DSHW-2015-003461 - 0901a06880505fd2

Orbital ATK
February 25, 2015
8200-FY15-078
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc. EPA ID number UTD009081357 ^
Annual Report of the Promontory Thermal Treatment Areas Operation Hazardous Waste
Storage Permit Module II.G.3
Dear Mr. Anderson:
Attached is the 2014 Annual Report for the operation of the ATK Launch Systems Inc. ("ATK")
Promontory Facility Thermal Treatment Areas as required by Hazardous Waste Storage Permit
Module II Condition G.3.
Please contact Blair Palmer at [phone] or myself at [phone], if you have any
questions concerning this report.
/ certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. Iam aware that there are significant penalties for submitting false information,
including the possibility offine and imprisonment for knowing violations.
Sincerely,
/L^r^&L^e^—<—^
George E. Gooch
Manager, Environmental Services
ATK Launch Systems Inc.
cc: JeffVandel
Division of
Solid and Hazardous Waste
FEB 2 5 2015
Orbital ATK, Inc. • 9160 N. Hwy 83, Corinne, UT 84307 • 435-863-3511
Orbital ATK
ATK Launch Systems Inc.-Promontory 2014 Annual Report of the Promontory Thermal
Treatment Areas Operation
Module II Condition G.3.a: requires an accounting of the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas.
Response: Table 1 and Table 2 shown below report the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas in 2014. The total
treated amounts treated in 2014 were 574,660 pounds at M-136 and 2,042 pounds at M-225.
Table 1: 2014 M-136 Thermal Treatment Totals
Propellant Class Percent of Total Reactivity Group Hazardous Waste
Treated (lb)
1.3 59.9% 341,208
B 22
2,904
G 44
1.1 38.5% 217,428
D 3,644
(1.3) Flare 1.6% E 9,410
Table 2: 2014 M-225 Thermal Treatment Totals
Propellant Class Percent of Total Reactivity Group Hazardous Waste
Treated (lb)
1.3 42.4% 802
B 0
63
1.1 53.0% 567
D 515
(1.3) Flare 4.6% E 95
Module II Condition G.3.b: requires an 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.
Response: A human health risk assessment report has been submitted to the Utah Division of
Solid and Hazardous Waste ("UDSHW"); however it has not been approved at this time. The
estimated quantity of TCDD-TEQ released, based on the total amounts treated in 2014, as
Orbital ATK, Inc. • 9160 N. Hwy 83, Corinne, UT 84307 • 435-863-3511
Orbital ATK
reported above in Module II Condition G.3.a, were 1.47xl0"3 pounds, or 700 milligrams from M-
136, and 5.21xl0"5 pounds, or 2.4 milligrams from M-225.
The human health risk assessment assumes that a maximum quantity of 10.6 million pounds of
material will be processed at M-136 on an annual basis using approved emissions factors
developed in conjunction the UDSHW. The UDSHW-approved air dispersion modeling report
provided emissions rates that were used in the risk assessment model and gave risks lower than
the UDSHW acceptable risk threshold. The amounts of TCDD-TEQ above were calculated by
interpolating the allowable annual amount used in the risk assessment model by the actual
amounts processed in 2014 that are reported in Module II Condition G.3.a, above.
Module II Condition G.3.c: requires an evaluation of the emission factors, identified in
Condition II.G.l.a, used in the human health risk assessment to determine whether these factors
are representative of the wastes treated and identified as directed by II.G.3.a, or if the emission
factors need to be updated.
Response: ATK considers the emission factors contained in the human health risk assessment
report to be representative of the wastes treated at the M-136 and M-225 Thermal Treatment
Areas.
Module II Condition G.3.d: requires a review of the human health risk assessment, identified in
Condition II.G.l.g., to evaluate whether the slope factors and reference dose for carcinogenic and
non-carcinogenic health effects related to 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.
Response: A human health risk assessment report has been submitted to the UDSHW; however
it has not been approved at this time. Prior to submission of the risk assessment report in
December 2014, the toxicological dose-response factors for all of the chemicals of potential
concern in the risk assessment were evaluated and revised to the current US EPA's IRIS
database, and the US EPA's Provisional Peer Reviewed Toxicity Values. It is highly unlikely
that the does-response values have changed between December 2014 and February 2015, and if
they have, the changes would be identified by the DSHW in their review of the risk assessment
report. Therefore, at this time, it is assumed that no changes to the dose-response factors have
occurred.
Orbital ATK, Inc. • 9160 N. Hwy 83, Corinne, UT 84307 • 435-863-3511