DSHW-2014-009634 - 0901a06880462c02

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State of Utatr
GARYR. I{ERBERT
Governor
SPENCERJ. COX
Lieutenanl Gweraor
Department of
Environmental Quality
Amanda Smith
Exzcutive Director
DIVISIONOF SOLIDAND
FIAZARDOUS WASTE
Scott T. Andenon
Director
Solid and Hazardous Waste Control Board
Kevin Munay, Cfiair
Dennis Riding, Vice-C la ir
Eugcnc Colc, DrPH
JeffCoombs, MPFI, LEHS
Mark Franc
Brett Mickelson
Amanda Smith
Shane Whitrey
Dwayne Woolley
Scott T. Anderson
Exccative Secretary
July 15,2014
George Gooch, Manager
Environmental Services
ATK Launch Systems -Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: Addendum - Air Dispersion Modeling Report for Open Burning and Open Detonation
ATK Launch Systems in Promontory Utah Revision, March 2014
ATK Launch Systems - Promontory Facility
uTD009081357
Dear Mr. Gooch:
The Division of Solid and Hazardous Waste, with the assistance of its contractor Techlaw, Inc., has
completed its review of the March 2014 Air Dispersion Modeling Report. The results of the air dispersion
modeling will be used to help evaluate the human health and ecological risks associated with open burning
and open detonation of hazardous wastes at ATK's Promontory facility. Based on this review, the Division
has concluded that there are seven issues that require revision of the modeling report to provide additional
information or clariff the existing text. These issues are discussed in the enclosed comments.
The seven issues discussed in the enclosed comments should be addressed by providing the requested
information in additional pages as necessary to insert into the March 2014 Report, or if ATK prefers, by
providing a revision of the entire report. Please submit the additional pages or revised report to the Division
on or before August 1,2014.
If you have any questions, please call JeffVandel at [phone] -
STA/JV/Ijm
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 1,f4880' Salt Lake City, UT 841144880
Telephonc (801) 53G0200'Fax [phone] 'T.D.D. (801) 5364414
aruwicq.utalugoo
Printed on 100% recYcled PaPcr
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
DSHW-2o14409634
(Over)
Enclosure: TechnicalReviewComments
c: BlairPalmer, ATK Launch Systems
Paul Hancock, ATK Launch Systems
Nancy Morlock, USEPA Region 8 @mail)
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Departrnent
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
DSFIW-2014{09634
UTAH DIVISION OF SOLID AI\ID HAZARDOUS WASTE
TECHNICAL REYIEW OF
ADDENDI]M AIR DISPERSION MODELING REPORT FOR OPEN BT'RNING AI\D OPEN
DETONATION AT ATK LATJNCH SYSTEMS IN PROMONTORY, UTAH REWSION
MARCH 2014
GENERAL COMMENTS
1. The Revised Hybrid Air Modeling Report does not include a comprehensive discussion of the
uncertainties associated with the hybrid air modeling analysis. Section 4.3.2, Open Detonation,
identifies the calculation of the initial vapor cloud dimensions for open detonation as a source of
uncertainty. However, other sources of uncertainty (e.g., use of lowest predicted cloud height to
represent the actual cloud height over a given range of wind speed and atmospheric stability values)
are not identified. The uncertainties associated with the hybrid air modeling analysis should be
identified and their impact on the air modeling results discussed in the Revised Hybrid Air Modeling
Report. In addition, the impact of these uncertainties on the human health and ecological risk
assessments should be discussed in the corresponding risk assessment reports. Please revise the
Revised Hybrid Air Modeling Report to identifi any sources of uncertainty associated with the
hybrid air modeling analysis and discuss their impact on the air dispersion and deposition modeling
results. In addition, please revise the report text to indicate the impact of air modeling uncercainties
on risk assessment results will be discussed in the risk assessment reports.
SPECIFIC COMMENTS
1. Section 5.0, Model Defaults and Assumptions, Page 19: Page 19 includes an example of the data
provided in the hourly emission rate files used in the American Meteorological
Society/Environmental Protection Agency Regulatory Model (AERMOD) modeling analysis. The
example indicates that an emission rate of 120.96 grams per second (g/sec) is associated with
scenario Ml36-4l for the hour of meteorological data addressed in the example. Thus, it is believed
this example is from the AERMOD modeling performed for the National Ambient Air Quality
Standards (NAAQS) and Air Toxics analysis. However, this is not noted in the description of the
example. Confirsion may arise as AERMOD modeling performed for determining air dispersion
factors (ADFs) for the risk assessment is based on a unit emission rate (e.g., emission rate of 1
g/sec). For clarity, it is recommended that an example from an hourly emission rate file used in
ADF modeling also be provided along with an explanation of the differences between the two
examples. Please revise the discussion of the hourly emission rate files to include this clarification.
2. Section 6.1, Meteorological Data Processing, Page20z The text does not identiff the preliminary
modeling analysis mentioned in the first two sentences of the first paragraph of Section 6.0. ATK
Promontory has indicated that the preliminary modeling referenced in Section 6.0 refers to the
Revised Preliminary Air Dispersion Modeling Assessment Draft Report for Open Burn and Open
Detonation Treatnent Unit at ATK Launch Systems dated July 2012. Please revise Section 6.0 to
include the name of the preliminary modeling report.
DSHW-2o14409634
6.
Section 6.2rLandl Use and Surface Characteristics, Page 20: ATK Promontory has included
Section 6.2 in the Revised Hybrid Modeling Report. Section 6.2 provides the details regarding land
use and surface characteristics as discussed in the March 2013 Hybrid Air Modeling Protocol.
However, Section 6.2 does not indicate that the land use and surface characteristic analysis was
presented in the preliminary modeling completed by Tetra Tech in July 2012. In addition, the
location of figures associated with the land use analysis is not included in Section 6.2 (ATK
Promontory has previously indicated these figures are provided in Appendix A of the Revised Air
Dispersion Modeling Assessment Report for Open Burn and Open Detonation Treatment Units at
ATK Launch Systems, dated July 2012. Section 6.2 should also note that the land use was not
reevaluated as part of the hybrid air modeling analysis. Please revise Section 6.2to include the
information discussed above-
Section 6.1, Meteorological l)ata Processing, Page20: ATK Promontory has indicated that a
meteorological data file was not used in the Open Burn Open Detonation Model (OBODM)
modeling to determine the vapor cloud dimensions as each combination of wind speed and
atmospheric stability were directly input to OBODM and modeled individually. This information is
included in Section 6.1. Please revise Section 6.1 to indicate how meteorological data were included
in the OBODM modeling.
Section 10.2' Meteorological Data Processing, Page 35: The next to last paragraph on Page 35
discusses the modeling of gas phase dry deposition. The last sentence of the paragraph states*UDSHW accepted the velocity of 0.03 m/sec [meters per second] in Tetra Tech's modeling." While
the Division acknowledges that 0.03 m/sec was used in the air dispenion modeling performed by
Tetra Tech, it is recommended that this paragraph be modified to reference the air dispersion
modeling protocol developed by Tetra Tech (ATK Launch Systems Waste Characterization and Air
Dispersion Final Modeling Protocol for Use in the Human Health and Ecological Risk Assessments,
dated 201l). Please revise the next to last paragraph on Page 35 to read, "This velocity is consistent
with the value used in the preliminary modeling performed by Teta Tech and proposed in ATK
Launch Systems Waste Characteiz,ation and Air Dispersion Final Modeling Protocol for Use in the
Human Health and Ecological Risk Assessments, dated 2011. UDHSW accepted the proposed value
as part of the technical review of the protocol document."
Section 11.0' Conclusion, Page 39: The discussion in Section I1.0 appears focused on the
modeling performed for the NAAQS and air toxic analysis and does not present conclusions related
to the air modeling performed for use in the risk assessments. Please expand the discussion in
Section 11.0 to include conclusions based on the air modeling results obtained for use in the human
health and ecological risk assessments.
DSHW-2o14{09534