DSHW-2015-003379 - 0901a06880505069

State
GARY R. HERBERT
Govemor
SPENCER J. COX
Lieutennnt Govemor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
Solid and Hazardous Waste Control Board
KevinMunay, Chair
Dennis Riding, Vice-Chair
Eugene Cole, DrPH
Jeff Coombs. MPH. LEHS
Mark Franc
Brett Mickelson
Amanda Smith
Shane Whitney
Dwayne Woolley
Scott T. Andenon
Executive Secretary
March 3.2015
George E. Gooch, Manager
Environmental Compliance
ATK Launch Systems - Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: Request for Permit Modification and Closure Plan Approval
urD009081357
Dear Mr. Gooch:
The Division of Solid and Hazardous Waste has completed its review of your request to modify ATK's
Hazardous Waste Storage Permit. The Division has determined that your requested changes can be
made as a Class 1 Modification with prior approval from the Director. As you know, the Division has
been working with ATK on the modifications to Module II, Attachment 5 and the Closure Cost Estimate
Tables. Based on our review of the Permit and cost estimate changes that ATK submitted with your
letter dated February 6,2015, the requested modification to the Permit is hereby approved.
Updated pages for Module II and Attachment 5 are enclosed with this letter. Please replace these
sections of the Permit in the copies that ATK maintains at the Promontory facility. As indicated in these
updated sections, ATK will now maintain the Closure Cost Estimates for all HWMUs in its Operating
Record.
Please be aware that, in accordance with 40 CFR $270.42(a)(ii), ATK is required to notify all persons on
the Facility Mail List within 90 days of modifying its permit.
The Division has also completed its review of the Closure Plans for Hazardous Waste Storage Buildings
M-47 and M-603. The Closure Plans were submitted by ATK in accordance with Permit Condition
III.J.2. As indicated in your letter, the buildings were inspected by the Division on August 20,2014.
195 North 1950 west. Salt l.ake City, UT
Mailing Address: P.O. Box 144880. Salt lake City, UT 84114-4880
Telephone [phone]. Fax [phone]. T.D.D. (801) 5364414
wno.deq.utah.goo
Printed on 100% recycled paper
DSHW-2O15-003379
(ovER)
The Closure Plans for these buildings are hereby approved for implementation.
Once ATK submits the Certification of Closure for these buildings, it will be released from financial
assurance for them. In addition, the Permit will be brought up to date when the new container storage
building is added to the Permit.
H you have any questions, please call Jeff Vandel at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
STAV[ir
Enclosures: Closure Plan and Financial Requirements (DSI{W-2O I 5-003383)
Module II - General Facility Conditions (DSHW-2015-003384)
c: Blair Palmer, ATK Launch Systems
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
David Duster, USEPA, Region 8
ATK kunch Systems Inc. - Promontory
Module II - General Facility Conditions
Modified February, 2015
uTD009081357
II.A.
II.A.1.
II.B.
II.B.1.
MODULE II - GENERAL FACILITY CONDITIONS
APPLICABILITY
The requirements of this permit module pertain to all Hazardous Waste Management
Units (HWMUs) identified within Modules I, II, IIL [V and V.
DESIGN AND OPERATION OF FACILITY
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.
Any construction changes associated with a permitted HWMU at lhe facility shall be
doiumented by as-buili drawings and certified by a registered professional engineer in
accordance with Condition I.R.1. and UAC R3l5-3-3.1(lX2Xi).
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.
REOUIRED NOTICE
As required by UAC R315-8-2.3(aX1), the Permittee shall notify the Director in_writing
at leasl 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.
When the Permittee :uranges 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) fo1, and will accept, the waste the generator
is shipping. The Permitiee shall keep a copy of this written notice as part of the
operatihg iecord as required by UAC R315-8-2.3(b).
WASTE ANALYSIS PLAN
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.
The Permittee shall use the test methods described in the Waste Analysis Plan
(Attachment 1) or an equivalent procedure that satisfies Condition I.O.3. Changes in a
test method described in the Waste Analysis Plan, as a result of an improvement or
refinement of that method, may be adopted by the Permittee and incorporated into this
Permit, in accordance with UAC R315-4-1.5 and Condition I.D.
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.
TI.B.2.
II.B.3.
ILc.
[.c.1.
tr.c.2.
II.D.
II.D.1.
TT.D.2.
II.D.3.
ATK l.aunch Systems [nc. - Promontory
Module II - General Facility Conditions
II.D.4.
II.D.5.
II.D.6.
II.D.6.a.
II.D.6.b.
ILD.6.c.
II.D.7.
II.D.8.
Modified February, 2015
urD009081357
II.E
II.E.1.
II.F.
II.F.1.
TI.F.2.
The waste characterization profiles shall be kept in the operating record.
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.
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.
At a minimum, the Permittee shall:
Maintain properly functioning sampling and analytical equipment;
Use approved sampling and analytical methods; and
Submit an updated list of parameters, analytical methods, and sample preparation
methods on an annual basis. The updated list shall be submitted to the Dilector on or
before January 15th of each calendui y"*.
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 Permitt-ee'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 Direitor'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 requesl for
extension to the Director for approval.
If the Permittee uses a contract laboratory to perform analyses, the laboratory must becertified by-the State of Utah to perform the contracted analyses. For parameters for
which certification is unavailable, the Permittee shall ensure that quality controVquality
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.
SECURITY
The Permittee shall comply with the security conditions and procedures contained in
AttachmentT of this Permit.
GENERAL INSPECTION REOUIREMENTS
The Permittee shall conduct inspections in accordance with UAC R315-8-2.6 and shallfollow the inspection schedule found in Attachment2.
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 lrom th6 time that the
ATK launch Systems lnc. - Promontory
Module II - General Facility Conditions
II.F.3.
II.F.4.
TI.F.5.
II.G.
II.G.1.
II.G.1.a.
rr.G.1.b.
II.G.1.c.
II.G.1.d.
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II.G.1.g.
tr.G.2.
Modifred February, 2bl5
uTD009081357
problem is detected, the Permittee shall submit to the Director, bef91e the expiration of
the72 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 o,f the
waste management unit involved in the inspection could endanger human health or the
environmeni, 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 andM-225 Thermal Treatment Areas shall be
conducted to minimize the risk to human health and the environment. The risk thresholds
identified in Condition tr.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 Characteization of Open Burning Waste Propellant Materials,
October 2009;
The Waste Characteization and Air Dispersion Modeling Protocol for use in the Human Health
and Ecological Risk Assessments - ATK Launch Systems - Promontory, November 2OO9,
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 hotocol for OB/OD Operations, August 2010; and
The Human Health Risk Assessment Report, to be completed in accordance with Condition
TV.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
ATK L:unch Systems Inc. - Promontory
Module II - General Facilitv Conditions
II.G.3.
II.G.3.a.
rr.G.3.b.
II.G.3.c.
rr.G.3.d.
II.G.4.
II.G.5.
II.H.
II.H.I.
II.H.2.
Modified February, 2015
uTD009081357
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 fV.C.s.
The Permittee shall submit to the Director by March l't 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 II.G.Z, 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.I.
An evaluation of the emission factors, identified in Condition II.G.1.a., used in the human
health risk assessment to determine whether these factors are representative of the wastes
treated and identified as directed by II.G.3.a., or if the emission factors need to be updated; and
A review of the of the human health risk assessment, identified in Condition II.G.1.g., to
evaluate whether the slope factors and reference doses for carcinogenic and non-carcinogenic
health effects related to the chlorinated dioxin, chlorinated furan and semi-volatile compounds
have changed, and a review of the potential human health risk scenarios that were evaluated in
the risk assessment to assure that these scenarios have not changed.
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 orM-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 Atiachment 3. New personnel*9TFng. with or around hazardous waste shall complete the required personnel trainingwithin 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 fositions inwhich they are employed.
The Permittee shall ryry41{argngdqcuments and records as required by UAC R315-8-2.7(d) and R3l5-8-2.7(e) [40 CFR 264.16(d) and264.16(e)], in accordance with the
Training Plan in Attachment 3. These records shall indicate the type and amount oftraining received.
II.H.3.
ATK hunch Systems Inc. - Promontory
Module II - General Facility Conditions
II.H.4.
II.H.5.
Modified February, 2015
uTD009081357
The Permittee shall maintain a copy of the Training Plan at the Facility until it is fully
closed and closure is certified.
Employees working at the M-136 andM-225 Thermal Treatment Areas shall receive
tasli sp-ecific on-the-job-training in addition to the training outlined in Attachment 3.
This tiaining shall be documented and maintained in the operating record.
II.I.
u.I.l.
fr.r.z.
II.J.
II.J.I.
II.K.
II.K.1.
II.K.2.
II.K.3.
II.K.4.
The Permittee shall comply with the requirements of UAC R315-8-2.8.
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.
LOCATION STANDARDS
The Permittee shall comply with the location standards specified by UAC R315-8-2.9.
PREPAREDNESS AND PREVENTION
The Permittee shall follow the Preparedness and Prevention Plan, Attachment 8.
At a minimum, the Permittee shall equip and maintain in good operating cond,ition at
the facility the equipment set forth in Attachment 8, as required by UAC R315-8-3.3'
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.
The Permittee shall maintain records of the preventative maintenance and repair
activities specified in Condition tr.K.3. and shall keep schedules, reflecting minimum
and planne^d frequency for the performance of preventative maintenance activities in the
Operating Record at the facilitY.
The Permittee shall maintain access to the communications or alarm system as required
by UAC R315-8-3.5.
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 .
The Permittee shall attempt to make arrangements (Coordlnation 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 Recota..I!: attempts to make such
agleements, any refusali and all final agreements shall be documented in the Operating
Record.
II.K.5.
II.K.6.
II.K.7.
ATK taunch Systems lnc. - Promontory
Module II - General Facility Conditions
II.L.
II.L.1.
II.L,2.
II.L.3.
tr.L.4.
II.M.
II.M.1.
II.N.
II.N.1.
II.N.2.
II.N.3.
II.N.4.
II.N.5.
Modified February, 2015
uTD009081357
CONTINGENCY PLAN
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.
The Permittee shall provide copies of the Contingency Plan to emergency agencies who
may.be caJled in an emergency, shall maintain a copy of the Plan at the facility, and
shall provide a copy upon request in accordance wiih UAC R315 -8-4.4.
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.
A trained emergency_co91d!n1tor shall be available at all times in case of an emergency,in accordance with UAC R315-8-4.6 and identified in Attachment 4.
MANIFEST SYSTEM
The Permittee shall comply with the manifest requirements of UAC R315-5-2 and UACR315-8-5. The manifest tracking number shall be recorded in the Operating Recordwith each waste load that arrives or leaves the Permittee's facility. ^
RECORDKEEPING AND REPORTING
The permittee shall maintain an accurate written Operating Record at the facility in
accordance with UAC R315-8-5.3 (40 CFR 264.7i incorporated by reference) andR315-50-2 (Appendix I to Part 264 rncorporated by referEnce).
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], signedin accordance with UAC R315-3-2.2, that the Permittee has a progiam in place.to
reduce the volume and toxicity of hazardous waste that he gen^eraies to th6 degree
determined by the Permittee to be economically practicablJ; and that the prop6sed
method of treatment, storage,. or disposal is the- most practicable method iurrently
available to the Permittee which minimizes the present and future threat to human
health or the environment.
The Permittee shall comply with the biennial report requirements of UAC R315-8-5.6,
by March 1 of each even-numbered reporting year. Th-e report shall include wastes
generated, treated or stored at the Permittee's facility during the previous odd-numbered
year.
The Permittee shall submit additional reports to the Director in accordance with UACR3l5-8-5.8.
Sll reports, notifications, applications, or other materials required to be submitted to theDirector shall be submitted in accordance with Condition I.DD.
ATK hunch Systems Inc. - Promontory
Module II - General Facility Conditions
II.o.
II.o.1.
il.o.2.
II.O.3.
II.O.4.
II.o.5.
II.O.6.
II.O.7.
II.O.8.
Modified February, 2015
urD009081357
CLOSURE/POST-CLOSURE
The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101
and Attachment 5.
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 iertification statements. The Permittee shall describe the rationale for
implementing minor changes as part of this narrative repg-rt. Within 60 days after
completion of closure of each HWMU, the Permittee shall submit the certification
statements and narrative reports to the Director.
The Permittee shall amend the closure/post-closure plan in accordance with UAC R315-
8-7 and Condition I.D. whenever necessary, or when required to do so by the Director.
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 ltiO days prior to the commencement of final facility closure..The closure p.lan
contained in Aitalhment 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 Direct-or for approval in accordance with Condition LD.
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.
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
orily at a permitted hazardous waste treatment, storage or disposal facility.
The Permittee shall certify that the facility has been closed in accordance with the
specifications in Attachmbnt 5 as required by UAC R31.5-8t, and shall provide a
c'ertification by an independent, Utah registered professionalengineer qualified by
experience and education in the appropriate engineering field-
In the event that any of the hazardous waste management units covered by this permit.-
cannot be clean cloied by decontaminating or removing contaminated structures or soil,
or releases have occurred which have impacted soil or groundwater, the Permittee shall
modify the ClosurelPost-Closure Plan for that hazardous waste management unit in
accordance with Condition I.D. Within 30 days of the date that the Director approves
the modification, the Permittee shall close the unit in accordance with the applicable
provision of UAC R315-8-7 and R315-101.
If a HWMU cannot be clean closed, the Permittee shall submit a survey plat and
property description for the HWMU with the submission of the certification of closure
iorlhe I{WMU-, in accordance with UAC R315-8-7 and R315-101.
II.O.9.
ATK launch Systems Inc. - Promontory
Module II - General Facility Conditions
il.P.
[.P.1.
II.P.2.
II.P.3.
II.P.4.
il.P.5.
II.Q.
rr.Q.1
rr.Q.2.
II.R.
II.R.1.
Modihed February, 2015
urD009081357
COST ESTIMATES FOR HWMU CLOSURE
The Permittee's closure cost estimate for each HWMU shall be prepared and maintained
at the facility in accordance with UAC R315-8-8 (40 CFR 264.142 incorporated by
reference) and Attachment 5.
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 ILP.2. above, the Permittee shall conduct a detailed evaluation of the
closure cost estimates for each HWMU and determine whether the annual adjustments
for inflation have been adequate to update the closure cost estimates. The Permittee
shall submit a report on this assessment and if necessary, a modification of the Permit in
accordance with Condition I.D. to the Director 90 days after the report is submitted.
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 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.
The Permittee shall revise the financial assurance for facility closure whenever there is
a change in the facility's closure plan that would change the cost estimate as required
by UAC R315-8-8.
LIABILITY REOUIREMENTS
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
ATK hunch Systems Inc. - Promontory
Module II - General Facility Conditions
TI.R.2.
TI.R.3.
II.s.
Its.1.
Modified Febmary, 2015
uTD009081357
Permittee shall submit an approved certificate of hazardous waste liability insurance
worded as required by UAC R315-8-8.
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 andM-225 Thermal Treatment
Areas.
Changes in liability coverage mechanisms shall be approved by the Director 60 days
prior to such a change.
The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (40 CFR 264.148 incorporated by reference).
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified February, 2015
uTD00908r357
CLOSURB 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.
Closure 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-298,M-47,
M-603 and 5-633.
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 CFR264 Subpart H.
All HWMUs in current operation are being managed in a manner that facilitates clean closure.
Historical sites, such as the LTTAs do require post-closure care, and are covered in our Post-
Closure Permit.
1.0 Closure PIan [40 CFR 270.14(bX13), 270.23(a)(2), and 264.112(a)(1) & (2) and UAC
R315-3, R315-81
This closure plan identifies the general 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 plan will be followed as written, unless modification to the
original plan has been submitted and approved by the Utah Department of Environmental
Quality, Division of Solid and Hazardous Waste (DSHW). Upon update/revision approval,
revised pages or complete documents will be sent to all plan addressees.
1.1 Closure Performance Standards [40 CFR 264.111 and UAC R315-8-7]
Closure standards specified under RCRA are designed to be protective of human health and the
environment. These goals will be achieved by one of the following closure methods:
' Clean closure - this method refers to residential risk-based levels. Cleanup to
residential risk-based levels, as outlined in UAC R315-101, will be considered clean
closure. Clean closure includes removal of all contaminants. or removal to the risk-
based level.
' Site Management - closure where waste remains in place and specific post-closure care
is required.
For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be "clean
closed." Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(cX1). All closures will
assess real and reasonably likely impacts to human and ecological exposures.
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified February, 2015
uTD009081357
Preliminary remediation goals can be established prior to implementing any of the closures.
Screening levels published by USEPA or site-specific risk based levels based on UAC R315-
I0I-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 DSHW review and Director approval, 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.LL2(b)(1) through (bX7)
and UAC R-315-8-71
This closure 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. A detailed plan for closing each HWMU will be submitted in accordance
with Permit Condition llI.J.2.
Soil monitoring has been conducted at the M-136 andM-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.LL2(b)(3) and UAC
R31s-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 Standard 4145.26M ot 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) --106,500lbs 1.3 l2O,0N lbs 1.1
M-225 (live) ----- 55,0001bs 1.3 / 1,5001bs 1.1
T-298 (inert) --- 1 ea. 55-gallon drum (pure) equivalent
M-47 (live) ----- 300,0001bs 1.3 lzl,000lbs 1.1
M-603 (live) ----- 120,0001bs 1.3 / 8,000Ibs 1.1
5-633 (live)--------:---------- 75,000lbs 1.3/20,0001bs 1.1
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified February, 2015
uTD009081357
ATK treats reactive hazardous wastes on-site at the M-136 andM-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.L13(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 moro time is required, a request will be submitted to the Director for
approval. 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 Director. 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 arry threats to human health or
the environment during the extension period.
1.5 Closure Procedures [40 CFR 264.112 and264.ll4 and UAC R315-8-7]
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 cleanup 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 5-633.
Detailed sampling plans will be submitted in accordance with Permit Condition III.J.2. Samples
will first be collected at locations most likely to have been affected by waste management
practices - as approved by DSIIW personnel. Twenty soil samples will be collected at M-136,
eight soil samples will be collected atM-225 and eight soil samples will be collected at 5-633.
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified February, 2015
uTD009081357
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.
Analvtical and extraction methods to be used are shown below.
1.5.1.1 Sampling Equipment Decontamination Procedures
All field sampling equipment will anive 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 off-site for treatment or disposal. Soils will be stored in UN containers
pending lab results. Any soil determined to be hazardous waste will be managed appropriately.
All non-aqueous hazardous waste generated by the sampling operation will be transported by a
third party contractor off-site to a fully permitted TSDF for disposal. Any waste determined not
to be hazardous under EPA regulations will be sent via third party to a non-hazardous landfill for
disposal.
A field log will be maintained to track and identify all samples. This log will include sample
numbers, dates, times, sample depth, samplers name, weather conditions, test methods and
constituents for which to analyze.
1.5.1.3 Health and Safety Procedures
Soil and water sampling will be performed by trained and qualified personnel. A determination
of appropriate personal protective equipment (PPE) to be used for this effort will be determined
at the time of closure. PPE selection will be based on potential hazards as determined at the time
of closure, and in consultation with Industrial Hygiene professionals.
Analvtical and Extraction Methods
Parameter Analwical procedure Extraction Procedure
Volatiles SW-846:82608 SW-846; 5030B(w), 50355
Semi-Volatiles SW-846:8270C SW-846; 35 l0C(W), 3550(5)
RCRA Metals SW-846:60108 SW-846; 3005A(W),747 I A(S)
Mercury SW-846: 747ON14714 SW-846;7470A(W), 747 1 A(S)
Exnlosives SW-846:8330 Modified SW-846: 8330 Modified
Perchlorate EPA 314.0 EPA 314.0
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified February, 2015
uTD009081357
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 R3l5-101-6(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(b)(3) and UAC R31.5-8-7]
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.I12(bX4),
264,112(e), and 264.1L4 and UAC R315-8-71
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 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 will be collected for off-site 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
Section 1.5.1.
ATK Launch Systems Inc. - Promontory
Attachment 5 - Closure Plan
Modified February,2015
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. 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 Utah
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(bX13)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 264.115 and UAC R315-8-7]
Within 60 days of completion of closure of each FIWMU, ATK will submit a certification to the
DSHW by registered mail, that the HWMU 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 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
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 R3l5-8-7, UAC R3l5-8-8, UAC
R315-101 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.