB/OD Report indicates that the Class 1.3 waste streams
(Categories A and B) made up just 50% of the total waste treated at M-I36 in2012. The
2013 Annual OB/OD Report indicates that the Class 1.3 waste streams (Categories A and
B) represent only 37Yo of the total waste treated. When the waste characterization
portion of the OB/OD risk assessment protocol was originally reviewed, the Class 1.3
waste streams made up approximately 96oh of the total waste treated. In recent years,
other waste categories have comprised a higher, more significant percentage of the total
wastes treated by OB/OD. Given that the mix of waste stream categories has fluctuated
and the need for a flexible operating permit that allows treatment of all waste categories,
the emission factors used in the HHRA should be representative of all waste categories
that could be treated by OB/OD. This is typically accomplished in two ways:
2DSHW-2O14-005543
. Address each category of waste stream separately in the risk assessment using
emission factors specific to each waste category; or
. Develop a list of the maximum emission factors from the lists of waste category-
specific emission factors. Where the same chemical is emitted from multiple
waste categories, the maximum emission factor is used. The list of maximum
emission factors is used to represent all wastes treated at the facility and the need
to specifically address each waste category is eliminated from the risk assessment.
Currently, ATK Promontory indicates the emission factors for Class 1.3 waste streams
will adequately represent all waste categories treated by OB/OD. Except for dioxin/firan
TEQ, this assertion is not adequately supported by the information provided in the
redline/strikeout version of the protocol document. Please revise the approved HHRA
Protocol to identiff the waste categories that will be treated by OB/OD at M-I36 and M-
225. lnaddition, please state whether the risk assessment will address each waste
category separately or will address a hypothetical "worst-case waste" that is represented
by the maximum emission factors identified after consideration of all waste category-
specific emission factors.
3. The first paragraph of Section 2.1 indicates that emissions from the 1.3-Class propellant
with trash are expected to capture the range of expected emissions from the 3 classes of
materials treated at ATK Promontory. The third full paragraph of Section 2.1 states
'0. ..the emissions from only the 1.3-Class waste material will be used in the risk
assessment." If ATK Promontory elects to represent OB/OD emissions by developing a
list of morimum emission factors for a hypothetical "worst case" waste, potential
emissions from l.l-Class propellant and Category E wastes must also be considered in
characterizing the emissions and speciffing the emission factors to be used in the HHRA.
While ATK Promontory is selective about the waste streams it accepts for treatrnent by
OB and OD, it does accept reactive wastes from Autoliv. These wastes are designated as
Category E wastes in the Waste Characteization portion of the 2011 version of the Air
Dispersion Protocol and are represented by surrogate emission factors developed for the
M816, 8l-mm Infrared (IR) Illumination Cartridge. These surrogate emission factors are
listed in Table 3-8, Category E Emission Factors for ATK Flare-Type Wastes, of that
document.
Although the Division previously agreed to the use of the Class 1.3 emission factors
listed in Table 2-5 of the March 2}l2Modeling Report to represent all of the waste
categories treated by OB/OD at ATK Promontory, the percentage of the total wastes
treated represented by each waste category has changed significantly in recent years.
Category E wastes represented a larger percentage of the total wastes treated by OB/OD
during 2012 and20l3. There are compounds present in Category E wastes that are not
represented by the Class 1.3 emission factors including ammonia, nitroglycerin and
propionaldehyde. In addition, the emission factor for cadmium,2.8E-05, appears to be
ttighr. than the emission factor reported for cadmium in Class 1.3 waste materials. The
metals strontium, tin, indium, bismuth, boron and cesium were identified in the waste
characteization for Category E wastes. These metals are not represented in the emission
DSHW-2014-005543
factors for Class 1.3 waste materials. Boron has toxicity values for noncarcinogenic
health effects (RfC, RfDo) as well as a Regional Screening Level (RSL) and should be a
site COPC. Indium has occupational health values (e.g., NIOSH REL, ACGIH TLV) and
should be addressed qualitatively in the uncertainty assessment of the HHRA. The other
metals are important in characteinng emissions from the treatment of Class E wastes but
should not contribute significantly to estimates of risk and hazard from exposure to
OB/OD emissions. Please review the constituents contained in and potentially emitted
from Class E wastes treated by OB/OD at ATK Promontory. Based on the results of the
review, please revise Section 2.0, Identification of Constituents of Potential Concern, to
indicate that emission factors for Category E waste materials will be used in lieu of
emission factors for 1.3-Class materials when the Category E emission factors are greater
than those for 1.3-Class materials. Please indicate that potentially emitted chemicals not
represented in Class I .l and 1.3 waste emissions will be considered in the emission
analysis. In addition, the metals identified in the waste characteization of Category E
wastes must be addressed, with boron and indium retained as COPCs. Please indicate
that boron will be quantitatively evaluated in the HHRA and indium will be qualitatively
evaluated in the uncertainty analysis of the HHRA.
4- The first paragraph of Section 2.1 indicates that emissions from the 1.3-Class propellant
with trash are expected to capture the range of expected emissions from the 3 Classes of
materials treated at ATK Promontory. The text further states that emission factors for
some PAHs detected during the BangBox testing of 1.1-Class materials will be used
instead of emission factors based on non-detected results from tests performed on 1.3-
Class materials. The third full paragraph of Section 2.1 states "...the emissions from
only the 1.3-Class waste material will be used in the risk assessment." While it is
expected and appropriate that detected quantities from testing of Class 1.1 materials
would be used in lieu of non-detected results from 1.3-Class tests, it is unclear why other
emission factors based on the results of 1.l-Class testing will not be used in the HHRA.If ATK Promontory elects to represent OB/OD emissions by developing a list of
maximum emission factors for a hypothetical "worst-case waste, potential emissions
from 1'l-Class propellant and Category E wastes must also be considered in determining
an appropriate list of emission factors. For example, the emission factors developed from
l.l-Class tests for 2-nitrophenol, acenaphthylene, 1,3,5-trimethylbenzene,2,2,4-
trimethylpentane,2,3,4-trimethylpentane, 2,3-dimethylpentane, 2-methylheptane, methyl
tert-butyl ether, methylene chloride and octane are nearly an order of magnitude (or
higher) than their 1.3-Class counterparts. Other chemicals such as benzene, ethyl
benzene and o-xylene also have Class 1.1 emission factors higher than the emission
factors resulting from Open Detonation Open Burn Improved (ODOBi) testing of 1.3-
Class waste materials. When the waste characteization portion of the OB/OD risk
assessment protocol was originally reviewed, Class 1.3 waste streams made up
approximately 96% of the total waste treated. However, ATK Promontory's 2012 and
2013 Annual OB/OD Reports indicate that Class 1.3 waste streams (Categories A and B)
currently constitute a lower percentage of the wastes treated at M-I36 andM-225 (aboui
50Yo in20l2 and37o/o in2013). Given that the mix of waste stream categories has
changed, please revise Section 2.0, Identification of Constituents of Potential Concem, to
indicate that emission factors for Class l.l waste materials will be used in lieu of
DSHW-2O14-005543
emission factors 1.3-Class materials when the Class 1.1 emission factors are greater than
those for Class 1.3 materials. Please indicate that potentially emitted chemicals from the
treatment of Class 1.1 waste materials that are not represented in Category E and Class
1.3 waste emissions will be considered in the emission analysis.
5. Section 2.2,Identifying Compounds of Potential Concern, provides discussion of the four
steps for identifying compounds of potential concem from EPA's Human Health Risk
Assessment Protocol for Hazardous Waste Combustion Facilities (HHRAP). ATK
Promontory has described how PAHs will be handled in the risk assessment under the
discussion entitled Step 3, Is the Non-detected Chemical Likely to be a Product of
lncomplete Combustion. In discussing PAHs, ATK Promontory indicates:
. ODOBi testing of 1.3-Class waste materials resulted in detections of 2-, 3-, and 4-
ring PAHs but PAHs with 6 rings were not detected. However, fluoranthene was
mistakenly identified as a 4-ring PAH in the text and Table 2-I (itwas correctly
characterized as a 3-ring PAH in another part of the text). Thus, only 2- and 3-
ring PAHs were detected during ODOBi testing of 1.3-Class waste materials.
I 4-,5-, and 6-ring PAHs will not be emitted during the open burning or open
detonation of 1.3-Class waste materials based on lines of evidence provided with
the redline/strikeout version of the HHRA protocol document.
o 4-ring and 6-ring PAHs were detected during BangBox testing of l.l-Class waste
materials (5-ring PAHs were not addressed in the text).
o Eight 4-,5-, and 6-ring PAHs, including the seven PAHs recommended for
consideration in risk assessments in EPA's HHRAP, were not detected in the
ODOBi tests of 1.3-Class waste materials. However, six of the listed PAHs (two
4-ing,two 5-ring, and two 6-ring) will be quantitatively evaluated in the risk
assessment. The discussion of PAHs indicates that PAHs detected in 1.l-Class
propellant samples "...will be quantitatively evaluated in the risk assessment..."
implying that the 4-,5-, and 6- ring PAHs listed in Table 2-l were detected dtiring
testing of 1.1-Class waste materials.o Anthracene, chrysene, pyrene, indeno(I,2,3,cd)pyrene,2-methylnaphthalene,
benzo(a)anthracene, benzo(b)anthracene, benzo(k)anthracene, and
benzo(g,h,i)perylene were detected in the BangBox tests of l.l-Class waste
materials. These detections include 2-,3-,4',5' and 6-ring PAHs.
As currently presented, the discussion of PAHs is confusing and appears to concentrate
on justiffing the exclusion from the risk assessment of non-detected PAH results for 1.3-
Class waste materials. Non-detect results obtained during PAH testing of 1.1-Class
wastes are not addressed. If ATK Promontory elects to represent OBIOD emissions by
developing a list of maximum emission factors, potential emissions from 1.1-Class
propellant and Category E wastes must also be considered in determining emission
factors. The PAH discussion should be reorganized and expanded to address the
handling of non-detected PAHs [e.g., benzo(a)pyrene, dibenz(a"h)anthracene] for 1 l-
Class wastes. Because 4-,5- and 6-ring PAHs were detected during Bang Box testing of
1.1-Class waste materials, non-detected PAHs (from l.l-Class testing) should also be
included as COPCs, non-detected PAHs from 1.l-Class material testing should be
DSHW-2o14{05543
6.
quantitatively evaluated in the risk assessment to ensure a conservative analysis of
potential PAH emissions. Please revise the approved HHRA Protocol to present an
accurate, concise and comprehensive discussion of the handling of PAHs in the risk
assessment. This discussion should address detects and non-detects for both 1.3-Class
and 1.l-Class waste materials. Please note that a final determination of the handling of
non-detected PAHs for Class 1.3 waste materials cannot be completed until the issues
raised in these general and specific comments are addressed.
Section 5.8, Validation of Environmental Concentrations and Risk, states "ATK's
operating permit requires that ATK perform soil sampling for dioxins after the risk
assessment process is completed. ATK proposes to conduct the sampling prior to the RA
[risk assessment] completion to have data available from the location of maximum
deposition, of the key chemicals of interest." The text also indicates "These samples will
likely be collected within weeks of submitting this protocol." Section 5.8 closes with
"Following the air quality modeling process, and the preparation of the risk assessment,
ATK proposes to collect soil data for dioxin congeners to determine if they are present,
and if so at what concentrations. These results will then be used to determine the validity
of the risk assessment process."
While monitoring of environmental media, including soil sampling, will be a part of the
operating permit for M-I36 andM-225, the sampling and revised risk-based analyses are
typically conducted according to the schedule provided in the permit. This allows for
development, submittal and review of the sampling and analysis plan (SAP) and quality
assurance project plan (QAPP) for the sampling effort(s) before sampling occurs. At this
time, the Division has not requested a SAP and QAPP for permit-required environmental
media sampling from ATK Promontory.
In addition, the discussion included in Section 5.8 is unclear with respect to the timeline
for sampling and determining "the validity of the risk assessment process." For example,
the text indicates that sampling and validation will occur after preparation of the risk
assessment. However, inclusion of this discussion in Section 5.0, Uncertainty
Assessment, implies the results of the sampling event will be used to validate risk and
hazard estimates and the sampling and validation will be discussed in the uncertainty
assessment included in the HHRA report. There are issues associated with validating
future operational risks using historical sampling data and these issues have not been
addressed in the current discussion. If these sampling results and the 'ovalidation"
analysis will be included in the HHRA, additional details on the use of the sampling
results and the methodology to be followed in validating the results of the risk assessment
should be provided. At a minimum, the additional information on the validation analvsis
should:
CluiS when the sampling will occur and when the validation analysis will be
performed.
State how the results of the sampling event and validation analysis will be
transmitted to the Division.
6DSHW-2014405543
II.
o Describe how sampling results that represent historical operations will be used to
validate risk and bazard estimates that represent future operations of M-136 and
M-225.o Describe the procedures to be followed in performing the validation analysis.
o Describe how the risk and hazard estimates and the validation results will be used
to characterize site risks.
o Demonstrate that risk and hazard estimates resulting from quantitative evaluation
of the COPCs addressed in the HHRA will not be changed as a result of the
validation analysis.
If the sampling results and validation analysis will appear in the HHRA report, please
revise Section 5.8 to address the issues noted above. If not, please ensure Section 5.8 is
removed from the revised version of the approved HHRA Protocol.
SPECIFIC COMMENTS
Table of Contents - "Section 3.2 Exposure Scenarios" is missing from the Table of
Contents.
The Table numbers in the Table of Tables don't match the numbers in the titles of the
actual Tables.
Comments on specific Tables are at the end of this list. (exposure assumptions for infant
ingestion of breast milk, updates to Table 4-1 also known as Table 9).
Please read through the draft document again and make the numerous grammatical
corrections that are needed.
Section 1.1. Overuiew and Purnose
The March 2010 date for approval of the HHRAP should be changed to June, 2011.
The sentence "The protocol was in support of ATK's new Subpart X Resource
Conservation and Recovery Act (RCRA) perrnit application," isn't accurate. Please
revise it to read "The protocol was in support of ATK's Subpart X Resource
Conservation and Recovery Act (RCRA) permit requirements."
The next sentence, which begins "The 2010 (should be20ll) approved protocol
document. . ." appears to be incomplete since the second half of "were either not
consistent..." isn't followed up with an "...of,..." This incomplete sentence is also
inaccurate since the TIHRA Protocol document that it refers to doesn't discuss air quality
modeling. These issues are addressed in the air dispersion modeling protocol.
1.
2.
aJ.
4.
5.
DSHW-2o14-00s543
It appears that the sentence which begins "This second modeling protocol..." should
begin "This second modeling report..." In addition, the previous sentence needs the
word "was" after "(Second Modeling Report)"
In the last sentence of this paragraph, the date and title of the report that is referred to is
wrong. In this same sentence, "...revised air dispersion model was..." should be
changed to ". -.revised air dispersion modeling protocol was. .."
The second paragraph of Section 1.1 states "The purpose of this amendment is to
systematically list elroneous assumptions or out-of-date procedures in the HHRAP (the
Approved HHRA Protocol) to provide reasons and, where appropriate, provide literature
justifications supporting why ATK believes they are erroneous, and to request that these
assumptions be corrected by accepting the Revised HHRAP submitted with this
document." While not stated in the redline/strikeout version of the protocol, the
document also serves to convey the methodology and input parameters to be employed in
estimating and characterizing the carcinogenic risks and noncarcinogenic hazards
associated with operation of the OB and OD units at M-136 andM-225. Given the
format of the redline/strikeout version of the protocol document, it is recommended that
the purpose be revised to state:
The purpose of this revision of the human health risk assessment protocol
is to systematically re-examine overly conservative and now out-of-date
assumptions related to oB/oD emissions reflected in the 201I Approved
Protocol; provide alternative assumptions and approaches; provide site-
specific information; and, where appropriate, scientific literature to
support the proposed changes in the risk assessment methodology. In
addition, this revision retains the original purpose of presenting the
methodology and parameters that will be used in estimating and
characteizing the potential risks and hazards associated with oB and oD
operations at M-I36 andM-225. Based on the information provided,
ATK proposes acceptance of this protocol, including the altemative
assumptions and approaches, to support the development of risk and
hazard estimates more indicative of actual unit operations over the life of
the RCRA operating permit.
Please revise the purpose stated in the second paragraph ofSection 1.1 as
recommended.
6. Section l.2.Introduction
o Please change "These units are currently operating as interim status facilities" to
something like "ATK is required by permit condition to evaluate the human health risk
associated with the units." The following sentence could then read something like..This
HHRA Protocol lays out the detailed process that will be followed when the HHRA is
conducted and it is being prepared in accordance with the USEPA guidance document...',
DSHW-2o14-005543
7.
The reference at the bottom of page 2 is inaccurate. In the context of the sentence
which begins "Information such as..." there are two documents that should be
referenced - the Waste Characteizationand Air Dispersion Modeling Protocol
document (Tetra Tech, 20ll) and the Addendum Air Dispersion Modeling
Protocol (Shaw/CBI, 2013).
section 2.0.Identilication of constituents of Potential concern
The discussion regarding the COPC selection process (beginning about half-way through
the first paragraph ofthis section) should be expanded. Please revise the text to describe
the process which began with an assessment of wastes generated at the facility that were
treated at the burn grounds, characterization of these wastes, the assembly of the ODOBi
test samples and the collection of data from the ODOBi tests. These steps all occurred
before the "starting point" of the COPC selection process which is stated in the text as a
"chemical analyte list."
Please clariff why the criteria pollutants and particulate matter are evaluated by
comparing with the NAAQS instead of being evaluated in the HHRA. Also, please
expand the discussion to indicate that Utah Toxic Screening Levels will be compared to
modeling results.
The third paragraph in this section is misleading. Based on ATK's Annual Report of the
Promontory Thermal Treatment Areas operation for 2013, ATK currently burns
approximately equal amounts of 1.3, l.l and Category E/Flare wastes at M-l36. Since
thi flare waste is quite a bit different than the "relatively homogeneous" waste described
in the text, please revise this paragraph to include a brief discussion of the three main
classes of waste that are treated.
The last sentence of the second full paragraph in Section 2.0 states "ATK attempts to
have the combustion process be as complete as possible because temperatures help
eliminate higher molecular weight compounds." This sentence requires clarification. It
seems likely that the word 'higher' has been omitted from the sentence. Please review
and revise this sentence for clarification. In addition, the intent of this sentence would be
strengthened by providing a reference to the site SOP(s) that detail the procedures
followed to ensure that the combustion process is 'oas complete as possible."
Section 2.l.Identifvine Emission Sources and Emission Rates
Section 3 of the 2011 Waste Charactenzation and Air Dispersion Modeling Protocol is
referenced near the beginning of this section. The Table in Section 3.2 which shows the
percentages of the waste groups treated is out of date. As stated above, ATK currently
bums approximately equal amounts of 1.3, l.l and Category E/Flare wastes at M-136.
This scenario warrants additional scrutiny of the l.l and Category E waste classes. The
Division is not convinced that the emissions from the 1.3 class waste will "capture" the
range of emissions that are expected from the three main classes of waste. Please revise
the text to explain how these classes of waste will be evaluated based on the expected
8.
DSHW-2014405543
9.
emissions for each class of waste (including unique constituents and metals). There is no
mention of the emission factors that will be used in the analysis. The 201I Modeling
Protocol states that the emission factors in Tables 3-5 and 3-6 will be used in the HHRA.
The Air Dispersion Modeling Protocol Addendum (Feb. 2013) states that the emission
factors from Table 2-5 of the March 2012Modeling Report will be used.'Please include
a discussion on how emission factors were determined for the three main classes of waste
(see Section 3.2 of the 20ll Air Dispersion Modeling Protocol) and a table of the
emission factors in the revised protocol for all COpCs.
In the second paragraph of this section please replace "A summary of how the waste
profiles were developed is provided..." with "A summary of how the emissions were
characterized based on ATK waste profiles is provided...',
The discussion on the risk associated with dioxins and frrans on page 2 of this section
lacks information on other potential risk drivers (such as semi-volatiles, PAHs). A
significant number of 1.1 emission factors are higher than the 1.3 emission factors for
detected COPCs. The higher emission factors. should be used in these cases, or as an
alternative, ATK could run the HHRA on each class of waste separately.
Section 2.1 includes a discussion regarding the size of wastes bumed during ODOBi
testing. The discussion notes that small bundles were burned during testing because of
concems regarding incomplete combustion due to the lack of adequate oxygen within the
test chamber. No other information related to this issue is provided. Thus, it is not clear
why this issue is discussed in the redline/strikeout version of the protocol document. It is
recommended that this discussion be removed. Please revise the Approved HHRA
Protocol to ensure this discussion is removed from the text.
Based on waste charccteization information provided by ATK, the second bullet item on
page 3 of this section which states that ATK's wastes do not contain lead appears to be
incorrect. It is indicated in Table 3-2thatGroup D, profile #PR49 (primary explosive
with lead) contains lead styphnate at44%o lead and lead azide atTlyolead,.
Section 2.2.Identifring Compounds of Potential Concern. Sten I Trial Burn and
Fueitive Emissions
Under Step I Trial Burn and Fugitive Emissions on page 4, the text states, "The HHRAp
process starts with the question - was compound detected? If yes, the chemical is
selected for evaluation in the risk assessment. Detected COPCs from the 1.3-Class
propellant studies are shown in Table 2-1, andwill be quantitatively evaluated in the risk
assessment." The detected COPCs from the l.l-Class propellant should also be included
in Table 2-1. lf the same COPC was detected in both classes of waste, the higher result
should be used. Alternatively, ATK could evaluate the classes of waste separately an$
then manage them separately at Promontory as is done at NIROp.
DSHW-2o14405543 l0
10.Section 2.2.Identifving Compounds of Potential Concern. Step 2Is Non-detected
Compound Present in the Waste
Please add a description of the Autoliv wastes that ATK accepts for open burning to the
discussion regarding wastes that ATK accepts in the first paragraph on page 6.
Please clariff in the second paragraph that the non-detect compounds on Table 2-2that
are considered COPCs will be included in the quantitative analysis at their detection
limits.
In the discussion entitled Alcohols, Phenols and Ethers, the text regarding phenols and
carbon cloths is confirsing. It is stated that phenols are used in carbon cloths that wrap
motors, but they are not typically burned in the process of buming motors. It is known
that ATK has burned whole motor segments in the past and it is stated that phenols will
be evaluated quantitatively in the HHRA. It is agreed that phenols should be included,
but please clariff or remove the statement that the carbon cloths are not typically burned.
In the discussion entitled Amine, Aniline, Hydrazine, and Benzidine Compounds, ATK
Promontory indicates "Hydrazine is highly flammable, especially in combination with
other fuels, and based on comment-responses with the Utah DSHW, hydrazine will not
be considered in the risk assessment." No other information regarding hydrazine is
provided in the text. In past comment and response documents, ATK Promontory has
provided justification for the exclusion of hydrazine from the risk assessment. However,
that information is not included in the redline/strikeout version of the protocol document.
Please revise the discussion of hydrazine to state that the chemical is an ingfedient in
liquid rocket propellant and is not found in solid rocket propellant. In addition, the
discussion should state that liquid propellants containing hydrazine are not treated by
OB/OD at the Promontory facility. Based on this information, the Division will include a
permit condition confirming that hydrazine will not be treated by OB/OD at ATK
Promontory.
In the discussion entitled Nitroaromatic Compounds, ATK Promontory states "HI\D( and
RDX are unlikely to survive the process and they will not be evaluated quantitatively in
the HHRA." The discussion also points out that HMX and RDX (as well as TNT) are
energetically unstable. This assertion requires additional lines of evidence to support the
exclusion of HND( and RDX frbm the quantitative risk analysis. Reference to technical
documents demonstrating that HI!D( and RDX are not found inthe air emissions and
treatment residues of OB and OD operations will suffice. However, it is likely that
HI\,DL RDX, and TNT residues may result from incomplete treatment. Thus, these
explosives must be added to the list of analytes to be monitored under the operating
perrrit. Please revise the discussion entitled Nitroaromatic compounds to address this
issue.
Section 2.2.Identifvine Compounds of Potential Concern. Step 3.Is the Non-
detected Chemical Likelv to be a Product of Incomplete Combustion
11.
t1DSHW-2014-005543
12.
Category E/Flare class wastes make up about one-third of the total wastes currently open
burned at ATK. The metals that are included in this class of waste are identified in the
Waste Characteization portion of the Air Dispersion Modeling Protocol. ATK needs to
explain in the protocol how these metals will be addressed in the HHRA.
The second paragraph of the discussion entitled Metals indicates that detections of lead
and nickel obtained during ODOBi testing are likely linked to the use of nickel chromium
wire in the initiator used during the test. While some information has been provided for
other metals believed to be artifacts of testing (e.g., chromium), no additional information
has been furnished on lead and nickel. Please revise Section 2.2 to provide additional
information on the use of lead and nickel during ODOBi testing. Please indicate if nickel
and/or lead were detected in the materials subjected to ODOBi testing (as was done for
chromium and mercury) as there is concern that lead is a component of some wastes that
could be treated at M-136 andM-225. If lead is a component, the uncertainty associated
with its identification as a COPC will be minimized.
In the discussion entitled Polynuclear Aromatic Hydrocarbons (PAHs), fluoranthene is
misidentified as a 4-ring PAH. This occurs in the second paragraph below the in-text
table entitled Summary of Higher Molecular PolyNuclear Aromatic Hydrocarbons, Ring
Number, Detections and Cancer Potency for 1.3-Class Emissions. Fluoranthene is also
listed under PAHs-Four aromatic rings in Table 2-1. Please revise the text and Table 2-1
for accuracy and consistency by indicating that fluoranthene has three aromatic rings.
The last sentence in the fourth paragraph, page 11, is misleading. The ODOBi samples
were assembled to represent the different waste streams that were generated by ATK at
the time. Please revise or remove this sentence of the text.
The first paragraph of this discussion indicates that the objective of the OB and OD
operations at ATK Promontory is not the burning of trash but rather "is the disposal of
perchlorate containing 'off-specification' rocket motors and fuel, missile rocket fuel and
laboratory trash contaminated with lower levels of energetic wastes." ATK Promontory
also notes that the treated waste streams are highly energetic and burn rapidly under
controlled conditions. No other site-specific factors are mentioned. Section 2.3 of EpA's
HHRAP indicates that site-specific factors include community and regulatory concerns.
Nearby residents have expressed concems related to particulate emissions from OB/OD
operations. Please revise this discussion to identify community concerns related to
particulate emissions as a site-specific factor. Please provide a summary of the
approaches that will be used to demonstrate that particulate emissions from OB/OD
operations will not adversely impact off-site receptor populations (e.g., risks and hazardswill be assessed at off-site locations for metals emissions and emissions of SVOCs that
adsorb to particles in the contaminant plume). The comparison of modeled air
concentrations to National Ambient Air Quality Standards for particulates in the air
modeling report should also be mentioned.
Dslrw-2o14-005543 t2
13. Section 3.5 - Ouantifvine Exposure
It appears that the reference to Table 3-6 on page I I should be changed to Table 3-4.
14. Section 4.3 - Risks for Nursine Infants
Please add text to this section to indicate that the exposure assumptions for evaluating
this pathway are presented in Table 3-4 (and add the assumptions to the Table).
15. Section 5.1 - Uncertaintv in the Selection of Emission Factors:
. Please change the date in the first sentence from 2010 to April, 2011.
o As commented on previously, please revise the text in the first paragraph that states the
1.3 emission factors were selected to represent the emissions from all classes of
propellants. This statement is no longer accurate.
16. Section 5.4 - Uncertaintv in Chemical Uptake. Food Chain Modeline and Dose
Estimates
It is stated in this paragraph that default factors for bio-uptake and bio-accumulation will
be evaluated to determine if more appropriate factors can be used in the HHRA. In the
case where default factors will not be used, justification for alternative factors should be
proposed in the Protocol.
17. References
Please change the date of the TetraTech 2010 reference to 2011.
18. Table 2-1
o Please clariff the units of detected concentrations in the Table (.tgl*').
. The units for dioxins and frrans should be picograms/m3.
o The CEM compounds Cl2 and HCI are included in the Table twice (pages 38 and 40) but
with different results. It appears that the concentrations shown on page 38 are correct.
Please revise accordingly.
19. Table 2-2. Chemical of Potential Concern Elimination Process
o The title header on Table 2-2reads "Chemical of Potential Concem Elimination Process
6Non-Detect Compounds Not Used by ATK or Found in Their Waste) (Non-Detect
Compound and Unlikely Generated During Burning)." This table, or the title, is
confusing because some of the compounds listed are present in the waste (e.g. the first
DsHw-2014-oos543 13
20.
compound listed - barium). In addition, the table includes a number of non-detected
chemicals that will be considered site COPCs. It is recommended that the title header be
revised to read: "Identification of Chemicals of Potential Concem (Chemicals Not
Detected in ODOBi and BangBox Studies of ATK Wastes)." Please revise Table 2-2to
address this issue.
Cobalt bearing material has been used by Autoliv and has been burned at ATK in the
past. This is a relevant and specific use of the metal. If it is no longer used or accepted
by ATK for open burning, please indicate this in the Table.
Based on the ODOBi sampling results, Cl2 was detected in all sample and background
analyses. Avalue of 4l70uglm'isshownforthe 100%APsampleonTable2-l,butitis
not considered a COPC on Table 2-2. Please revise as needed.
Table 2-2. Chemical of Potential Concern Elimination process
Table 2'2provides three columns of information (Typical Use of Chemical, Present in
Waste?, and Generated or Possibly Emitted) used in determining if a non-detected
chemical should be considered a COPC. Based on the information provided in the Table,
it is clear how the determination was made for many of the listed chemicals. However, it
is not clear how the determination was made for the following chemicals: bis(2-
chloroethoxy)methane, bis(2-chloroethyl)ether, bis(2-chloroisopropyl)ether, 4-
bromophenyl phenyl ether, 3 -nitroaniline, 4-aminobiphenyl, hydrazine, n-
nitrosodimethylamine, n-nitrosodi-n-butylamine, n-nitrosodi-n-propylamine, 2-
chloronaphthalene, 3-methylcholanthrene, ethyl methanesulfonate,
hexachlorocyclopentadiene, carbazole, methyl methanesulfonate, n-nitrosomorpholine,
pentachloroethane and isoprene. Some ofthese cases can be addressed by reference to an
in-text discussion via a footnote as was done for 2-acetylaminofluorene and other PAHs.
Others may require additional information in the table columns. Please revise Table2-2
to include additional support of the COPC determination for these chemicals.
Table 3-4 (Table 5)
Please add exposure assumptions to the Table for evaluating the risk for nursing infants.
In addition, EPA now has a toxicity value fo^r dioxin, therefore the target level should be
based on the EPA reference dose of 7 x l0-t0 mg/kg/day and the California EPA Toxicity
Values - not the ATSDR value.
Table 4-l (Table 9)
The "Changes in Human Health Toxicity Data" Table included with the revised HHRA
Protocol needs mrmerous updates. The updates in toxicity data needed are highlighted in
yellow in the attached table. Please revise the Table so that it is consistent with the
current values.
2t.
22.
DSHW-2O14-005543 I4
TABLE 9
CHANGES IN HUMAN HEALTH TOXICITY DATA
ATK PROMONTORY, UTAH
PAGE 1 OF 2
Cas No,Ghemical
Cancer Slope
Factor
(mo/ko/dav)'1
Unit Risk
Factor
(uq/m3)-r
Reference
Dose
lmo/ko/davl
F(eterence
Goncentration
(mq/m3)
71-55-6 1.1 .1 -Trichloroethane NA NA 2.0E+00 :;i;
79-3+5 1 .1 .2.2-T elr achloroethane 2.0E-01 |5.8E-05 C :ti:ihffii##ffiF-ry.ffiH.fi.
75-34-3 1,1-Dichloroethane 5.7E-03 C 1.6E-06 C |n;r
95-94-3 1,2,4,5-f etachlorobenzene NA NA 3.0E-04 :_ r. {iEl;;i:
120-82-1 1,2,4-Trichlorobenzene 'i.:,mffimFF'NA 1.0E-02 I
7+95-3 2-Dibromomethane NA NA 1.0E-02 H
107-O&2 l.20icfiloroethane 9.1ts-t Z I 2.6E-05 |6.0E-{t3 X 7.0E-03
78-87-5 1.2-Dichloropropane 3.6E-02 C 1.0E-05 C r:F t1lffi&Sfftr&:r;r:4.0E-03 |
99-35-4 1 .3.S-Trinitrobenzene NA NA 3.0E-02 I ;3rI
9965-0 l,$Dinitrobenzene NA NA 1:0E-04
.".IlYltq;W*s:106-4G7 1.4-Dichlorobenzene 5.4E-03 C 1.1E-05 C 8.0E-01 I
123-91-1 ,4-Dioxane 5.0E-06 |3.OE-02
58-90-2 2.3.4.6-Tetrachlorophenol NA NA 3.0E-02 ','..'-';:-l
174e|01-6 .3.7.&TCDD.! i.lr''4, i,'7.0E-10
95-95-4 ,4,5-Trichlorophenol NA NA 1.0E-01 |
120-83-2 .4-Dichloroohenol NA NA 3.0E-03 |
105-67-9 2.4-Dimethylphenol NA NA 2.0E-02
51-28-5 2.4-Dinitrophenol NA NA 2.0E-03
606-20-2 2-6.Dinituntoluene 1.5E+00 P NA 3-OE44 X NA
91-58-7 Z-Chloronaohthalene NA NA 8.0E-02
95-57-8 2-Chlorophenol NA NA 5.0E-03
95-4&7 2-Methvlohenol NA NA 5.0E-02
106-47-8 4-Chloroaniline l:-tr'4Gffiffi,ffial NA 4.0E-03
83-32-9 Acenaphthene NA NA 6.0E42
75-07-0 Acetaldehyde NA 2.2E-O6 |;,1*'i ;r':J -r-n l,1dllY.i".,-.'9.0E-03 I
67-64-1 Acetone NA NA 9.0E-01 I
98-86-2 Acetophenone NA NA 1.0E-01 |
107-1 3-1 Acrvlonitrile 5.4E-01 I 6.8E-05 |*e#tf$5f,rofltffi 2,0E-03 |
120-12-7 Anthracene NA NA 3.0E-01 I
7440-36-0 Antimony NA NA 4.0E-04 I
7440-38-2 \rsenic 1.5E+00 |4.3E-03 |3.0E-04
7440-39-3 3arium NA NA ;lEffiNffi 5.0E-04 H
100-52-7 3enzaldehvde NA NA 1.0E-01
65-85-0 Senzoic acid NA NA 4.0E+00
117-81-7 2-Ethvlhexvl )phthalate 1.4E-O2 |2.4E-O6 C !ffiffiil NA
75-27-4 3romodichloromethane 6.2E-02 |2.OE421
75-25-2 3romoform 7.9E-03 1.1E-06 2.OE-02
7440-43-9 3admium t-ffiffiiffiffi 1.8E-03 r rffilgt&
10&90-7 0hlorobenzene NA NA 2.0E-02
7$00-3 Chloroethane NA NA tffiiffiii'E:i 1.0E+01 |
67-66-3 Chloroform tffiffi
2.3E-05 I 1.0E-02
74-87-3 )hloromethane Itrrffifieffiltr#ffi i-&trw 9.0E-02 I
16065-83-1 hmndwn lll t.EE+ql
18540-29'9 irr:tmllnrr vl 5.00E{rr J E./ffi.GZ S 3-offi{t3 1.00E{t
7782-50-5 )12 NA NA 1.0E-01
12448-1 )ibromochloromethane 8.4E-O2 |2.OE-O2
84-7+2 )i-n-butyl phthalate NA NA 1.0E-01
100-41-4 lbenzene 1.0E-01 1.0E+00 |
97-63-2 lEEryl l6ducrytets NA NA 9.0E-02 H 3.(E-01 P
206-444 =luoranthene NA NA 4.OE-O2
86-7}.7 =luorene NA NA 4.0E-02l
TABLE 9
CHANGES IN HUMAN HEALTH TOXICITY DATA
ATK PROMONTORY, UTAH
PAGE 2 OF 2
Notes:
'l - The criteria presented for 1,3-dichlorobenzene in the HHRAP database has been withdrawn. The values presented here
are for 1,4-dichlorobenzene.
2 - Phenanthrene is in the HHRAP database but no toxicity criteria is included. The values presented here are for pyrene.
A = Agency for Toxic Subsistence and Disease Registry (ATSDR)
C = California Environmental Protection Agency
H - USEPA Health Effects Assessment Summary Tables (HEAST).
| - USEPA lRlS Database, April 2011.
N = Final Report, Trichloroethene Air Criteria Document, New York State Department of Health, October, 2006
NA - No toxicity criteria available.
P = Provisional Peer Reviewed Toxicity Value (PPRTV)
W - The value in the HHMP database is no longer valid and no new crileria is available.
shading ind&ates criteria that haa *ranwo sinae the UHRAP database wae pub$ehed.
Gas No.Chemical
Cancer Slope
Factor
(mo/ko/dav)-1
Unit Risk
Factor
(uq/m3)'1
Reference
Dose
{mo/ko/davl
Reference
Concentration
(mq/m3)
50-00-0 Formaldehyde W 1.3E-05 |2.0E-01 |9.8E-03 A
7647-01-0 HCI NA NA 2.OE-O2 |w
87-68-3 Hexachlorobutadiene 7.8E-02 |2.2E-O5 |1.0E{3 P W78-59-1 lsophorone 9.5E-04 |W 2.0E-01 |2.0E+00 c
7439-97-6 Mercury NA NA 3.0E-04 |
75-09-2 Methvlene Chloride 2.0E-03 I 1.0E-08 |6.0E-03 6.0E-01 |
91-20-3 Naohthalene NA 3.4E45 C 2.OE-02 3.0E-03 |
7440-02-0 Nickel NA 2.ffi.04 C 2.OE-02 E45 A
98-95-3 \itrobenzene NA 4.0E-05 |a0E-03 r.03 |
95-47-6 r-Xylene NA NA 2.0E-01 S 1.0E-01 S
608-93-5 )entachlorobenzene NA NA 8.0E-04 W
82-68-8 )entachloronitrobenzene 2.6E-01 H w 3.0E-03 w
87-86-5 )entachlorophenol 4.0E-01 |6.1E-00 C 5.0E-03 NA
85-01-8 )henanthrene(1)NA NA 3.0E-02 NA
1 29-00-0 ryrene NA NA 3.0E-02 w
1 10-86-1 ryridine NA NA 1.0E-03 w
7440-22-4 Silver NA NA 5.0E-03 w
127-18-4 letrachloroethene 2.1E-03 |2.6E-O7 |6.0E-03 4.0E-02 |
7440-28-0 Ihallium NA NA 1.0E-05 X NA
1 08-88-3 Toluene NA NA 8.0E-02 s,0E+00 |
1 56-60-5 trans-1 .2-Dichloroethene NA NA 2.OE42 6.0E-02 P
79-01-6 Trichloroethene 4.6E-02 |4.1E-O6 I 5.0E-04 2.0E-03 |
7440-66-6 Zinc NA NA 3.0E-0'l w
7440-66-6 Zinc NA NA 3.0E-01 w