DSHW-2015-002570 - 0901a068804f020a

L/'HL.UIO Mall-Ke: l""romornory v1osure vost permn moomcauon
cJO /6-00;J57 o
Jeff Vandel <[e-mail]>
Re: Promontory Closure Cost permit modification
1 message
JeffVandel <[e-mail]> Wed, Jan 14, 2015 at 12:23 PM
To: "Gooch, George" <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "Brad Maulding ([e-mail])"
<[e-mail]>, "Palmer, Blair'' <[e-mail]>
Hi George-
I have had a look at your proposed changes to Attachment 5 and Module 2 and the cost estimate tables that
were submitted back in September. Please see my comments in the attached documents.
In regard to the revised closure cost becoming effective on July 30, 2015, won't the cost estimate need to
change with the closure of M-47 and M-603 and the addition of the new storage building?
We'll want to keep in mind that the Permit requires 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.
In addition, regarding the closure of buildings M-47 and M-603, Permit Condition III.J.2. requires that Closure
Plans for each HWMU shall be submitted 180 days prior to beginning closure activities.
Let's discuss these issues once you have had a chance to look at the attached comments.
Thanks,
Jeff
DISCLAIMER:
Statements made in this e-mail do not constitute the official position of the Director of the Division of Solid and
Hazardous Waste. If you desire a statement of the Director's position, please submit a written request to this
office, on paper, including documents relevant to your request.
On Sat, Dec 27, 2014 at 7:07PM, Gooch, George <[e-mail]> wrote:
.: Jeff & David,
Please review these proposed changes and let me know your thoughts. I'm proposing to make changes to
Module II and Attachment 5 to make requirements similar to what we're doing at Bacchus, and to make the
change as a Class I modification. I'm also proposing to change the value for Promontory closure costs
i effective as of July 30, 2015 to reflect the value in our September 30, 20141etter. I'll wait to submit this until
i Dec. 31 5t in the event you have comments on it. Enjoy your time off work and thanks for the help.
3 attachments
~ ATTACHMENT 5 2014_rev 17 Dec 2014 (2).docx
1/?
t: rTqncrxfflt rJrGlro rJctp€rmrr moqflcaon
96K
IiODULE2 2014_revlsion_1 7Dec2014 (l).docx
40K
Comments on Glosure Goet Esffmate Tables Submitted Sqptember 29.docx
15K
lfiF'rrmail^ .v{am/mil/irill?ri=?ljt=72h7aflA{c2lviru=r*l,csaheca'*lfir€la- ^ ^-qfFf-l6tugciml=lr@ Itt . ll-rrl
ATK Lauch S)stms Inc. - Promontort
Module II - Gmral Faciliry Conditions
u.P.
II.P.1.
\.P.2.
u.P.3.
II.P.4.
II.P.5.
II.Q.
Modined !ceE!bcr?g,l_4 -," {-*t*-, ,":,r*, -*--_-l
COST ESTIMATES FOR HVYMU CLOST]RE
The Permittee's closure cost estinute for each HWMU shall be prepared and
maintained at the faciliry in accordance with UAC R315-8-8 (40 CFR 2&.142
incorporated by reference) and Attachment 5.
On the one year anniversary date of Permit issuance, the Permittee shall submit to theDirector for approval updated closure plans and detailed closure cost estimates for
each trwMU at the ATK facility. The closure cost estimates shall identifu 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 2&.142 incorporated
by reference).
On the five year anniversary date of the submittal of the closure cost estirnates
required by Condition ILP.2. above, the Permittee shall conduct a detailed evaluation
of the closure cost estirnates for each HWMU and determine whether the annual
adjustments for inflation have been adequate to update the closure cost estinntes. 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 <iays after the report
is submitted.
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). '
For each new FIWMU placed into operation, an updated closure cost estirnte to thefacility must be prepared which includes the new unit, 60 days prior to waste being
placed on or into the new unit.
FINANCIAL ASSI.]RANCE FOR FACILITY CLOSURE
Il.O.1 The Permittee shall demonstrate continuous compliance with UAC R315-8-8 blrproviding documentation offinancial assurance. as reguired by UAC R3l5-8-8.
Changes in financial assurance mechanisms shall be approved b], the Director at least
60 days prior to such a chanee. On ten day notice from the Director. the Permittee shall
direct any entitv that is responsible for payrnent of closure costs, to provide copies of
documents demonstrating the status of the financial assurance mechanism.
Il.O.2. By Julv 30 of each calendar year. the Permittee shall adjust the closure cost estirnate for
inflation or submit the latest adjusted closure cost estimate for review and approval bv
the Director. After approval. thq Permittee shall maintain the latest adjusted closure cost
estimate in the operatine record. For any new HWMU beirig olaced into operation. an
II.O.3. The Permittee shall revise the closure cost estimate whenever there is a change in the
facilitv's closure plan that would chanse the cost estimate as required bv UAC R3 15-8-
Oonrtrrat W!,lr Y/Srodee ATKvrntlo ba
abb to ltorc h3L waSE in the w luilrtirtg? W'i[srt estinrte fd nci, building ie0act 6E Gsindc
prqoicdlsst S€tsabq0tat i5 to bc ctrccti16July
30,20t5?
Deleted: II.e.l
Deleted: The Pemitte stull demoNuare
cmtitruos fimcial assruce complimce by
providing a third party fmmcial as$ruce
cenifcation of at le6t tlrc mut of the
clo$relpost{lo$rc cost estimtes established
in Condition Il.P. The Pemirtee may
sbstitute other instrumnts of fmmcia.l
ssrmce prcvided the method, funding md
wording requirerents of UAC R3l5-8-8 de
followed md approved by the Dirstor.lt
ll.Q.2. - The fmcial ssrmce dculmt
shall be updated wilhin 60 days of the mual
adjustnetrt for inflation or within @ days of
the approval of a revisd clo$relpost{losre
cost estimte in accordmce with UAC R3l5-
8-8.
ATK LMch Systms lnc. - P|mmtory
Module II - C@qal Feility Conditions
II.R.
II.R.1.
II.R.2.
II.R.2.
tr.s.
II.s.1.
Modifi ed Dsmbq?9-l-4-, - : - -;;t-rTD0090E1357 De{eted: Jmuary,
ILO.3. The Permittee shall revise the closure cost estimate whenever there is a chanse in the
facilitv's closure plan that would change the cost estimatp as required by UAC R3l5-8-
8.
LIABILITY REOUIREMENTS
The Permittee shall demonstrate continuous conpliance with the liability requirements
of U-A,C R315-8-8 (40 CB. 2eJ47(a) incorporated by reference). ttr6 peimittee
shall have and maintain hazardous waste liability coverage for sudden accidental(rccurrences in the amount of at least one $1 million U.S. dollars per occurrence with
an annual aggegate of at least $2 million U.S. dollars, exclusive bf legal defensecosts. The Permittee shall submiq an apploved certificate of hazardous waste liability
insurance worded as required by UAC R315-8-8.
The Permittee shall demorntrate continuous conpliance with the requirenrcnts of UACR3l5-8-8 (40 CFR 2&J47(b) incorporated by reference) to have and mainainliability co-verage for non-sudden acCidental oocrurences arising from operations ofthe
two Hazardous Waste Management Units, designated as the M-136 and M-225 Therrnal
Treatment Areas.
Changes inliability coverage mechanisms shall be approved by the Director 60 daysprior to such a change.
a,:,..,,
ryq4P= .Agf,rx, qI owNER oR opERAroRs.FINANCIAL INSTITI.]TIONS
The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (,+0 CFR 2&J48 incorporated by reference).
ATK launch Systems Inc. - Promontory
Attachment 5 -Closure Plan
Modified Decembet-20-l_4 _
uTD009081357
Ddeted: Jmary
CLOSURE PLAI\ AND FINAI\CIAL 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.
tlwMVs
included in this document are: M-186; M-705S; E-501; M-l36;M-225;T-298; M-47, M-603
and 5-633.
The Closure Plan was developed to comply with R315-8-7 and R3l5-8-9.9 of the Utah
Administrative Code (UAC). UAC R3l5-8-7 incorporates by reference the requirements of 40
CFR 264 Subpart G. The closure cost estimates were made in accordance with UAC R3l5-8-8,
which incorporatgs by reference the requirernents of40 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 caro, and are covered in our Post
Closure Permit.
1.0 Closure Plans [40 CFR 270.14(b)(13),270.23(s)(2), and 26a'Il2(t)(l) & (2) and UAC
RIf l5-3, Rt15-81
This Closwe Plan identifres Ssfrhd q!9pq ry_"4p!_!_o ctsse C!_ofeg9 qp-q qg4lqgqt &qlltiqq, q_s
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.lll and UAC R3f5.&71
Closure standards specified under RCRA are desiped 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
residsntial risk based levels, as outlined in UAC R3l5-101, 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 puiposes 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 R3l5-l0l-6(cxl). All closures will
assess real and reasonably likely impacts to human and ecological exposures.
=1..'-
,-1,,1 I .::...1:
ATK l:unch Systems Inc. - Promontory
Attachment 5 - Closue Plan
Modified Decembe!.2014
uTD00908t357
Deleted: Jmuary
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 R3l5-
l0l-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)(l) through (b)(7)
and UAC R-315-8-71
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. ,.Qglqi&4]plgllL&LQlesing perdtted..&cilities have been submitted to.the Division. and
are maintained as nart of the facility operatins record.
Soil monitoring has been conducted at the M-I36 andM-225 bum 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
rurs-8-71
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 Standar d, 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)
M-705S (inert) ------
E-501 (inert)
M-136 (live)
M-225 (live)
T-29B (inert)
M-47 (live)
M-603 (live)
5-633 (live)
400 ea.55 gallon drum equivalent
32 ea. 55 gallon drum equivalent
160 ea. 55 gallon drum equivalent
106,500 lbs I .3 / 20,000 lbs I . 1
55,000lbs 1.3 / l,500lbs 1.1
I ea. 55 gallon drum (pure) equivalent
300,000 lbs 1.3 / 21,000 lbs 1.1
120,000 lbs 1.3 / 8,000 lbs l.l
75,000 lbs 1.3/20,000 lbs l.l
Coilnc||t pV3I! Should'!lans" be replaed
with "cost cstieteaT' Daailed plru m *bmittcdwta it is d€cidcdto clo* a llWM{J.
t eleted: Details for closing pmitted faciliries are
provided in Tables I through 8.
Cfirdft pval: Cmidq adding smthinglika Dcrailodpltr ftr closing €.i H!ilMUwill begubmincd in rcmdae with Pmit CmditionmJ2.
ATK kunch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified Drcembct 2014
uTD009081357
ATK treats reactive hazardous wastes on-site at the M-136 andM-225 open buming 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 R3f 5-8-71
Section I .4. I 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 accorffnodate 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(t) 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 (l) 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
modihcation 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 and264.ll4 and UAC R315-8-71
All permitted treatment and storage facilities have been designed and managed to minimize
possible contamination. This includes chemical resistant concrete coatings, blind containment
sumps, regular inspections, regular maintenance, and prompt clean up of any spilled materials.
These practices should greatly reduce the need for significant remediation efforts upon closure.
1.5.1 Soil and Groundwater Sampling
Groundwater sampling is not covered under this plan. A groundwater monitoring program is
currently in place as discussed above. Soil sampling should not be required for any ofthe
permitted facilities, except for the two burn ground areas (M-136 and M-225) and 5-633.
Soil samples will be collected within the top 12" of the surface.l Samples will first be collected al
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, [welve soil samples will be
collected atM-225 and eight soil samples will be collected at 5-633. These samples will be sent
m
Comms* Pvslr I don't think this lev€l of (bail
is appropriate bre. Plee onsida omething like:
Detailed wpling ples win be $bmitted in
rcordrue with Pmit Condition IIIJ.2.
Co|nm€nt [tv6l: cw6t cost €stimate indicates
only 5 wpl* will be coll@ted. This k a chege
we should dism.
ATK l:unch System Inc. - Promontory
Attachment 5 - Closure Plan
Modified Decembe! 2014
uTD009081357 ffi
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.
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 R3l5 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
ofclosure, and in consultation with tndustrial Hygiene professionals.
Analytical and Exfraction Methods
Parameter Analytical procedure Extraction Procedure
Volatiles SW-846:82608 SW-846: 50308(w). 5035S
Semi-Volatiles SW-846;8270C SW-846; 35 I OC(W), 3550(S)
RCRA Metals SW-846:6010B SW-846; 3005A(W),747 lA(S)
Mercury SW-846;7470N7471A SW-846:7470A(W). 747 lA(S)
Explosives SW-846:8330 Modified SW-846: 8330 Modified
Perchlorate EPA 314.0 EPA 314.0
ATK kunch Systems Inc. - Promontory
Attachment 5 - Closue Plan
Modified Decembei 2014
t1TD009081357
Soil sampling should only be required at the bum 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 R3l5-l0l-6(cXl). 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(bX3) and UAC R315-8-71
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 ofa 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 Disposat or Decontamination of Equipment and Structures [40 CFR 264.112(b)(4),
264,112(e\, and 264.114 and UAC R:l 15-8-71
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 buming facilities use bum 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 healy 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 I .5 ' I .
m
ATK kunch System Inc. - Promontory
Attachment 5 - Closue Plan
Modified Decenbet 2014
uTD009081357
All facilities except for M-136, M-225 and, 5-633 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. lAfter removal of all containerized waste, the containment pads will
be high presswe 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.
f .5.3.3 Closure Containers [40 CFR 264.178,264.112(b)(3). and 270.14(b)(E) and UAC
R315-8-9.9, R315-807, and R315-3-5@Xf3)l
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.tt5 and UAC Kf5-8-71
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 264.1421
@!'!'laintainEd jn thegp=qrati!=rg.record. Closure cost estimates are.based
on usine a third party except for the thermal treatment and disposal ofieaciive waite whiCh will
be conducted on site.4.0 Financial Assurance Mechanism for closure t40 cFR 264.143 and Riil15-3091
ATK will maintain current lurancial 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 R3l5-g-g 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.
m
coanltEnt [ty4: ATK doe$'r plm to pr€sw
wadt flors at M-47 od M{03 if I'm mt mistakq
Wc might wilt to r€vie this laguagc to avoidpotatidpmitmod.t t r.
Comment [tYtI3 Wewsld like to add: -Once
apprcved by thc Dirwtor," ro rh€ begimirg of thisffi|lnc,
Deleted: Closure costs are ilm{ized in Table 9.
A detailed blmkdoM ofthese costs is orovided in
Tables I rhrough 8. The entire estimate is based onhiring a third party, except for the thmal teatrnent
md dislrcsl of reactive waste, which will be hmdled
onsite.!l
ATK Launch Systems Inc. Promontory
Attachment 5 -Closure Plan
Modifi ed lluct'rlb,e1, 20 I 4
urD00908 I 357 l-9-.!.!4.rq*o I
I
lt...lLU
Deleted: Table lll
Nl-136 Closure
tlItem No.
Cost Estimatel'
7: tU DdM €ooctl LU2rlmt.49:10:0OAl,l
Table 1
M-136 Closure Cost Estimater
Item No.Description Means No./Source Units Est. Quan.Unit Price TotalPrice
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
Site prep (ClH)
Site prep (technician)
Treat remaining waste
Excavate contaminated soil
Load soil and burned waste
Haulwaste and soilto Clean
Harbors
Landfill disposal, waste and soil
State disposalfee, waste and soil
Steam clean burn pans
Load rinsate
Haul rinsate to Clean Harbors3
Landfill disposal, rinsate3
State disposal fee, rinsate3
Demolish pans
Load pan debris
Haul pan debris to Clean Harbors
Landfill disposal, pan debris
State disposalfee, pan debris
Sample collection
Sample analyses, metals
Sample analyses, explosives
Samole analvses. volatiles
33-22-0111x2
33-22-0112x2
ATK
17-O3-O231
17-03-0222
33-19-0221
33-19-72't4
Utah DEQ
33-17-0812
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
17-02-0105
17-03-0222
33-19-0221
33-19-7263
Utah DEQ
Site crew
Chemtech-Ford
Chemtech-Ford
Chemtech-Ford
hr
hr
tb
hr
hr
truck-mi
ton
ton
sf
drum
truck-mi
drum
ton
cf
hr
truck-mi
ton
ton
hr
ea
ea
ea
20
40
106,500
20
8
1,050
50
50
1,000
5
350
5
1
2,000
4
350
50
50
40
20
20
20
83.44
50.96
0.25
105.63
68.13
2.50
169.45
32.50
0.39
4.87
2.26
145.00
28.00
0.14
68.13
2.50
169.45
32.50
65.00
210.00
210.00
250.00
1,669
2,O39
26,625
2,113
545
2,625
8,473
1,625
280
273
875
8,473
1,625
2,600
4,200
4,200
5.000
390
24
791
725
28
SUBTOTAL
INFLATION ADJUSTMENT=1 .2042
75,196
90.536
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Eng i neeri n g/perm itting
DSHW oversight
Contingency
4,527
9,054
9,054
9.054
5
10
10
10
o/o
o/o
o/o
Yo
TOTAL ESTIMATED COST 122.225
Table 2
M-225 Closure Cost Estimater
Item No.Descriotion
Means
No./Source Units Est. Quan.Unit Price TotalPrice
1
2
3
4
5
6
7I
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Site prep (ClH)
Site prep (technician)
Treat remaining waste
Excavate contaminated soil
Load soiland burned waste
Haulwaste and soilto Clean Harbors
Landfill disposal, waste and soil
State disposalfee, waste and soil
Steam clean burn pans
Load rinsate
Haul rinsate to Clean Harbors3
Landfill disposal, rinsate3
State disposal fee, rinsate3
Demolish pans
Load pan debris
Haul pan debris to Clean Harbors
Landfill disposal, pan debris
State disposalfee, pan debris
Sample collection
Sample analyses, metals
Sam ple analyses, explosives
Sample analvses, volatiles
33-22-0111x2
33-22-0112x2
ATK
17-03-0231
17-03-0222
33-19-0221
33-19-7214
Utah DEQ
33-17-0812
33-19-0103
33-19-0243
33-19-72',14
Utah DEQ
17-02-0105
17-O3-O222
33-19-0221
33-19-7263
Utah DEQ
Site crew
Chemtech-Ford
Cherntech-Ford
Chemtech-Ford
hr
hr
tb
hr
hr
truck-mi
ton
ton
sf
drum
truck-mi
drum
ton
cf
hr
truck-mi
ton
ton
hr
ea
ea
ea
8
20
55,000
12
4
350
25
25
400
3
350
3
1
800
4
350
20
20
20
12
12
12
83.44
50.96
.025
105.63
68.13
2.50
169.45
32.50
0.39
4.87
2.26
145.00
28.00
0.14
68.13
2.50
169.45
32.50
65.00
210.00
210.00
250.00
668
1,019
13.750
1,269
273
875
4,236
813
156
15
791
43s
28
112
273
875
3,389
650
1,300
2,520
2,520
2,520
38.084
45,853
SUBTOTAL
INFLATION ADJUSTMENT = 1.2042
Misc. costs as a percent of the inflation-adjusted
Subtotal:
Mob/demob
Engineering/perm itting
DSHW oversight
Continoencv
5
10
10
10
o/o
o/o
o/o
o/o
2,293
4,585
4,585
4,585
TOTAL ESTIMATED COST 61,901
Table 3
M-47 Closure Cost Estimatel
Item
No.Descriotion
Means
No./Source Units
Est.
Quan.Unit Price
Total
Price
1
2
3
4
5
6
I
10
1'l
12
13
14
15
16
17
18
Materials prep (ClH)
Materials prep (technician)
Load waste motor (crane)
Haul motor to burning ground
Off-load motor
Handling evaluation/planning
Motor handling
Disposal at burning ground
Sweep area
Steam clean floor
Load rinsate/sweepings
Load drums
Haulto Clean Harbors
State disposalfee
Sample collection
Samole analvses. metals/exo
33-22-0111x2
33-22-0112x2
Crew SIWSM
Crew COET2
Crew SIWSM
Site personnel
Site personnel
ATK
33-22-0112x2
33-17-0812
33-19-0103
33-19-0103
33-19-0243
Utah DEQ
33-22-0112x2
Chemtech-Ford
hr
hr
hr
hr
hr
hr
hr
lb
hr
sf
drum
ea
truck-mi
ton
hr
ea
12
20I
16
8
80
40
300,000I
5,680
10
10
350
1
4
2
83.44
31.58
393.57
93.31
393.57
65.00
65.00
0.25
31.58
0.39
4.87
3.05
2.26
28.00
31.58
210.00
1,001
632
3,149
1,493
3,149
5,200
2,600
75,000
253
2,215
49
31
791
28
126
420
SUBTOTAL
INFLAT]ON ADJUSTMENT = 1.2042
96,135
115.747
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineerin g/perm itting
DSHW oversight
Contingency
5
10
10
10
%
o/o
o/o
o/o
5,787
11,575
11,575
11.575
TOTAL ESTIMATED COST 156.258
Table 4
M-603 Closure Cost Estimater
Item
No.Descriotion
Means
No./Source Units
Est.
Quan.Unit Price
Total
Price
1
2
3
4
5
6I
10
11
12
13
14
15
16
17
18
Materials prep (ClH)
Materials prep (technician)
Load waste motor (crane)
Haul motor to burning ground
Off-load motor
Handling evaluation/planning
Motor handling
Disposal at burning ground
Sweep area
Steam clean floor
Load rinsate/sweepings
Load drums
Haul to Clean Harbors
State disposalfee
Sample collection
Sam ole analvses. metals/exo
33-22-0111x2
33-22-0'112x2
Crew SIWSM
Crew COET2
Crew SIWSM
Site personnel
Site personnel
ATK
33-22-0112x2
33-17-0812
33-19-0103
33-1 9-01 03
33-19-0243
Utah DEQ
33-22-0112x2
Chemtech-Ford
hr
hr
hr
hr
hr
hr
hr
tb
hr
sf
drum
ea
truck-mi
ton
hr
ea
8
't2
8
12I
40
20
120,000
8
1,930
4
4
350
1
4
2
83.44
31.58
393.57
93.31
393.57
65.00
65.00
o.25
31.58
0.39
4.87
3.05
2.26
28.00
31.58
210.00
668
379
3,149
1j20
3,149
2,600
1,300
30,000
253
714
19
12
791
28
126
420
44,727
53,851
SUBTOTAL
INFLATION ADJUSTMENT = 1.2042
2,693
5,385
5,385
5.385
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/perm itting
DSHW oversight
Continoencv
5
10
10
10
o/o
%
%
o/o
72.699TOTAL ESTIMATED COST
Table 5
M-186A Closure Cost Estimater
Item
No.Description
Means
No./Source Units
Est.
Quan.Unit Price
Total
Price
1
2
3
4
5
6
7
8
9
10
11
Site prep (ClH)
Site prep (technician)
Load drums
Hauldrums to Clean Harbors
Landfilldisposal
State disposalfee
Truck washouUdecon
Steam clean floor
Rinsate sample collection
Sample analyses, metals
Sample analvses. exolosives
33-22-0111x2
33-22-01'12x2
33-19-0103
33-19-0243
33-19-72't4
Utah DEQ
33-19-031 1
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
8
24
400
1,750
400
100
1
1,930
4
1
1
83.44
31.58
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
668
758
1,220
3,955
58,000
2,800
158
753
260
210
210
SUBTOTAL 68,991
INFLATION ADJUSTMENT = 1.2042 83,065
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/perm itting
DSHW oversight
Contingency
5
10
10
10
o/o
%
%
o/o
4,153
8,307
8,307
8.307
TOTAL ESTIMATED COST 112.138
Table 6
M-705S Closure Cost Estimatel
Item
No.Description
Means
No./Source Units
Est.
Quan.Unit Price
Total
Price
1
2
3
4
5
6
7
8
I
10
11
Site prep (ClH)
Site prep (technician)
Load drums
Haul drums to Clean Harbors
Landfilldisposal
State disposalfee
Truck washouVdecon
Steam clean floor
Rinsate sample collection
Sample analyses, metals
Samole analvses. exolosives
33-22-0111x2
33-22-0112x2
33-1 9-01 03
33-19-0243
33-19-72't4
Utah DEQ
33-19-031 1
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
4
I
32
350
32
8
1
1,850
4
1
1
83.44
31.58
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
334
253
98
791
4,640
224
158
722
260
210
210
SUBTOTAL
INFLATION ADJUSTMENT = 1.2042
7,899
9,510
5
10
10
10
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineerin g/perm itting
DSHW oversight
Continoencv
%
%
o/o
o/o
475
951
951
951
TOTAL ESTIMATED COST 12,838
Table 7
E-501 Closure Cost Estimater
Item
No.Description
Means
No./Source Units
Est.
Quan.Unit Price
Total
Price
1
2
3
4
5
6
7
I
9
10
11
Site prep (ClH)
Site prep (technician)
Load drums
Haul drums to Clean Harbors
Landfilldisposal
State disposalfee
Truck washouUdecon
Steam clean pad
Rinsate sample collection
Sample analyses, metals
Samole analvses. exolosives
33-22-011'l x2
33-22-0112x2
33-19-0103
33-19-0243
33-',t9-7214
Utah DEQ
33-19-031 1
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
4
8
160
700
160
40
1
1,760
4
1
1
83.44
31.58
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
334
253
488
1,582
23,200
'1 ,120
158
686
260
210
210
28,501
34.315
SUBTOTAL
INFLATION ADJUSTMENT = 1.2042
5
10
10
10
1,716
3,431
3,431
3.431
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/perm ift ing
DSHW oversight
Contingency
o/o
%
%
%
46.325TOTAL ESTIMATED COST
Table 8
T -2gB Closure Cost Estimatel
Item
No.Description
Means
No./Source Units
Est.
Quan.Unit Price
Total
Price
1
2
3
4
5
6
7
8
I
10
11
12
13
Site prep (ClH)
Site prep (technician)
Extra drum for dilution
Transfer and dilute hydrazine
Load drums
Haul drums to Clean Harbors
Landfill disposal
State disposalfee
Truck washouUdecon
Steam clean floor
Rinsate sample collection
Sample analyses, metals
Samole analvses, exolosives
33-22-0111x2
33-22-0112x2
33-19-0402
Site crew
33-19-0103
33-19-0243
33-19-7214
Utah DEQ
33-19-031 1
33-17-0812
Site crew
Chemtech-Ford
Chemtech-Ford
hr
hr
ea
hr
ea
truck-mi
drum
ton
ea
sf
hr
ea
ea
4
8
1
4
2
350
2
1
1
200
4
1
1
83.44
31.58
80.00
65.00
3.05
2.26
145.00
28.00
158.00
0.39
65.00
210.00
210.00
334
253
80
260
6
791
290
28
158
78
260
210
210
2,958
3,561
SUBTOTAL
INFLATION ADJUSTMENT = 1.2042
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineering/perm itting
DSHW oversight
Continqencv
5
10
10
10
178
356
356
356
%
o/o
o/o
o/o
4,807TOTAL ESTIMATED COST
Table 9
5-633 Closure Cost Estimater
Closure Cost Estimate Footnotes:
I 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-l36 and M-zzsbeing 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
2
3
4
5
6
7
Site prep (ClH)
Site prep (technician)
Disposal at Burning Ground
Sample Collection
Sample analyses, metals
Sample analyses, explosives
Sam ple analyses, volatiles
33-22-0111x2
33-22-0112x2
ATK
Site crew
Chemtech-Ford
Chemtech-Ford
Chemtech-Ford
hr
hr
hr
tb
ea
ea
ea
4
8
75,000
I
I
I
8
83.44
50.96
0.25
65.00
210.00
210.00
210.00
334
253
18,750
520
1,680
1,680
1,680
SUBTOTAL 24,897
INFLATION ADJUSTMENT = 1.2042 29.976
Misc. costs as a percent of the inflation-adjusted subtotal:
Mob/demob
Engineerin g/perm itting
DSHW oversight
Contingency
5%
10%
10 o/o
10 o/o
1,499
2,997
2,997
2,997
TOTAL ESTIMATED COST 40,468
Teble 10
Summary of Closure Cost Estimetes
Hazardous Waste ManaeemeNrt Unit Estimated Cost ($)
M-l36 122.225
M-225 61.901
I.l47 t56.258
M-603 72,699
M-l86 lr2,l38
M705S 12.838
E-501 46.325
T29B 4,807,
s-633 40,468
Total 629.6s9
Comments on Closure Cost Estimate Tables Submitted September 2912014
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? 5 samples may not be
adequate to characterize theM-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
Should landfill disposal costs be added to the M-47 Table under Item No. l5 ("Haul to Clean
Harbors") for disposal of 10 rinsate/sweepings drums?
M-603 Closure Cost Estimate
Should landfill disposal costs be added to the M-603 Table under Item No. 15 ("Haul to Clean
Harbors") for disposal of 4 rinsate/sweepings drums?
M-186 Closure Cost Estimate
Should the line items load rinsate/sweepings,load drums, haul to Clean Harbors, landfill
disposal, and state disposal fee be added to the M-186 Table under Itern 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. I 1.
M-705S Closure Cost Estimate
Should the line items load rinsate/sweepings,load drums, haul to Clean Harbors,landfill
disposal, and state disposal fee be added to the M-705S Table under Itern No. 8? Based on the
cost estimates for other HWMUs at Promontory, it appears that these iterns are missing.
In addition, it appears that sample analyses for VOCs should be added to the table under Item
No. I l.
E-501 Closure Cost Estimate
Should the line items load rinsate/sweepings, load drums, haul to Clean Harbors, landfill
disposal, and state disposal fee be added to the E-501 Table under Itern No. 8? Based on the cost
estimates for other HWMUs at Promontory, it appears that these iterns are missing.
In addition, it appears that sample analyses for VOCs stould be added to the table under Itern
No. 11.
T-29B Closure Cost Estimate
Should the line items load rinsate/sweepings, load dnrms, haul to Clean Harbors, landfill
disposal, and state disposal f,ee be addd to the T-298 Table rmder Item No. l0? Based on:the
cost estimates for other HWMUs at Promontory it appears that these iterns 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 atT-298? -