DSHW-2015-001729 - 0901a068804dc233

DSHW-2015-001729 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith Executive Director DIVISION OF SOLID AND HAZARDOUS WASTE Scott T. Anderson Director

Solid and Hazardous Waste Control Board Kevin Murray, Chair Dennis Riding, Vice-Chair Eugene Cole, DrPH Jeff Coombs, MPH, LEHS Mark Franc Brett Mickelson
Amanda Smith Shane Whitney Dwayne Woolley Scott T. Anderson Executive Secretary

January 22, 2015

George Gooch, Manager
Environmental Services
ATK Launch Systems – Promontory P.O. Box 707
Brigham City, UT 84302-0707

RE: Five-Year Permit Anniversary Closure Cost Estimate and Permit Modification Request
ATK Launch Systems – Promontory Facility UTD009081357

Dear Mr. Gooch:

The Division of Solid and Hazardous Waste has completed its review of the Closure Cost Estimate tables that ATK submitted in September 2014 and the Permit Modification Request that was submitted
in December 2014. Review comments are enclosed. These issues were also discussed in a meeting held
at our office on December 15, 2014.

Please revise the cost estimates and proposed permit modifications as discussed in the meeting and submit them to this office. The changes to the permit are classified as a Class 1 Permit Modification
with the prior approval of the Director of the Division of Solid and Hazardous Waste.

If you have any questions, please call Jeff Vandel at [phone].
Sincerely,

Scott T. Anderson, Director Division of Solid and Hazardous Waste
(Over)

STA\JV\al

Enclosures: Comments on Module II Modification (DSHW-2015-001789) Comments on Attachment 5 Modification (DSHW-2015-001788)
Comments on Closure Cost Estimate Tables (DSHW-2015-001787)

c: Blair Palmer, ATK Launch Systems
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department Grant Koford, EHS, Environmental Health Director, Bear River Health Department

ATK Launch Systems Inc. – Promontory Modified DecemberJanuary, 2014 Attachment 5 – Closure Plan UTD009081357
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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 of the 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 LTTAs 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 of the 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)(1). All closures will assess real and reasonably likely impacts to human and ecological exposures.
Comment [JV1]: Closure costs will be removed from plan by mod. Could change it to something like: Closure Cost estimates are maintained in the Operating Record once approved by the Director.
Comment [JV2]: Suggest replacing “all of the” with “the general” since detailed closure plans are submitted when it is decided to close a HWMU.
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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 of the 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. Detailed plans
for closing permitted facilities have been submitted to the Division, and are maintained as part of
the facility operating record. 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
Comment [JV3]: Should “plans” be replaced with “cost estimates?” Detailed plans are submitted when it is decided to close a HWMU.
Comment [JV4]: Consider adding something like: Detailed plans for closing each HWMU will be submitted in accordance with Permit Condition III.J.2.
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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 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 of the 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
Comment [JV5]: I don’t think this level of detail is appropriate here. Please consider something like: Detailed sampling plans will be submitted in accordance with Permit Condition III.J.2.
Comment [JV6]: Current cost estimate indicates only 5 samples will be collected. This is a change we should discuss.
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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 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; 6010B 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.
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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.
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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 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. Closure cost estimates are maintained in the operating record. Closure cost estimates are based on using a third party except for the thermal treatment and disposal of reactive waste which will
be conducted on site.
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.
Comment [JV7]: ATK doesn’t plan to pressure wash floors at M-47 and M-603 if I’m not mistaken. We might want to revise this language to avoid potential permit mod. Later.
Comment [JV8]: We would like to add: “Once approved by the Director,” to the beginning of this sentence.
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Table 1 M-136 Closure Cost Estimate1

Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH) 33-22-0111 x 2 hr 20 83.44 1,669
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Table 2 M-225 Closure Cost Estimate1

Item No. Description Means Units Est. Quan. Unit Price Total Price
2 Site prep (technician) 33-22-0112 x 2 hr 40 50.96 2,038
3 Treat remaining waste ATK lb 106,500 0.25 26,625
4 Excavate contaminated soil 17-03-0231 hr 20 105.63 2,113
5 Load soil and burned waste 17-03-0222 hr 8 68.13 545
6 Haul waste and soil to Clean Harbors 33-19-0221 truck-mi 1,050 2.50 2,625
7 Landfill disposal, waste and soil 33-19-7214 ton 50 169.45 8,473
8 State disposal fee, waste and soil Utah DEQ ton 50 32.50 1,625
9 Steam clean burn pans 33-17-0812 sf 1,000 0.39 390
10 Load rinsate 33-19-0103 drum 5 4.87 24
11 Haul rinsate to Clean Harbors3 33-19-0243 truck-mi 350 2.26 791
12 Landfill disposal, rinsate3 33-19-7214 drum 5 145.00 725
13 State disposal fee, rinsate3 Utah DEQ ton 1 28.00 28
14 Demolish pans 17-02-0105 cf

2,000 0.14 280
15 Load pan debris 17-03-0222 hr 4 68.13 273
16 Haul pan debris to Clean Harbors 33-19-0221 truck-mi 350 2.50 875
17 Landfill disposal, pan debris 33-19-7263 ton 50 169.45 8,473
18 State disposal fee, pan debris Utah DEQ ton 50 32.50 1,625
19 Sample collection Site crew hr 40 65.00 2,600
20 Sample analyses, metals Chemtech-Ford ea 20 210.00 4,200
21 Sample analyses, explosives Chemtech-Ford ea 20 210.00 4,200
22 Sample analyses, volatiles Chemtech-Ford ea 20 250.00 5,000
SUBTOTAL 75,196

INFLATION ADJUSTMENT=1.2042 90,536

Misc. costs as a percent of the inflation-adjusted subtotal:

Mob/demob 5 % 4,527
Engineering/permitting 10 % 9,054
DSHW oversight 10 % 9,054
Contingency 10 % 9,054

TOTAL ESTIMATED COST 122,225
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No./Source
1 Site prep (CIH) 33-22-0111 x 2 hr 8 83.44 668
2 Site prep (technician) 33-22-0112 x 2 hr 20 50.96 1,019
3 Treat remaining waste ATK lb 55,000 .025 13.750
4 Excavate contaminated soil 17-03-0231 hr 12 105.63 1,268
5 Load soil and burned waste 17-03-0222 hr 4 68.13 273
6 Haul waste and soil to Clean Harbors 33-19-0221 truck-mi 350 2.50 875
7 Landfill disposal, waste and soil 33-19-7214 ton 25 169.45 4,236
8 State disposal fee, waste and soil Utah DEQ ton 25 32.50 813
9 Steam clean burn pans 33-17-0812 sf 400 0.39 156
10 Load rinsate 33-19-0103 drum 3 4.87 15
11 Haul rinsate to Clean Harbors3 33-19-0243 truck-mi 350 2.26 791
12 Landfill disposal, rinsate3 33-19-7214 drum 3 145.00 435
13 State disposal fee, rinsate3 Utah DEQ ton 1 28.00 28
14 Demolish pans 17-02-0105 cf 800 0.14 112
15 Load pan debris 17-03-0222 hr 4 68.13 273
16 Haul pan debris to Clean Harbors 33-19-0221 truck-mi 350 2.50 875
17 Landfill disposal, pan debris 33-19-7263 ton 20 169.45 3,389
18 State disposal fee, pan debris Utah DEQ ton 20 32.50 650
19 Sample collection Site crew hr 20 65.00 1,300
20 Sample analyses, metals Chemtech-Ford ea 12 210.00 2,520
21 Sample analyses, explosives Chemtech-Ford ea 12 210.00 2,520
22 Sample analyses, volatiles Chemtech-Ford ea 12 250.00 2,520
SUBTOTAL 38,084

INFLATION ADJUSTMENT = 1.2042 45,853

Misc. costs as a percent of the inflation-adjusted Subtotal:

Mob/demob 5 % 2,293
Engineering/permitting 10 % 4,585
DSHW oversight 10 % 4,585
Contingency 10 % 4,585

TOTAL ESTIMATED COST 61,901
Table 3
M-47 Closure Cost Estimate1

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Table 4 M-603 Closure Cost Estimate1

Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Materials prep (CIH) 33-22-0111 x 2 hr 12 83.44 1,001
2 Materials prep (technician) 33-22-0112 x 2 hr 20 31.58 632
3 Load waste motor (crane) Crew SIWSM hr 8 393.57 3,149
4 Haul motor to burning ground Crew COET2 hr 16 93.31 1,493
5 Off-load motor Crew SIWSM hr 8 393.57 3,149
6 Handling evaluation/planning Site personnel hr 80 65.00 5,200
9 Motor handling Site personnel hr 40 65.00 2,600
10 Disposal at burning ground ATK lb 300,000 0.25 75,000
11 Sweep area 33-22-0112 x 2 hr 8 31.58 253
12 Steam clean floor 33-17-0812 sf 5,680 0.39 2,215
13 Load rinsate/sweepings 33-19-0103 drum 10 4.87 49
14 Load drums 33-19-0103 ea 10 3.05 31
15 Haul to Clean Harbors 33-19-0243 truck-mi 350 2.26 791
16 State disposal fee Utah DEQ ton 1 28.00 28
17 Sample collection 33-22-0112 x 2 hr 4 31.58 126
18 Sample analyses, metals/exp Chemtech-Ford ea 2 210.00 420
SUBTOTAL 96,135

INFLATION ADJUSTMENT = 1.2042 115,747

Misc. costs as a percent of the inflation-adjusted subtotal:

Mob/demob 5 % 5,787
Engineering/permitting 10 % 11,575
DSHW oversight 10 % 11,575
Contingency 10 % 11,575

TOTAL ESTIMATED COST 156,258
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Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Materials prep (CIH) 33-22-0111 x 2 hr 8 83.44 668
2 Materials prep (technician) 33-22-0112 x 2 hr 12 31.58 379
3 Load waste motor (crane) Crew SIWSM hr 8 393.57 3,149
4 Haul motor to burning ground Crew COET2 hr 12 93.31 1,120
5 Off-load motor Crew SIWSM hr 8 393.57 3,149
6 Handling evaluation/planning Site personnel hr 40 65.00 2,600
9 Motor handling Site personnel hr 20 65.00 1,300
10 Disposal at burning ground ATK lb 120,000 0.25 30,000
11 Sweep area 33-22-0112 x 2 hr 8 31.58 253
12 Steam clean floor 33-17-0812 sf 1,830 0.39 714
13 Load rinsate/sweepings 33-19-0103 drum 4 4.87 19
14 Load drums 33-19-0103 ea 4 3.05 12
15 Haul to Clean Harbors 33-19-0243 truck-mi 350 2.26 791
16 State disposal fee Utah DEQ ton 1 28.00 28
17 Sample collection 33-22-0112 x 2 hr 4 31.58 126
18 Sample analyses, metals/exp Chemtech-Ford ea 2 210.00 420
SUBTOTAL 44,727

INFLATION ADJUSTMENT = 1.2042 53,851

Misc. costs as a percent of the inflation-adjusted subtotal:

Mob/demob 5 % 2,693
Engineering/permitting 10 % 5,385
DSHW oversight 10 % 5,385
Contingency 10 % 5,385

TOTAL ESTIMATED COST 72,699

Table 5
M-186A Closure Cost Estimate1

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Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH) 33-22-0111 x 2 hr 8 83.44 668
2 Site prep (technician) 33-22-0112 x 2 hr 24 31.58 758
3 Load drums 33-19-0103 ea 400 3.05 1,220
4 Haul drums to Clean Harbors 33-19-0243 truck-mi 1,750 2.26 3,955
5 Landfill disposal 33-19-7214 drum 400 145.00 58,000
6 State disposal fee Utah DEQ ton 100 28.00 2,800
7 Truck washout/decon 33-19-0311 ea 1 158.00 158
8 Steam clean floor 33-17-0812 sf 1,930 0.39 753
9 Rinsate sample collection Site crew hr 4 65.00 260
10 Sample analyses, metals Chemtech-Ford ea 1 210.00 210
11 Sample analyses, explosives Chemtech-Ford ea 1 210.00 210
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

Table 6 M-705S Closure Cost Estimate1
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Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH) 33-22-0111 x 2 hr 4 83.44 334
2 Site prep (technician) 33-22-0112 x 2 hr 8 31.58 253
3 Load drums 33-19-0103 ea 32 3.05 98
4 Haul drums to Clean Harbors 33-19-0243 truck-mi 350 2.26 791
5 Landfill disposal 33-19-7214 drum 32 145.00 4,640
6 State disposal fee Utah DEQ ton 8 28.00 224
7 Truck washout/decon 33-19-0311 ea 1 158.00 158
8 Steam clean floor 33-17-0812 sf 1,850 0.39 722
9 Rinsate sample collection Site crew hr 4 65.00 260
10 Sample analyses, metals Chemtech-Ford ea 1 210.00 210
11 Sample analyses, explosives Chemtech-Ford ea 1 210.00 210
SUBTOTAL 7,899

INFLATION ADJUSTMENT = 1.2042 9,510

Misc. costs as a percent of the inflation-adjusted subtotal:

Mob/demob 5 % 475
Engineering/permitting 10 % 951
DSHW oversight 10 % 951
Contingency 10 % 951

TOTAL ESTIMATED COST 12,838

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Table 7 E-501 Closure Cost Estimate1

Item
No. Description
Means
No./Source Units
Est.
Quan. Unit Price
Total
Price
1 Site prep (CIH) 33-22-0111 x 2 hr 4 83.44 334
2 Site prep (technician) 33-22-0112 x 2 hr 8 31.58 253
3 Load drums 33-19-0103 ea 160 3.05 488
4 Haul drums to Clean Harbors 33-19-0243 truck-mi 700 2.26 1,582
5 Landfill disposal 33-19-7214 drum 160 145.00 23,200
6 State disposal fee Utah DEQ ton 40 28.00 1,120
7 Truck washout/decon 33-19-0311 ea 1 158.00 158
8 Steam clean pad 33-17-0812 sf 1,760 0.39 686
9 Rinsate sample collection Site crew hr 4 65.00 260
10 Sample analyses, metals Chemtech-Ford ea 1 210.00 210
11 Sample analyses, explosives Chemtech-Ford ea 1 210.00 210
SUBTOTAL 28,501

INFLATION ADJUSTMENT = 1.2042 34,315

Misc. costs as a percent of the inflation-adjusted subtotal:

Mob/demob 5 % 1,716
Engineering/permitting 10 % 3,431
DSHW oversight 10 % 3,431
Contingency 10 % 3,431

TOTAL ESTIMATED COST 46,325

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Table 8 T-29B Closure Cost Estimate1

Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH) 33-22-0111 x 2 hr 4 83.44 334
2 Site prep (technician) 33-22-0112 x 2 hr 8 31.58 253
3 Extra drum for dilution 33-19-0402 ea 1 80.00 80
4 Transfer and dilute hydrazine Site crew hr 4 65.00 260
5 Load drums 33-19-0103 ea 2 3.05 6
6 Haul drums to Clean Harbors 33-19-0243 truck-mi 350 2.26 791
7 Landfill disposal 33-19-7214 drum 2 145.00 290
8 State disposal fee Utah DEQ ton 1 28.00 28
9 Truck washout/decon 33-19-0311 ea 1 158.00 158
10 Steam clean floor 33-17-0812 sf 200 0.39 78
11 Rinsate sample collection Site crew hr 4 65.00 260
12 Sample analyses, metals Chemtech-Ford ea 1 210.00 210
13 Sample analyses, explosives Chemtech-Ford ea 1 210.00 210
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
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Table 9 S-633 Closure Cost Estimate1

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.

Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price
1 Site prep (CIH) 33-22-0111 x 2 hr 4 83.44 334
2 Site prep (technician) 33-22-0112 x 2 hr 8 50.96 253
3 Disposal at Burning Ground ATK hr 75,000 0.25 18,750
4 Sample Collection Site crew lb 8 65.00 520
5 Sample analyses, metals Chemtech-Ford ea 8 210.00 1,680
6 Sample analyses, explosives Chemtech-Ford ea 8 210.00 1,680
7 Sample analyses, volatiles Chemtech-Ford ea 8 210.00 1,680

SUBTOTAL 24,897

INFLATION ADJUSTMENT = 1.2042 29,976

Misc. costs as a percent of the inflation-adjusted subtotal:

Mob/demob 5 % 1,499
Engineering/permitting 10 % 2,997
DSHW oversight 10 % 2,997
Contingency 10 % 2,997

TOTAL ESTIMATED COST 40,468
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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

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MODULE II - GENERAL FACILITY CONDITIONS II.A. 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.1. and UAC R315-3-3.1(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 t he 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
Field Code Changed
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1. 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 of the 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 of the data. The Permittee shall inform the laboratory in writing that it must operate under the Waste Analysis Plan conditions set forth in this Permit. II.E SECURITY II.E.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
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time that the 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-136 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 IV 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.1.

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.
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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 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 II.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 IV.M.1. 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
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Training Plan in Attachment 3. These records shall indicate the type and amount of training received. 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. II.I. GENERAL REQUIREMENTS FOR IGNITABLE, REACTIVE, OR INCOMPATIBLE WASTE II.I.l. The Permittee shall comply with the requirements of UAC R315-8-2.8. II.I.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. II.J. LOCATION STANDARDS II.J.1. The Permittee shall comply with the location standards specified by UAC R315-8-2.9. II.K. PREPAREDNESS AND PREVENTION II.K.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. II.K.4. 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. II.K.5. The Permittee shall maintain access to the communications or alarm system as required by UAC R315-8-3.5. II.K.6. At a minimum, the Permittee shall maintain 30 inches of aisle space between containers or pallets of containers at storage areas M -186 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.
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II.L. CONTINGENCY PLAN 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 I.T. 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. M ANI FEST 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.
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II.O. CLOSURE/POST-CLOSURE II.O.l. The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101 and Attachment 5. II.O.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.O.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.O.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. II.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. II.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.O.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 soi l, 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.O.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.
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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 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 i n 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.Q.1 The Permittee shall demonstrate continuous compliance with UAC R315-8-8 by providing documentation of financial assurance, as required by UAC R315-8-8. Changes in financial assurance mechanisms shall be approved by the Director at least 60 days prior to such a change. On ten day notice from the Director, the Permittee shall
direct any entity that is responsible for payment of closure costs, to provide copies of
documents demonstrating the status of the financial assurance mechanism.
II.Q.2. By July 30 of each calendar year, the Permittee shall adjust the closure cost estimate for
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inflation or submit the latest adjusted closure cost estimate for review and approval by
the Director. After approval, the Permittee shall maintain the latest adjusted closure cost
estimate in the operating record. For any new HWMU being placed into operation, an
updated facility closure cost estimate must be prepared for the new unit(s), 60 days
prior to waste being placed on or into the new unit.
II.Q.3. The Permittee shall revise the closure cost estimate whenever there is a change in the
facility’s closure plan that would change the cost estimate as required by 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. 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).
Comment [JV1]: When does ATK want to be able to store haz. waste in the new building? Will cost estimate for new building impact the estimate proposed last September that is to be effective July 30, 2015? In addition, any change in the cost estimate – such as a new HWMU, or change in the closure plan – needs to be approved by the Director. Please make revisions as discussed in our meeting on January 15th.
Comments on Closure Cost Estimate Tables Submitted September 29, 2014

M-225 Closure Cost Estimate In the cost estimate submitted, the quantity of soil samples that will be collected and analyzed
has been reduced from 12 to 5. What is the basis for this reduction? Five samples may not be
adequate to characterize the M-225 area and demonstrate that clean closure is appropriate for the
site. Page 3 of the Closure Plan (Attachment 5) currently states that 12 samples will be collected
during closure of M-225.

M-47 Closure Cost Estimate The line item “steam clean floor” should be removed from the Table through the Class 1 mod. If
this is done, should line items 13, 14 and 15 also be removed? Floor sweepings may be disposed
in the on-site landfill. Revised cost estimate tables that reflect how M-47 will be closed should
be submitted with a revised permit modification request. In addition, the Closure Plan for M-47 could be submitted at the same time.
M-603 Closure Cost Estimate

The line item “steam clean floor” should be removed from the Table through the Class 1 mod. If this is done, should line items 13, 14 and 15 also be removed? Floor sweepings may be disposed of in the on-site landfill. Revised cost estimate tables that reflect how M-603 will be closed
should be submitted with a revised permit modification request. In addition, the Closure Plan for
M-603 could be submitted at the same time.
M-186 Closure Cost Estimate
Should the line items load rinsate, load drums, haul to Clean Harbors, landfill disposal, and state
disposal fee be added to the M-186 Table under Item No. 8? Based on the cost estimates for
other HWMUs at Promontory, it appears that these items are missing. In addition, it appears that sample analyses for VOCs should be added to the table under Item
No. 11.

M-705S Closure Cost Estimate Should the line items load rinsate, load drums, haul to Clean Harbors, landfill disposal, and state
disposal fee be added to the M-705S Table under Item No. 8? Based on the cost estimates for
other HWMUs at Promontory, it appears that these items are missing.

In addition, it appears that sample analyses for VOCs should be added to the table under Item
No. 11.

E-501 Closure Cost Estimate
Should the line items load rinsate, load drums, haul to Clean Harbors, landfill disposal, and state
disposal fee be added to the E-501 Table under Item No. 8? Based on the cost estimates for
other HWMUs at Promontory, it appears that these items are missing.
In addition, it appears that sample analyses for VOCs should be added to the table under Item
No. 11.

T-29B Closure Cost Estimate
Should the line items load rinsate, load drums, haul to Clean Harbors, landfill disposal, and state
disposal fee be added to the T-29B Table under Item No. 10? Based on the cost estimates for
other HWMUs at Promontory, it appears that these items are missing.

In addition, what would be the appropriate analyses for the rinsate sample? Are analyses for metals and explosives needed for the rinsate sample at T-29B?