DSHW-2015-007848 - 0901a0688054cb5d

7/2G'2015 Mail-ATK HHRA Response to Comments/Evaluation
OSfhU-rJ-0!5-007?:'-{ r
Jeff Vandal <[e-mail]>
ATK HHRA Response to Comments/Evaluation
1 message
Palmer, Blair <[e-mail]> Tue, Jul14, 2015 at 11:02 AM
To: Jeff Vandel <[e-mail]>, "[e-mail]" <[e-mail]>
Hi Jeff and Mike, attached are the responses , the second round of comments/evaluations.
As you go through this document, you wi Je looking for our responses in green font. There
are some track changes edits at the bep . 1ning of the document that provide some
clarification on our first round of respor .es.
I have also attached two other files that go with our response to the comments:
1 . The revised Acute Hazard Quotients spreadsheet so that everyone can see that the
Acute HIs did not change based on the slight change in the nickel adjustment factor from
0.015 to 0.017.
2. The emails between ATK and URS about the stainless steel in the test pans for the
08/0D tests.
Once you review and agree with the responses to the comments/evaluations, we will email you an
updated HHRA report with the changes noted by a different color. Jeff and I talked about the
track change issues and decided it would be easier to mark the changed language with a
different colored text.
Thanks,
Blair
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7run15 Miil - ATK HHRA Respqse to CqnmerG/Evdrdicr
3 attachments
El Draft HHRA report second round comments 071315.docx" 141K
g1 Acute HQs for {26,500 lbs REVlSED.xlsx* 487K
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RESPONSE TO THE
TECHNICAL REVIEW OF THE
OPEN BURN AND OPEN DETONATION HUMAN HEALTH RISK
ASSESSMENT
PREPARED BY ATK LAUNCH SYSTEMS
PROMONTORY. UTAH
JUNE and JULY,2015
The following comments were generated based on evaluation of Open Burning and Open
Detonation Human Health Risk Assessment for ATK Launch Systems in Promontorv.
Utah dated December 2014 (HHRA Report).
GENERAL COMMENTS
1. The HHRA Report indicates that short-term 1-hour (acute) hazard,indices (HIs)
for inhalation exposures exceed the Utah Department of Environmental Quality(DEQ) non-cancer target level of 1 at some receptor locations. Text discussions
indicate the exceedances are driven by nickel. According to information
presented in the Executive Summary and Section 9.1, Short-term Non-Cancer
Hazards in Air-Methods, all acute HIs are below the Utah DEQ threshold of I if
simultaneous open burning/open detonation (OB/OD) operations are restricted to
sources AI, A2, and ,{3 at M-136 and nickel is eliminated from calculation of the
acute HI. Section 9.1 notes that the inclusion of nickel in the human health risk
assessment (HHRA) is addressed in Section 10, Estimating Uncertainty for
Human Health Risk Assessment. Because nickel is the risk driver for all acute
HIs that exceed the Utah DEQ target level, it is important that the uncertainty
discussion provides a technically sound and defensible argument for considering
nickel a testing artifact, generated by the test equipment, and thus, not a chemical
of potential concern (COPC).
General Responsei
The section of the risk assessment that relates to the contribution of nickel and chromium
to the short term;(or acute) hazard indicesex (HIs) have been revised and supplemented
to provide a mere-cleargl explanation of this issues-* In addition, the hazards related to the
assumption that all of the burning grounds are used at the same time have also been
revised, specifically:t In the body of the HHRA report the acute HIs are calculated using TIhe emission
rates for chromium and nickel from the OB/OD tests. while in the uncertaintv
section it is; assumgg[ing that these metals come from AP-waste only.;_fhg_acgle
hazards have been #{€-re-calculate{ $e!q a€u+e-hazards;and are
significantly lower.
The assumptions that all burning grounds are used simultaneously have been
revisited and the hazards calculated using ATKs actual operational protocol, and
the results are significantly lower.
When these two modifications are combined. the acute hazard indices are below
one.
Therefore, these draft responses provide clarification on the emissions rates for chromium
and nickel as well as revised Acute ++amr&+*dieesHIs based on revised emissions rates
for both chromium and nickel (see Table I below). We have evaluated chromium and
nickel emissions rates based on the suggestion from the DSHW, and adjusted those based
on new analyses from ATK.
These comments from the Utah DSHW also prompted a discussion on which burning
grounds would most realistically and efficiently be used at the same time. The Acute
I+azar4{ndieesHls presented here include a revised scenario based on actual operating
conditions, as explained below.
The uncertainty analysis provided in Section 10 indicates that AP waste may contain up
to 3.1 mg per kilogram (mg/kg) chromium (Cr) and 29.1 nickel (Ni) (based on the April
2OI4 analysis conducted by ATK, of the aluminum in AP waste). Therefore, Cr and Ni
may be found in the emissions from ATKs process and so cannot be eliminated as COIs.
The text indicates that if complete combustion were to occur, and there is little or no Cr
and Ni in trash, lower levels of Cr and Ni would be expected than those calculated using
the emissions factors from the 2007 OB/OD test.
If it were assumed that aluminum contains 3.1 mg/kg chromium, AP waste and the
aluminum is the source of all of the chromium in the waste (i.e., none in the trash), the
feed material in the OBIOD test, and material being processed, would contain between
zero and 3.1 mglkg chromium for 85Vo AP waste (shown below).
cr tn Ap waste = 3.r. H "rfu f
*s /roo s) , (#) : 0.42*n /un
Evaluation: The units provided in parenthesis for the term 16/100 are incorrect. The
appropriate units would be mg of Cr per mg of wastes. For consistency, it is
recommended that the units in parenthesis be eliminated from the equation.
Response to Evaluation: The incorrect units have been removed fi'orn all relevant
equations, as sug-qested. Also, please note that minor edits have been made on pages l-5
of this document (as shown in track changes) in an attempt to clarify the original
responses.
With 85%AP waste mixed with I5Vo trash (assuming the trash contains no chromium) the
waste would contain 0.42 mgkg chromium.
The HI's based on an adjustment of chromium and nickel shown in Table 1 below were
calculated based on the following assumptions:
Chromium
Using the equation and the emissions factor from the 2007 OBIOD test report (ATK,
2001; Table 8) for theS5Vo AP waste, l5%o trash, the amount of chromium released from
the waste in the test can be calculated as follows:
Cr tn waste - Emi.ssi.o"t (9\ x Source P\ x Itnit Correction(W\\Rg/ \kg / \ kg /
cr = 2.0 x Ll-s(tb1rr)' (#) x s.r >< (#) x 106 = 8.4 (^n /on) r,
/, \cr - 2.0 x 10-s
\-n /on)x 0.16 x 3.1 x 0.85 x 106 = e.+ (^s /kg) c,
Where:
2.0x10-5 (f) tt the emissions rate for chromium from 85Vo AP/lSVo trash,
or 2.ox1o.' (H)
L6,* ir l6vo aluminum in the AP waste
I t (T\ is the chromium content in the aluminum in the Ap waste\kg /
85
,oo- ir the 85Vo AP waste in the test burn
10o is a conversion factor from kg to mg
The resulting amount of chromium in waste from the OBIOD emission is calculated to be
8.4 mglkg, which is greater than the amount estimated to be in the waste, based on the
original feed material, which is0.42 mg/kg, also calculated in the 85VoAP/I5Vo trash
scenario, indicating there is more chromium released than is available in the Ap waste
(assuming its only source is the aluminum in the Ap waste).
This emissions factor was used in the risk assessment, and based on the above calculation
the HHRA assumes there is 20 times more chromium released than is present in the Ap
waste.
If the emissions factor of 2.0x10-5 lb Cr per lb of waste were adjusted to be consistent
with the amount of chromium in the wuri" (from the analysis above) one would expecr ro
have an emissions factor given by the following equation:
Cr Emi.ssons f actor = 2.0 x 10-s "#= e.S " n- (ff)
The emissions factor is calculated by multiplying by a factor of O.42+8.4, or 0.05. This
factor of 0.05 for chromium was used in calculating the HI:s presented in the Table Icolumn titled "Adjusted Ni and Cr".
Further, if the process is repeated for Ni, which is present in the aluminum in Ap waste at
a concentration of 29.I mgkg, and therefore present in85Vo APlI5Vo trash at the level of4 mgkg, the same type of calculation shows that Ni is overestimated by a factor of 67 in
the emissions factor compared with the Ni in the waste. The details of that calculation
are provided below.
Evaluation: While an equation illustrating that0.42 mglkg of Cr is present in the 85/15
waste has provided, no equation is provided to illustrate that 4 mg/kg of Ni is present in
the 85/15 waste. Provide such an equation.
Response to Evaluation: The equation illustrating the nickel content in 85/14 waste is
provided in Section 10.1.2.4.2.
Nickel
Using the equation and the emissions factor from the 2001 OBIOD test report (ATK,
2OO7; Table 8) for the 85Vo AP waste, ISVo trash, the amount of nickel released from the
AP waste in the test can be calculated as follows:
Nt tnwoste = Emi"ssior, (Y\ x Source P\ x llni"t Correction(ry\\kg)' -- \ks ) - ----- \ ks )
Ni = 5.8 x 10-s (,0l,)' (#) x ze.t' (#d) x r.06 = zze.s (^n lun)
Nr = 5.8 x 10-s (ut nr)x 0.16 x ze.rx 0.85 x 105 - 22e.5(^n /un)
Where:
5.8x10-s (#) tr the emissions rate for nickel fromSSVo AP/ISVo trash,
or 5.8x l0 5 fg)\ks/9 ir 16%o aluritnum in the AP waste100
29.l (ry\ is the nickel content in the aluminum in the AP waste\Rg /E ir the 85Vo AP waste in the test burn
100_
10o is a conversion factor from kg to mg
The resulting amount of nickel in waste from the OBIOD emission is calculated to be 230
mg/kg, which is greater than the amount estimated to be in the waste, based on the
original feed material, which is 4.0 mg/kg, also calculated in the 857oAPlI5Vo trash
scenario, indicating there is more nickel released than is available in the AP waste
(assuming its only source is the aluminum in the AP waste)'
This emissions factor was used in the risk assessment, and based on the above calculation
the HHRA assumes there is 57 times more nickel released than is present in the AP
waste.
If the emissions factor of 5.8x10-5 lb Ni per lb of waste were adjusted to be consistent
with the amount of nickel in the waste (from the analysis above) one would expect to
have an emissions factor given by the following equation:
Ni Emi.ssons f actor = 5.8 x 10-s " #= 1.0 >< to-t (#)
The emissions factor is calculated by multiplying by a factor of 4.0+230, or 0.017. This
factor of 0.017 for nickel was used in calculating the HI's presented in the Table I
column titled "Adjusted Ni and Cr".
Note that the calculations include the burning of sources M136 AI, A2, 43 and M225A.
M225A was not originally included in the Acute ++azare+n+ieesHlg calculated using the
sub sources M136 Al, A2, and A,3 in the draft HHRA, but after reviewing the burning
history, it would be more efficient to be able to burn M225A at the same time, and the
relative contribution of M225A to the overall ++azar++neexffl is very small due to the
small amount of material burned.
Evaluation: Please ensure that the revised HHRA Report explicitly and consistehtly
identifies the operating scenario(s) considered in each risk and hazard calculation in the
text. In addition, ensure that all calculations and accompanying explanatory text
provided in this general response are included in the revisions made to the HHRA Report.
Response to Evaluation: All tables, text, equations and appendices have been updated to
include the sub sources that are assumed to be operating in each scenario, and all
information provided in the response to comments has been included in the HHRA.
Table 1. Acute Hazard Indices
Eeceptor
Summed
Hlall
sources
Summed
Hlfor M-
136 A and
M-225 A2
Adjusted
Ni and
Cr3
Adams Ranch 2.9 1.4 0.4
ATK Ranch Pond o.2 0.1 2.9E-O2
Autoliv 4.3 2.2 0.5
Blue Creek 4.7 2.4 0.6
Boundarv 1 5.3 2.7 o.7
Boundarv 2 2.3 7.2 0.3
Boundarv 3 o.7 o.4 0.1
Boundarv 4 0.8 o.4 0.1
Christensen Ranch 0.9 o.4 0.1
Holmsren Ranch 0.5 o.2 0.1
HowellDairv 0.3 0.1 3.6E-02
North Plant Main Adm 2.O 1.0 o.2
Penrose 0.3 0.1 3.4E-02
South Plant Main Adm 3.8 1.9 0.5
Thatcher 0.3 o.2 4.4E-O2
'The Hl presented in this column assumes all sources and use the original amounts of
chromium and nickel. These values are consistent with those presented in the draft HHRA.
'These Hl are based on using only sources M136A1, A2, A3 and M225A and the original
amounts of chromium and nickel. These values are shown for comparative purposes only,
and will not be carried forward in the revised HHRA.
t These Hl are based on using only sources M135 A!, A2,A3 and M225A and the adjusted
amounts of chromium and nickel. The adjustment is based on the April 2015 chromium and
nickel analvtical results from ATK.
Using the same logic applied for chromium and nickel, an adjustment will be made to the
chronic risks and hazards, and those adjusted results will be presented in the revised
HHRA.
According to Page ES-2 of the Executive Summary, simultaneous OB/OD
operations at M-136 andM-225 are prohibited by ATK Promontory operational
safety protocols. However, these protocols are not provided in the text or
appendices or listed in Section 11, References, of the HHRA Report. In addition,
the HHRA Report does not indicate if the safety protocols are included in the
RCRA permit application for the site.
Response:
The modeling protocol assumes processing occurs at all of the burning grounds
simultaneously; however, limiting simultaneous burns to M-136: Al, A2 and 43,
andM225A or a different combination of burn locations would limit exposure to
COIs and comply with ATK's operational protocols. While these protocols are
important to maintain the health and safety of ATK's employees, they are revised
from time to time, and appending them to the permit might require a permit
modification when small operational changes are made. This is a cumbersome
and ineffective method of operating.
It has been developed throughout the Air Dispersion Modeling Protocol, Air
Dispersion Modeling Report, HHRA Protocol, and the HHRA Report that the
burn scenarios for M-136 andM-225 are alternative and mutually exclusive.
Meaning that any one of the M-136 scenarios A (Al, A2, A3), B, or C could
occur once a day, and conversely that any one of theM-225 scenarios A or B
could also occur once a day. ATK anticipates that this will be a permit condition
and therefore operational protocols would not be necessary in the HHRA report or
the RCRA permit. Table 1 also shows the results of adjusting the hazards to
assume normal operating conditions at ATK, and the results indicate lower
hazards.
Evaluation: A narrative similar to the response above should be added to the revised
HHRA report. The narrative should include the following points:o The HHRA is based on ATK's actual operating protocols.o The HHRA addresses simultaneous operation of burn scenarios M l36,4 (sub-
scenarios Al, A2, and A3) andM225A.o ATK anticipates that permit conditions will be based on the combinations of burn
scenarios demonstrated in the HHRA and ecological risk assessment (ERA) as
protective of human health and the environment with other scenarios (M 1368,
Ml36C, andM225B) treated as alternative and mutually exclusive options.
Response to Evaluation: This language will be added into the Executive Summary of the
HHRA, as well as Section 10.2.1. The third bullet will be modified slightly to clarify that
ATK anticipates that the permit conditions will be based on the combinations of burn
scenarios in the HHRA, and fitture ERA, and those would include any one of the M-136
scenarios (A, B, or C) and any one of the M-225 scenarios (A or B). For example,
M-136 B and M-225 B might occur on the same day.
Section 10.I.2.4, Chromium and Nickel in Waste, presents information intended
to demonstrate that both metals are not associated with the waste streams treated
by OB/OD at ATK Promontory but are artifacts of the facility-sponsored OB/OD
emission tests conducted at the Dugway Proving Grounds. The same approach is
used in addressing chromium and nickel. The following issues were identified as
a result of the review of Section 10.1.2.4:
o The discussion at the top of Page73 indicates that the OD/OB test
released up to 1300 milligramsper kilogram (mg/kg) of chromium. Based
on the emission factor (1.3x10-) lb/lb) referenced to the OB/OD emission
test report, the test could have released up to 13 mglkg.
Response:
The text has been revised by adding a calculation showing the derivation of
13 mglkg. The value of 1300 mg/kg was inadvertently included on page 73.
Evaluation: Ensure that 1300 mg/kg is removed from the repofi text.
Response to Evaluation: The value of 1300 mg/kg was removed from the report text.
o The discussion at the top of Page 73 indicates that the burn pans used in
the tests contained 15 percent chromium in the steel. A reference to the
information source for this parameter is not provided.
Response:
The text has been revised to add the citation to the chromium content of the test
pans. The citation, ATK, 2}l3b will be provided in Section I I (References).
o The discussion related to nickel in the second full paragraph on Page 73
references the percentage of aluminum and the amount of nickel in
ammonium perchlorate (AP) propellant to (ATK, 2013b). Reference
ATK. 2013b is not listed in Section 11. References.
Response:
The citation will be provided in Section 11.
o The discussion in the second full paragraph on Page 73,the text states: "If
it were assumed that aluminum [contained in AP Propellant] contains 20
mg/kg nickel, AP waste would contain between zero and 3.2 mgkg." A
reference to an information source supporting this assumption is not
provided.
Response:
The text has been revised by adding a calculation showing where ATK
determined the aluminum contains 29.1mgkg nickel and the text has been
revised to show how AP waste contains between zero and 4.0 mg/kg nickel. A
nickel concentration of 4.0 mglkg was used in calculating the Acute Hazard
Indices in Table I above.
o The discussion in the second full paragraph on Page 13 indicates that the
OD/OB test released up to 5800 milligrams per kilogram (mglkg) of
chromium. Based on the emission factor (3.6x10-5lb/lb) referenced to the
OB/OD tests report, the test could have released up to 36 mg/kg.
Response:
The value of 5800 mg/kg was inadvertently included onpage73.
Evaluation: Ensure that 5800 mg/kg is removed from the repofi text.
Response to Evaluation: The value of 5800 mg/kg was removed frorn the reporl text.
o Section 10.I.2.4 does not include a determination of the acute hazard
associated with treatment of 3.2 mgkg of chromium in AP Propellant.
Response:
The text has been revised to include an analysis showing the potential impacts
from the emissions of 3.1 mg/kg chromium.o Section 10.1.2.4 does not include a determination of the acute hazard
associated with treatment of the nickel emissions (e.g., 4.0 mglkg of
nickel) from AP Propellant (85:15).
o Section I0.I.2.4 presents emission factors for chromium and nickel based
on oB/oD rest results of 1.3x10-5 and 3.6x10-s lb[b, respectively.
However, Table 2-r and Appendix A of the HHRA Report, and the ATK
Launch Systems Human Health Risk Assessment Protocol for the
Evaluation of the open Burning and open Detonation units at
Promontory, Utah-, dated August 2014 (HHRA Protocol) list emission
factors of 2.0x10-) lb/lb for chromium and 5.8x10-5 lb/lb for nickel. Based
on the information contained in the text and appendices of the HHRA
Report, it is not clear why the values presented in Section 10.1.2.4 are less
than those used in the HHRA.
Response:
Table 2-1 shows the chromium and nickel based on OB/OD test results of
2.0x10 s and 5.8x10-5 lbnb, respectively, which are based on the emissions from
85 percent AP and 15 percent trash (ATK,2007 , Table 8). These are the highestchromium and nickel levels found in any of the test runs conducted in ZO07 , andwere used in the HHRA because they are the most conservative emissions factors
available from these tests. The emissions rates used in the uncertainty section(Section 10.1.2.4) are from the 100 Vo Ap test burn.
If it is assumed that the AP waste is the only source of chromium available, and
there is no chromium in the trash, the amount of chromium available would begiven by rhe following:
Evaluation: The assumption that the AP waste is the sole source of chromium should be
strengthened if possible. Provide a discr-rssion that compares the chromium results foreach of the waste streams addressed in the OB/OD tests and draws conclusions regarding
the amount of Cr in the trash (e.g., the amount of trash in the waste stream does not
appear to significantly impact the value of the Cr emission factors determined during the
OB/OD tests).
Response to Evaluation: The following discussion will be added to the end of Section
10.1.2.4.2 to support the assumption that the chromium source is the AP Waste: "The
highest chromium emissions rate (2.0x10-s; from the 2007 OB/OD tests was used in the
HHRA. This value was the highest emissions factor of all of the tests and represents the
85Vo AP waste 75Vo trash test. The amount of trash in the waste sheam does not appear
to significantly impact the value of the Cr emission factor. This can be seen from the fact
that as the amount of trash in the waste increases from I5Vo to 35Va, the Cr emission
factor decreases from 2.0x l0-s to l.6xl0--s."
cr = 2.0' 1s-s (rb /ro) ,(#) x 3.2 x(#) x 106 : 0.4 (*n / un) t,
Ni = 5.8 ' 16-s(rb /,r) *(#) x 2e.t' (#) x 106 = 26s.2 (^n /un)
Evaluation: The above equation for nickel results rn 229.7 mg/kg and not 265.2 mg/kg.
Review this equation and revise it for consistency with the equation for Ni presented in
the General Response for estimating the amount of nickel released from the waste during
the OB/OD tests.
Response to Evaluation: The nickel equation in question has been conected such that the
result is 229.5 mglkg. This change affects only the nickel adjustment factor, which is
explained and presented in Appendix F. Please see the response directly following this
one for more explanation on the nickel adjustment factor.
Where:
2.0x10-5 (lbnb) is the emissions rate for chromium from 85Vo APlI5Vo trash,
Or 2.0x10-' (kg/kg)
And, 5.8xlOr (UnU) is the emissions rate for nickel fromS5Vo APlI5To trash,
Or 5.8x10-t (tglt g)
16/100 is 16%o aluminum in the AP waste
20 (mglkg) is the chromium content in the aluminum in the AP waste
85/100 is the 857o AP waste in the test burn
106 is a conversion factor from kg to mg
Evaluation: The emission factor cited above for nickel in85Vo AP/l|c/o trash (5.8x10 s)
does not agree with the value cited for nickel in857o AP/I5Vo trash (6.7x10 s) as part of
the Generil Response for estimating the amount of nickel released from the waste during
the OB/OD tests. Review these two discussions and ensure that the appropriate emission
factor is used for nickel. Please ensure that the correct value is used in the revised HHRA
report.
t0
Response to Evaluation: The colrect emissions factor for nickel in 85Va AP/157o trash is
5.8xl0 ). The incorrect emission factol(6.7xl0-5) has been removed from the report,
and it has been conected in the General Response on page 4 of this document. The
correct value has also been r-rpdated in Appendix F, and this resulted in a slight change in
the nickel adjustment factor that was applied in Appendix F and the new tables in Section
10 (10-1 through l0-10). The nickel adjr"rstment factor was changed from 0.015 to 0.017
based on using the correct emission factor of 5.8x l0'. This slight change did not affect
the adjusted Acute Haz'aad Quotients or the adjusted Chronic risks/hazards that were
submitted in June, because the slight increase in the nickel adjustment factor only
changed the value in the third decimal place, and the risks and hazards are presented with
one or two decimal places.
The text will be revised to use the emissions factors from the HHRA.
Evaluation: The intent of the sentence "The text will be revised to use the emission
factors from the HHRA" is unclear. To eliminate confusion, the text of the HHRA
should be revised to indicate the source (e.g., Class 1.3 wastes for 85/15 waste stream) of
all cited emission factors.
Response to Evaluation: The emissions factors used in the HHRA were taken frorn the
85/15 waste stream OB/OD. Any other emission factors presented in Section l0 are now
labeled to avoid confusion (e.g., 100%o AP Waste, 857o AP Waste/l 57a Trash, or 65Vo AP
Wastel35%c Trash).
Revise Section 10.1.2.4 to address each of these issues. Once all issues related to
Section 10.L.2.4 are adequately addressed, the impact of chromium and nickel
emissions on the calculated acute HIs for inhalation, the chronic HIs, should be
reassessed and the HHRA Report revised accordingly.
Response:
The emissions factors agreed upon with the Division of Solid and Hazardous
Waste were used in the HHRA. The adjusted emissions factors for nickel and
chromium are used to calculate Acute Hazard Indices that reflect a subtraction of
what is believed to be chromium and nickel added to the emissions from the test
pans. The results are provided above in Table 1.
2. Sections 3,6.I, M-136 Stations, and3.6.2,M-225 Stations, reference Section 4,
Compliance with NAAQS, of the HHRA Report for the criterial pollutant
emission rates used in the National Ambient Air Quality Standards (NAAQS) and
Utah Toxic Screening Level (TSL) analyses. The emission rates were not found
in Section 4.0. The emission rates were found in Sections 4.5.1 (Tables 4-2 and
4-3), and 4.5.2 (Tables 4-5, and 4-6) of the Air Modeling Report. To improve
transparency and clarity in the HHRA Report, it is recommended that the
references to Section 4 in Sections 3.6. I and3.6.2 be modified to identify the
tables in Sections 4.5.I and 4.5.2 of the Air Modeling Report as the source for
ll
NAAQS and air toxics emission rates. A reference citation should be provided
for both documents as well. Revise Sections 3.6.1 and 3.6.2 to address this issue.
Response:
Sections 3.6.1 and 3.6.2 will be revised to include a reference to the Air Modelins
Report.
3. The non-cancer HIs, ELCRs, and the average daily doses (ADDs) listed in Tables
9-1 through 9-18 are presented with two significant figures to the right of the
decimal point. Tables ES-1 through ES-3 list the acute (short-term) HIs with one
significant figure to the right of the decimal point. Tables ES-4 through ES-6 list
all ELCR values with one significant figure and all HIs with two significant
figures to the right of the decimal point. [n general, HI values appearing in the
text of Section 9, Characterizing Risk and Hazard, are presented with two
significant figures and ELCR values are presented with one. For consistency, it is
recommended that calculated HI, ELCR, and ADD values be presented in the text
and the tables supporting the Executive Summary and Section 9 with one
significant figure to the right of the decimal point. A reference can be provided to
Appendix D for those readers who wish to see the results expressed with
additional precision. Scientific notation should be used for small values of HI if
necessary. Revise the HHRA Report to address this issue.
Response:
The report will be revised to provide all of the numbers to one significant figure
to the right of the decimal point.
4. In Section 5.1, Characterizing the Exposure Setting, at the bottom of page 39, it is
stated "As shown on Table 4-4 rn the TetraTech Air Dispersion Modeling Report
(TetraTech, 2011b), the predominant wind direction is from northwest through
northeast." Table 4-4 could not be found in the referenced document and it
appears that the locations of maximum off-site and on-site summed risks and
hazard indices (shown on Figure 9-9 of the HHRA Report) do not support the
statement on predominant wind direction. These maximum locations are shown
to be north and northwest of the M-136 Burn Grounds. Please revise the HHRA
Report to address this issue.
Response:
The locations where maximum impacts occurred were taken from the Air Quality
Modeling Report. The information in this report will be provided to correct
discrepancies related to wind direction in the text. The locations of maximum off-
site and on-site risks and hazard indices are consistent with past modeling and are
believed to be correct.
Evaluation: In revising the text of the HHRA report to address the issue raised in
General Comment 4, ensure the revised discussion is explicit and consistent in describing
wind directions as "blowing from" or "blowins toward."
t2
Response to Evaluation: In order to avoid confusion, the following sentence will be
renroved from Section 5.1: "As shown on Table 4-4 in the TetraTech air dispersion
rnodeling report (TetraTech, 201lb), the predominant wind direction is from northwest
through the northeast." The table that was referenced is contained in the 201 I Tetra Tech
Waste Characterization and Air Dispersion Modeling Protocol. However, upon review of
the table, it does not appear that any conclusive statements can be made regarding a
single, prevailing wind direction. Also, a review of the final CB&I air dispersion
modeling report revealed that the prevailing wind direction was not stated. However, the
CB&I modeling report stated that the four facility boundary receptors were selected
based on "the annual prevailing wind directions that are measured over a five-year period
(1991 through 2001 ) at the M-245 meteorological monitoring station." Those four
receptors are located all around the M 136 and M225 source areas, no single cardinal
direction is provided from the solrrce area, indicating a single prevailing wind direction
fbr the Facility was nbt specifically provided. The meteorological data were incorporated
in the model directly. This inforrnation is already contained in Section 5. l, so no other
revisions were made to that section.
SPECIFIC COMMENTS
1. Executive summary, open Burn open Detonation Human Health Risk
Assessment for Promontory, Page ES-l: The second sentence of the first
paragraph of the Executive Summary states "The location of the Promontory
Facility is shown on Figure ES-1." While the general location of the facility can
be discerned from the figure, the exact location cannot be determined as the
facility boundary is not included. Revise Figure ES-1 to include the facility
boundary lines.
Response:
The facility boundary was added to Figures ES-l and 1-1. They are attached andwill be included in the revised HHRA.
2. Executive summary, open Burn open Detonation Human Health Risk
Assessment for Promontory, Page ES-l: The labt paragraph on Page ES-1 notes"Short-term risks are greater than one on-site due to nickel, but the source of this
nickel is believed to be the test ignition wire and the tray used in the test." No
additional information on the test and the source of the nickel is provided. The
quoted discussion should be clarified to indicate that the Acute HI was greater
than one; to identify the test referred to in the text; and to indicate that the impact
of the nickel in the test ignition wire and burn tray is addressed in Sections 2, 9,
and l0 of the HHRA Report. Revise the last paragraph on Page ES-1 to address
these issues.
Response:
This comment is partially addressed in the responses to the General Comments,
and to a greater extent in Section 10, the uncertainty section of the revised risk
13
assessment. In the text we show that the AP-waste might have low (part per
million) levels of chromium and nickel in the aluminum that is in the propellant,
but that these levels of chromium and nickel would lead to emissions that are far
lower than actually measured in the emissions tests. The "extra" chromium and
nickel are most likely due to the pans and igniters used in the OB/OD test.
Revised acute Hazard Quotients are calculated with and without the estimated
level of chromium and nickel from the test. These tables show that when the
extra chromium and nickel are removed the acute hazards are lower, and below
one for all receptors.
Further, ATK has demonstrated that the chromium and nickel released would be
bound into small agglomerations of aluminum and so are not as bio-available as
the toxicology test used to determine the potency of nickel for determining the
acute (1-hour) dose-response used to determine the HQ in the risk assessment.
The supporting documentation is also provided in Section 10 of the HHRA.
3. Executive Summary, Open Burn Open Detonation Human Health Risk
Assessment for Promontory, Page ES-6: The third paragraph on Page ES-6
indicates the results listed in Tables ES-5 and ES-6 are also shown on Figures EC-
3 and EC-4. However, Figures EC-3 and EC-4 were not included among the
figures submitted with the HHRA Report. Also note that the HHRA Report does
not include or reference Figure EC-z. Please ensure that Figures EC-3 and EC-4
are included with all subsequent submittals of the HHRA Report and that the
figures associated with the Executive Summary are properly numbered.
Response:
The sentence referring to Figures EC-3 and EC-4 will be deleted from the report.
All of the relevant information is contained in Tables ES-5 and ES-6.
4. Section 2.5, M-136 Stations, PageT: In the first paragraph of this section, it is
stated that six of the 12 stations located closest to the western property line
(Stations 1,4,7,8, 10 and 11) are modeled as six separate sources and Burn
Stations 1 3 and 14 are modeled separately. Are Station s 2, 3, 5, 6, 9 and 12
modeled as one source then? Please clarify this paragraph.
Response:
The paragraph has been modified to read:
M-136 has 14 burn stations (1 through la) and any one of the following alternative and
mutually exclusive scenarios could occur in these stations:
o A1: OB in six of Burn Stations 1 through 12 at 16,000 pounds (lbs) in each
station totaling 96,000 lbs reactive waste weight per event
o A2 10,000lbs reactive waste weight per event in Burn Station 13
o 43: 16,000lbs reactive waste weight per event in Burn Station 14
o B: OB of 125,000 lbs of large rocket motors in Station 14
o C: OD of 600 lbs reactive waste in Stations 13 and 14 each, totaling 1,200 lbs
reactive waste weight Per event
t4
At M-136 A1, burn stations 1 through L2 are clustered within 100 meters of each other.
Six of the 12 stations are located closest to the western property line (Stations 1, 4, 7, 8,
10, and 1 1) and six are further from the boundary. The six areas near the boundary are
modeled as six separate sources and used in the HHRA because their use in the model is
more conservative. The other stations (Stations 2,3, 5,6, 9 and 12) are used by ATK but
were not modeled as they are further from the boundary. Burn Stations 13 and 14 are
modeled separately.
5. Section 2.9.1.1, Metals, Page 11: The second sentence of the second paragraph
in Section 2.9.1.1 indicates the stainless steel pans used in the OB/OD emission
tests sponsored by ATK Promontory contained l57o chromium and I4Vo nickel.
However, a reference is not provided for the source of these weight percentages.
Revise Section 2.9.1.1 to include a reference citation for the source of the weight
percentages for chromium and nickel in the burn trays used in the OB/OD tests.
Ensure the information source is listed in Section 11, References. of the HHRA
Report.
Response: The reference for the weight percentages will be added to Section 2.9.I.1.
It is as follows: Type 316 stainless steel contains high levels of chromium and nickel. In
type 316 steel, the chromium content is reduced from lSVo found in other formulations to
I6Vo, and the nickel content is increased from 8Vo to I0-I6Vo, forming austenitic steel
which also contains 2-3Vo molybdenum. (www.bosunsupplies.com)
Evaluation: In addition to the information provided in the response, the text of the
HHRA repofi should also include a sentence that ties the cited values of chromium and
nickel in type 3 l6 stainless steel to the pans used in the OB/OD tests. For example, a
sentence stating that the pans used in the OB/OD tests were constructed of Type 316
stainless steel would address UDEQ's concern.
Response to Evaluation: Section 2.9.1.1 will be revised as follows: "The pans used in the
OB/OD test burns were Type 316 stainless steel (see Appendix F), which contain high
levels of chrornium and nickel. In Type 316 steel, the chromium content is reduced from
l8% fournd in other formulations to 167o, and the nickel content is increased from 8Zo to
l0-l6vo, forming austenitic steel which also contains z-3vo molybdenum
( www.bosunsupolies.com)."
6. section 2.ll.l.3rPolynuclear Aromatic Hydrocarbons (pAHs), page
17: The first paragraph of Section 2.II.I.3 refers to indeno(1 ,2,3-cd)pyrene as a"complex six (or more) aromatic ring" compound. However, indeno(1,2,3-
cd)pyrene has five aromatic rings and six total rings. Revise Section 2.1I.1.3 to
indicate that indeno(1,2,3-cd)pyrene has five aromatic rings.
Response:
The paragraph has been revised to read:
t5
PAHs are a broad class of chemical compounds, ranging from two aromatic ring
compounds, such as naphthalene, to complex six (or more) aromatic ring
compounds such as benzo(ghi)perylene.
In the next paragraph in this Section, it is indicated that fluoranthene, a three
aromatic ring PAH with four total rings, was detected in the ODOBi test in 5 of
18 samples. In the following paragraph it is stated that no four ring PAHs were
detected. Please clarify that no four, five or six aromatic ring PAHs were detected
and ensure that the number of aromatic rings are used (as opposed to total rings)
when PAHs are discussed in the report.
Response:
The text has been revised to read:
For example, the two aromatic ring PAH naphthalene is detected in 16 of l8
samples, compared with three ring aromatic PAHs, phenanthrene (detected in 8 of
18 samples), and the three aromatic ring fluoranthene, (four rings total) was
detected in 5 of 18 samples
Evaluation: ln addition to the revision noted in the above response the text of the
HHRA report should also be revised to clarify that no four, five or six aromatic ring
PAHs were detected. In addition, ensllre that all discussion of PAH rings in the HHRA
report are based on the number of aromatic rings and not the number of total rings.
Response to Evaluation: Section 2.11.1.3 describes the process of selecting the enrissions
f-actors for PAHs. In this section it conectly states that no PAHs with four, five or six
aromatic rings were detected in any sample when Class 1.3 Propellant wils burned.
Because the risk assessment required the use of a method detection limit in the
calculation of risk, the method detection limit fbr higher molecular weight PAH from
Class 1.1 Propellant was used because four and five aromatic ring PAHs were detected'
In order to clarify aromatic rings versns total rings, the fbllowing sentence of the text was
revised: "In 1.3-Class propellant tests, only three aromatic ring PAHs are detected. As
described above, the higher emissions factors of the 1.3- or 1.1-Class AP propellant will
be evaluated quantitatively."
7. Section 2.ll.l.3,Polynuclear Aromatic Hydrocarbons (PAHs)' Page L9: The
last paragraph on Page 19 begins "With the exception of small quantities of
naphthalene and its alkylated sister compounds, emission products larger than the
molecules in the EM were not found in the detonation and burn plumes." For
clarity revise the quoted sentence to include a parenthetical definition of EM.
Response:
The sentence has been revised to read:
With the exception of small quantities of naphthalene and its alkylated sister
compounds, emission products larger than the molecules in the EM (Energetic
Materials) were not found in the detonation and burn plumes.
t6
8. Section 2.13, Category E/Flare Wastes, Page 232 In the last paragraph on page
23,itis stated that "the toxicological information on many of these chemicals is
unavailable, and the table below shows information that is available." There isn't
a table below this section showing this information. Should "table below" be
changed to "Table 2-3"?
Response:
The text has been modified to read:
The toxicological information on many of these chemicals is unavailable, and the
information that is available is provided in Table 2-3.
In addition, the last paragraph on Page 23 includes the sentence "I€ad has been
discussed previously." A discussion of lead, prior to Page 23, was not found in the
HHRA Report. In addition, it is not clear why the quoted sentence has been
included in Section 2.13 as the discussion is focused on the metals associated with
Category ElFlare Wastes that are not included in other waste streams at ATK
Promontory (e.9., boron, bismuth, cesium, indium, iron, silicon, tin, zinc, and
zirconium). Review the discussion in the last paragraph on page 23 and
determine if a discussion of lead is appropriate. If not, delete the quoted sentence
from the text.
Response:
The sentence on lead has been deleted.
9. section 2.14, Emission Factors, Page 26: The first sentence onpage26
indicates that calculated soil lead concentrations were less than 400 mg/kg at all
locations. It is recommended that this discussion be expanded to note that the
analysis of lead in soils is detailedin Section 9.6,1-eadin Soils. Revise the text to
address this issue.
Response:
The text has been revised to read:
The risks are evaluated by comparing the Lakes model calculated soil lead
concentrations to the US EPA default residential lead goal of 400 milligr:rms per
kilogram (mg/kg). [,ead has been shown to have neurological effects, and young
children are particularly susceptible to the effects of lead. The US EPA evaluates
lead using a bio-uptake model call the Integrated Exposure Uptake Bio-kinetic(IEUBK) model, which calculates potential blood lead concentrations based on
exposure to media, food and water. The estimated blood lead levels are compared
with acceptable blood lead levels for children. This model was used by the EpA
to calculate a soil lead level below which no adverse effects on children would be
expected. This acceptable soil lead concentration is 400 mg/kg (EPA, 2OO2). The
calculated soil lead concentrations at all locations are well below (by a factor of
several thousand) 400 mg/kg and no further processing is necessary. More
I7
details on the soil lead concentrations and the comparison to the EPA's acceptable
lead level are provided in Section 9.6.
10. Section 2.L4, Emission Factors, Page 262 Page 26 includes an in-text table that
lists emission factors for 2,3,7,8-TCDD as a single constituent and as a toxicity
equivalent (defined in the table as TCDD - TE). The values listed are results
obtained from an analysis of the dioxin/furan emissions from 1.3-Class and 1.1-
Class wastes treated by OB/OD at ATK Promontory. However, the details of the
analysis of dioxin/furan emissions are not provided. In addition, note that the
paragraph prior to the in-text table refers to the HHRAP when a reference to the
HHRA is more appropriate. Revise the HHRA Report to include a summary of
the dioxin/furan emissions analysis as an appendix. In addition, eliminate the
reference to the HHRAP on Page 26 andreplace it with a reference to the HHRA.
Response:
This section has been deleted and a revised section has been added. This section
reads as shown below, and a new Appendix (Appendix B) has been added.
The class of chemicals called dioxins is a mixture of similarly structured
compounds or congeners, with many different congeners in the class. When
selecting the emissions factors for this class of compounds the data were
examined to determine which class of AP propellant (Class 1.1 or Class 1.3)
would have the highest risk, and that Class was selected. This was achieved by
multiplying the emissions (pound of dioxin per pounds of waste processed) for
each class of dioxin and difurans by the 2,3,7 ,8-TCDD-Toxicity Equivalence
Factor (TCDD-TEF) (shown in Table 2-4), and summing the results for all
compounds in the class. The emissions factors for each class, the TCDD-TEF, the
method used, and the results of the analysis are shown in Appendix B.
Based on the calculation in Appendix B, the 1.3-Class propellant emissions factor
has more dioxin risk than the 1.l-Class, and therefore the 1.3-Class emissions are
considered the higher, and are used to represent emissions from ATK materials.
Section 3.3.1.1, Open Burning, Page32: The discussion on Page32 describes
the procedure used to determine vapor cloud heights for specified combinations of
the atmospheric stability class and wind speeds. This discussion mentions the
2013 air modeling protocol but does not include a formal reference to the
document. Additional information on the procedure used and the results of the
analysis are available in the Addendum to the Revised Air Dispersion Modeling
Report for Open Burning and Open Detonation at ATK Launch Systems in
Promontory, Utah dated June 2OI4 (Air Modeling Report) and the HHRA Protocol.
However, these information sources are neither identified nor referenced. To
improve the transparency and clarity of the HHRA Report, it is recommended that
the Air Modeling Report and HHRA Protocol be included in the discussion as
sources of additional information. In addition, all three documents should be
11.
t8
formally referenced. Revise Section 3.3.I.1 to address this issue and ensure the
2013 Hybrid Air Modeling Protocol is added to Section 11, References.
Response:
This comment has been addressed by adding text at various locations throughout
the HHRA, as described below.
Section 1.4 has been revised to include the following:
As a result of this guidance document, Lakes Environmental, Ontario, Canada
developed a software product that calculated short-term hazards and long-term
hazards and risks based on the equations and parameters in EPA, 2005 (Lakes,
2Ol4). The Lakes risk assessment model was approved by EPA for incineration
projects. However, dose-response and default exposure assumptions change from
time to time, and this HHRA is based on a Utah DSHW protocol developed by
ATK (ATK,2OI4a). The HHRA protocol also incorporates EPA's most recent
default exposure assumptions (EPA, 2014a), dose-response information (EPA,
2014b;EPA,2OI4c), and other modifications that were approved by the Utah
DSHW, as of November 2014, prior to conducting the HHRA.
Evaluation: The clanse reading "and this HHRA is based on a Utah DSHW protocol
developed by ATK (ATK, 2}l4a)" should be revised to read "and this HHRA is based on
a protocol developed by ATK (ATK, 2014a) which was accepted and approved by
UDEQ DSHW."
Response to Evaluation: The text in Section 1.4 has been revised as suggested.
Section 3.3.1.1 has been revised to include the following:
The CB&I (2014b) air modeling protocol (Section 4.2) describes the modeling
process and the parameters used in the model related to the release height.
And later in the text the followins has been added:
The assumed conditions for this burn assumed the most conservative
meteorological conditions (lowest dispersion) under normal operating conditions.
The resulting vapor cloud heights are then applied to each of the other identical
burn stations for that scenario. The results of the open burn model are used by the
air dispersion portion of the model, and the output files are used by the Lakes risk
model (Lakes, 2014) without modification.
section 3.4.1.2, open Detonation, Pages 33 and 34: The discussion at the
bottom of Page 33 and continuing at the top of Page 34 summarizes the
application of Equation 2-'75 from volume 2 of the oBoDM {Jser's Guide to
calculate initial vapor cloud dimensions. This discussion is derived from the Air
12.
t9
Modeling Report. However, the Air Modeling Report has not been identified or
referenced in the discussion. Revise Section 3.4.I.2 to identify and reference the
Air Modeling Report as the source of the information contained in Section
3.4.r.2.
Response:
The text has been revised to include the following:
Based on the Utah DsHw-approved model developed for the project by CB&I
(2014) and per AERMOD guidance.. ...
In addition, citations WDTC, 1998a and 1998b, have been added for the OBODM
users guide:
WDTC, 1998a Open Burn/Open Detonation Dispersion Model User's Guide,
Volume I,Ijser's Instructions, DPG Document No. DPG-TR-96-008a, SERDP,
U.S. Army Dugway Proving Ground, Utah, February
WDTC, 1998b Open Burn/Open Detonation Dispersion Model User's Guide,
Volume II, Technical Description, DPG Document No. DPG-TR-96-008a,
SERDP, U.S. Army Dugway Proving Ground, Utah, February
13. Section 4.L, National Ambient Air Quality Standards, Page 37 and Table 4-1,
Criteria Pollutants Considered in NAAQS Compliance Demonstration, Page
109: The first paragraph of Section 4.1 references Table 4-l to demonstrate that
none of the NAAQS are exceeded as a result of OB/OD treatment at ATK
Promontory. However, carbon monoxide (CO) and lead (Pb) are not listed in the
body of Table 4-1. Note 1 at the bottom of the table states: "This table is taken
from CB&I's 2014, Air Quality Modeling Report. Carbon monoxide and lead
NAAQS were not included because preliminary modeling...showed compliance
with NAAQS." For clarity, transparency, and completeness in presenting risk-
related information in the HHRA Report, Table 4-1 should be revised to list CO
and Pb in the table body. In addition, note 1 should be revised to indicate that CO
and Pb information was taken from the CB&I Modeling Report and that
compliance was demonstrated in the Revised Air Dispersion Modeling
Assessment Report for Open Burn and Open Detonation Treatment Units at ATK
Launch Systems dated July 2012." Revise Table 4-1 to address this issue.
Response:
Table 4-1 was revised to provide the carbon monoxide and lead concentrations
calculated by CB&I, and TetraTech, and citations to their work are provided in
the table.
20
T.q'nln 4-l
CnrrnRrl Por,r,ur,llrs CoNSTnERED rN NAAQS Coupr,rlNcn DnlroNSTRATroN
Criteria
Pollutant Source
NAAQS
averaging
time
Design Model
Concentration Method of Determination of Design Value
PM-IO (a)24-Hour 150 pglm3 Sixth highest of 5 years of meteorological data
PM-2.5 (a)24-Hour 35 pg/m3 Average of first highest of 5 years of meteorological
data
PM-2.5 (a)Annual 12 pglm3 Average of first highest of 5 years of meteorological
data
Soz (a)l-Hour 75 ppb
(195 pglm3)
Five-year average ofthe 99th percentile (4th highest)
of the annual distribution of daily maximum l-hour
average concentrations
Soz (a)3-Hour 1,300 pglm3 Five-year average of 2nd highest (not to be exceeded
once per year)
Noz (a)l-Hour 100 ppb
il89 pglm3)
Five-year average ofthe 98th percentile (Sth highest)
of the annual distribution of daily maximum l -hour
average concentrations
Noz (a)Annual 100 pglm3 Maximum over 5 years of meteorological data
CO (a)l-Hour 40,000 pglm3 Average of first highest of 5 years of meteorological
data
(a)8-Hour 10,000 pg/m3 Average of first highest of 5 years of meteorological
data
Lead (b)3-Month
Rolling
Average
0.15 trrg/m3 l00tn percentile; maximum over 3 years of
meteorological data
Abbreviations:
PM-10 = Particulate matter (10 micrometers in diameter)
PM-2.5 = Particulate matter (2.5 micrometers in diameter)
NO2 - Nitrogen dioxide.
S02 = Sulful 6i.)(;4..
CO = Carbon monoxide
ppb = Parts per billion.
Fdm-'= Micrograms per cubic meter
(a) From: CB&I' 2014b, Addendum to the Revised Air Dispersion Modeling Report for Open Burning and Open Detonation
at ATK Launch Systems in Promontory, Table 9-l(b) From: TetraTech,20l2b, Revised Air Dispersion Modeling Assessment Report for Open Bum and Open DeronationTreatment Units at ATK Launch Systems, Table 3-69 and Table 3-71.
21
14.Section 4.L, National Ambient Air Quality Standards, Page 37 and Table 4-2,
Criteria Pollutants Considered in NAAQS Compliance Demonstration, Page
110: The sentence of Section 4.1 references Table 4-2 to demonstrate that
cumulative results for criteria pollutants do not exceed the NAAQS for OB/OD
treatment at ATK Promontory. However, Pb is not listed in the body of the table.
For clarity, transparency, and completeness in presenting risk-related information
in the HHRA Report, Table 4-2 should be revised to list Pb in the table body. In
addition, a note should be added to indicate that Pb compliance was demonstrated
in the Revised Air Dispersion Modeling Assessment Report for Open Burn and
Open Detonation Treatment Units at ATK Launch Systems dated July 2012."
Revise Table 4-2 to address this issue.
Response:
Table 4-2 was revised to provide the carbon monoxide and lead concentrations
calculated by CB&I, and TetraTech, and citations to their work are provided in
the tables. The Table indicates that both carbon monoxide and lead
concentrations are below the NAAQS.
22
Ttw"n 4-2
Rnsulrs or Cuuur,ATrvE llrplcr ron M-136lNn M-225
Cnrrnnn PolluuNrs
COPC Source Averaging
Time
Sub-
source Rank
Design
Model
Conc.
@elm')
NAAQS
@etm3)
Percent
of
NAAQS
Exceedance
of NAAQS?
(Yes/No)
PM-2.5 (a)
24-HR
MI36 A sl 25.00 35 7 l%o No
M225_A SI 1.48 35 4.2 7o No
Total st 26.49 35 75.7Vo No
Annual
M136_4,st 5.75 t2 48Vo No
M225 A St 0.05 t2 0.4Vo No
Total 5.8 r 2 48.47o No
PM-IO (a)24-Hr
MI36 A st 57.14 50 38.17o No
M225_A 3.65 50 2.4Vo No
Total 60.79 50 40.57o No
Noz (a)
l-Hr
MI36 A sl 64.01 89 33.9Vo No
M225_A st 3.79 89 2.OVo No
Total st 67.80 89 35.9Vo No
Annual
Ml36_.4 1"o.70 00 0.lVo No
M225 A lt'0.007 00 O.lVo No
Total l*o.71 00 0.7Vo No
Soz (a)
l-Hr
M136_A l"5.00 95 2.6Vo No
M225_A l*0.30 95 0.27o No
Total ltt 5.30 95 2.77o No
3-HR
M136 A lt'1.67 300 o.tvo No
M225_A l*0.10 1300 0.lVo No
Total l"1.7'7 I 300 O.lVo No
CO (a)
I-HR
M136_A lt'64.01 40,000 O.2Vo No
M225 A lt'3.79 40,000 0.lVo No
Total lt'67.80 40,000 O.8Vo No
8-HR
MI36 A l"8.00 10,000 O.l7o No
M225_A l*0.41 t0.000 0.17o No
Total lt'8.48 10,000 O.lVo No
Lead (b)3-Month
M136,
Sources l-3
(comparable
ro Ml36_A)
lt'
0.03 0.15 2OVo No
M136,
Source 4
(comparable
to Ml36_C)
ltt
0.05 0.15 33.3Vo No
23
Tnsrr.4-2
Rnsulrs op Cuuur,ATrvE Ivrpacr ron M-136lNo M-225
Cnrrnnll Por,r,uunrs
COPC Source Averaging
Time
Sub-
source Rank
Design
Model
Conc.
Qt{^')
NAAQS
(pglm')
Percent
of
NAAQS
Exceedance
of NAAQS?
(Yes/1.{o)
M225,
Source I
(comparable
toM225_A)
l"
0.01 0.15 6.7Vo No
Abbreviations:
l-Hr = l-Hour 24-Hr = 24-Hour
8-Hr = S-Hour ltt = First
Conc. = Concentration COPC = Chemical of Potential Concern
PM-10 = Particulate matter (10 micrometers) PM-2.5 = Particulate matter (2.5 micrometers)
NO2 = frJi6egen dioxide. SO2; Sulfur dioxide.
ppb = Parts per billion. pg/m' - Micrograms per cubic meter
Vo = Percent NAAQS = National Ambient Air Quality Standard
Notes:
(a) From: CB&I, 2}l4b , Addendum to the Revised Air Dispersion Modeling Report for Open Burning and Open
Detonation at ATK Launch Systems in Promontory, Table 9-l
(b) From: From: TetraTech,2}l2b, Revised Air Dispersion Modeling Assessment Report for Open Burn and
Open Detonation Treatment Units at ATK Launch Systems.
15.Section 4.3, Quantitatively Estimating Acute Non-Cancer Hazard, Page 38:
The last sentence in Section 4.3 indicates that COPC concentrations are compared
to Cal EPA PAC-1 concentrations and DoD AERGL-1 air concentrations.
However. the discussion does not mention that the criteria used in assessing Acute
Non-Cancer Hazard were identified and selected based on the hierarchy presented
in EPA's 2005 HHRAP. For clarity, transparency, and completeness, revise
Section 4.3 to indicate that acute inhalation exposure concentrations (AIECs)
were identified and selected based on the hierarchy presented in Section 7.4.1
Existing Hierarchical Approaches for Acute Inhalation Exposure, of EPA's 2005
HHRAP.
Response:
The section has been revised to read as follows:
In the ATK risk assessment protocol (ATK, 2014a), was prepared to address potential
short-term and long-term adverse health effects. Based on EPA's 2005 Incineration
Guidance (EPA, 2OO5; Section 7), short-term ambient air concentrations are evaluated
by comparison to short-term air criteria developed from short-term dose-response
studies in humans and animals. The source of short-term criteria is selected based on
24
the following hierarchy, which is consistent with HHRAP Section 7.4.1 Existing
Hierarchical Approaches for Acute Inhalation Exposure (EPA, 2OO5):
l. Cal/EPA Acute Reference Exposure Levels (RELs) - the concentration in air at or
below which no adverse health effects are anticipated in the general population,
including sensitive individuals, for a specified exposure period (Cal EPA, 1999,
or more recent version).
2. Acute inhalation exposure guidelines (AEGL-l) - "the airborne concentration of a
substance above which it is predicted that the general population, including
susceptible individuals, could experience notable discomfort, irritation, or certain
asymptomatic non-sensory effects. However, the effects are not disabling and are
transient and reversible upon cessation of exposure." (NOAA, z0or, or more
recent version).
3. Level I emergency planning guidelines (ERPG-I) - "the maximum concentration
in air below which it is believed nearly all individuals could be exposed for up to
one hour without experiencing other than mild transient adverse effects or
perceiving a clearly defined objectionable odor." (DoE 2ool; scApA 2001, or
more recent version).
4. Temporary emergency exposure limits (TEEL-l) - "the maximum concentration
in air below which it is believed nearly all individuals could be exposed without
experiencing other than mild transient adverse health effects or perceiving a
clearly defined objectionable odor." (DoE, 200r; scApA, 2001, or more recent
version).
5. AEGL-? values - "the airborne concentration of a substance above which it is
predicted that the general population, including susceptible individuals, could
experience irreversible or other serious, long-lasting adverse health effects or an
impaired ability to escape." AEGL-} values are to be used only if lower ERPG-I
or TEEL-1 values are not available. (NOAA, 2001), or more recent version.
In the evaluation of acute risk, (l-hour) modeled air concentrations were compared
with the short-term (1-hour) air goal concentrations selected using this hierarchy (See
25
Section 8, and Table 8-2). The most recent sources of short-term air concentrations
are available from Cal-EPA and the Department of Defense (DOD). Where these
sources did not contain a short-term air goal, a surrogate value was developed based
on carbon chain length, structure and class of chemical (using professional judgment)
(see Section 8, Table 8-l). The list of l-hour acceptable air concentrations (Table 8-
2) was developed and presented to the Utah DSHW, who agreed with the use of these
values. To determine the potential exposure to short-term emissions, estimates of
acute (l-hour) hazards from air emissions are calculated. The estimated l-hour
ambient air concentrations for all 2009 COPCs are generated from the air quality
model and evaluated in the Lakes software (Lakes, 2014). The COPC concentration
is compared with its California EPA (Cal EPA) PAC-I concentration (Cal EPA,
2Ol3), if available, or the Department of Defense AEGL-I air concentration (DOE,
2Ol2). This analysis is provided in Section 9-1 of this report.
L6. Section 5.1.L, Current and Reasonable Potential Future Land Use, Page 41:
This paragraph is confusing; it states that "it is possible for the area within the
facility boundaries to be developed for residential or agricultural use if the facility
is closed in the future." Then it states that "Therefore, future exposures are
evaluated for a farmer and resident scenario at the point of maximum risk located
off-site, and a future worker scenario (is) evaluated for the point of maximum risk
located on-site." Please provide additional information to clarify why this
approach was taken.
Response:
The text has been revised as follows:
The current land use is considered in this risk assessment. In addition, while
farmers or residents are not currently located within the facility boundaries it is
possible for the area within the facility boundaries to be developed for residential
or agricultural use if the facility was closed in the future. Risks would be
estimated and reevaluated at some point in the future if the facility closed and on-
site redevelopment took place. Therefore, future exposures considered in this
HHRA include the evaluation of a farmer and resident scenario at the point of
maximum risk located off-site, and a future worker scenario evaluated for the
point of maximum risk located on-site.
17. Section s.l.z,Water Bodies and their Associated Watershed,Page 4lz
It is stated near the end of this paragraph that "based on discussions with the Utah
DSHW, this water body (Blue Creek) is unlikely to be significantly impacted by
ATK's treatment operations." Please revise the text to indicate that, based on
discussions with the Utah DSHW, it was agreed to follow the HHRAP guidance.
26
18.
Response:
The text in Section 5.1.2 will be revised as follows:
There is a creek on the western side of the Facility, but the water is of poor quality
because it has high total dissolved solids and minerals. It is a small stream that has
eroded a channel approximately 2o feet deep where it runs across ATK property,
making it largely inaccessible to cattle and humans. While the water in Blue
Creek is potentially accessible by livestock approximately 5 months of the year in
the fall and winter, it is not the only water source; ATK provides clean water to
the ranches that water cattle in that area. As stated in Section 3.2 of the approved
HHRA protocol, the HHRAP guidance recommends not evaluating ingestion of
water by animals, because it is expected that the contribution of that pathway to
the total risk is negligible compared to the contributions of the recommended
exposure pathways for cattle which include ingestion of contaminated forage,
silage and grain and incidental ingestion of soil. In addition, there are some small
natural ponds formed from natural springs at the southern end of Promontory.
These springs do not support game fish. Therefore, based on discussions with
utah DSHW concerning Blue creek and the springs, the decision was made to
follow the HHRAP guidance concerning the recommended exposure pathways.
Section 5.3.4, Witdlife Areas, Page 43: It is stated in the second to last sentence
of this paragraph, "Receptors would not consume wildlife from these areas and so
there would be no indirect exposure." why would receptors (hunters) not
consume wildlife from these areas? Please explain this statement in the text or
remove it.
Response:
Section 5.3.4 will be revised as follows:
Prior to the development of the first HHRA protocol, the areas where hunting
might occur were discussed and it was agreed with UDSHW that the risks would
be de minimis. The wildlife areas near ATK are further away from the Facility
than areas that are currently being evaluated for an assumed Resident or Farmer.
Because the wildlife locations are further away exposure to COPCs released by
the Facility will be further away, and so COPC concentrations (and risks) will be
much lower. Therefore, the risks and hazards in wildlife areas would be
negligible, and are not quantified. See Section 10.6 for further discussion.
Evaluation: the information provided in ATK's response partially addresses the issue
raised by UDEQ in Specific Comment 18. In addition to the information provided in the
response regarding the relative location of potentially hunted game, justification fbr not
quantifying exposlrres from ingestion of hunted game should be based on the potential
percentage of diet that ingestion of game would represent for a resident or farmer that
also hunts. Ensure that the revision to the HHRA Report addresses both the relative
location of the hunted game and the percentage of diet that ingestion of game represents
for a resident or farmer that hunts.
27
Response to Evaluation: In response to this comment, Section 5.3.4 has been modified as
follows: "Prior to the development of the first HHRA protocol, the areas where hunting
might occur were discussed and based on the available modeling data, the distance from
the source areas to the nearest hunting area, and the amount of meat that might be
ingested by a hunter compared with an adult farmer it was agreed with USDHW that the
risks would be de ninimis. To further substantiate this, the Lakes model assumes were
reviewed, and the farmer is assumed to ingest beef, poultry, produce, e8gS, milk and pork
at a total rate of I ,1 l7 pounds per year (lbs/yr) for a farmer adult weighing 80 kilograms.
This weight of food was obtained by adding up the ingestion rates (kg/kg-day) for the
farmer adult listed in Table 7-1, multiplying by a body weight of 80 kg and an exposure
frequency of 350 days/year. The model assumes that IOOVo of these foods have all taken
up COPCs at the point of maximum deposition from the sollrce, which is very
conservative.
The Lakes model does not have a hunter scenario, and these assumptions are typically
site specific. Based on data from the University of Wyoming Agricultural Experiment
Station (U of WY, 2003) it is assumed that a hunter would ingest up to 55 pounds of
contaminated game each year. This is significantly lower than the I,117 lbs for the
farmer, and it represents approximately five percent of the hunter's total diet. Even if the
meat contained COPCs from the sources it would not increase the hunter's risk
significantly. The weight of 55 lbs represents the available meat on an average size mule
cleer buck after field dressing and butchering. A mule deer would be one of the largest
edible game animals that could be hunted near the Facility. Within the approximately
20,000 acres that constitute the Facility, there is no hunting allowed. The wildlife areas
near ATK are further away from the Facility than areas that are cttrrently being evaluated
for an assumed Farmer or Resident. Because the wildlife locations are further away
exposure to COPCs released by the Facility will be further away, and so COPC
concentrations in hunted game and the associated risks, will be lower. Therefole, the
risks and hazards in wildlife areas would be negligible, and are not quantified. See
Section 10.6 for further discttssion."
Section 6.1.!,Mercury Wizard, Page 45: Section 6.1.1 explains how the Lakes
software uses the percentage of mercury lost to the global cycle and the
percentages of divalent mercury and elemental mercury deposited back to the
earth's surface recommended in the 2005 HHRAP. However, the discussion does
not identify the equations from the 2005 HHRAP used by the Mercury Wizard to
calculate the concentrations of divalent and elemental mercury in soil. Revise
Section 6.1.1 to specify the 2005 HHRAP equations used in performing the
mercury calculations.
Response:
After consulting with the Lakes' risk assessment specialist about the Mercury
Wizard, Sections 6.1.1 and 6.2w1ll be revised as follows:
Within the Lakes software, there is a tool called the Mercury Wizard. The
calculated emissions rate for mercury from Appendix A is entered into the model
19.
28
for each sub source (M136 AI, A2, etc), and then the model adjusts for the
portion of mercury that is lost to the global cycle (5l.8Vo), the portion of mercury
that is deposited as divalent mercury (48Vo), and the portion that is emitted as
elemental mercury (0.2Vo). These percentages are consistent with the information
presented in Chapter 2, Section 2.3.5.3 Mercury of the HHRAP (EPA, 2005).
The model then generates emissions factors for mercuric chloride and elemental
mercury using those percentages, and those emissions factors are carried forward
in the calculations of media concentrations and ultimately, non-cancer hazard
quotients for mercuric chloride and methyl mercury. Section 6.2 below provides
a discussion of calculating mercury concentrations in soil.
And Section 6.2 will be revised as follows:
The recommended equations for calculating soil concentration and soil losses of
COPCs are presented in App. B Tables B-l-l through 8-1-6 (EPA, 20O5; starting
on page B-1) for land use areas. Note that the Appendix B equations contain
adjustments for calculating mercury soil concentrations, and the Lakes model
applies these necessary adjustments to account for each species of mercury, as
described in Section 6.1.1 above.
20. Section 6.4, Calculating COPC Concentrations in Beef and Dairy Products,
Page 48: The discussion at the top of Page 48 notes that Tables B-3- 1 through B-
3-1 I of the 2005 HHRAP are used to determine the COPC concentrations in
forage, silage, grain, and soil consumed by cattle. In fact, Table B-3-10 presents
the equation for calculating COPC concentrations in beef tissue and Table B-3- 1 1
details the calculation of COPC concentrations in milk. These same equations are
presented in Sections 5.4.4 (Equatron 5-22) and 5.4.5 (Equation 5-24) of the 2005
HHRAP. Sections 6.4.1 and 6.4.2 note that Equations 5-22 and 5-24 are used to
calculate COPC concentrations in animal tissue and milk, respectively. However,
Section 6.4, Section 6.4-1, and Section 6.4.2 do not indicate that the equation in
Table B-3-10 is identical to Equation 5-22 and the equation in Table B-3-11 is
identical to Equation 5-24. To eliminate confusion in the text of the HHRA
Report, revise the discussion at the top of Page 48 to indicate that the equations
for calculating COPC concentrations in animal tissue and milk are presented in
Appendix B and Sections 5.4.4 and 5.4.5 of the 2005 HHRAP.
Response:
Thediscussiononpage48willberevisedasfollows:@
is
rnaterigs tnat will U . The equations for
calculating the COPC concentration in animal tissue and milk are presented in
Appendix B and Sections 5.4.4 and 5.4.5 of the HHRAP (EPA, 2005).
29
21.
Evaluation: The response partially addresses the issue raised by UDEQ in Specific
Comment 20. lt is recommended that the discussion of page 48 be revised to read:
"Appendix B Tables B-3-1 through B-3-11 (EPA, 2005) contain the equations nsed to
determine the COPC concentrations in forage, silage, grain and soil, this is consumed by
beef and dairy cattle, and the resulting COPC concentration in Feed materials that will be
consumed by beef cattle and dairy cattle. The equations for calculating the COPC
concentration in animal tissue and milk are presented in Appendix B, Tables B-3- l0 and
B-3-l l, and in Equation 5-22 of Section 5.4.4 and Equation 5-24 of Section 5.4.5 of the
HHRAP (EPA,2005)."
Response to Evaluation: The suggested text has been added to Section 6.4.
Section 6.5, Calculating COPC Concentrations in Pork, Page 49: Section 6.5
provides a reference to a discussion of biotransfer factors for animals; however a
reference to the equation used to calculate COPC concentrations in pork is not
provided. Revise Section 6.5 to include a reference to Table B-3-I2 of Appendix
B in the 2005 HHRAP for the equation used to determine COPC concentrations in
pork in the HHRA.
Response:
The discussion in Section 6.5 will be revised as follows: Once the COPC
concentrations in feed are determined, the animal COPC tissue concentration can
be calculated. The equation used to determine COPC concentrations in pork is
presented in Table B-3-12 of Appendix B of the HHRAP (EPA, 2005).
Section 6.6, Calculating COPC Concentrations in Chicken and Eggs, Page
49: Section 6.6 discusses the calculation of COPC concentrations in chicken and
eggs and provides a reference to the appropriate biotransfer factors for chickens
and eggs. However references to the equations used to calculate COPC
concentrations in chicken and eggs pork are not provided. Revise Section 6.6 to
include references to Table B-3-13 (eggs) and Table 3-14 (chicken) of Appendix
B in the 2005 HHRAP for the equations used in the HHRA to determine COPC
concentrations in eggs and chicken.
Response:
The discussion in Section 6.6 will be revised as follows: The equations used to
determine COPC concentrations in eggs and chicken are presented in Appendix B
Tables 8-3-13 (eggs) and 8-3-14 (chicken) of the HHRAP (EpA,2005).
Section 6.8, Using Site-Specific vs. Default Parameter Values, Page 50: The
discussion in Section 6.8 notes that default (i.e., EPA-recommended parameter
values for suitable for use when site-specific parameter values are not available)
parameter values are used in all media concentration calculations except for the
biotransfer factors for aboveground provide (BV^e) and forage (BVro.ue.). The
text indicates "Those two values are reduced by a factor of 100, in accordance
with HHRAP guidance (EPA, 2005; App. A, Section A-2-2.12.'4, pages A-2-20
),
23.
30
and A-2-2I). Appendix A presents a discussion of the methodology used to
calculate those biotransfer factors..." For clarity, it is recommended that the
quoted text be revised to read: "Those two values are reduced by a factor of 100,
in accordance with HHRAP guidance (EPA, 2OO5). Appendix. A, Section A-2-
2.12.4, pages A-2-20 and A-2-21of the HHRAP guidance presents a discussion
of the methodology used to calculate those biotransfer factors..." Revise Section
6.8 to address this issue.
Response:
The discussion in Section 6.8 will be revised as follows: Those two values are
reduced by a factor of 100, in accordance with HHRAP guidance (EPA, 2005;
npp, n; Seetienzf Z Z,l2.4;pa€esA220andz\ ). AppendixA, Section
A-2-2.12.4, pages A-2-20 and A-2-21, presents a discussion of the methodology
used to calculate those biotransfer factors. anCilt states that the methodology
overestimates the BVu, and BVro.us" and that it is appropriate to reduce them by a
factor of 100 for all organics, with the exception of PCDDs and PCDFs.
24. Section 6.8, Using Site-Specific vs. Default Parameter Values, Page 50: The
last sentence of Section 6.8 indicates that site-specific values for BVu, and
BVfo."s" are presented in Appendix C. For clarity, amend this sentence to indicate
these values are found in Appendix C of the HHRA Report.
Response:
The last sentence of Section 6.8 will be revised as follows: These values are
presented in Appendix C of this HHRA report.
25. Section T.l.r Inhalation Exposure Pathways, Page 51: Section 7.1 defines the
parameter Cair as the COPC concentration in air. However, Section 7.1 does not
indicate how C6. is calculated. Revise 7.I to reference Section 6.1, Calculating
COPC Concentrations in Air for Direct Inhalation, of the HHRA Report for
details regarding the calculation of C6.
Response:
The discussion in Section 7.1 will be revised as follows: Cui, = COPC
concentration in air (pgl^t); see Section 6.1 for details on Cu;r.
26. Section T.2rlngestion Exposure Pathways, Page 53: The last paragraph of
Section '7.2 indicates that the Lakes software calculates COPC intake values in
accordance with HHRAP guidance. However, references to the equations used to
calculate COPC intakes for direct and indirect pathways are not provided. To
provide transparency and consistency in the presentation of information related to
the HHRA, it is recommended that SectionT.2be revised to include references to
the intake equations used in the HHRA, similar to the references provided in
Section 6 for calculating COPC concentrationS and Section 7.7, Breast Milk
3l
Exposure, for calculating the average daily dose (ADD;n6n1) of contaminated
breast milk. Revise Section 7 .2 to address this issue.
Response:
The discussion in Section 7 .2 wrll be revised as follows: The equations for direct
and indirect intake exposure pathways are not provided here, but can be found in
the HHRAP Guidance Appendix C, Tables C-1-1, C-I-z, and C-1-3 (EPA, 2005)
for COPC intake from soil, intake from produce, and intake from beef, milk, pork,
poultry and eggs, respectively. EPA.4ee*
27. Section 7.2.1, Body Weight, Page 53: Section 7.2.1 notes that "The value of 80
kg [kilograms] is from OSWER Directive 9200.1-120, dated Feb. 6, 2OI4a." For
clarity, revise this sentence to read: "The value of 80 kg is from OSWER
Directive 92W.1 -I20 (EPA, 2ol4a) ;'
Response:
The sentence will be revised as follows: The value of 80 kg is from OSWER
Directive 9200.1 -120 (EPA, 2OI4a) aa*ee+eU-6;:g+aa.
28. Section 7.5, Exposure Duration, Page 55: Sin referring to the value of the
exposure duration for an industrial worker, Section 7.5 states that "This value is
consistent with OSWER Directive 9200.1-120, dated Feb. 6, 2014." For clarity,
revise this sentence to read: "This value is consistent with OSWER Directive
9200. | - I2O (EPA, 20 l4a) ;'
Response:
For clarity, the sentence will be revised as follows: This value is consistent with
the OSWER Directive 92O0.1-I2O (EP A, 201 4a) dated+eb-6r4014
29. Section 7.7, Breast Milk Exposure, Page 56: The formatting of the parameter
definitions on Page 56 for the equation used to calculate ADDins-1does not
conform to the formatting used in defining the parameters included in other
equations presented in the HHRA Report (e.g., parameter definitions for the
calculation of ingestion intakes, I, in SectionT.2,Page 52). For clarity and
consistency, revise the formatting of the parameter definitions on Page 56 to
conform to the format used in other parts of the HHRA Report.
Response:
For clarity, the parameter definitions will be reformatted to be consistent with the
rest of the report.
30. Section 9.1, Short-term Non-Cancer Hazards in Air Methods, Page 60:
Hypothetical, on-site receptor locations are discussed in the last paragraph on
page 60. These six locations were selected based on the annual prevailing wind
direction and include four points located on the facility boundary, one point at
Blue Creek at the western edge of the facility and one point at the ATK Ranch
32
31.
Pond which is located approximately seven miles south of the facility. Why are
these receptor locations considered on-site in the HHRA Report? This same
question would apply to Figures 9-2,9-5 and 9-6 and many of the Tables.
Response:
The designation for the four boundary locations and Blue Creek will be changed
from "on-site" to "boundary", and ATK Ranch Pond will be changed to "off-site"
in order to more accurately reflect the location of these receptors.
Section 9.1, Short-term Non-Cancer Hazards in Air Methods, Page 61: The
first complete sentence at the top of Page 61 states "None of these on-site
locations have actual receptors..." These locations, which are referred to as on-
site (four boundary points, Blue Creek, ATK Ranch Pond) could provide habitat
for ecological receptors. Thus, it is recommended that the quoted text be revised
to read: "None of these receptor locations have actual human receptors..."
Response:
For clarity, the sentence will be revised as follows: None of these receptor
locations have actual human receptors....
32. Section 9.1,, Short-term Non-Cancer Hazards in Air Methods, Page 61: The
discussion at the top of Page 6l indicates that the hazard index (HI) calculated for
Boundary 2 is both greater than and less than the target value of l. It appears that
the statement regarding Boundary 2being less than I should actually refer to
Boundary 4. Review the discussion at the top of Page 61 and revise as necessary
regarding the HI values obtained for the four boundary points.
Response:
For clarity, the discussion will be revised as follows: The HIs are less than one
for Boundary 3, Boundary 4 and ATK Ranch Pond.
Section 9.1, Short-term Non.Cancer Hazards in Air Methods, Page 61: The
second full paragraph on Page 61 indicates that a discussion regarding the
presence of nickel in ATK Promontory waste streams is included in the
uncertainty section. Due to the importance of the referenced discussion, it is
recommended that the existing text be revised to state: "As discussed in Section
10.1.2.4, Chromium and Nickel in Waste, of the uncertainty discussion, nickel is
not present in ATK's waste stream.. ." Revise Section 9.1 to address this issue.
Response:
For clarity, the sentence will be revised as follows: As discussed in the
uncertainty Section IO.1.2.4, Chromium and Nickel in Waste, nickel is not present
in ATK's waste stream...
Section 9.1, Short-term Non-Cancer Hazards in Air Methods, Page 61.: The
second complete paragraph on Page 61 indicates that the stainless steel pans used
33.
34.
33
35.
in the OB/OD tests were I4Vo nickeL However, no reference is provided for the
source of this information. Revise this discussion to include a reference to the
information sources that indicates the stainless steel pans used in the OB/OD tests
were l4%o nickel. Ensure the referenced information source is included in Section
I 1, References, of the HHRA Report.
Response:
This is the same issue as comment #5. The same reference will be added to this
section.
Section 9.1, Short-term Non-Cancer Hazards in Air Methods, Page 61: In the
fourth paragraph of this section, it is stated that "chlorine is not present in ATK's
waste because it is a gas and ATK does not burn gas cylinders." Chlorine was
detected in the ODOBi tests, and it is known that chlorine is part of the emissions
generated through open burning. In addition, ATK is not making the case that
chlorine is not present in the emissions. Therefore, why does the discussion in the
previous paragraphs of this section include subtracting the hazard attributed to
chlorine? If chlorine is present in the emissions, subtracting the hazard attributed
to it would be inappropriate.
Response:
Chlorine was detected in the emissions from the OBIOD tests, and this is likely
generated from chlorine-containing compounds, such as perchlorate in AP wastes.
The text will be revised to make this clear.
Furthermore, in the fourth paragraph it is stated that aluminum chloride is likely
the source of chlorine. Should perchlorate be added to this discussion as a
potential chlorine source?
The following text has also been added:
However, ATK does process waste that contains 16 percent aluminum, and
ammonium perchlorate which contains chloride ion, which is likely to form
chlorine gas and aluminum chloride in the combustion process.
Section 9,2,Long-term Non-Cancer Hazards in All Media, Page 622 The last
sentence of the first paragraph of Section 9.2 references EPA's 2005 HHRAP by
stating: "The default approach used by EPA to assess the potential for health
effects associated with this threshold relationship is set out in EPA (2005). For
clarity, it is recommended that the sentence be revised to read "The default
approach used by EPA to assess the potential for health effects associated with
this threshold relationship is set out in Section 7.2, Quantitatively Estimating
Noncancer Hazard, of the 2005 HHRAP (EPA, 2005)." Revise Section 9.2 to
address this issue.
36.
Response:
34
For clarity, the sentence will be revised as follows: The default approach used by
EPA to assess the potential for health effects associated with this threshold
relationship is set out in Section 7.2 Quantitatively Estimating Noncancer Hazard,
of the HHRAP (EPA, 2005) ....
37. Section 9,2rLong-term Non-Cancer Hazards in All Media, Page 63: The
discussion at the top of Page 63 states: "As described in Section 8, the DOE
TEELS are used to evaluate l-hour air concentrations." For clarity and
transparency of the information presented in the HHRA Report, it is
recommended that the quoted sentence be revised to read: "Acute inhalation
exposure concentrations (AIECs) based on EPA's recommended hierarchy (EPA,
2005) are used to evaluate l-hour air concentrations." This revised sentence
should be followed by the types of AIECs used and references to the documents
from which the values were extracted. Revise Section 9.2 to address this issue.
Response:
The information requested in this comment is provided in Section 8.1 Selection of
Toxicological Parameters, which discusses the hierarchy used to select the acute
criteria. The last sentence of the first paragraph of Section 8.1 of the HHRA
report will be revised as follows: Dose-response values for these types of
exposure are selected from:the sources identified in Section 7 .4.2 of the HHRAP -
(EPA,2005).
38. Section g.2.l,Quantitative Non-cancer Hazards for all COPCs, Page 63: The
first paragraph reports "The highest HI is 0,O24 for Autoliv." This sentence
should be revised to read: "The highest HI is O.O24 for Autoliv."
Response:
The sentence will be revised to correct the typo.
39. Section 9.5, Hypothetical Future Scenarios, Pages 67 and 68: The discussion
on Pages 67 and 68 addresses the risks and HIs calculated for the receptors
associated with the locations of the maximum on-site and off-site modeled annual
concentration, annual deposition, and one hour concentration. As indicated in the
text, these locations are identified on Figure 9-9 and the results are listed in Table
9-17 of the HHRA Report. However, the results listed in Table 9-17 could not be
verified because the results obtained from the Lakes software for these locations
were not found in Appendix D, Estimated Hazards and Risks By Receptor
(Section 9). Revise Appendix D of the HHRA Report to include the risk and
hazard, results obtained from the Lakes software for the points of maximum
annual concentration, annual deposition, and one-hour concentration so that the
results presented in Table-l7 can be verified.
Response:
In order to allow for verification of the information that is presented in Table 9-
17, Appendix D will be revised to include a list of risks and hazards for the
maximum on-site and off-site locations,listed by subsource and COPC, similar to
35
what was already presented in Appendix D for the other receptor locations. The
last sentence of the first paragraph of Section 9.5 will be revised as follows: The
results are shown in Table 9-IJ , and the details of the risks and hazards, listed bv
subsource and COPC, are provided in Appendix D.
40. Section 10.1.1, Volumes and Types of Materials Processed, Page 70: The
fourth sentence in this paragraph, regarding the burning of metals, could be more
accurate. ATK does burn wastes that contain metals, although the metals may not make
up a large percentage of the waste. Flare wastes in particular typically contain more
metals than the other common wastes ATK treats and these weren't part of the test
bundles that were prepared. Please revise the text accordingly.
In addition, at the end of this section it is stated that flare wastes are "discussed below."
Where is this discussion?
Response:
The following text will be added to Section 10.1.1:
While waste profiles have changed over the years of operations, ATK prepared
test bundles for the OB/OD testing that were believed to represent a range of
possible waste streams. The waste bundles contained AP waste, which typically
constitutes the major waste stream, and included wastes such as paper, wood,
plastics, and propellants. The composition of these test bundles is provided in the
Characterization of the OB/OD Emissions Report (ATK, 2OO9; see Table 1,2 and
3). These wastes may contain low levels of metals as trace components in trash,
packaging, containers and housings, and metals were detected in the emissions
from the OB/OD tests. As the materials processed by ATK have changed, more
Flare wastes have been incorporated into the waste stream. Some unique metals
are also present in proprietary flare wastes, and these were not contained in the
OB/OD test bundles. The major metal additives present in these flares are
identified specifically in Table 2-3, and are discussed below in Section 10.1.2.8.
Section 10.2.1, Air Quality Modeling, Page 75: At the bottom of this section, it
is stated that "There are a number of components to the model, as discussed in
Section 3, and the uncertainty associated with these components is summarized
below." Where is this discussion?
Response:
The following discussion has been added to Section 10.2 Modeled Air
Concentrations and Deposition:
Evaluation: The response to Specific Comment 4l parrially addressed the issue raised.
However, it is recommended that the response be revised as presented below before it is
added to Section 10.2. The suggested revisions are intended to preserve the intent of the
discussion while clarifying several points made in the original response.
41.
36
The original OBODM air dispersion model was developed by the West Desert
Test Center, Dugway, Utah (WDTC, 1998a), and was used by TetraTech in 201|
for project scoping. ln2014, the OBODM was used by CB&I Environmental &
Infrastructure, Inc. (CB&I) in conjunction with the air dispersion portion of the
AERMOD model to take maximum advantages of advances in air dispersion
modeling science. The approach used by CB&I, while less conservative than the
TetraTech approach, better represents the process and is still considered
conservative. However, in their modeling protocol CB&I stated the following
concerning the OBODM: at this time, OBODM is not actively supported by its
developers or by any regulatory agency.
The models use meteorological data from the facility, and the protocol was
approved by the Utah DSHW. There are a number of components to the model,
as discussed in Section 3. These include: emissions source parameters (such as,
emissions rates and plume rise characteristics), air dispersion parameters, and
depositional characteristics. The uncertainty associated with these components is
summarized below.
10.2.1 Emissions Source Parameters
Source emissions are estimated based on the amount of material processed
(pounds per year) and emissions of compounds from the burning process
(combustion by products, and products of incomplete combustion). The HHRA is
based on the amount of material processed per year by ATK, and is provided in
the modeling protocol. This amount is used in the HHRA and represents the
maximum amount that may be processed by ATK under their permit. In the past
few years ATK has processed significantly less material than allowed in the
permit, and therefore, the actual emissions during those years were lower.
Current and future operations will not exceed the permitted amount, and so the
risk assessment is intended to represent an over-estimate of emissions and thus,
provide a conservative estimate of risk.
The emissions factors are discussed above in Section I0.I.2.
ATK uses two burning grounds M136 andM225, and within each of these areas
there are designated locations for processing different types and/or amounts of
materials. Ml36 is the primary processing area, and it has three operational
scenarios, M136-A, M136-8, and M136-C. Scenario M136-,\ is further sub-
divided into Al, A2 and ,A.3. ATK uses M136-A to process the majority of the
AP,related waste, whereas M136-B is used to process single motors, and Ml36-C
is used to treat waste material through open detonation. The three scenarios are
not used on the same day for safety reasons. It would be hazardous to employees
to have all treatment scenarios contain materials for processing at the same time.
The initial HHRA modeling protocol assumed all burning grounds scenarios
would operate at the same time; however, the model assumed each source
37
operates independently, and the results are summed together. This approach over-
estimates risk, whereas adjusting for burn scenarios that cannot occur on the same
day calculates risks that reflect the actual operating situation.
This issue of selecting specific subsources does not affect the chronic aspect of
the risk assessment because it addresses long term exposures that are summed to
evaluate combined exposures from multiple sources.
The initial assumption of all treatment scenarios operating together would over-
estimate the acute air concentrations because it combines estimated air
concentrations from sources M136-A, M136-8 and M136-C together, to give a
summed potential air chemical concentrations at each receptor, when in fact this
does not occur. Due to the operating conditions at M136, acute air chemical
concentrations would come from processing at either M136-,{, or M136-8, or
M136-C and not from the sources added tosether.
Based on discussions with the Utah DSHW, the initial protocol was modified to
reflect actual operating conditions and not the hypothetical situation of all
grounds operating together. Any permit associated with this risk assessment will
reflect the actual operating condition(s) demonstrated to be protective of human
health and the environment in the HHRA and ecological risk assessment (ERA).
10.2.2 Emissions Rates
The emission rate is a combination of the emissions factor and the amount processed. The
modeling protocol provides emissions at a unit rate in grams per second (g/s), which is
multiplied by the compound specific emission factor to give the amount released. ATK
uses a batch process and emissions occur within a short period of time. There is some
uncertainty; however, the use of conseryative emissions factors selected in the modeling
is designed to help provide results that tend to over-estimate exposure, and risk. When
modeling short-term air chemical concentrations, the amount burned in a single batch
will have a direct impact on potential exposure.
Modeling was conducted by modeling single burns using a unit emissions rate in grams
per second, and adjusting the air concentration by the emissions factor. The single burn
uses conservative factors to give the highest air concentration for calculation of the short-
term inhalation Hazard Index. This is more conservative for the estimation of acute risk
because it is based on exposure and not the amount processed.
When estimating the long-term (chronic) hazards and risks, the overall amount processed
is more important because the summed accumulation of exposure is important, not one
particular burn cycle. In the chronic case, the risks are based on the total amount
processed, as discussed above.
The OBODM is designed to model air emissions from open burning/open detonation
process. There are a number of components to the model:o The location of the burning ground relative to the local terrain
38
The type of source release (quasi-continuous or instantaneous)
The area of the source
The release height relative to the local topography
The heat of combustion and associated plume rise
Some of these parameters can be measured with relative precision, such as the height
of the burning grounds, and other may vary, such as the combustion temperature and
the estimated plume rise. The more uncertainty present in a parameter, the greater the
uncertainty in the final result. At the time of its development through the present day,
the OBODM portion of the modeling approach is a listed EPA alternative air
dispersion model, and is thought to be conservative. The combustion temperature is
one of the key parameters in the model as it affects gaseous plume rise, and so affects
the height above the ground where dispersion starts. At Promontory, the plume
dimension and volume was verified through video monitoring, and the volume was
found to be four to eight times the size of the burn pan. A volume of four times the
burrr pan was used, to be conservative.
10.2.3 Air Dispersion Parameters
The AERMOD dispersion model was used by CB&I. This model calculated the
dispersion of the gas cloud under the assumed meteorological conditions, and the
associated theoretical air chemical concentration at the locations on a receptor grid. The
following parameters were used in the model:o Emission rate of 1 g/s
o Release height predicted from OBODM using five Wind Speed Categories
covering a range of 3.0 mph - 15 mph
r Initial volume source diameter 28.06 m (four times the size of the burn pan)
o The events will occur only between the hours of 9:00 a.m. Mountain Standard
Time (MST) and 6:00 p.m. MST
o The wind speed during the events will be between 3 mph and 15 mph
o The Clearing lndex during the events will be 500 or higher
There is uncertainty in parameters, and the values were selected by CB&I to be
conservative. The Stability Class was selected based on the available meteorological data
to provide the lowest dispersion under ATK's normal operating conditions.
The dispersion modeling conducted with AERMOD utilized hourly meteorological data
files. Five years (1997 to 2001) of on-site meteorological data obtained from the site
were used in the modeling entitled "Addendum Air Dispersion Modeling Report for
Open Burning and Open Detonation at ATK Launch Systems in Promontory Utah" dated
August 2014. The hourly meteorological data were obtained from the site in CD-I44
format and included wind speed, wind direction, temperature, and barometric pressure
monitored at the site along with concurrent ceiling height and opaque cloud cover from
a
o
a
a
39
Hill Air Force Base. These data may not precisely represent the meteorological
conditions at the facility, but are believed to constitute the best available representation of
conditions at the burning grounds.
For NAAQS and air toxics analysis, an off-site receptor grid was used to determine the
maximum off-site ground level concentrations. The layout of the receptors was placed
along the property fence line at 100-m intervals. A Cartesian receptor grid starting from
the property line extended up to 10 km in all directions with a receptor grid spaced at
100-m intervals to a distance of 3 km from the facility and at 500-m intervals between 3
km and 10 km from the facility. This grid spacing was considered sufficiently small to
represent the area.
The uncertainty in the air modeling approach is discussed in CB&I's 2014 modeling
report. The approach was considered to be sufficiently conservative by the Utah DSHW,
who accepted the protocol in November 2014.
Response to Evaluation: The modified text suggestions have been added throughout
Sections IO.2.l, 10.2.2 and 10.2.3.
In addition, the following text was added to Section 10 to clarify the chromium and
nickel adjustments:
Evaluation: The proposed addition to the text adequately addresses UDEQ's concern.
For clarification, UDEQ has offered some editorial suggestions in the version of the
proposed text presented below. Please note that locations for key references have been
presented parenthetically in the revised text in red bold font.
10.1.2.6 Chromium and Nickel - Acute Hazards Based on Adjusted Emissions
The HHRA results (Section 9.0) are based on the assumption that the chromium and
nickel emissions are due entirely to their presence in AP waste plus trash (85: l5), and the
highest of any emissions factors is selected to characterize emissions. As described in
Section 10.1.2.4.1, elevated chromium and nickel levels may be from the OBOD test. It
has been shown that chromium emissions may be over-estimated by some 20-fold
(PLEASE PROVIDE A RBFERENCE TO THE SECTION OF THE HHRA
REPORT THAT PRESENTS THIS CALCULATION), and the emission and risks
due to direct exposure should be correspondingly lower; the uncertainty can be quantified
by adjustingthehazards by the factor of 0.05, as described in Section 10.1.2.4.1.
Similarly for nickel, it has been shown that the emissions may be over-estimated by
approximately 67-fold (PLEASE PROVIDE A REFERENCE TO THE SECTION
OF THE HHRA REPORT THAT PRESENTS THIS CALCULATION); thus, the
uncertainty can be quantified by adjusting the hazards by the factor of 0.015, as described
in Section 10.1.2.4.2. Below is a discussion of the calculation of the acute hazards, using
the adjustment factors of 0.05 for chromium and 0.015 for nickel.
40
Response: The requested sections are 10.1.2.4.1and 10.I.2.4.2 forchromium and nickel,
rcspectively. The references have been added to the text. Note that the over-estimation
of nickel has been revised from 67-fold to 57-fold, based on using the correct emissions
factor for 85/15 waste (5.8x10-5). See the Response to Evaluation on pages l0-11 of this
document.
Acute Inhalation Hazard Ouotients
Section 9.0 describes how the Acute Inhalation Hazard Quotients zu'e calculated by
dividing the modeled 1-hour air concentrations by the short-term PAC-l (1-hour)
concentration provided in Table 8-2. The resulting quotients, called aHazard Quotient
(HQ) for each individual COPC, are then added together for each receptor to give a
Hazard Index (HI). These summed indices are shown in Tables 9-I,9-2 and 9-3 for on-
site industrial workers, boundary/off-site locations where there are no receptors
(hypothetical receptors), and off-site locations representing actual receptors, respectively.
The values were calculated assuming the following:o All sources (Ml36A, B, C,M225A and B) are burned simultaneously, and
o The original assumptions for chromium and nickel were used, potentially
overestimating the amounts present in waste by a factor of 2O-fold and 67-fold,
respectively.
After discussions with ATK and UDSHW, these HQs were recalculated assuming the
following:
o Sources Ml36 AI, A2, 43 and M2254 are burned simultaneously, and
o The chromium amounts were adjusted by multiplying by a factor of 0.05, and
o The nickel amounts were adjusted by multiplying by a factor of 0.015.
The recalculated, summed indices are shown in Table 10-1, 10-2 and l0-3 for on-site
industrial workers, boundary/off-site locations where there are no receptors (hypothetical
receptors), and off-site locations representing actual receptors. The HIs are below one for
all receptors and scenarios. The HIs range from 0.2 to 0.5 for the on-site workers as
shown in Table l0- l. The HIs for the boundary/off-site hypothetical receptors are
presented in Table 10-2, and range from2.9E-02 to 0.1; the latter of which is the
maximum HI for the discrete receptors and represents a hypothetical receptor located at
Blue Creek. The HIs range from 3.4E-02 to 0.4 for the actual, off-site receptors, as
presented in Table 10-3. The Acute HQs for each individual COPC at each individual
receptor are provided in Appendix F.
It can be seen from these tables that the HIs have been reduced significantly due to the
reduction in the HQ for both chromium and nickel.
4l
10.1.2.7 Chromium and Nickel - Chronic Hazards and Risks Based on Adjusted
Emissions
Similar to the process described in the previous section, the chronic non-cancer hazards
and excess lifetime cancer risks presented in Tables 9-4 through 9-14,9-ll and 9-18,
were originally calculated assuming the following:
o All sources (M136A, B, C,M225A and B) are burned simultaneously, and
o The original assumptions for chromium and nickel were used, potentially
overestimating the amounts present in waste by a factor of 20-fold and 67-fold,
respectively.
Applying the same logic that was used to adjust the chromium and nickel in the Acute
Hazard calculations, the chronic risks andhazards were recalculated assuming the
following:. Only sources Ml36A(subunits Al, A2 and ,A3) and M225A are burned
simultaneously, and
Evaluation: Tables 10-4 through 10-10 indicate that the revised calculations reflect
simultaneous operation of burning scenarios Ml36A andM225A. Review the text and
the tables and revise them for accuracy and consistency. The bullet point above has been
revised on the basis that the information provided in the table endnotes is correct.
o The inhalation risks due to chromium were adjusted by multiplying by a factor of
0.05, and
o The inhalation risks due to nickel were adjusted by multiplying by a factor of
0.015.
The chronic risks and hazards address long term exposures that are summed and evaluate
combined exposures from multiple sources, therefore specific sub sources are not
selected as they were in addressing acute hazards. Also, the chromium and nickel
adjustment factors were only applied to the inhalation pathway. An example of the linear
adjustment made to the chromium inhalation risk is shown below. The values represent
the Industrial Worker scenario at Autoliv, where inhalation is the only pathway via which
workers are potentially exposed to emissions.
Original Cr Inhalation Risk X Cr Adjustment Factor = Adjusted Cr Inhalation
Risk
1.5E-07 X 0.05 =7.78-09
The original inhalation risk for chromium was multiplied by a factor of 0.05 to obtain the
adjusted risk estimate. Similarly, the original inhalation risk for nickel was multiplied by
a factor of 0.015 to obtain the adiusted risk estimate.
42
l.4E-09 X 0.01 5 = 2.1E-1 I
Chromium was a risk driver for the inhalation pathway, so the chromium adjustment has
a greater impact on the total risk than the nickel adjustment.
A similar calculation was done for all of the receptor types (Adult and Child Farmer and
Adult and Child Resident) for all of the discrete receptor locations. Also, the same
calculation was performed for the non-cancer hazards. The results of the adjusted risks
and hazards are presented in Tables l0-4 through l0-8. Tables 10-9 and l0-10 present
the adjusted risks and hazards for the future scenarios at the maximum on-site and
maximum off-site locations, respectively. The details of these adjusted chronic risk and
hazard calculations are presented in Appendix F.
42. Section 1,0.5, Overall Risk Estimates, PageT9z The second paragraph of
Section 10.5 states: "These and other uncertainties in the risk assessment process
will be examined in this section of the report." It is recommended that this
sentence be eliminated from the text and replaced by a discussion of the impact of
the uncertainties identified in the first paragraph of Section 10.5 on the overall
risk and hazard estimates presented in the HHRA Report. Revise Section 10.5 to
address these issues.
Response:
A sentence has been removed.
Evaluation: Based on the response it is not clear which sentence will be removed from
the text. Please ensure that Section 10.5 is revised to address the impact of the
uncertainties identified in the first paragraph of Section 10.5 on the overall risk and
hazard estimates presented in the HHRA Report.
Response to Evaluation: The following sentence was removed: "These and other
uncertainties in the risk assessment process will be examined in this section of the
refort." In addition, a reference to Table l0-11 was added and Section 10.5 was revised
to read as follows: "Table 10-1 I summarizes many of the uncertainties in the HHRA and
the risk assessment process. It also indicates that the final risk estimates will likely
overestimate the potential risks because they multiply conservative uncertainties assumed
in the various pal'ameters and compound it. While some of the items listed in
Table l0-11 demonstrate that risks may be underestimated in some cases, the majority of
the assumptions lead to an overestimation of the final risks and hazards. For example,
the use of the highest emissions factors fi'om the OB/OD tests, the addition of
non-detected chemicals, the use of worst case meteorological conditions at the time
wastes.are burned or detonated, the use of conservative biotransfer and uptake factors,
the use of human exposure and diet and intake factors that represent the Reasonable
Maximum Exposure, and finally the use of toxicological dose-response factors that
contain uncertainty and safety factors that are designed to be health protective ofthe
43
43.
majority of the population, all lead to an overestirnation of risk." Table l0- I I was
originally Table 10-1 in the December draft document, and it is also inciuded at the end
of this document.
Section 10.6, Hunters at Salt Creek Waterfowl Management Area and Bear
River Migratory Bird Refuge, Page 79: Near the bottom of page 79 it is stated
that Figure 9-3 shows the location of the Salt Creek Waterfowl Management Area
and Bear River Migratory Bird Refuge. These areas are not shown on this Figure,
but are shown on Fisure 5-1. Please revise.
Response:
The text in Section 10.6 will be revised to correctlv reference Fisure 5-1 instead
of Figure 9-3.
Tlsr,B 10-1
Snonr-TnRM (l-HouR) NoN-CANCER H.lzlnn Innrcps Acruu, ON-srrn
Wonxnns, Sunrvrnc Alr, COPCs wrrH ADJUSTED Cunourulr AND NTcKEL
Eutsslons ro REMovE PoTENTIAL CoNTRTBUTToN FRoM TrrE STATNLESS SrEEL
TnsrncPlNs
Receptor Location Hazard Index with Adjusted
Nickel and Chromium
Autoliv Facilitv 0.5
South Plant Main Buildine 0.5
North Plant Main Buildrns 0.2
Hazard Indices calculated assuming sources M- I 36 Al , A2, A,3 and M-225 A are active at the same
time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted bv a factor of 0.015.
Tmln 10-2
Snonr-TnRM (l-Houn) Nou-CINCER Hlzlnn INucBs FoR HyporrlETrcAl
BouNnlnv/OFF-sIrE Rrcnprons (RESTDENTTAL/FARMER) SUMMTNG ALL COPCs
WITHADJUSTED CUNOUTUU AND NICKEL EMISSIONS TO RTUOVB POTBNTNT,
CoNrnrnurroN FRoM THE STAINLESS SrEEL TEsrrNG PlNs
Receptor Location llazard Index with Adjusted
Nickel and Chromium
Blue Creek 0.6
44
Tmln 10-2
Snonr-Trnu (l-Houn) NoN-CINCER Hlz,lnn lNorcrs ron HyporrmrrcAl
Borno.lny/OFF-srrE Rncnprons (RnsmnnuAUFARMEn) SuulrrNc Ar,r, COPCs
wITH ADJUSTED Cnnovrruu aNn Nrcrnr, EvrrssroNs To RrvrovB Pornntnr,
CoNrnrsurroN FRoM rrm Srnrrr,nss Strpr, TEsrrNc Plns
Receptor Location Hazard Index with Adjusted
Nickel and Chromium
Boundarv I 0.7
Boundarv 2 0.3
Boundarv 3 0.1
Boundarv 4 0.1
ATK Ranch Pond 0.1
Hazard Indices calculated assuming sources M-136 Al, A2, ,A,3 and M-225 A are active at the same
time. This scenario is more representative of actual operating conditions.
Chromium was ad.iusted by a factor of 0.05, arid nickel was adiusted by a factor of 0.015
Tlnln 10-3
Snonr-Tnnu (l-HouR) NoN-CANcER H.lz.lRD lNorcns FoR AcruAL OFF-srrE
Rrcnprons (RnslnnNuAUtr'ARMEn) Suvrrumc ALL COPCs wrrH ADJUSTED
Cnnouruu AND NICKEL EMISSIoNS ro Rnuovn PornNrnt, CoNTRTBUTIoN FRoM
THE STAINLESS STEEL TESTING PINs
Receptor Location Hazard Index with
Adjusted Nickel and
Chromium
Adams Ranch 0.4
Christensen Ranch 0.1
Holmgren Ranch 0.1
Howell Dairv 3.6E-2
Penrose 3.48-2
Thatcher 4.48-2
Hazard Indices calculated assuming sources M-136 A1, A2, A,3 and M-225 A are active at the same
time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted bv a factor of 0.015
T,lnr,n 10-4
SuuTuBo Nox-CINcER HAzARD lxnlcns AND CANCER RIsKs FoR ALL COPCs:
Acru.Ir, On.srrB Innusrnr.tr. RECEPToRs (ADJUSTED NIcKEL AND CHRoMIUM)
Receptor Name Industrial Worker
Cancer Risk
Industrial Worker
Non-cancer HI
Autoliv Facilityo 2.0E-08 2.38-02
North Plant Main Administration
Buildinsu 7.rE-09 8.38-03
45
Tmln 10-4
Suvrunn NoN-ClNcnn H.nzlnn lNnrcrs .lno ClNcnn Rrsrs ron Alr. COPCs:
Acru^1l, ON-srrB Innusrnnr, Rncnprons (Aorusrro Nrcxnr, lNn CnnoMruM)
Receptor Name Industrial Worker
Cancer Risk
Industrial Worker
Non-cancer HI
South Plant Main Administration
Buildine u l.7E-08 2.OE-02
uThese chronic hazard indices and cancer risks were calculated assuming sources M-136 Al, A2, A,3
andM-225 A are active at the same time. This scenario is more representative of actual operating
conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted by a factor of 0.015.
46
TasI,r L0-5
Sunnurno NoN-C,l,Ncnn Hlzlnn Innrcns ron Ar,r, COPCs:
Acrun, Orr-srrn Rncnpron (AoJusrnn NrCxnl lNo Cnnouruvr)
Receptor Name Resident Adult
Chronic HI
Resident Chitd
Chronic HI
Farmer Adult
Chronic HI
Farmer Child
Chronic HI
Adams Ranchu t.7E-02 r.7E-02 t.7E-02 t.7E-O2
Christensen Ranchu 5.08-03 5.08-03 5.08-03 5.lE-03
Holmgren Ranchu 2.5E-03 2.58-03 2.58-03 2.5E-03
Howell Dairvn l.9E-03 t.9E-03 l.9E-03 t.9E-03
Thatcher"l.8E-03 t.8E-03 1.88-03 r.8E-03
Pentosen l.6E-03 1.6E-03 l.6E-03 1.6E-03
Maximum Off-siteu 4.88-02 4.88-02 4.8F-02 4.8F-02
"These chronic hazard indices and cancer risks were calculated assuming sources M-136 Al, A2, ,A3 and M-
225 A arc active at the same time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted by a factor of 0.015.
Tmr,n 10-6
Suvrvrno NoN-CnxcER HAzARD Ixorcns FoR ALL COPCs:
HyporrmucAr, RESTDENT AND Fanunn Rpcrprons ar BoUNDARy/OFF-srrE
LoclrroNs (Aorusrno Nrcxnr. AND CHRoMTUM)
Receptor Name Resident Adult
Chronic HI
Resident Child
Chronic HI
Farmer Adult
Chronic HI
Farmer Child
Chronic HI
Blue Creeku 3.38-02 3.38-02 3.38-02 3.38-02
Boundarv lo 3.2F-02 3.28-02 3.38-02 3.3F-02
Boundarv 2n t.2E-O2 I.2E-O2 t.2E-02 r.2E-02
Boundarv 3u 3.28-03 3.28-03 3.28-03 3.28-03
Boundarv 4u 3.5E-03 3.5E-03 3.5E-03 3.5E-03
ATK Ranch Pond"l.lE-03 l.1E-03 l.1E-03 t.1E-03uThese chronic hazard indices and cancer risks were calculated assuming sources M- 136 Al . A2. A,3 and M-
225 A are active at the same time. This scenario is more representative Jf actual operating condiiions.
Chromium was adiusted bv a factor of 0.05. and nickel was adiusted bv a factor of 0.015.
47
Tlnle 10-7
SuuprBo Excnss Lmrrnrrn ClNcrn Rrsxs ron Ar,r, COPCs:
Hypornnrrclr RnsmENT AND Flnurn Rrcnprons lr BouNn.lny/Orr-srrn
LoclrtoNs (Aorusrno Nrcxnr. lxn Cnnonrrurrl)
Receptor Name Resident Adult
Cancer Risk
Resident Child
Cancer Risk
Farmer Adult
Cancer Risk
Farmer Child
Cancer Risk
Blue Creeku 2.98-08 l.2E-08 2.88-07 6.0E-08
Boundarv ln 2.8E-08 l.lE-08 2.7E-07 5.88-08
Boundarv 2u l.lE-08 4.4E-O9 l.lE-07 2.2E-08
Boundary 3u 2.88-09 l.lE-09 2.7E-08 5.88-09
Boundarv 4"3.0E-09 t.2E-09 2.9E-08 6.3E-09
ATK Ranch Pondu 9.6E-10 3.98-10 9.5E-09 2.OE-09uThese chronic hazard indices and cancer risks were calculated assuming sources M-l36 Al, A2, A3 and M-
225 A are active at the same time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted by a factor of 0.015.
Tmr,n 10-8
Suuvrnn Excpss Lrrnrnvrn Cmrcnn Rrsrs FoR ALL COPCs:
Acru,lr, Orr-srrn Rncnpron (Aorusrno Nrcxnr, AND CHRoMTUM)
Receptor Name Resident Adult
Chronic Risk
Resident Child
Chronic Risk
Farmer Adult
Chronic Risk
Farmer Child
Chronic Risk
Adams Ranchu l.5E-08 5.9E-09 t.4E-07 3.08-08
Christensen Ranchn 4.4E-O9 t.7E-09 4.28-08 9.0E-09
Holmsren Ranchu 2.2E-09 8.8E-10 2.1E-08 4.6E-09
Thatchern t.6E-09 6.4E-10 r.5E-08 3.3E-09
Howell Dairvu l.6E-09 2.08-09 l.6E-08 5.78-09
Penroseu l.4E-09 5.6E-10 r.4E-08 3.0E-09
'These chronic hazard indices and cancer risks were calculated assuming sources M-136 Al, A2, ,A,3 and M-
225 A are active at the same time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05. and nickel was adiusted bv a factor of 0.015.
48
T.lnlr 10-9
Sulruno Rrsxs aNo HazlRDS FoR Ar,l COPCs:
Furunn ON-srrn Wompn (Aorusrnn Nrcrrr,lNn CHnourulr)
Receptor Name Industrial Worker
Cancer Risk
Industrial Worker Non-
cancer HI
Maximum On-site 2.9E-08 3.38-02
nThese chronic hazard indices and cancer risks were calculated assuming sources M-136 Al, A2, .A,3 and M-
225 A are active at the same time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted by a factor of 0.015.
T.lnr.B 10-10
Suuuno RTsTs AND HAZARD INDICES FOR AI,I COPCs:
Furunn RnSmBNTIFARMER (AnIusrnn Nrcrnr, AND CHRoMIUM)
Receptor Name Resident Adult
Chronic HI
Resident Child
Chronic HI
Farmer Adult
Chronic HI
Farmer Chitd
Chronic HI
Maximum Off-site 4.88-02 4.88-02 4.88-02 4.88-02
Receptor Name Resident Aduf!
Chronic Risk
Resident Child
Chronic Risk
Farmer Adult
Chronic Risk
Farmer Child
Chronic Risk
Maximum Off-site 4.3E-08 1..8E-08 4.OE-07 8.8E-08
"These chronic hazard indices and cancer risks were calculated assuming sources M-136 Al, A2, A3 and M-
225 A are active at the same time. This scenario is more representative of actual operating conditions.
Chromium was adiusted by a factor of 0.05, and nickel was adiusted by a factor of 0.015.
49
Tlnr.n 10-11
Sour oF Trm UxcrnrnNTrES rN THE Pnouoxrony RrsrAssnssunnr,
ANDA Ous-rrlrrvnAssnssMnNT oF TITEIR PornNrnr,Iupacr oN Trm RrsrAssnssMENT
Aspect Risk
Assessment Process Assumption Effect on the Risk
Assessment
Emissions Tests The worst case emissions from nine different tests is used to provide the emissions factors
for the modeling of COPCs Likelv overestimates risr
Emissions Tests The contribution from background is not subtracted from the emissions factors used to
calculate COPC emissions rates Likely overestimates risk
Emissions Tests
The chromium and nickel contribution from the stainless steel test trays likely creates
artifacts that are not subtracted from the emissions factors used to calculate COPC
emissions rates
Likely overestimates acute Hazard
Indices
Emissions Tests The contribution from non-detected PAH in the 1.3-Class tests was replaced with I . I -Class
emissions factors Likelv overestimates risk
Emissions Tests The contribution from non-detected chemicals was shown to contribute an additional 7 to
25 percent ofthe risks Shown to overestimate risk
Emissions Tests Two PAH were eliminated from the COPC list Likelv underestimates risk
Air Oualitv Modelins Acute air concentrations are calculated assumins all sources oDerate at the same time Shown to overestimate risk
Air Oualitv Modelins Assumes reasonable worst case meteorological conditions at the time of processing wastes Likelv overestimates risk
Air Quality Modeling The model has a number of complex assumptions built in to represent plume rise, air
dispersion. and particulate deposition. All have uncertaintv.
Could overestimate or underestimate
risk
Air Quality Modeling The model has two components: OBODM and AERMOD, the operation of these two
models tosether has not been validated.
Could overestimate or underestimate
risk
Media Concentration
Models
Soil concentrations are modeled based on deposition, release of COPCs to soil. COPCs
mav remain on released particles and not be released to soil.Likelv overestimates risk
Media Concentration
Models
COPC uptake into plants from air is based on the assumption that higher molecular weight
COPCs are in the vapor phase, when they are likely to be adsorbed to particulates.
Likely significantly over estimates
risk
Media Concentration
Models
Plant uptake of COPCs is based on chemical specific modeling, often using physical
Darameters and often un-validated assumptions
Likely significantly over estimates
risk
Media Concentration
Models
Bio-transfer factors for COPCs from plants-to-animals, plants-to-humans, animals-to-
humans, and human-to-human is based on chemical specific modeling, often using physical
Darameters and often un-validated assumotions
Likely overestimates risk
ExDosure AssumDtions Human exDosure Darameter assumDtions are US EPA default and are based on Reasonable Could overestimate or underestimate
TAsr.n 10-11
Sovrn oF TrrE UncnnrnNTIEs IN TIrE Pnouoxrony Rrsr AssnssvtpNt.
AND A Ou,ll,rurrvr AssnssMENT oF THEIR Potnnrnr, Ivrpl,cr oN THE Rtsr AssnssMENT
Aspect Risk
Assessment Process Assumption Effect on the Risk
Assessment
Maximum Exposure, these are conservative for the majority of the population, but may be
exceeded in some instances.
risk
Exposure Assumptions
Human diet and intake exposure assumptions are US EPA default and are based on
Reasonable Maximum Exposure, these are conservative for the majority of the population,
but mav be exceeded in some instances.
Will overestimate risk in this risk
assessment
Exposure Assumptions
Human diet and intake exposure assumptions are unlikely at this location in Utah becausd
the soil and water are ofa quality that could not produce the assumed levels ofplant and
animal food for the farmer diet.
Will overestimate risk in this risk
assessment
Toxicological dose-
response
Risk assessment uses US EPA and other regulatory dose-response factors that are designed
to be health protective for the majority of the population. By definition, these are
conservative for the maiority of the population, but may be exceeded in some instances.
Likelv overestimates risr
Risk and Hazard
Calculations
These calculations will multiply the conservative uncertainty:in the parameters presented
above. and will increase the uncertaintv.Likelv overestimates risx
DRAFT Appendix F: Geosyntec Consultants
M-136 A and M-225 A Acute HQ's and Hl Summary of Hazard lndices
Table 1. Acute Hazard lndices
Receptor
Summed Hl
Summed Hlfor with
adiusted NiM-136 A and
all sources'M-225 A2 and Cr3
Adams Ranch 2.9 L,4 o.4
ATK Ranch Pond o.2 0.1 2.9E-O2
Autoliv 4.3 2.2 0.5
Blue Creek 4.7 2.4 0.5
Boundary 1 5.3 2.7 o.7
Boundary 2 2.3 L.2 0.3
Boundary 3 o.7 o.4 0.1
Boundary 4 0.8 o.4 0.1
Christensen Ranch 0.9 o.4 0.1
Holmgren Ranch 0.5 o.2 0.1
HowellDairy 0.3 0.1 3.6E-02
North Plant Main Adm 2.C 1.0 o.2
Penrose 0.3 0.1 3.4E-O2
South Plant Main Adm 3.8 1.9 0.5
Ihatcher 0.3 o.2 4.4E-O2
t the Nt presented in this column assume all sources and use the
original amounts of chromium and nickel. These values are
consistent with those presented in the draft HHRA.
'These Hl are based on using only sources M136A1, A2, A3 and
M225A and the original amounts of chromium and nickel.
'These Hl are based on using only sources M136 A!, A2,A3 and
M225A and the adiusted amounts of chromium and nickel. The
adjustment is based on the April 2014 chromium and nickel
analytical results from ATK.
Acute HQs for 126,500 lbs REVISED (2).xlsx 7 /2O/2OL5 1of1
7tnf2015
From:
Sent:
To:
Subject:
RE Quesliqt on SO2 data in q.r ODOEI| testing (1).htm
Sastry, Chandra [[e-mail]]
Wednesday, October t9,2OLl9:33 AM
Palmer, Blair
RE: Question on SO2 data in our ODOB|testing
Our notes from the testing indicate that it was made from stainless steel .
Chandra
Chandramouli Sastry
URS Corporation,
1093 Commerce Park Drive, Suite 100
Oak Ridse, TN 37830.
Tel: [phone]
From: Palmer, Blair [mailto: Blair.Palmer@ATK,com]
Sent: Wednesday, October 19, 2011 11:30 AM
To: Sastry, Chandra
Subject: RE: Question on SO2 data in our ODOB| testing
Thanks Chandra. This information is very helpful. Do you recall if the tray was made from stainless steel? | just
remember what appeared to be a bright shiny new tray'
Thanks,
Blair
From : Sastry, Cha ndra [mai lto : [e-mail]]
Sent: Wednesday, October 19, 2011 9:11AM
To: Palmer, Blair
Cc: Carson, John R
Subject: RE: QuesUon on SO2 data in our ODOB| testing
Blair, I have some answers:
1) 38 grams of black powder and a squib was used to detonate the items.
Z) The exact formulation of the black powder is not available. Our notes say that it was smokeless black
powder. However, a typical black powder composition is 74o/o potassium nitrate, L5.6Yo charcoal, and
LO.4% sulfur.
3) Our recollection on the initiation wire is that it was some form of a nichrome wire that would get hot
when electricity passes through - like the wire in a heat gun. I did not find anything in our notes on this'
4l We don't recall the stainless steel pan being anything fancy - it was just a regular tray. I think the
Dugway folks found one in their labs for your tests.
Chandra
Chandramouli Sastry
URS Corporation,
1093 Commerce Park Drive, Suite 100
Oak Ridge, TN 37830.
Tel: [phone]
file:///C:AJsers{vadd/Dovrtoads/RE%4Ctr.estion%20on%2osO2o/6Mao/ofrnoloMr%20oDOB%20testind/620(1).hfn 1t4
7tNn15 RE Qrcstim on SO2 data in ou ODOB testirg (l).tilm
From : Palmer, Bla i r [mai lto : Blair. [e-mail]]
Sent: Tuesday, October 18,2011 10:10AM
To: Sastry, Chandra
Cc: Carson, John R
Subject: RE: Question on SO2 data in our ODOB| testing
Thanks Chandra and John, that does help. I also have a couple of other questions:
U What was the size (g or mg) of the black powder squib that was used for ignition?
2l Any idea exactly what black powder formulation was used?
3) Also the initiation wire, what was this made of, it seems like we have discussed this before?
4) Last question, I remember the test samples being burned in a small, new, stainless steel tray that was
constructed for ATK. Do you have any information on this?
Any information on these questions would be helpful. I appreciate your help.
Thanks,
Blair
From : Sasby, Chandra [mailto: [e-mail]]
Sent: Friday, October L4,20lt 2:t4 PM
To: Palmer, Blair
Cc: Carson, John R
Subject: RE: Question on SO2 data in our ODOB| testing
Blair,
John forwarded your request to me and I went back and looked at the CEMS data from the ODOB| testing. The
SO2 CEMS was calibrated for a 0 - 30 ppm range during those tests and the measured values during each test
were within O - !2o/o of the calibrated range of the instrument. In fact, a majority of the measured values were
within O - 2% of the calibrated range. See the graph below.
When EPA test methods 6C,78 etc. (instrumental methods aka CEMS)are used to measure SO2, NOX, etc. the
instruments are typically ranged so that a majority of the measured values are within 20 -8O% of the calibrated
range of the instrument. Hence we made the comment that "SO2 levels were too low to be reliably measured".
Hope this helps.
Chandra
fite///C:/users{vandellDoryrloads/RE%20Qr.estiorfi6M/onSO2o/oMaoAXlrf/oMro,620ODOB%20testirg7o20(1).hfn z4
RE Qwstim on SO2 datra in ou ODOE testing (1).htrn
HDescription : cid :imageOOt.png@01CC8DAF.31718330
Chandramouli Sastry
URS Corporation,
1093 Commerce Park Drive, Suite 100
Oak Ridse, TN 37830.
Tel:[phone]
From: Carson, John R
Sent: Friday, October 07,20t14:56 PM
To: Sastry, Chandra
Subject: FW: Question on SO2 data in our ODOBItesting
Can we help Blair with this?
Note: new email address
John R. Carson
URS Corporation
1093 Commerce Park Drive, Suite 100
Oak Ridge, TN 37830-8029
Phone: [phone]
Fax: [phone]
E-mail : [e-mail]
From : Pal mer, Blair [mai lto: Blair. [e-mail]]
fle:///C:AJsers/ivandel/Do.,'rnlo*/RE%20Qr.estiono/o?frcr1o/o2fFor2o/o?fdedta%N*h20ou%20ODOBi%2Otestir€%20(1).hfrt 314
7lntn15 RE Qrcstim on SO2 data in otr ODOB testing (1).film
Sent: Friday, October 07,20LL2:27 PM
To: Carson, John R
Subject: Question on SO2 data in our ODOBItesting
Hello John:
Hope all is going well for you and your family. I have a question relating to our ODOB| testing and SO2. In our
report Volume I Summary Report, section 5, page 32, it states that "SO2 levels were too low to be reliably
measured." SO2 is giving us some problems in our modeling showing us exceeding the NAAQS. I don't have any
experience with CEMs and their reliability. Do you have any information regarding SO2 and the other compounds
that were measured by the CEMs from our testing, and information behind the statement "SO2 levels were too
low to be reliably measured?" Any information would be helpful.
Thank you,
Blair Palmer
Environmental Engineer
ATK Launch Systems, Inc.
435-863-2430
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fife:///C:4Jsers/ivandel/Doarto*/REo620Qr.estimo/offioN2o/oMao/oTJrf/o20ott%20ODOB%20e8tirg%20(1).tttm