DSHW-2014-009658 - 0901a0688046304d

State of Utah
CARY R. HERBERT
Governor
SPENCERJ. COX
Lieutenant Governor
Ju|y28,2014
George Gooch, Manager
Environmental S ervices
ATK Launch Systerns - Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: Review of Draft Human Health Risk Assessment Protocol - Final, June 2014
ATK Launch Systems - Promontory Facility
uTD009081357
Dear Mr. Gooch:
The Division of Solid and Hazardous Waste and its contractor Techlaw Inc., have completed their
review of the June 2014 Human Health Risk Assessment Protocol. This protocol document outlines the
procedures that will be used to evaluate the human health risk associated with the open burning and
open detonation of hazardous waste at ATK's Promontory facility.
The Division identified some issues that require revisions to the HHRA protocol document. These
issues were discussed in the comments the Division provided to ATK by e-mail on June 18, 2014. ATK
responded to these comments by e-mail on June 25,2014. The comments were also discussed in a
conference call with the Division, ATK and respective consultants. Based on ATK's responses to our
comments and our follow-up discussion, it was concluded that ATK had sufficiently addressed the
issues that had been identified, However, it was agreed that ATK would provide an appendix to the
protocol document that would explain how emission rates would be calculated for producing risk
estimates using the Lakes Environmental software (Industrial Rl,sftr4ssessment Program - Human
Healthfor the U.S.EPA OSW Hurnan Health Risfrr4ssessment Protocol (Lakes,20t4).
ATK provided a draft of the appendix (Appendix A) on June27,2014. After review of this draft
document, the Division requested a minor change and on July 9, 2014 ATK provided a revised appendix
that addresses the issue that was identified. Therefore, it appears that ATK has addressed all of the
issues the Division has identified and discussed with ATK since the June 2014 HHRA protocol
document was submitted. Please inoorporate all of the revisions including Appendix A, as discussed,
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
195 North 1950 West . Salt Lake City, UT
Mailing Address: P.O. Box 1,t4880 . Salt kke City, tl't 841144880
Telephone [phone] . Fax [phone]' T.D.D. (801) 5364414
toruw.deq.utah.gort
Printed on 100% recycled paper
Solid end Hazardous Weste Control Board
Kevin Murray, Clair
Dennis Riding, Vice-Chair
Eugene Cole, DIPH
JeffCoombs, MPH, LEHS
Mark Franc
Brett Mickelson
Amanda Smith
Shane Whitney
Dwayne Woolley
Scott T. Anderson
Executive Secretary
DSHW-2014{09658
into a final HHRA protocol document and submit it to the Division for approval on or before
August 8,2014.
If you have any questions, please call JeffVandel at [phone].
Division of Solid and Hazardous Waste
STA/JV/tjm
c: Blair Palmer, ATK Launch Systerns
Paul Hancock, ATK Launch Systems
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Departrnent
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Nancy Morlock, USEPA Region 8 (Email)
2DSHW-2014409658