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HomeMy WebLinkAboutDSHW-2015-002783 - 0901a068804f2707February 6, 2015 8200-FY15-071 Mr. Scott T. Anderson, Director UL State of Utah Department of Environmental Quality Division of Solid and Hazardous Waste 195 N.1950W. P.O. Box 144880 Salt Lake City, Utah 84114-4880 Re: ATK Launch Systems-Promontory EPA ID number UTD009081357*^ Request for Closure Plan for Hazardous Waste Storage Buildings M-47 and M- 603. Dear Mr. Anderson: ATK is requesting a Class 1 Permit Modification to Attachment 5 and Module II of Hazardous Waste Storage Permit EPA ID number UTD009081357. Changes are identified in the attached documents. These changes have been reviewed with the Utah Division of Solid and Hazardous Waste (UDSHW), and are being submitted as a Class 1 Modification. Revised closure cost estimates tables are also being submitted for approval. Following approval from the UDSHW, the closure cost estimates will then be maintained in the facility operating record. ATK submitted notice of their intent to close hazardous waste storage Buildings M-47 and M-603 on September 29, 2014. Also enclosed with this submittal, is a Closure Plan specific for Buildings M-47 and M-603 as required by permit condition III. J.2. This closure will be conducted in accordance with Attachment 5 of the Hazardous Waste Storage Permit. The UDSHW has been onsite to review and inspect these buildings and the Closure Plan has been discussed with the UDSHW. ATK will proceed with closing these buildings once approval is received. If you have questions regarding this correspondence, Please contact Blair Palmer at (435) 863-2430. Sincerely George E. Gooch, Manager Environmental Compliance cc: JeffVandel Closure Plan for Hazardous Waste Storage Buildings M-47 and M-603 ATK is requesting the closure of hazardous waste storage buildings M-47 and M-603. These building are not practical for storing hazardous waste since Building M-47 is currently used to store flight ready rocket motors and Building M-603 does not have accessible floor space for storage of hazardous waste. ATK will replace the storage capability of these two buildings with another building to be used for storage of reactive hazardous waste following this closure. The new building will be added to ATK's Hazardous Waste Storage Permit through another permit modification. Buildings M-47 and M-603 have had limited use for storage of hazardous waste. ATK has no record of ever storing hazardous waste in Building M-47. Inspection records for Building M-603 report that only solid reactive hazardous waste was stored for a two and a half week period in the spring of calendar year 2010. No liquid hazardous waste has ever been stored in these buildings. All storage Buildings at ATK have been designed and managed to minimize possible releases or contamination. ATK has no record of any spills or releases for these two storage buildings. Because Buildings M-47 and M-603 were never or rarely used to store solid reactive hazardous waste, and have no release or spill history, ATK recommends a closure method of sweeping the area to verify cleanliness, followed by a visual inspection looking for any solid reactive hazardous waste. In the very unlikely event that any solid reactive waste was found it would be containerized and treated appropriately at the M- 136 treatment area. This cleaning process will be documented appropriately and maintained in ATK's operating record. Once Buildings M-47 and M-603 have been closed, ATK will submit a certification by an independent engineer to UDSHW within 60 days. The current Attachment 5 closure plan and financial requirements contained in ATK's Hazardous Waste Storage Permit indicates that these Buildings will be high pressure water washed. ATK has discussed this with the UDSHW and it has been deemed not necessary since as discussed above, their history shows little or no use for storage of hazardous waste, and no history of liquid waste. Building M-47 also contains flight ready rocket motors and could not be high pressure water washed because of potential damage to the rocket motors and danger to personnel working around live motors with a high pressure source. The UDSHW has been onsite to review and inspect these buildings and the closure plan has been discussed with the UDSHW. Since these buildings were used either once or never to store hazardous waste and have had no reasonable potential to impact the environment, ATK believes the closure actions discussed above are appropriate. EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory E-501 closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Site prep (CIH) Site prep (technician) Load drums Haul drums to Clean Harbors Landfill disposal State disposal fee Truck washout/decon Steam clean pad Load rinsate/sweepings Load drums Haul to Clean Harbors Landfill disposal State disposal fee Rinsate sample collection Sample analyses, metals Sample analyses, volatiles Personal protective equipment 33-22-0111 x2 33-22-0112x2 33-19-0103 33-19-0243 33-19-7214 Utah DEQ 33-19-0311 33-17-0812 33-19-105 33-19-0103 33-19-0243 33-19-7214 Utah DEQ Site crew Chemtech-Ford Chemtech-Ford 16-02-916 hr hr ea truck-mi drum ton ea sf ea ea truck-mi drum ton hr ea ea ea 4 8 160 700 160 40 1 1,760 1 1 200 1 1 4 1 1 10 83.44 31.58 3.05 2.26 145.00 28.00 158.00 0.39 30.11 3.05 2.26 145.00 28.00 65.00 210.00 250.00 36.36 334 253 488 1,582 23,200 1,120 158 686 30 3 452 145 28 260 210 250 364 SUBTOTAL Jnflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 29,563 39,969 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 1,998 3,997 3,997 3,997 TOTAL ESTIMATED COST 53,958 EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory M-47 closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 Materials prep (CIH) 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 Load sweepings ATK landfill disposal Personal protective equipment SUBTOTAL 33-22-0111 x2 33-22-0112x2 Crew SIWSM Crew COET2 Crew SIWSM Site personnel Site personnel ATK 33-22-0112x2 33-19-0103 32-19-7201 16-02-916 hr hr hr hr hr hr hr lb hr ea ea ea 12 20 8 16 8 80 40 300,000 1 1 1 10 83.44 31.58 393.57 93.31 393.57 65.00 65.00 0.25 31.58 3.05 98.50 36.36 1,001 632 3,149 1,493 3,149 5,200 2,600 75,000 32 3 99 364 92,720 Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 125,357 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency O 7o 10 % 10 % 10 % 6,268 12,536 12,536 12,536 TOTAL ESTIMATED COST 169,232 EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory M-136 closure cost estimate Project*: UC-1022-01 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Site prep (CIH) Site prep (technican) Treat remaining waste Excavate contaminated soil Load soil and burned waste Haul waste and soil to Clean Harbors Landfill disposal, waste and soil State disposal fee, waste and soil Steam clean burn pans Load rinsate Haul rinsate to Clean Harbors Landfill disposal, rinsate State disposal fee, rinsate Demolish pans Load pan debris Haul pan debris to Clean Harbors Landfill disposal, pan debris State disposal fee, pan debris Sample collection Sample analyses, metals Sample analyses, explosives Sample analyses, volatiles Personal protective equipment 33-22-0111 x2 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 33-19-7214 Utah DEQ 17-02-0105 17-03-0222 33-19-0221 33-19-7263 Utah DEQ Site crew Chemtech-Ford Chemtech-Ford Chemtech-Ford 16-02-916 hr hr lb hr hr truck-mi ton ton sf drum truck-mi drum ton cf hr truck-mi ton ton hr ea ea ea ea 20 40 106000 20 8 1050 50 50 1000 5 350 5 1 2000 4 350 50 50 40 20 20 20 4 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 36.36 SUBTOTAL 75,216 Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 101,692 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob 5 % 5,085 Engineering/permitting 10 % 10,169 DSHW oversight 10% 10,169 Contingency 10 % 10,169 TOTAL ESTIMATED COST 137,285 EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory M-186 closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Site prep (CIH) Site prep (technician) Load drums Haul drums to Clean Harbors Landfill disposal State disposal fee Truck washout/decon Steam clean floor Load rinsate/sweepings Load drums Haul to Clean Harbors Landfill disposal State disposal fee Rinsate sample collection Sample analyses, metals Sample analyses, volatiles Personal protective equipment 33-22-0111 x 2 33-22-0112x2 33-19-0103 33-19-0243 33-19-7214 Utah DEQ 33-19-0311 33-17-0812 33-19-105 33-19-0103 33-19-0243 33-19-7214 Utah DEQ Site crew Chemtech-Ford Chemtech-Ford 16-02-916 hr hr ea truck-mi drum ton ea sf ea ea truck-mi drum ton hr ea ea ea 8 24 400 1,750 400 100 1 1,930 1 1 175 1 1 4 1 1 15 83.44 31.58 3.05 2.26 145.00 28.00 158.00 0.39 30.11 3.05 2.26 145.00 28.00 65.00 210.00 250.00 36.36 668 758 1,220 3,955 58,000 2,800 158 753 30 3 396 145 28 260 210 250 545 SUBTOTAL Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 70,178 94,881 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 4,744 9,488 9,488 9,488 TOTAL ESTIMATED COST 128,089 EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory M-225 closure cost estimate Project*: UC-1022-01 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Site prep (CIH) Site prep (technican) Treat remaining waste Excavate contaminated soil Load soil and burned waste Haul waste and soil to Clean Harbors Landfill disposal, waste and soil State disposal fee, waste and soil Steam clean burn pans Load rinsate Haul rinsate to Clean Harbors Landfill disposal, rinsate State disposal fee, rinsate Demolish pans Load pan debris Haul pan debris to Clean Harbors Landfill disposal, pan debris State disposal fee, pan debris Sample collection Sample analyses, metals Sample analyses, explosives Sample analyses, volatiles Personal protective equipment 33-22-0111 x 2 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 33-19-7214 Utah DEQ 17-02-0105 17-03-0222 33-19-0221 33-19-7263 Utah DEQ Site crew Chemtech-Ford Chemtech-Ford Chemtech-Ford 16-02-916 hr hr lb hr hr truck-mi ton ton sf drum truck-mi drum ton cf hr truck-mi ton ton hr ea ea ea ea 8 20 55,000 12 4 350 25 25 400 3 350 3 1 800 4 350 20 20 20 8 8 8 4 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 36.36 668 1,019 13,750 1,268 273 875 4,236 813 156 15 791 435 28 112 273 875 3,389 650 1,300 1,680 1,680 2,000 145 SUBTOTAL 36,429 Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 49,252 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 10 % 2,463 4,925 4,925 4,925 TOTAL ESTIMATED COST 66,490 EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory M-603 closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 Materials prep (CIH) 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 Load sweepings ATK landfill disposal Personal protective equipment 33-22-0111 x2 33-22-0112x2 Crew SIWSM Crew COET2 Crew SIWSM Site personnel Site personnel ATK 33-22-0112x2 33-19-0103 32-19-7201 16-02-916 hr hr hr hr hr hr hr lb hr ea ea ea 8 12 8 12 8 40 20 120,000 1 1 1 8 83.44 31.58 393.57 93.31 393.57 65.00 65.00 0.25 31.58 3.05 98.50 36.36 SUBTOTAL 42,787 Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 57,848 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob 5 % 2,892 Engineering/permitting 10 % 5,785 DSHW oversight 10 % 5,785 Contingency 10 % 5,785 TOTAL ESTIMATED COST 78,095 EarthFax Engineering Group, LLC Cost Estimate Project: ATK - Promontory M-705S closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Site prep (CIH) Site prep (technician) Load drums Haul drums to Clean Harbors Landfill disposal State disposal fee Truck washout/decon Steam clean floor Load rinsate/sweepings Load drums Haul to Clean Harbors Landfill disposal State disposal fee Rinsate sample collection Sample analyses, metals Sample analyses, volatiles Personal protective equipment 33-22-0111 x2 33-22-0112x2 33-19-0103 33-19-0243 33-19-7214 Utah DEQ 33-19-0311 33-17-0812 33-19-105 33-19-0103 33-19-0243 33-19-7214 Utah DEQ Site crew Chemtech-Ford Chemtech-Ford 16-02-916 hr hr ea truck-mi drum ton ea sf ea ea truck-mi drum ton hr ea ea ea 4 8 32 350 32 8 1 1,850 1 1 200 1 1 4 1 1 6 83.44 31.58 3.05 2.26 145.00 28.00 158.00 0.39 30.11 3.05 2.26 145.00 28.00 65.00 210.00 250.00 36.36 334 253 98 791 4,640 224 158 722 30 3 452 145 28 260 210 250 218 SUBTOTAL Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 8,815 11,918 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 10 596 1,192 1,192 1,192 TOTAL ESTIMATED COST 16,089 Earth Fax Engineering Group, LLC Cost Estimate Project: ATK - Promontory S-633 closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 Materials prep (CIH) Materials prep (technician) Disposal at burning ground Sample collection Sample analyses, metals Sample analyses, explosives Sample analyses, volatiles Personal protective equipment 33-22-0111 x2 33-22-0112x2 ATK Site crew Chemtech-Ford Chemtech-Ford Chemtech-Ford 16-02-916 hr hr lb hr ea ea ea ea 4 8 75,000 8 8 8 8 8 83.44 31.58 0.25 65.00 210.00 210.00 250.00 36.36 SUBTOTAL 25,507 Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 34,486 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob 5 % 1,724 Engineering/permitting 10 % 3,449 DSHW oversight 10 % 3,449 Contingency 10 % 3^449 TOTAL ESTIMATED COST 46,556 Earth Fax Engineering Group, LLC Cost Estimate Project: ATK - Promontory T-29B closure cost estimate Project*: UC-1023-18 Estimator: RB White Date: 3-Feb-15 Costs: Means 2005 Environmental Remediation Cost Data, adjusted for inflation, except as otherwise noted Assume Level C PPE Item No. Description Means No./Source Units Est. Quan. Unit Price Total Price 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Site prep (CIH) Site prep (technician) Extra drum for dilution Transfer and dilute hydrazine Load drums Haul drums to Clean Harbors Landfill disposal State disposal fee Truck washout/decon Steam clean floor Load rinsate/sweepings Load drums Haul to Clean Harbors Landfill disposal State disposal fee Rinsate sample collection Sample analyses, volatiles Personal protective equipment 33-22-0111 x2 33-22-0112x2 33-19-0402 Site crew 33-19-0103 33-19-0243 33-19-7214 Utah DEQ 33-19-0311 33-17-0812 33-19-105 33-19-0103 33-19-0243 33-19-7214 Utah DEQ Site crew Chemtech-Ford 16-02-916 hr hr ea hr ea truck-mi drum ton ea sf ea ea truck-mi drum ton hr ea ea 4 8 1 4 2 350 2 1 1 200 1 1 175 1 1 4 1 4 83.44 31.58 80.00 65.00 3.05 2.26 145.00 28.00 158.00 0.39 30.11 3.05 2.26 145.00 28.00 65.00 250.00 36.36 334 253 80 260 6 791 290 28 158 78 30 3 396 145 28 260 250 145 SUBTOTAL Inflation adjustment (see Means 2015 Heavy Construction Cost Data) 1.352 3,535 4,779 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 239 478 478 478 TOTAL ESTIMATED COST 6,451 Summary of Closure Cost Estimates HWMU E-501 M-47 M-136 M-186A M-225 M-603 M-705S S-633 T-29B Revised Estimate 53,958 169,232 137,285 128,089 66,490 78,095 16,089 46,556 6,451 TOTAL $ 702,245 $ 670,382 I ATK Launch Systems toe. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 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.I, and UAC R315-3-3. l(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 the 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 1.0.3. 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 1. l I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 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 time that the 2 ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 II.F.3. II.F.4. II.F.5. II.G. n.G.i. n.G.l.a. n.G.l.b. n.G.i.c. n.G.l.d. ILG.l.e. n.G.i.f. n.G.i.g. II.G.2. 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. 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. 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. Records of inspections shall be kept as required by UAC R315-8-2.6(d). RISK THRESHOLDS 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 E.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: Sampling Results for Emissions Characterization of Open Burning Waste Propellant Materials, October 2009; 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; 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; The Waste Characterization and Air Dispersion Modeling Report, to be completed in accordance with Condition IV.M.l. The Human Health Risk Assessment Protocol for OB/OD Operations at the ATK Promontory Facility, February 2010; 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 The Human Health Risk Assessment Report, to be completed in accordance with Condition 1V.M.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 3 I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 H.G.3. n.G.3.a. II.G.3.b. n.G.3.c. n.G.3.d. II.G.4. H.G.5. II.H. II.H.l. II.H.2. II.H.3. 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. 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: 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; The estimated quantity of TCDD TEQs, or other compounds as identified in accordance with Condition H.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. 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 n.G.3.a., or if the emission factors need to be updated; and A review of the of the human health risk assessment, identified in Condition II.G.l .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. 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. 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. PERSONNEL TRAINING 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. 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. 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 Training Plan in Attachment 3. These records shall indicate the type and amount of training received. 4 I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 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. ILL GENERAL REQUIREMENTS FOR IGNITABLE. REACTIVE. OR INCOMPATIBLE WASTE 11.1.1. The Permittee shall comply with the requirements of UAC R315-8-2.8. 11.1.2. 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. ILK. PREPAREDNESS AND PREVENTION U.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. ILKA The Permittee shall maintain records of the preventative maintenance and repair activities specified in Condition II.K.3. and shall keep schedules, reflecting mimmum 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 UACR315-8-3.5. 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. ILL. CONTINGENCY PLAN 5 I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 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. MANIFEST 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. II.O. CLOSURE/POST-CLOSURE 6 I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 II.0.1. The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101 and Attachment 5. II.0.2. 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. ILO.3. The Permittee shall amend the closure/post-closure plan in accordance with UAC R315- 8-7 and Condition LD. whenever necessary, or when required to do so by the Director. II.0.4. 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 LD. II.0.5. 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.0.6. 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.0.7. 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.0.8. 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 soil, 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 LD. 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.0.9. 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. 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 7 I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 reference) and Attachment 5. II.P.2. On the one year anniversary date of Permit issuance, tho Permittee shall submit to the Director for approval updated closure plans and detailed closure cost estimates for oaoh HWMU at the ATK facility. By July 30 of each calendar year, the Permittee shall adjust the closure cost estimate for 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. 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). 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 LD. to the Director 90 days 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 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. FINANCIAL ASSURANCE FOR FACILITY CLOSURE 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 in 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. 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. 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.0.2. Intontionallv Blank II.Q.32. The Permittee shall revise the financial assurance for facility closure wheneverclosure whenever there is a change in the facility's closure plan that would change the cost 8 II.P.3. II.P.4. II.P.5. II.Q. II.O.l I ATK Launch Systems Inc. - Promontory Module II - General Facility Conditions Modified JanuarvFebruarv. 20145 UTD009081357 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.2-3. Changes in liability coverage mechanisms shall be approved by the Director 60 days prior to such a change. ELS. INCAPACITY OF OWNER OR OPERATORS. GUARANTORS. OR FINANCIAL INSTITUTIONS U.S. 1. The Permittee shall comply with the notification and financial requirements of UAC R315-8-8 (40 CFR 264.148 incorporated by reference). 9 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruary. 20145 UTD009081357 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 detailod in this PlanClosure Cost estimates are maintained in the Operating Record once approved by the Director. 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 LTT As 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 the generalall 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 1 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 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. 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 maybe 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 each HWMU will be submitted in accordance with Permit Condition III.J.2.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 2 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 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 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 upcleanup 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. 3 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Detailed sampling plans will be submitted in accordance with Permit Condition III.J.2.Seit 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, twelveeight soil samples will be collected at M-225 and eight soil samples will be collected at S-633. These samples will be sent 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; 601 OB 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 containerized and sent offsite for treatment or disposal 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. 4 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 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. 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)(l). 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 5 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 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. 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 liquid chemical containment pads of facilities E-501. M-186, M-705S, and T-29B 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 once approved by the Director. 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 6 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 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. Table 1 M 136 Closure Cost Estimate* 7 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Item h Or Description Means No./Source UfHte Est. Quan. Unit Price Total Price 4 Sito prop (CIH) 2 Site prep (technician) 3 Treat remaining waste 4 Excavate contaminated soil § Load soil and burned waste Haul waste and 6oil to Clean 6 Harbors 7 Landfill disposal, waste and soil State disposal fee, waste and soil 9 Steam clean burn pans 40 Load rinsate 44 Haul rinsate to Clean Harbors3 42 Landfill disposal, rinsate3 43 State disposal fee, rinsate3 44 Demolish pans 4-§ Load pan debris 40 Haul pan debris to Clean Harbors 47 Landfill disposal, pan debris 40 State disposal fee, pan debris 40 Sample collection 20 Sample analyses, metals 24 Sample analyses, explosives 221 Sample analyses, volatiles 33 22 0111 x 2 33 22 0112x2 ATK 17 03 0231 17 03 0222 33 10 0221 33 19-7214 Utah DEQ 33 17 0812 33 10 0103 33 10 0243 33 10 7214 Utah DEQ 17 02 0105 17 030222 33 19 0221 33 10 7263 Utah DEQ Site crew Chemtech Ford Chemtech-Ford Chemtech-Ford RF hr lb hr hr truck-mi sf drum truck-mi drum Of hr truck-mi hf ea ea ea -20 -40 106,500 20 -8 4,050 §0 -50 4^00 5 -350 -4 2r000 4 -350 -50 -50 -40 -20 -50 -20 8344 5&06 Q 25 105.63 §840 2 5Q 16945 32£0 Q 39 4^7 145.00 2&00 044 0840 2 5Q 169.45 32^50 6540 210.00 210.00 250.00 4^09 2,038 26,625 2440 5/] 5 2,025 8473 4r§2§ 300 24 794 725 28 oop 273 8473 4^25 2r§00 4500 4500 5r000 SUBTOTAL 75,106 INFLATION ADJUSTMENT-1.20^ 00,536 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 4,527 0,054 0,054 0,054 TOTAL ESTIMATED COST 122,225 Table 2 M 225 Closure Cost Estimate* 8 4 2 3 4 § 6 7 8 9 40 44 42 40 44 40 40 47 40 40 20 24 22 ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Description Means No./Source Unite Est. Quan. Unit Price Total Price Site prep (CIH) Site prep (technician) Treat remaining waste Excavate contaminated soil Load soil and burned waste Haul waste and soil to Clean Harbors Landfill disposal, waste and soil State disposal fee, waste and 6oil Steam clean burn pan6 Load rinsate Haul rinsate to Clean Harbors3 Landfill disposal, rinsate3 State disposal fee, rinsate3 Demolish pan6 Load pan debris Haul pan debri6 to Clean Harbors Landfill disposal, pan debris State disposal fee, pan debris Sample collection Sample analyses, metals Sample analyses, explosives Sample analyses, volatiles 33 22 0111 x 2 33-22 0112x2 17 03 0231 17 03 0222 33 10 0221 33 10 7214 Utah DEQ 33 17 0812 33-19 0103 33 10 0243 33 10 7214 Utah DEQ 17 02 0105 17 03 0222 33 10 0221 33 10 7263 Utah DEQ Site crew Chemtech-Ford Chemtech-Ford Chemtech-Ford nr- hf lb Ftf hr truck-mi toft Sf drum truckmi drum of hr- truck-fFH toft toft hr ea ea ea -8 -50 55,000 42 -350 -25 -25 -400 -350 -800 -350 -20 -20 -20 42 42 42 33 y\/\ mm 025 105.63 0840 2 5Q 160.45 32^0 0 3Q 4^87 2T2§ 145.00 2&O0 044 6840 25Q 1694 5 32T50 65=00 210.00 210.00 250.00 068 4^40 13.750 4508 273 4536 840 I VV 45 794 ^135 28 445 273 8=388 050 4^00 2,520 2^520 2,520 SUBTOTAL 38,084 INFLATION ADJUSTMENT - 1.204a 45,853 Misc. costs as a percent of the inflation-adjusted Subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 2503 4,505 A gag I , VJKJKJ 4=585 TOTAL ESTIMATED COST 61,001 Table 3 M 47 Closure Cost Estimate* 9 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Description Means No./Source Unjte list Quan. Unit Price Prico 4 Materials prep (CIH) 2 Materials prep (technician) 3 Load waste motor (crane) 4 Haul motor to burning ground § Off-load motor § Handling evaluation/planning 9 Motor handling 40 Disposal at burning ground 44 Sweep area 42- Steam clean floor 43 Load rinsate/sweepings 44 Load drums 4§ Haul to Clean Harbors 46 State disposal fee 4-7- Sample collection 48 | Sample analyses, metals/exp 33 22 0111 x2 33 22 0112x2 Crow SIWSM Crew COET2 Crow SIWSM Site personnel Site personnel 33 22 0112x2 33 17 0812 33 19 0103 33 10 0103 33 10 0243 Utah DEQ 33 22 0112x2 Chemtech-Ford hr hr hr hr hr hr lb hr sf drum ea truck fr-H hr ea 42 20 8 40 0 80 40 300,000 8 0=080 40 40 350 4 4 2 8344 34^8 303.57 93=34 393.57 05=00 05=00 0 25 34=58 0 30 4=0? 3 05 2=20 28=00 34^8 210.00 4,004 Q32 0440 4493 3449 5=200 2=000 75,000 253 2=245 48 34 784 20 420 420 SUBTOTAL 96,135 INFLATION ADJUSTMENT - 1.204* 115,747 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 5=787 11,575 11,575 11,575 TOTAL ESTIMATED COST 156,258 Tabic 4 M 603 Closure Cost Estimate* 10 I ATK. Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 N=>7 Description Means No./Source Unite list. Quan. Unit Price Prico 4 2 3 4 5 6 9 40 44 45 40 44 40 40 47 40 Materials prep (CIH) 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 disposal fee Sample collection Sample analyses, metals/exp 33 22 0111 x 2 33 22 0112x2 Crew SIWSM Crew COET2 Crow SIWSM Site personnel Site personnel ATK 33 22 0112x2 33 17 0812 33 10 0103 33 10 0103 3310 0243 Utah DEQ 33 22 0112x2 Chemtech-Ford hf hf hr hf hf hf hr lb hf sf drum ea truck ffW hr ea 42 8 45 8 40 50 120,000 0 4^30 4 4 www 4 4 2 0344 34^8 303.57 85=04 393.57 05=00 05=00 0-25 34^0 0 30 4=07 3=05 250 58=00 34^0 210.00 008 37f> wf w 0449 4450 0449 5=000 4=000 30,000 253 744 48 45 784 58 450 420 SUBTOTAL INFLATION ADJUSTMENT - 1.204a 44=727 53,851 Mi6c. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 5=083 5=085 5=085 5=085 TOTAL ESTIMATED COST 72,699 Tabic 5 M 186A Closure Cost Estimate* 11 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 4t ?ro Description Means No./Source Unite 1st Quan. Unit Price 4 Site prop (CIH) 2 Site prep (technician) 3 Load drums 4 Haul drums to Clean Harbors 5 Landfill disposal 0 State disposal fee 7 Truck washout/decon 8 Steam clean floor 9 Rinsate sample collection 49 Sample analyses, motals 44 Sample analyses, explosives 33 22 0111 x 2 33 22 0112x2 33-10 0103 3340 0243 33 10 7214 Utah DEQ 33 10 0311 33 17 0812 Site crew Chemtech-Ford Chomteoh-Ford hF hF ea truck-mi drum ea sf hf ea ea 24 400 4=700 400 400 4 4=830 4 4 4 fl3 AA 04^0 3 05 2=20 145.00 20=00 158.00 Q go 05=00 210.00 210.00 SUBTOTAL 68,001 INFLATION ADJUSTMENT ~ 1.204a : 83,065 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/domob 5 % 4=453 Engineering/permitting 40 % 8,307 DSHW oversight 40 % 8=007 Contingency 40 % 0=007 TOTAL ESTIMATED COST - : - 112,138 Tabic 6 12 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 M 705S Closure Cost Estimotc* It Description Means No./Source Units list Quan. Unit Price Total Prico 4 Site prep (CIH) 2 Site prep (technician) 3 Load drums 4 Haul drums to Clean Harbors § Landfill disposal State disposal fee Truck washout/deoon Steam clean floor 9 Rinsate sample collection 40 Sample analyses, metals 44 Sample analyses, explosives 33 22 0111 x 2 33 22 0112x2 33 10 0103 33 10 0243 33 10 7214 Utah DEQ 33 10 0311 33 17 0812 Site crew Chemtech-Ford Chemtech Ford hr hf ea truck-mi drum ea sf hr ea ea 32 yuv 32 4^50 8344 34=58 3 05 2=20 145.00 20=00 158.00 Q 30 05=00 210.00 210.00 33d 253 90 794 4=040 224 450 722 26Q 240 240 SUBTOTAL 7-899 INFLATION ADJUSTMENT ~ 1.204a 9=540 Mi6C costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 475 954 954 051 TOTAL ESTIMATED COST 12,838 13 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Table 7 E 501 Closure Cost Estimate* •It Dosoription Means No./Source Unite list Quan. Unit Price Total Price 4 Sito prep (CIH) 2 Sito prep (technician) 3 Load drums 4 Haul drums to Clean Harbors § Landfill disposal 6 Stato disposal fee 7 Truck washout/decon § Stoam clean pad 9 Rinsate sample collection 49 Sample analyses, metals 44 I Sample analyses, explosives 33 22 0111 x2 33 22 0112x2 33 10 0103 33 10 0243 33 10 7214 Utah DEQ 33 10 0311 33 17 0812 Site crew Chemtech- Ford Chemtech-Ford hf ea truck-mi drum ea sf hf ea ea 480 700 400 40 4 4,700 4 4 4 83=44 34^0 3 05 2=20 145.00 28=00 158.00 0=09 05=00 210.00 210.00 334 400 4=082 23,200 4,420 153 080 26Q 240 240 SUBTOTAL 28,501 INFLATION ADJUSTMENT - 1.204^ 34,315 Misc. costs a6 a percent of the inflation-adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 0=404 5=434 3454 TOTAL ESTIMATED COST 46,325 14 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Table 8 T 29B Closure Cost Estimate* I torn No. Description Means No./Source Unite Est Quan. Unit Price Total Price 4 Sito prop (CIH) 2 Site prep (technician) 0 Extra drum for dilution 4 Transfer and dilute hydrazine § Load drums § Haul drum6 to Clean Harbors 7 Landfill disposal 8 State disposal fee 9 Truck washout/decon 40 Steam clean floor 44 Rinsate sample collection 42- Sample analyses, metals 40 I Sample analyses, explosives 33 22 0111 x 2 33 22 0112x2 33 19 0402 Site crew 33 10 0103 33 10 0243 33 10 7214 Utah DEQ 33 10 0311 33 17 0812 Site crew Chemtech-Ford Chemtech-Ford hr hr ea hr ea truck-mi drum too ea sf hr ea ea 4 4 2 350 2 4 4 PQO cv/v 4 4 4 83=44 34=08 80=00 00=00 3 05 2=20 145.00 20=00 158.00 0 30 00=00 210.00 210.00 334 200 0 794 2QQ 28 153 78 26Q 240 240 SUBTOTAL 2T900 INFLATION ADJUSTMENT - 1.204' 3=004 Misc. costs as a percent of the inflation-adjusted subtotal: Mob/demob Engineering/perm itting DSHW oversight Contingency § % 40 % 40 % 40 % 478 356 356 356 TOTAL ESTIMATED COST 4=007 15 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Table 9 S 633 Closure Cost Estimate* I torn Description Means No./Source Units Est Quan. Unit Price Price 4 2 3 4 5 6 7 Site prep (CIH) Site prep (technician) Disposal at Burning Ground Sample Collection Sample analyses, metals Sample analyses, explosives Sample analyses, volatiles 33 22 0111 x2 33 22 0112x2 Site crew Chemtech-Ford Chemtech-Ford Chemtech-Ford hr hr hr lb ea ea ea 4 3 75,000 83=44 50=88 0 25 05=00 210.00 210.00 210.00 034 253 18,750 52Q 4=080 4,080 4=000 SUBTOTAL 24,807 INFLATION ADJUSTMENT - 1.204' 29,076 Misc. costs as a percent of the inflation adjusted subtotal: Mob/demob Engineering/permitting DSHW oversight Contingency 5 % 40 % 40 % 40 % 4,499 2=897 2=997 2=997 TOTAL ESTIMATED COST 40,468 Closure Cost Estimotc Footnotes: *"A11 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. ^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. ^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. 16 I ATK Launch Systems Inc. - Promontory Attachment 5 - Closure Plan Modified JanuarvFebruarv. 20145 UTD009081357 Table 10 Summary of Closure Cost Estimates Hazardous Waste Management Unit M 136 M-225 M-47- M-603 M 186 M705S E-504 T29B S-633- Total Estimated Cost ($) 122,225 61,901 156,258 72,699 112,138 12,838 46,325 1,807 10,168 629,659 17