DSHW-2015-011438 - 0901a068805961cd

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieulenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Drector
DTVISION OF WASTE MANAGEMENT
AND RADIATIONCONTROL
Scott T. Andenon
Director
November 76,2015
George Gooch, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham city, uT 84302.0707
RE: Storage Permit Modification
urD009081357
Dear Mr. Gooch:
The Division of Waste Management and Radiation Control has completed its review of ATK's request to
modify its Storage Permit to add hazardous waste storage building M-629. The addition of this storage
building has been classified as a Class II Permit Modification. The 60-day public comment period associated
with the modification ended on October 19,2015. No comments from the public were received. ATK's
permit modification request is hereby approved.
The closure of hazardous waste storage buildings M-47 and M-603 was approved on August 20, 2015.
Permit conditions regarding these buildings have been removed from the Permit. ln addition, the closure
cost estimate that was submitted for storage building M-629 is hereby approved in accordance with Permit
Condition II.P.5. The closure cost estimates for eachHazardous Waste Manasement Unit must be
maintained in ATK's Operating Record.
Enclosed with this letter is a CD containing the modified portions of the Permit (Module 3 and Attachments
2, 4, 5, 6,7,8,9 and I l) in Word and PDF file formats. Please use the PDF files to replace these sections of
the Permit. The Word files may be kept in case changes to the Permit are needed in the future.
If you have any questions, please call Jeff Vandel at [phone].
Si
T. Anderson,
Division of Waste
195 North 1950 West . Salt lake City, UT
Mailing Address: P.O. Box 144880. Salt t-ake City, UT 841l4-4880
Telephone [phone]. Fax [phone]. T.D.D. (801) 5364414
zuno.deq.utnh.gou
Printed on 100% recycled paper
Director
Management and Radiation Control
DSHW-2015-01 1438
(Over)
STA/JV/jr
Enclosure: CD: Module 3 (DSHW-2014-004377); Attachment 2 (DSHW-2014-004365); Attachment 4
(DSHW-2014-004367); Attachment 5 (DSHW-2014-004368); Attachment 6 (DSHW-2014-
004369); Attachment 7 (DSHW-2014-004370); Attachment 8 (DSHW-2014-004371);
Attachment 9 (DSHW-2 0l 4-00437 2); Attachment I I (DSHW-20 I 4-00 437 4)
cr Blair Palmer, ATK Launch Systems
Grant Koford, EHS, Environmental Health Director, Bear River Health Departrnent
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Deparbnent
Moye Lin, USEPA Region 8
ATK Launch Systems Inc. – Promontory November 2015 Module III – Storage in Containers UTD009081357
MODULE III – STORAGE IN CONTAINERS III.A. APPLICABILITY III.A.1. The requirements of this permit Module pertain to the operation of hazardous waste container storage areas at the facility. The Permittee shall comply with R315-8-9 and all conditions of this Module. III.A.2. The designated hazardous waste storage areas are the bays of Buildings M-705S, E-501, M-629, M-186, the burn trays at M-136, Burn Station 14 at M-136, and Storage Pad S-633. Drawings of these storage areas are presented in Attachment 6. III.B. WASTE IDENTIFICATION III.B.1. The Permittee shall, subject to the terms of this Permit, store only the following hazardous wastes, as listed by EPA hazardous waste code, in containers at storage areas M-186, M-705S and E-501: D001, D002, D003, D004, D005, D006, D007, D008, D009, D010 D011, D016, D018, D019, D021, D022, D023, D024, D026, D027,D028, D029, D035, D036, D038, D039, D040, D042, D043, F001, F002, F003, F004, F005, F006, F007, F008, F009, K044, P003, P012, P022, P028, P029, P030, P047, P048, P064, P067, P077, P087, P092, P093, P095, P098, P102, P105, P106, P112, P116, P119, U001, U002, U004,U006, U008, U009, U019, U025, U028, U029, U031, U037, U041, U044, U048, U053, U056, U057, U069, U070, U072, U077, U079, U080, U085, U088, U092, U093, U095, U098, U101, U102, U103,U105, U108, U112, U113, U117, U118, U120, U121, U122, U123, U131, U133, U134, U140, U147, U148, U149, U151, U154, U156, U159, U160, U161, U162, U165, U168, U169, U170, U171, U185, U186, U188, U190, U196, U201, U209, U210, U211, U218, U219, U220, U221, U223, U224, U225, U226, U228, U238, U239, U240, U243, U244, U246, U253, U328, U353, U359, U404. III.B.2. The Permittee may store solid reactive hazardous waste, EPA hazardous waste code D003, in storage Building M-629 subject to the terms of this Permit. III.B.3. The Permittee may store solid reactive hazardous waste, EPA hazardous waste code D003, received from off-site in burn trays at M-136 for up to 14 days prior to thermal treatment. Waste stored in burn trays shall be containerized only in covered drums, boxes, plastic bags, woven bags, US Department of Transportation (DOT) approved shipping containers or containerized as described in Attachment 11. Containers shall be labeled and managed as specified in Attachment 9. III.B.4. The Permittee may store waste rocket motors, EPA hazardous waste code D003, received from off-site that contain solid propellant, one at a time on the ground at M-136, Burn Station 14 for up to 14 days prior to thermal treatment. The waste rocket motors shall be labeled and managed as specified in Attachment 9. III.B.5. The Permittee may store solid reactive hazardous waste, EPA hazardous waste code D003, on Storage Pad S-633 subject to the terms of this Permit.
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ATK Launch Systems Inc. – Promontory November 2015 Module III – Storage in Containers UTD009081357
III.B.6. The Permittee is prohibited from storing hazardous waste that is not identified in Section III.B. of this Module. Any addition of hazardous waste codes to Condition III.B.1. requires modification of the permit in accordance with Condition I.D.3. III.C. CONDITION OF CONTAINERS III.C.1. If a container holding hazardous waste is not in good condition (e.g., severe rusting, bulging, apparent structural defects) or it has begun to leak, the Permittee shall transfer the hazardous waste, or the container itself, to a UN approved container in accordance with Section 8-1-10 of Attachment 8. The transfer shall be completed as soon as possible but not later than 24 hours from the time the problem was first discovered. III.D. COMPATIBILITY OF WASTE WITH CONTAINERS III.D.1. The Permittee shall assure that the waste is compatible with the containers as required by R315-8-9.3. The Permittee shall follow the compatibility plan as indicated in Section 9-2.1 and Table 9-2 of Attachment 9. III.E. MANAGEMENT OF CONTAINERS III.E.1. The Permittee shall manage containers in accordance with this module of the Permit, UAC R315-8-9.4 and the procedures identified in Attachment 9. A container holding hazardous waste shall always be closed during storage except when the Permittee is adding or removing waste from the container. The Permittee shall not open, handle, or store containers in a manner which may cause the containers to leak. III.E.2. The Permittee shall store liquid hazardous wastes in containers only at storage areas M-186, E-501 and M-705S. Drawings of the container storage areas are shown in Attachment 6. At capacity, the Permittee may store the following volumes of wastes: III.E.2.a. E-501 - 8,800 gallons, which is 160 55-gallon containers or the equivalent; III.E.2.b. M-186 - 22,000 gallons, which is 400 55-gallon containers or the equivalent; and III.E.2.c. M-705S - 1,760 gallons, which is 32 55-gallon containers or the equivalent. III.E.3. The Permittee shall store solid reactive hazardous waste in containers at storage areas M-629, M-136 and S-633. Drawings of the storage areas are shown in Attachment 6. At capacity, the Permittee may store the following amounts of wastes: III.E.3.a. M-629 - 110,000 lbs 1.3 or 55,000 lbs 1.1 solid reactive hazardous waste; III.E.3.b. M-136 – 106,500 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste, as described in Condition III.B.3. or III.B.4., in burn trays or in a rocket case placed on the ground; and III.E.3.c S-633 – 75,000 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste.
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ATK Launch Systems Inc. – Promontory November 2015 Module III – Storage in Containers UTD009081357
III.E.4. The Permittee shall maintain an aisle space of 30 inches minimum between containers or pallets of containers at storage areas M-186 and E-501. III.E.5. The Permittee shall store hazardous wastes at M-705S, M-629, S-633 and M-136 so that the container or waste rocket motor may be readily inspected and hazardous waste labels are visible. III.E.6. The Permittee may stack 55-gallon drums at a maximum of two high at storage areas M-186 and E-501. III.E.7. Hazardous waste containers shall not be stacked at storage areas M-705S, M-629, S-633 and M-136 except as described in Attachment 9-2.3. III.E.8. The Permittee shall unload any transport vehicle hauling containers of hazardous waste for storage within 10 days following arrival at the site. Arrival for purposes of this permit shall be the day the vehicle arrives at the facility. III.E.9. The Permittee shall provide storage for and maintain on-site, 85 gallon over-pack drums at areas where liquid hazardous waste is stored. III.F. CONTAINMENT SYSTEMS III.F.1. The Permittee shall maintain the containment systems in accordance with the attached plans and specifications contained in Attachment 9 and as specified in UAC R315-8-9.6. III.F.2. Container management areas shall be inspected for the presence of free liquids in accordance with Attachment 2. If free liquids are discovered in the sumps or other containment areas, the Permittee shall identify the location in the inspection log. Any liquids discovered shall be removed immediately, but in no case later than twenty-four hours after the liquid is discovered and managed according to the spill contingency plan specified in Section 9-4.3 of Attachment 9. III.F.3. For purposes of inspections, all containers stored in the liquid hazardous waste storage area shall be considered full to their respective capacities with liquid hazardous waste. Gondolas/roll-offs that are used only for the storage of solid hazardous waste need not be considered in the calculations for containment. The area for storing solid waste shall be identified. III.F.4. The burn trays at M-136 are only permitted for the storage of solid reactive wastes in containers received from off-site for no more than 14 days. However since some of the
containers contain small amounts of desensitizing fluid (e.g. diesel, shingle oil, etc.), the
containment requirements, as specified in Attachment 9, apply to the storage of wastes
in the burn trays. Inspection of the burn trays shall be conducted in accordance with Attachment 2.
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ATK Launch Systems Inc. – Promontory November 2015 Module III – Storage in Containers UTD009081357
III.G. SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE III.G.1. The Permittee shall not locate containers holding ignitable or reactive waste within 15 meters (50 feet) of the facility boundary. III.G.2. The Permittee shall take precautions to prevent accidental ignition or reaction of ignitable or reactive waste and follow the procedures specified in Attachment 8, UAC R315-8-2.8 and UAC R315-8-9.7. III.H. SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTE III.H.1. The Permittee shall not place incompatible wastes, or incompatible wastes and materials, in the same container, in accordance with UAC R315-8-2.8 and UAC R315-8-9.8(a). III.H.2. The Permittee shall not place hazardous waste or materials in an unwashed container that previously held an incompatible waste or material in accordance with UAC R315-8-2.8 and UAC R315-8-9.8(b). III.H.3. A storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby shall be separated from the other materials or protected from them by means of a dike, berm, wall, or other device. III.I. INSPECTION SCHEDULES AND PROCEDURES III.I.1. The Permittee shall inspect the hazardous waste storage and treatment facilities identified in Condition III.B. of this Permit as specified in the Inspection Schedules contained in Attachment 2. The purpose of this inspection shall be to detect leaking containers, standing liquids, deterioration of containers, and to detect deterioration of, or liquids in, the secondary containment system caused by corrosion and other factors as specified in R315-8-9.5. III.I.2. If problems are observed during the inspections, the Permittee shall correct the problem in accordance with Module II, Section F. III.J. CLOSURE/POST-CLOSURE III.J.1. The Permittee shall close the storage areas in accordance with UAC R315-8-7, UAC R315-8-9.9, Condition II.O. and Attachment 5 of this Permit. III.J.2. Closure plans for each individual hazardous waste management area shall be submitted to the Director for approval no less than 180 days prior to the commencement of closure activities. No closure activities shall take place that have not received prior approval from the Director.
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357

ATTACHMENT 2

INSPECTION SCHEDULES AND PROCEDURE

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
INSPECTION SCHEDULES AND PROCEDURES

II.A. Purpose and Scope

The inspection schedule used by ATK for the hazardous waste management areas
has been designed to meet the requirements of R315-8.2.6. The design of the
schedule promotes the detection of malfunctions, deterioration, discharges, and
other situations which may be causing or leading to a release of hazardous waste
constituents into the environment or pose a threat to human health. Inspections are
conducted by personnel trained to identify potential problem areas and to use the
inspection schedule and the inspection log. Eight areas are designated for
inspection: the container storage area at E-501, M-705S, M-186, the Thermal
Treatment Areas at M-136 (including the LTTAs, burn trays and Burn Station 14),
M-225, T-29B hydrazine dilution and the solid propellant/motor storage
buildings, M-629 and storage pad S-633.

Waste solid propellant and rocket motors are stored at buildings M-629 and
storage pad S-633 and waste hydrazine is treated (by dilution) at building T-29B
periodically. Therefore inspections of these facilities, in accordance with their
inspection schedules, are only required when hazardous waste is being stored or
treated at the facility. A facility must be inspected, however, prior to receiving
hazardous waste for storage or treatment if inspections were discontinued during
the period of inactivity. If any problems are identified with the areas of concern
that are listed in the inspection schedules (contained in this attachment), they must
be corrected before the facility is put back into use.

II.B. Remedial Action or Maintenance

Repairs or corrective action for any deterioration or malfunction discovered by an
inspection shall be conducted as outlined in Module II, Section F. Repairs to
security equipment shall be completed as soon as practicable, but not later than 72
hours after the problem is discovered. As stated in R315-8-2.6(c), where a hazard
is imminent or has already occurred, remedial action shall be taken immediately.

II.C. Inspection Records

All records of inspections and remedial actions shall be retained in the Operating
Record, for a period of at least three years. At a minimum, inspection records
shall include the date and time of the inspection, the name of the inspector, a
notation of the observations made, and the date and nature of any repairs or
maintenance taken.

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
II.D. Inspection Schedules

The inspection schedules appear in detail in Tables II-A through II-F. Each
inspection schedule is designed so that the items appearing on the schedule are
inspected frequently enough to avoid any deterioration of equipment and thus
reduce the probability of an environmental or human health incident between
inspection times. Each inspection schedule is divided into individual categories
and each category contains a specific list of items to be inspected. Inspections are
also required within 24 hours after a storm event as outlined in the schedules
below. A storm event is defined as precipitation in excess of 1.0 inch in a one-
hour period. It shall be documented in the inspection log that the inspection was
conducted in response to a storm event.

TABLE II-A
INSPECTION SCHEDULE FOR DRUM STORAGE AT M-186

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines and look for
broken or downed fence lines, loose wires

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate, safety
flags in place

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Inspect road for spills,
soil discoloration

Loading/ Daily1 Inspect loading areas for
Unloading Areas spills, soil discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
3. Safety Equipment

Eyewash/Shower Monthly Ensure in working order by
testing, check water supply

Telephone/Radio Monthly Working condition

4. Storage Containment

Containers Weekly Number of containers, severe
corrosion (i.e., flaking, large rust buildup,
rusty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums,
adequate aisle space (2.5 feet)

Pads Weekly Chips, cracks, or irregularities in concrete,
general condition

Sumps/Pads Daily2 Standing liquid on pad or in sumps

Drainage Area Weekly Spills, discolored soil

Roof Weekly General condition including holes or defects

5. Emergency Equipment

Fire Monthly Fire extinguisher full, in working order
Extinguisher

Absorbent Monthly Adequate supply (minimum 25 lbs)

Repack Drums Monthly Two repack drums with seals

55-Gallon drums Monthly Six empty 55-gallon drums with bungs
in good condition, no dents, etc.

Generator Monthly Routine oil check, fill with gas, test startup

Pump Monthly Good working order, hoses intact, test
startup and pump

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 Daily except for nonscheduled work days and holidays

TABLE II-B
INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-136

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines, look for
loose wires or broken lines

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Spills, discolored soil

Loading/ Daily1 Spills, discolored soil
Unloading Areas

Periphery Daily1 Spills, discolored soil, stressed vegetation

3. Safety Equipment

Telephone/Radio Monthly Check operating condition of equipment

4. Burn Ground Area

Erosion Weekly3 Survey area and note severe erosion on
grounds

5. Storage/Containment

Burn tray Weekly2,3 Tray is intact and liquid tight, accumulation
of liquids

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
Container Weekly2 Closed, labeled, signs of leaks or spills

6. Emergency Equipment

Fire
Extinguisher Monthly Fire extinguisher full and in working order

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 Inspect upon arrival, then each calendar week
3 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.

TABLE II-C
INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-225

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines, look for
loose wires or broken lines

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Spills, discolored soil

Loading/Unloading Daily1 Spills, discolored soil

Areas

Periphery Daily1 Spills, discolored soil, stressed
vegetation

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
3. Safety Equipment

Telephone/Radio Monthly Check operating condition of equipment

4. Burn Ground Area

Erosion Weekly2 Survey area and note severe erosion on
grounds

Burn Tray Weekly2 Tray is intact and liquid tight, accumulation
of liquids

5. Emergency Equipment

Fire Extinguisher Monthly Fire extinguisher full and in working order
1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.

TABLE II-D
INSPECTION SCHEDULE FOR STORAGE AND CONSOLIDATION
ROOM AT M-705S

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Weekly Readable signs, signs in place

2. Area

Roadway Daily1 Spills, discolored soil

Loading/Unloading Daily1 Spills, discolored soil
Areas

Periphery Daily1 Spills, discolored soil, stressed
vegetation

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
3. Safety Equipment

Eyewash/Shower Monthly Ensure in working order by testing,
check water supply

Telephone/Radio Monthly Check operating condition of equipment

4. Storage containment

Containers Weekly Number of containers, severe corrosion (i.e.
flaking, large rust buildup, rusty bungs),
dented drums, hazardous waste labels in
place, properly marked, readable, no open
bungs, no standing liquid on the drums

Pads, Sumps Weekly Chips, cracks, or irregularities in the
concrete, general conditions

Portable Secondary Daily2 Cracks, liquid, containment integrity

Roof Weekly General condition including holes or defects

Sump, pads Daily2 Check for standing liquids in the sump and
containment system

5. Emergency Equipment

Fire Extinguisher Monthly Fire extinguisher full and in working order

Absorbents Monthly Adequate supply (minimum 25 lbs.)

Repack Drums Monthly Two repack drums with seals

55-Gallon Drums Monthly Six empty 55-gallon drums with bungs in
good condition, no dents, etc.
1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 Daily except for weekends and holidays.

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
TABLE II-E
INSPECTION SCHEDULE FOR M-629

(Note: As stated in section II.A. of this Attachment, inspections of these
storage buildings are not required during periods when hazardous waste is not
being stored at the facility)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Weekly Readable signs, signs in place

Bay Doors Weekly Function properly

Lock Weekly Function properly

2. Area

Roadway Daily1 Inspect road for spills, soil
discoloration

Loading/Unloading Areas Daily1 Inspect loading areas for spills, soil
discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation
3. Communications Equipment

Telephone Monthly Working condition; place
call to verify operation

4. Storage Containers

Motors/bags, etc. Weekly Verify condition of motors/bags,
properly marked and labeled, out of
place material and check for leakage,
or liquid discharge from waste solid
rocket motors and propellant .

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
Building Weekly Verify no damage done to exterior of
facility

Roof Weekly General condition including holes or
defects

5. Emergency Equipment

Fire Extinguisher Monthly In working order and full
1 Daily when in use (i.e. when loading or unloading operations occur at the facility).

TABLE II-F
INSPECTION SCHEDULE FOR DRUM STORAGE PAD AT E-501

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines and look for
broken or downed fence lines, loose wires

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate, safety
flags in place

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Inspect road for spills,
soil discoloration

Loading/ Daily1 Inspect loading areas for
Unloading Areas spills, soil discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
3. Safety Equipment

Eyewash/Shower Monthly Ensure in working order by
testing, check water supply

Telephone/Radio Monthly Working condition

4. Storage Containment

Containers Weekly Number of containers, severe
corrosion (i.e., flaking, large rust buildup,
rusty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums,
adequate aisle space (2.5 feet)

Pads Weekly Chips, cracks,or irregularities in concrete,
general condition

Sumps/Pads Daily1 Standing liquid on pad or in sumps

Drainage Area Weekly2 Spills, discolored soil

Roof Weekly General condition including holes or defects

5. Emergency Equipment

Fire Monthly Fire extinguisher full, in working order
Extinguisher

Absorbent Monthly Adequate supply (minimum 25 lbs)

Repack Drums Monthly One repack drum with seals

55-Gallon drums Monthly Three empty 55-gallon drums with bungs
in good condition, no dents, etc.
1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
TABLE II-G
INSPECTION SCHEDULE FOR T-29B Hydrazine Dilution Bay

(Note: As stated in section II.A. of this Attachment, inspections of building T-29B are not
required during periods when hazardous waste is not being treated at the facility)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Prior to treatment Readable signs, signs in place

Door Locked Prior to treatment In working order, locked

2. Area

Roadway Daily1 Inspect road for spills,
soil discoloration

Loading/ Daily1 Inspect loading areas for
Unloading Areas spills, soil discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation

3. Safety Equipment

Eyewash/Shower Prior to treatment Ensure in working order by
testing, check water supply

Telephone(cell) Prior to treatment Working condition

4. Storage Containment

Containers Prior to treatment Number of containers, severe
corrosion (i.e., flaking, large rust buildup,
rusty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
Floor Prior to treatment Chips, cracks,or irregularities in concrete,
general condition

Roof Prior to treatment General condition including holes or defects

5. Emergency Equipment

Fire Prior to treatment Fire extinguisher full, in working order
Extinguisher

Absorbent Prior to treatment Adequate supply (minimum 25 lbs)
1 Daily when in use (i.e. when loading or unloading operations occur at the facility).

TABLE II-H
INSPECTION SCHEDULE FOR STORAGE PAD S-633
(Note: As stated in section II.A. of this Attachment, inspections of this storage
pad are not required during periods when hazardous waste is not being stored
on the pad)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines, look for

loose wires or broken lines

Signs Weekly Readable signs, signs in place

Gate Weekly Able to properly close gate

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Spills, discolored soil

ATK Launch Systems Inc. – Promontory November 2015 Attachment 2 – Inspection Schedules and Procedures UTD009081357
Loading/Unloading Daily1 Spills, discolored soil
Areas

Periphery Daily1 Spills, discolored soil, stressed
vegetation

Erosion Weekly2 Survey area and note severe erosion on or
around storage pad

3. Storage Containers

Motors/containers, etc. Weekly3 Verify condition of motors/containers,
properly marked and labeled, out of
place material and check for leakage, or
liquid discharge from waste solid rocket
motors and propellant.
1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 And after each storm event. A storm event is defined as more than one inch of precipitation in a
one-hour period. 3Inspect upon arrival, then each calendar week

HAZARDOUS WASTE MANAGEMENT

Contingency Plan and
Emergency Procedures
For Spills of
Hazardous Materials

November 2015

ATK Launch Systems
Promontory Facility
P.O. Box 707 Brigham City UT 84302-0689
[phone]

ATK Launch Systems – Promontory November 2015 Attachment 4 – Contingency Plan UTD009081357

PREFACE

This document, HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY PROCEDURES FOR SPILLS OF HAZARDOUS MATERIALS, (herein referred to as Contingency Plan), provides
written instructions on how to take care of spills of hazardous substances. It is intended to meet the requirements of
the Utah Hazardous Waste Rules and Subpart D of the EPA Resource Conservation and Recovery Act.
This CONTINGENCY PLAN does not replace, nor is it to be used instead of, the ATK Launch Systems -
Promontory EMERGENCY AND DISASTER RESPONSE PLAN, or any other plan which outlines procedures to
be followed during general emergencies, disasters, civil disturbances, riots, bomb threats, etc.

Most spills involving hazardous substances will not require use of the EMERGENCY AND DISASTER
RESPONSE PLAN. Spills that create an emergency situation involving possible injury to personnel or damage to
property will require use of the EMERGENCY AND DISASTER RESPONSE PLAN to take care of the emergency.
This CONTINGENCY PLAN applies to containment and cleanup of a hazardous waste spill.
Definitions in the HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND EMERGENCY
PROCEDURES reflect EPA and State of Utah environmental language while those in the EMERGENCY AND
DISASTER RESPONSE PLAN reflect OSHA, UOSH, FEMA, and ATK Launch Systems language. The user must
be careful not to be confused by differences in language between these documents and must evaluate the applicability of each document to the particular situation.

ATK Launch Systems – Promontory November 2015 Attachment 4 – Contingency Plan UTD009081357
TABLE OF CONTENTS

I. INTRODUCTION .......................................................................................................................... 1
A. PURPOSE ............................................................................................................................. 1
B. SCOPE .................................................................................................................................. 1 C. NOTIFICATION .................................................................................................................. 1
D. POSTING.............................................................................................................................. 1
E. REVISIONS AND UPDATING ........................................................................................... 1
F. DEFINITIONS ...................................................................................................................... 2 G. PLANT LOCATIONS AND SITE INFORMATION........................................................... 5
H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES ........................................................................................................................... 7
II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION ......................................... 7
A. EVACUATION CRITERIA ................................................................................................. 7
B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL ......................................... 7
C. REPORTING OF EMERGENCY INCIDENTS ................................................................... 8
D. PERSONNEL RESPONSIBILITIES .................................................................................... 8 E. ALARM SYSTEMS ........................................................................................................... 19
F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND
HOSPITALS ....................................................................................................................... 15
III. SPILL CONTAINMENT AND CLEANUP ................................................................................. 16
A. CONTROL PROCEDURES ............................................................................................... 16
B. SPILL CONTAINMENT AND CONTROL....................................................................... 16
C. SPILL CLEANUP ............................................................................................................... 16 D. FOLLOWUP PROCEDURES ............................................................................................ 17
E. INCOMPATIBLE WASTE ................................................................................................ 18
F. CLEANUP MATERIAL AND EQUIPMENT ................................................................... 18
G. DECONTAMINATION EQUIPMENT AND PROCEDURES ......................................... 20 H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT .................................. 20

IV. INSTALLATION RESPONSE TEAM TRAINING .................................................................... 21
A. TRAINING ......................................................................................................................... 21 B. SIMULATION .................................................................................................................... 22

V. TRAINING PLAN ........................................................................................................................ 22
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN ............................................ 22 B. REVIEW OF LEGAL REQUIREMENTS ......................................................................... 22 C. LOCAL ATK CORPORATION REQUIREMENTS ......................................................... 22
D. CUSTOMER REQUIREMENTS ....................................................................................... 22
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER . 22
F. EMERGENCY COMMUNICATION SYSTEM................................................................ 22 G. FIRE PLANS/FIRE DRILL ................................................................................................ 22
H. BOMB SEARCH TECHNIQUES ...................................................................................... 22
I. FIRE BARRICADE/CORDON AREAS ............................................................................ 23
J. EMERGENCY MEDICAL TREATMENT ........................................................................ 23 K. SECURITY OF SITE ......................................................................................................... 23
L. INVESTIGATION .............................................................................................................. 23
M. PUBLIC RELEASE OF INFORMATION ......................................................................... 23
N. FACT-FINDING METHODS ............................................................................................ 23 O. SAFING THE AREA .......................................................................................................... 24
P. CONTROL OF THE CURIOUS......................................................................................... 24

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Q. HANDLING OF REMAINS ............................................................................................... 24
R. NOTIFICATION PROCEDURES ...................................................................................... 24 S. RESCUE EFFORTS ........................................................................................................... 24

TABLES
TABLE I COMPATIBILITY INFORMATION ......................................................................................... 25 TABLE II EMERGENCY COORDINATOR CALL LIST ........................................................................ 26

FIGURES
FIGURE 1. DECONTAMINATION/SPILL SCENE ............................................................................... 27 FIGURE 2. DECONTAMINATION ....................................................................................................... 28

APPENDIX I
NORTH PLANT SITE MAP ..................................................................................................................30
SOUTH PLANT SITE MAP ...................................................................................................................31

TEST AREA SITE MAP ........................................................................................................................32
PLANT 3 SITE MAP ..............................................................................................................................33

M-136 BURNING GROUNDS FACILITY FUNCTION TABLE .........................................................34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE ............................................34
M-136 SITE MAP AND EVACUATION PLAN……………………………………………………….35
M-186 SITE MAP AND EVACUATION PLAN ...................................................................................36 E-501 STORAGE YARD FACILITY FUNCTION TABLE ..................................................................37
E-501 SITE MAP AND EVACUATION PLAN ...................................................................................38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE .........................................................39
M-225 SITE MAP AND EVACUATION PLAN ...................................................................................40 T-29B SATELLITE ACCUMULATION AREA FUNCTION TABLE .................................................41 T-29B SITE MAP AND EVACUATION PLAN....................................................................................42
M-705 WASTEWATER TREATMENT FACILITY FUNCTION TABLE ..........................................43
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM ................................................................43
M-705 SITE MAP AND EVACUATION PLAN ...................................................................................44 M-629 PROPELLANT STORAGE FUNCTION TABLE.....................................................................45
M-629 SITE MAP AND EVACUATION PLAN ..................................................................................46
S-633 PROPELLANT STORAGE FUNCTION TABLE………………………………………………47 S-633 SITE MAP AND EVACUATION PLAN………………………………………………………..48

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APPENDIX II
A. BULK FLAMMABLE LIQUID STORAGE AREAS ............................................................................50
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE ................................................51

APPENDIX III

ARRANGEMENTS WITH LOCAL AUTHORITIES…………………………………………………..52

ATK Launch Systems – Promontory November 2015 Attachment 4 – Contingency Plan UTD009081357

I. INTRODUCTION
A. PURPOSE
This plan may be activated by requesting emergency response on phone number 2222 or 911.

The purpose of this Contingency Plan and Emergency Procedures is to set forth responsibilities,
establish organizational structure, and outline the procedures required to ensure effective warning, response, and control to minimize hazards to human health or the environment from fires, explosions,
or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to
air, soil, or surface water.
B. SCOPE
This organizational plan is intended to meet requirements of the Utah Hazardous Waste Management
Rules and Subpart D of the Resource Conservation and Recovery Act.
The provisions of this plan will be carried out immediately whenever there is a fire, explosion, or
release of hazardous waste or hazardous waste constituents at one of the permitted facility that could
threaten human health or the environment. This plan specifically addresses company actions to be initiated in the event of a spill or release of hazardous materials.
C. NOTIFICATION
Incidents covered by this contingency plan and which meet applicable State of Utah and U.S. EPA
reporting requirements will be reported to the appropriate agencies by Environmental Specialists. The
Environmental Specialist should confer with the Director or Manager of Environmental Services prior
to notification.
D. POSTING

Copies of the Contingency Plan and all revisions must be:
1. Maintained at the facility and the Fire Department's Spill Response vehicle.

2. Submitted to all local police departments, fire departments, hospitals, and State and local emergency response teams that may be called upon to provide emergency services.
(Arrangements have been made between ATK Launch Systems – Promontory and the hospitals
located at Brigham City and Tremonton regarding emergency services that would be provided as
required. Letters of agreement are kept in the Environmental Services Central Files.) E. REVISIONS AND UPDATING

This contingency plan will be reviewed and amended whenever:
1. Applicable regulations are revised.

2. The plan fails in an emergency. 3. The facility changes its design, construction, operations, maintenance, or other circumstances in
a way that materially increases the potential for fires, explosions, or release of hazardous waste
or hazardous waste constituents, or changes the response necessary in an emergency.

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4. The list of emergency coordinators change.
5. The list of emergency equipment changes.

F. DEFINITIONS 1. Disaster - An event in which loss of life, serious and/or multiple injuries, major property or
environmental damage, or major disruption of normal operations has occurred. This includes
serious fires or major hazardous material spills, explosions, injuries to multiple people, and acts
of nature such as floods, violent storms, or earthquakes.
2. Discharge - The accidental or intentional spilling (see Spill), leaking, pumping, pouring,
emitting, emptying, or dumping of hazardous waste on or into the air, land, or water.

3. Emergency - A situation which, if not quickly controlled, can lead to death, serious and/or
multiple injuries, major loss or damage to property, significant damage to the environment, or disruption of normal operations.

4. Emergency Command Unit - The group of personnel selected by the emergency commander to
assist in the full scope administration of the emergency.
5. Emergency Commander - The General Manager or his designee, as head of the Command
Unit, is responsible for the overall direction, coordination, and function of all units charged with
providing countermeasures to cope with conditions and/or events within the scope of this plan.
The Command Unit will consist of any and all persons selected by the Emergency Commander.
NOTE
The Emergency Commander will be the head of the Command Unit for all civil disturbances, bomb threats, national emergencies, and natural disasters.

The Command Unit will operate from a pre-designated Emergency Operations Center specified
by the Emergency Disaster Response Plan or the Emergency Commander.
6. Emergency Operations Center (E.O.C.) - The location of senior management where decisions
and incident specific policies are made.

7. Environmental Specialist - The Environmental Specialist is the Spill Team Leader from Environmental Services. He or his designated alternate will assist the Incident Commander in
the evaluation of the impact on the environment resulting from any emergency, disaster, or
hazardous substance discharge.
NOTE
When required, notification of Federal, State, and/or local environmental agencies shall be through the Environmental Specialist. Company policy requires that the event be discussed
with the Vice President of the applicable division and ATK
Corporate Environmental.
8. Fire Brigade - A group of employees, generally from maintenance, who have received
HAZWOPER training and are called on as needed to assist the full-time fire department in
emergency response.

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9. Fire Warden - A designated individual assigned in advance to assist the fire department in
evacuation procedures and give information on the building and surrounding area. 10. Hazardous Waste - Identified in 40 CFR 261 and in Utah Hazardous Waste Management Rules,
Section 2.1 on the basis of specific listed material and general characteristics. Specific listed
wastes are found in these documents. The EPA regulations provide detailed technical
specifications of four characteristics:
Ignitable (D001) - An ignitable compressed gas, an oxidizer, a liquid having a flashpoint <
140ΕF, or a non-liquid capable of causing fire, under standard temperature and pressure, through friction, absorption, moisture, or spontaneous chemical
changes.

Corrosive (D002) - A solid waste that (1) is aqueous and has a pH < 2 or > 12.5; or (2) is a liquid and has a corrosion rate > 0.25 inches/year on steel.

Reactive (D003) - A solid waste that:
a. Is unstable and readily undergoes violent change without detonating.

b. Reacts violently with water.
c. Forms potentially explosive mixtures with water.

d. Generates toxic gases, vapors or fumes in a quantity sufficient to present
a danger to human health or the environment when mixed with water. e. Is a cyanide or sulfide bearing waste which can generate toxic gases,
vapors, or fumes in a quantity sufficient to present a danger to human
health or the environment when exposed to pH conditions between 2 and
12.5.
TCLP Toxicity - (as determined by Toxicity Characteristic Leachate Procedures) - Presence of
certain listed toxic materials at levels greater than those specified in the
regulation.

11. Chemical Safety Software EMS-E - a computer based system which contains a scanned image
of the MSDS, plus additional safety and disposal information.
12. Hazardous Waste Profile Data (HWPD) Sheet - An ATK document that lists all EPA, DOT,
and chemical information needed for marking, labeling, and identifying waste streams on plant.

13. Hazardous Waste Operations and Emergency Response (HAZWOPER) - Refers to specific
training requirement for handling hazardous materials and for emergency operations. These requirements are found in 29 CFR 1910.120.

14. Human Resource Coordination - An intermediate between management and personnel who
deals with employee concerns and interests. 15. Incident Commander/Emergency Coordinator - The Incident Commander will be the on-duty
Assistant Fire Chief/Incident Commander.

The Incident Commander will direct the activities of all Field Units from a designated control
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point at the scene of the emergency, disaster, or other event.
The Security Manager will be the Incident Commander for countermeasures in situations caused
by hostile persons.

The Fire Prevention Captain will act as Incident Commander until relieved by an Assistant Fire Chief.

The following items are identified as principles for the Emergency Commander and Incident
Commander to apply to the unique circumstances of the emergency or disaster:
a. Assist the injured.

b. Stabilize situation and site.
c. Assure evidence is not destroyed, lost, or moved.

d. Record situation through text, photographs, videos, and/or mapping.
e. Notify State and local officials.

f. Secure and admit only qualified essential personnel to the site.
g. Debrief participants.

16. Material Safety Data Sheet (MSDS) - Provides information on safe handling , proper PPE, and
disposal information for each chemical. This document is prepared by the chemical manufacture.
For additional information, contact your local Industrial Hygiene representative.
17. Non-sudden Release - The accidental discharging (see Discharge), spilling, leaking, pumping,
pouring, emitting, emptying, or dumping of hazardous wastes or materials which, when spilled
become hazardous wastes, into or on any land or water over an extended period of time. This also includes spills onto asphalt or concrete pads.
18. Reportable Spill (Discharge) - A hazardous waste spill which must be reported to the Utah
Department of Environmental Response and Remediation, National Response Center and/or
other applicable Federal, State or local authorities. The Utah Hazardous Waste Management Rules list reportable spill quantities as:

a. One kilogram (2.2 lb) of material in accordance with R315-9-1(b)(1). A spill of a lesser
quantity must be reported if there is a potential threat to human health or the environment.
b. One-hundred kilograms (220 lb) of hazardous waste or material which, when spilled,
becomes hazardous waste, in accordance with R315-9-1(b)(2). A spill of a lesser quantity
must be reported if there is a potential threat to human health or the environment.
c. Subpart J of 40 CFR Part 265 of the Resource Conservation and Recovery Act stipulates
that a spill of 1 lb from a leaking hazardous waste sump is a reportable quantity.
NOTE For complete descriptions and listings, contact Environmental
Services or refer to R315-9 of the Utah Hazardous Waste
Management Rules.
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The following is a partial list of materials used at ATK and the quantities which, if spilled, would
require State or Federal notification:
EPA Utah

Material Quantity Quantity Acetone 5000 lbs. 220 lbs.
Methanol 5000 lbs. 220 lbs.
Methylchloroform 1000 lbs. 220 lbs.
Methylene Chloride 1000 lbs. 220 lbs. Methyl Ethyl Ketone 5000 lbs. 220 lbs.
Methyl Isobutyl Ketone 5000 lbs. 220 lbs.
Nitroglycerin 10 lbs. 2.2 lbs.
Propellants, reactive materials (HMX) oxidizers (AP) 100 lbs. 220 lbs.
Sodium Azide 1000 lbs. 2.2 lbs.
Toluene 1000 lbs. 220 lbs.
Xylene 100 lbs. 220 lbs.

19. Solid Waste - Any discarded material that is a solid, liquid, semi-solid or contained gaseous material resulting from industrial, commercial, mining, or agricultural operations and is not excluded under 40 CFR 261.4(a), 260.30, or 260.31.

20. Spill - The accidental discharging (see Discharge), spilling, leaking, pumping, pouring, emitting,
emptying, or dumping of hazardous wastes or materials which, when spilled become hazardous wastes, into or on any land or water. This also includes spills onto asphalt or concrete pads.

21. Environmental Services - A department with expertise in the areas of hazardous waste, air and
water management, including environmental regulations in these areas.

G. PLANT LOCATIONS AND SITE INFORMATION
1. The ATK Launch Systems – Promontory (ATK) plant is located in Box Elder County
approximately 30 miles northwest of Brigham City. The 30-square mile plant site is remote from any major population centers and is reasonably isolated from ranches located at varying distances from the area boundaries. The plant site is composed of four major areas in which manufacturing and testing activities take place: South Plant, North Plant, Test Area, and Plant 3. There are approximately 675 buildings located on
the plant site, (See Appendix I for facility site maps).
ATK owns and operates these 4 areas. All of these areas are contiguous and waste disposal is managed by one organization.
From the beginning of operations in 1956 to the present time, plant activities have encompassed a wide range of programs requiring the production of solid rocket
propellants, rocket motor testing, and industrial support necessary to achieve each program's objectives. Solid rocket motors manufactured during this period vary from motors containing 7-9 lb of propellant to 1,100,000 lb. Programs have included Space
Shuttle SRM, Peacekeeper, Trident, SRAM, HARM, Standard, Genie, Minuteman, Poseidon and a variety of ground and air launched flares.

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2. The plant site has eight hazardous waste treatment and storage facilities: Burning Grounds at M-136, and M-225; Drum Storage areas at E-501 and M-186; the T-29B
Hydrazine Dilution Facility; the M-705S Hazardous Waste Consolidation Room; and the solid propellant waste storage facilities at building M-629 and storage pad S-633.. The site maps and evacuation plans for these facilities are shown in Appendix I.
These eight facilities serve as waste management units for the entire facility. Reactive
wastes treated at the burning grounds include waste propellants, waste explosives, oxidizers, or solid waste contaminated with propellants, explosives, or oxidizers. No propellants or explosives are ever stored in the drum storage areas; hazardous wastes
that are flammable, toxic, or corrosive are stored in these units. The Hydrazine Dilution Facility at T-29B dilutes waste hydrazine to between 5 to 50 percent by volume for
shipment to an off-plant disposal site. The M-705 Wastewater Treatment Facility treats hazardous and industrial waters from building sumps. Hazardous wastes are consolidated and lab packed at the M-705S Hazardous Waste Consolidation Room.
3. Approved hazardous waste accumulation areas are described in Table I.
4. Fire hydrants are located as follows: 101 hydrants in the Administrative and Manufacturing area, 95 at North Plant, 47 in the Test Area, and 9 in Plant 3. Static and
dynamic pressure heads have been measured for each hydrant and the Fire Department maintains this information. The fire protection system at the plant site
meets the NFPA codes for fire protection. ATK owns and operates two pumper fire engines and two brush trucks which are used for emergency response.
The following water tanks are interconnected:
Location Capacity (gal) X-1 200,000
X-2 20,000 M-131 50,000
M-132 50,000 M-133 100,000 M-587 (North Plant) 1,000,000
M-696 20,000 T-59 (Test) 1,000,000
The M-203 (Propellant Development Area) water tank with a 100,000 gallon capacity is not interconnected to the other tanks.
Fire hydrants throughout the plant are color coded according to capacity.
Color Code Flow Capacity (gpm)
Green Fire Hydrant 1,000 or more Orange Fire Hydrant 500 - 1,000
Red Fire Hydrant 500 or less 5. Information depicting the capacity, location, and practical consequences of a
catastrophic failure of large hazardous material storage areas is found in Appendix II C, p.67.
6. All buildings with 10 or more regular occupants have an evacuation plan posted at all major exits of the building. (See Appendix I for the site maps and evacuation routes of
the hazardous waste treatment and storage facilities).
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H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES
1. There are many steps that can be taken to prevent the recurrence and spread of fires, explosions, or releases at the drum storage areas, burning grounds, and operating buildings. These include limiting propellant quantities placed in the burning trays,
following safe handling procedures, personnel training, segregating incompatible and reactive materials in the burning trays and in the drum storage areas, practicing good
housekeeping procedures, proper labeling, regular inspections, and separating the burning trays by safe distances. These procedures are outlined in company operating manuals. 2. Each fire, explosion, or release into the environment is unique. The Incident
Commander must be an experienced individual who will take all possible steps to prevent a recurrence, to limit the extent of the damage, and to stop the discharge.
These steps may include: a. Stopping processes and operations.
b. Collecting and containing released wastes.
c. Removing and isolating containers.
d. Preventing additional harm to the environment through knowledge of the potential hazards associated with storage areas (found in Appendix II, A and B, pp. 65 and
66, their locations, capacities, and identification. 3. User organizations conduct regular inspections on items such as bulk storage
containers that store hazardous wastes or materials which, if released to the environment, would become hazardous wastes. Audits are taken on volumes of stored
materials versus consumption to ensure that non-sudden releases are not occurring. If a non-sudden release of materials is discovered, steps are taken immediately to minimize the impact on the environment.

II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION
A. EVACUATION CRITERIA
1. A fire that is a threat to human safety.
2. A spill that is a threat to human safety.
B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL
1. The building personnel working the operation identify the material.
2. The Material Safety Data Sheet (MSDS) is referred to for chemical constituents, health hazards and protective clothing. 3. The Hazardous Waste Profile Data sheet, Chemical Safety Software EMS-E, or MSDS is referred to for proper disposal of the waste.

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C. REPORTING OF EMERGENCY INCIDENTS
1. Spilled material is reported to Security.
2. Security contacts the Environmental Service’s Spill Advisory Team and Safety for technical support and advice.
3. Environmental Services contacts the State and EPA to report the incident (if required).
4. Environmental Services obtains the log from Security to prepare the written report to the State.
5. Within 15 days, Environmental Services submits the written report to the State and maintains a permanent copy in the Environmental Services' Central File as required.

D. PERSONNEL RESPONSIBILITIES
1. EMERGENCY MANAGER a. At all times, there shall be at least one employee either present on the facility
premises or on call with the responsibility for coordinating all emergency response measures.
b. The facility emergency coordinator is thoroughly familiar with all aspects of the facility's contingency plan, all operations and activities at the facility, the location
and characteristics of waste handled, the location of manifests and all other records within the facility, and the facility layout, or has immediate access to
persons with this information. c. This person shall have the authority to commit the resources needed to carry out
the contingency plan.
d. Arranges for and directs a spill contingency plan simulation. 2. EMPLOYEES, FIRST LINE SUPERVISORS AND FIRE WARDENS
a. Report all fires or emergencies by activating the fire alarm or calling the emergency
number. b. Report from a safe telephone location:
Your name and phone number
Type of incident (fire, explosion, injury, spill, etc.) Location of incident
c. Stay on the line when possible until released by the emergency operator.
d. Do not attempt to fight fires involving live or possibly toxic hazardous materials. e. Do not attempt to contain spills that are beyond capability or training. 3. FIRST LINE SUPERVISORS
a. Ensure personnel evacuate buildings or areas to the assembly point indicated on
the Emergency/Evacuation Plan located in each building.
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NOTE Handicapped personnel must be provided priority and
assistance during evacuation and assembly.
b. Advise the Fire Captain and the Incident Commander of conditions at the scene.
c. Account for all employees that were in or assigned to the affected building or area. d. Report any injured or missing personnel to the Incident Commander.
e. Remain at the assembly point until released by the Incident Commander.
f. Notify appropriate Safety Department and fill out a Mishap Report.
4. INCIDENT COMMANDER
a. Initiate the first response actions. b. Contact line supervision at the assembly point to determine the details of the
situation:
i. Nature of incident ii. Number of personnel injured or not accounted for and the location of their last known assignment.
iii. Location and type of hazardous materials that may be exposed to fire or explosion (Quantity Distance Criteria).
c. Applicable Quantity Distance Criteria.
d. Assume control of emergency area.
e. Declare severity of event such as an emergency or disaster as appropriate. f. Establish emergency scene, coordinate road blocks, cordon the site, and control
entry/exit from the area.
g. Make an initial assessment of situation. h. Notify the Security Radio Dispatcher as appropriate, close the switchboard, if
absolutely necessary. The Environmental Specialists must be included if a building deluge system has been activated and the building sump has overflowed or
another known spill of hazardous material has taken place. i. Identify safe response routes for follow-on units.
j. Coordinate activities with other emergency units.
k. Commit rescue and first aid crews as necessary.
l. Obtain emergency rescue and ambulance as required.
m. Keep the Emergency Commander informed of the emergency situation. n. Request outside assistance from the EOC as needed.
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p. Check with building’s supervision to identify propellant ingredients and hazardous
constituents in any building or building sump which must be pumped by Water Operations personnel. Evaluate what hazards, if any, exist which may hinder safe access to the building.
q. Perform actions in accordance with 29 CFR 1910.120 (HAZWOPER).
5. SECURITY
a. Set up road blocks as directed by the Incident Commander to preclude unauthorized entry of personnel and provide clear traffic flow for emergency
vehicles. b. Coordinate with Incident Commander to ensure orderly evacuation of personnel.
c. Provide protection for classified information, valuable records, and special
equipment. d. Ensure protection of Company and Government property from theft or sabotage.
e. Provide proper disposition, storage, and protection of classified material in
accordance with the Department of Defense Industrial Security Manual. f. Establish perimeter boundary for emergency scene, set up road blocks, cordons,
etc.
g. Above actions must be consistent with HAZWOPER requirements. 6. SECURITY RADIO DISPATCHER
a. When directed by the Incident Commander, notify appropriate personnel in
accordance with the Emergency and Disaster Response Plan.
b. Monitor and record all emergency radio communications, and establish required communications between radio units.
c. Upon direction of the Incident Commander, notifies appropriate ATK management.
7. TELEPHONE OPERATORS a. When directed by the Incident Commander, refuse incoming and outgoing calls
unless directed otherwise by the Emergency Commander.
8. INDUSTRIAL HYGIENIST a. Report to the Incident Commander at the assembly point or Field Command Post.
b. Advise the Incident Commander on emergencies involving toxic chemical or
radiation hazards. c. Perform the following activities as necessary:
i. Sample air at the scene, including any sumps which have to be pumped. (if
determined to be necessary by the Industrial Hygienist (IH) on the scene)
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ii. Monitor radioactivity at the scene. (if determined to be necessary by the IH on the scene)
iii. Advise Emergency Response Team concerning proper decontamination controls.
iv. Notify Medical Services of personnel exposure to toxic chemicals or
radioactive materials. v. Advise the Incident Commander to notify public health authorities.
d. Performs these duties in accordance with HAZWOPER requirements.
9. MAINTENANCE CRAFTS PERSONNEL
a. Respond to all alarms when notified by the Security Police Radio Dispatcher and report to the Incident Commander at the command post.
b. Control distribution of air, water, steam, and electrical power as directed by the Incident Commander.
c. Provide equipment, barricading, and shoring as necessary per direction of Incident
Commander. d. As Fire Brigade, assist when needed.
e. Provide construction type materials and services for containment of hazardous
material spills. f. Performs these duties per direction of Incident Commander.
10. ENVIRONMENTAL SERVICES PERSONNEL
a. Report to the Incident Commander at the command post, when notified by Security Police Radio Dispatch.
b. Perform duties as directed by the Incident Commander after material to be
collected has been identified, any hazards associated with the material have been identified, and safe procedures to handle the material have been established. c. Perform these duties in accordance with HAZWOPER requirements.
d. Advise the Incident Commander on potential environmental hazards, safe handling, and disposal options.
11. MEDICAL SERVICES PERSONNEL
a. Remain at or report to the Dispensary to receive and treat patients.
b. Report to the emergency area when requested by the Incident Commander. c. Coordinate with surrounding community hospitals and doctors for the receipt and
treatment of injured.
d. Requisition supplemental medical supplies, equipment, and personnel as needed. May request helicopter transportation in life or death situations.
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e. Conduct and supervise treatment for injured personnel.
f. Review MSDS and other relevant information, and transmit same to receiving hospital.
12 TRANSPORTATION PERSONNEL (IN-PLANT TAXI SERVICE)
a. Coordinate with Incident Commander to ensure adequate transportation of plant personnel.
13. EMERGENCY COMMANDER
a. Control and coordinate overall activities of the emergency situation. The Emergency Commander will work from the Emergency Command Center, and will
assist and direct the On-Scene Incident Commander as needed.
b. Evaluate situation and determine need to convene the Emergency Command Unit. c. Direct the Telephone Operators to open or close the switchboard according to the
nature of the emergency.
d. Open the Emergency Operations Center as necessary. e. Identify the disaster potential posed by the emergency.
f. Make the disaster declaration when necessary (disaster responsibilities are listed in
Section III). 14. PHOTOGRAPHER
a. Report to the Incident Commander at the Command Post.
b. Advise the Incident Commander on photo coverage.
c. Photograph the scene as directed.
d. Expedite printing and delivery of the photographs. e. Interpret the photographs as required. 15. HUMAN RESOURCES COORDINATOR
a. Provide food and assistance with personal needs for emergency team members
and those affected. b. Notify next of kin of injured persons when advised by Emergency Commander.
(See Section IV, the Emergency and Disaster Response Plan for procedures).
16. ENVIRONMENTAL SPECIALIST a. Assess possible environmental hazards resulting from the incident including
assessment of spills caused by the activation of a building deluge system which in turn caused the building sump to overflow.
b. Initiate reports required by the Comprehensive Environmental Response
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Compensation and Liability Act (CERCLA) and Utah Solid and Hazardous Waste Regulations.
c. Determine (along with the responding local emergency agency) whether the facility has had a discharge, fire, or explosion which could threaten the environment
outside of the facility. Assure immediate implementation of emergency procedures.
d. Notify the State and Federal environmental agencies as required. e. The Environmental Specialist contacts either the government official designated as
the on-scene coordinator or the National Response Center, [phone], and Utah Dept. of Environmental Response and Remediation (DERR) at (801) 536-
4123 to relaying the following information: i. Name and telephone number of reporter.
ii. Name and address of facility.
iii. Time and type of incident (such as discharge, fire, etc.).
iv. Name and quantity of material(s) involved, to the extent known.
v. The extent of injuries, if any. vi. The possible hazards to human health or to the environment outside the
facility.
f. Notify the Corporate Environmental Engineer if the spill is reportable. David Shead
[phone]
g. Utah Hazardous Waste Management Rules require that the Environmental Specialist note in the operating record the time, date, and details of any incident
that requires implementing the contingency plan. Within 15 days after the incident, he must submit a written report on the incident to the Director of the Division of
Waste Management and Radiation Control. The report must include: i. Name, address, and telephone number of the owner or operator. ii. Name, address, and telephone number of the facility.
iii. Date, time, and type of incident (such as fire, explosion, etc.).
iv. Name and quantity of material(s) involved.
v. The extent of injuries, if any.
vi. An assessment of actual or potential hazards to human health or the environment where this is applicable.
vii. Estimated quantity and disposition of material recovered from the incident.
h. Notify the community emergency coordinator for the local emergency planning committee in compliance with requirements outlined in 40 CFR 355.40, where
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applicable.
i. Immediately after an emergency, the Environmental Specialist must provide direction for treating, storing, or disposing of recovered waste, contaminated soil or surface water, or any other material that results from a discharge, fire, or explosion
at the facility.
j. The Environmental Specialist and the Incident Commander must ensure that, in the affected area(s) of the facility:
i. A determination is made who will do the spill remediation work (Building Personnel, ATK Spill Remediation Team, or Off-Site Contractor).
ii. No waste that may be incompatible with the discharged material is stored or disposed of until cleanup procedures are completed; and
iii. All emergency equipment listed in the contingency plan is cleaned and ready
for its intended use before normal operations are resumed. 17. CORPORATE PUBLIC AFFAIRS
a. Establish liaison with representatives of public information media.
b. Prepare drafts of general/public information press releases relating to the emergency.
c. Release information as directed by the Emergency Commander, according to ATK
Policy. 18. RECORDER
a. Record incoming and outgoing communications at the EOC.
. b. Record all significant events and actions.
c. Initiate and maintain record information in a time line log.
d. Assist in the preparation of interim and final reports. E. ALARM SYSTEMS
1. Alarm systems are available at ATK for fires or building evacuations if an emergency or
disaster situation exists: Type People/Materials Sound
Fire and Building People Fire Alarm Evacuation
Hazardous Waste People Verbal Signal (or fire alarm, if
available) Storage and
Thermal Treatment Materials Verbal Signal (fire alarm or air horn, if available)
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2. The hazardous waste storage facilities at M-186 and E-501 are located outdoors in open areas, evacuation of personnel will be in any direction away from the problem. The assembly area for E-501 is directly across the street (to the north) from the entrance gate. The
assembly point for M-186 is at the M-381 trailer.
3. The hazardous waste storage facility at the M-705 Consolidation Room is a single room equipped with two exits, a single door on the west and a double door on the east. Both sets of doors open directly to an open outdoor area where personnel are to evacuate to an area
near the intersection of the main in-plant road and the M-705 access road. The room is equipped with a heat sensor alarm, a fire alarm and a carbon monoxide alarm on the
supplied air system. 4. M-629 is a storage building with multiple exits as outlined in the evacuation plan in
Appendix I.
5. Tables and maps showing the function of the various hazardous waste sites and area evacuation plans are found in Appendix I, p. 34.

F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND HOSPITALS 1. Local law-enforcement agencies, fire departments, and hospitals have been contacted to respond to or treat any ATK emergency. The most recent copy of this Contingency
Plan is sent to each agency in order to familiarize them with the layout, description of hazardous wastes handled, and evacuation plan for the plant. Copies of the letters sent
to each agency are kept in the Operating Record. 2. All emergency response units from off-plant will be escorted from the gate to the
fire/explosion/spill site by an ATK authorized agent. This will ensure the units reach the location as quickly and efficiently as possible.

III. SPILL CONTAINMENT AND CLEANUP A. CONTROL PROCEDURES 1. Detailed emergency response procedures whenever there is a fire, explosion, or release
(spill) are found in the current Emergency and Disaster Response Plan.
2. Specific directives for cleaning up spills are given in the Hazardous Waste Profile Data (HWPD). There are over 1,000 chemical entries in the HPWD. Approximately 800 of
the chemicals in current use exhibit hazardous properties. The MHSI documents are generated in-house to provide a standard format for easy use. Each entry contains Material Safety Data Sheet (MSDS) information as well as other information. There are
approximately 100 sets of MHSI distributed throughout the facility. In addition, a complete MHSI is accessible through over 1,000 computer terminals at the facility.
3. The Wastewater Treatment Facility (M-705) is designed to treat wastewater containing hazardous constituents. The responsible building foreman or supervisor should report
to the M-705 facility personnel any spill or accidental discharge to a sump suspected of containing chemicals at concentrations above the levels normally discharged. The
report should include the incident location, name of person reporting, chemical involved, and approximate quantity. The treatment facility personnel will then be able to determine how best to handle the wastewater.
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4. The propellant storage buildings will be inspected daily or weekly as required when in use. While the propellants stored in these buildings are solid, occasionally a small
amount of nitro glycerin or similar material can ooze from the motor and drip to the floor. These drips will be checked for during the inspections, and cleaned up using rags and acetone within 24 hours of discovery or as soon as is practicable.

B. SPILL CONTAINMENT AND CONTROL §265.56(e) of the Resource Conservation and Recovery Act (RCRA) states:
"During an emergency, the Emergency Commander must take all reasonable
measures to ensure that fires, explosions and releases do not occur, recur, or spread to other hazardous waste at the facility. These measures must include where applicable, stopping processes and operations, collecting and containing
released waste and removing or isolating containers."
Confine hazardous material spills to the affected area with dams, Quicksorb, or other approved means. Hazardous material properties may be determined by consulting the Hazardous Waste Profile Data Sheet, MHSI, or the DOT Emergency Response
Guidebook. No attempt will be made to contain a spill until the hazardous properties are known. Secondary containment is provided for most storage tanks. For those tanks
without secondary containment, consult Appendix II for spill containment considerations.
C. SPILL CLEANUP
1. Waste Management and Environmental Services will be responsible for the coordination of spill cleanup activities. Building personnel will clean up smaller sized spills, incidental
to the work process, that are deemed within the skills and level of training possessed by available building personnel, where the spill occurred. All other spills will be cleaned up by the Spill Remediation Team or a company contracted by ATK.
Proper procedures will be followed for every release of hazardous wastes. Because of
the extensive inventory of hazardous materials managed at ATK Corporation, each release will require specific safety precautions, cleanup procedures, and/or disposal methods. See Table II p. for chemical compatibility information.
WARNING
Do not attempt to contain or clean up any spill until hazards associated with the material are known and proper safety
precautions are taken.
2. Response procedures to be used during container spills or leaks are as outlined:
a. Identify the material ! From the hazardous waste label
! From Waste Management and Environmental Services inventory records
! Through laboratory analysis
! From carrier manifest or placard DOT guide number

b. Protect personnel through the use of personal protective equipment specific to the identified material (refer to MHSI or Material Safety Data Sheet, available from
Industrial Hygiene.) c. Stops the spill or leak
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d. Contain the material
! Eliminate the source
! Use Quicksorb, or other approved methods
e. Clean up the material
! Re-drum
! Wipe up, use absorbent material, excavate soil
f. Dispose of the material (refer to Haz Com Web and Disposal Instructions for
Waste Materials, GM-3.1) g. Decontaminate the site and clean the equipment

D. FOLLOWUP PROCEDURES 1. When the spill has been properly contained and stopped, appropriate equipment
will be used to remove the spilled material to a disposal site
2. Spills involving very large quantities of material caused by the failure of a large storage tank should be dealt with as quickly as possible to minimize exposure to the environment. The method of pickup generally will be pumping material into a tank truck, the original tank after repairs, or into another tank. An alternative may be to use the Environmental Waste Disposal sump truck to pump liquid hazardous
wastes and transfer them to a 5,000 gallon storage tank trailer at M-705. Contact Waste Management and Environmental Services for use.
3. Proper steps will be taken to repair equipment and facilities and/or remove the cause of the spill.
4. Operating procedures will be changed, if necessary, to prevent recurrence of a
spill. 5. Safety and Operational Training will be instigated, if required.
6. When possible, all reasonable effort will be made to salvage reusable material.
E. INCOMPATIBLE WASTE
The Environmental Coordinator and Incident Commander will ensure no waste is
incompatible with any material during the cleanup of a discharge. Table II, p. lists the information and its available location to the Environmental Coordinator and Incident Commander to make decisions regarding compatibility. All of these materials are available
for inspection at the plant site.
F. CLEANUP MATERIAL AND EQUIPMENT
The following is a partial list of safety equipment that may be used for cleanup as required per Chemical Safety Software EMS-E. All items can be obtained from Stores or from a call
contract.
Item Stock No. Use
Coveralls Live Operations
Smocks Manufacturing Area 17
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Tyvek Suit (m) Asbestos & Dust Tyvek Suit (l) Asbestos & Dust
Tyvek Suit (xl) Asbestos & Dust Tyvek Sack Suit Asbestos & Chemical Spills Tyvek Hood Asbestos & Chemical Spills
Polyethylene- Tyvek Suit Asbestos & Chemical Spills
Saranex Tyvek Suit Chemical Spills Booties (Yellow) Asbestos & Chemical Spills Booties (Clear) Asbestos & Chemical Spills
Boots (Rubber) Chemical Spills Glasses, Safety Spills-Less than 1 quart
Monogoggles Spills-Greater than 1 quart Ear Plugs Noise-Greater than 90 B(A) Gloves, Rubber (s) Methyl Ethyl Ketone
Gloves, Rubber (m) Methyl Ethyl Ketone Gloves, Rubber (l) Methyl Ethyl Ketone
Gloves, Leather General Use Gloves, Cotton General Use Gloves Solvent Resistant
Gloves, NBR (s) Methyl Chloroform Gloves, NBR (m) Methyl Chloroform
Gloves, NBR (l) Methyl Chloroform Respirator, Half Mask Air Purifying In O2 Sufficient Areas Only
Respirator, Full-face Cart In O2 Sufficient Areas Only
Respirator, Fresh Air In O2 Deficient Areas Only Respirator, No. 8710 Dust, Single-use Only Filter S (Gray) Dusts, Mists, Fumes, Radon
Daughters, Asbestos Filter H (Purple) Dusts, Mists, Fumes, Radio-
nuclides, Asbestos Filter GMA (Black) Organic Vapors Filter GMC (Yellow) Organic Vapors, Acid Gases
Filter GMD (Green) Ammonia & Methylamine Filter (Purple/Black) Organic Vapors, Dusts, Mists,
GMA-H Fumes, Radionuclides, Asbestos Filter (Purple/
Yellow) GMC-H Organic Vapors, Acid Gases, Dusts, Fumes, Mists,
Radionuclides, Asbestos Filter (Black/Olive) Pesticides GMP
Acetone Propellant solvent
Rumple cloth wipe
Chemliner bag Contain solvent rags
Velostat bag Conductive bag to contain chemiliner

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In addition, the following materials are available if required:
Item Location Ext Description Lumber M-90 2680/2757 Plywood, Lumbers
Sawdust M-90 2680/2757 Bulk Pipe M-90 2680/2757 All dimensions
Quicksorb (27-200002) M-3 (Stores) 2757 50 lb Bag Absorption Clay Landfill 2837 Bulk Hydrated Lime (54-426006) M-3 (Stores) 2757 50 lb Bag
Chemical Spill J. T. Baker Neutralizer
Acids (General) M-53 2617 3.2 kg Bases (General) M-53 2617/7436 1.2 kg Flammable Solvents M-53 2617 (1.1 kg) (18 kg)
Mercury Cleanup Kits M-53 2617 0.9 kg NG Spill and M-585 8446 5 liter bottle
Detector Kit Bulldozer (Space/DLV) M-55/M-321 2837/2455 D-8 Front-end Loader M-55/M-321 2837/2455 1½ and 3 yd bucket
Portable Lights and M-6 3431 2 Mercury Lamps Generator
Sump Tank M-136 2520 3,000 gal Portable Diaphragm Pumps M-55/M-321 2837/2455 General Trucks M-55/M-321 2837/2455 1½ - 5 Ton
SCBA Respirators Fire Dept 2222 30 Min. Tank Water Ops. Equip M-705 2222 Sump Trucks, Etc.
Spill Response Truck Fire Dept 2222 Spill Response and Rescue
G. DECONTAMINATION EQUIPMENT AND PROCEDURES
1. Equipment available for decontamination includes two disposable wading pools, a
wood-framed plastic pool carried on the spill truck for tool and spill team decontamination, and fire trucks to supply wash down water. Decontamination procedures outlined on Figures 1 and 2 will be followed to ensure spill containment and
to minimize the area of contamination.
2. The M-186 hazardous waste drum storage site is located near the burning grounds. This area is serviced by the E-522 Fire Station which is located 3-5 minutes away. The M-705 Hazardous Waste consolidation room and the E-501 drum storage yard are also
serviced by the E-522 Fire Station which is located 1-2 minutes away. Both the E-522 and M-11 Fire Stations are outfitted with quick-response spill control equipment (See
maps, Appendix I). In addition, spill response kits are available at the M-53 and M-585 Laboratories.
H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT 1. The Incident Commander, or his designee, will ensure all equipment has been properly decontaminated, cleaned, and replaced before normal operations are resumed. The
following guidelines are to be used for decontamination of equipment after a discharge has occurred. These steps are also supplemented by the information found in the
sources listed in Paragraph F. 2. As much as possible, measures should be taken to prevent contamination of
equipment. Any delicate instrument which cannot be decontaminated easily should be
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protected while it is being used. It should be bagged and the bag taped and secured around the instrument. Openings can be made in the bag for sample intake.
a. Sampling Devices
Sampling devices require special cleaning. The instruction and care manuals provide information on proper decontamination methods for each instrument used.
b. Tools and Equipment
Equipment and tools designated for spill response should be disposable; however, some tools and equipment require decontamination.
Decontamination equipment, materials, and supplies are generally selected based on availability. Soft-bristle scrub brushes or long-handle brushes are used to
remove contaminants. Water in buckets is used for rinsing. Large galvanized wash tanks or stock tanks can hold wash and rinse solutions; children's wading
pools can also be used. Open top (55-gallon) drums or similar containers lined with plastic bags can be used to store contaminated clothing and equipment. Contaminated liquids can be stored temporarily in metal or plastic cans or drums.
Other supplies include paper or cloth towels for drying protective clothing and equipment.
Personal protective equipment, sampling tools, and other equipment are usually decontaminated by scrubbing with detergent-water using a soft-bristle brush
followed by rinsing with copious amounts of water. While this process may not be fully effective in removing some contaminants, it is a relatively safe option
compared with using a chemical decontaminating solution. Occasionally, a decontamination chemical is then needed to change the contaminant into a less harmful substance during decontamination. The Environmental Coordinator and
Incident Commander, or his designee, may consult the information sources in Table I, p. 33, to determine the necessity of using a chemical decontamination
solution. All materials and equipment used for decontamination must comply with proper
disposal. Clothing, tools, buckets, brushes, and all other equipment that are contaminated must be secured in drums or other containers and labeled. Clothing
not completely decontaminated onsite should be secured in plastic bags before being removed from the site. Contaminated wash and rinse solutions should be contained to hold spent solutions. The spent solutions are transferred to drums which are labeled and
properly disposed of. The Environmental Specialist and Incident Commander, or his designee, will ensure the disposal of these materials is done in an appropriate
manner. c. Respirators
Certain parts of contaminated respirators, such as the harness assembly and
leather or cloth components, are difficult to decontaminate. If grossly contaminated, they may have to be discarded with the other spill cleanup wastes. Rubber components can be soaked in soap and water and scrubbed with a brush.
Regulators must be maintained according to manufacturer's recommendations. Persons responsible for decontaminating respirators should be thoroughly trained
in respirator maintenance.
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d. Heavy Equipment
Bulldozers, trucks, back-hoes, bulking chambers, and other heavy equipment are difficult to decontaminate. The method generally used is to wash them with water under high pressure and/or to scrub accessible parts with detergent/water solution
under pressure, if possible. Shovels, scoops, and lifts may be sandblasted or steam cleaned. Particular care must be given to those components in direct
contact with contaminants such as tires and scoops. Wash water generated during the decontamination process must be contained and disposed of in a proper manner.
IV. INSTALLATION RESPONSE TEAM TRAINING
Building/area personnel responding to spills of hazardous materials incidental to the normal
processes within their building/area will not need training beyond that required by ATK’s Hazard Communication Program. Personnel responding to spills, who are not assigned to the building/area
where the spill occurred, are to be members of the Spill Remediation Team with the proper OSHA training.
NOTE
Hazard Communication Plus Program is a combination of
the HAZ-COM Program required by OSHA 29 CFR
1910.1200 and HAZWOPER first awareness level required by OSHA 29 CFR 1910.120.

A. TRAINING
All personnel involved in cleanup operations will be trained. This training will include an
awareness of the locations of cleanup materials and equipment and the procedures for the operation of such equipment.
B. SIMULATION
The Spill Contingency Plan will be simulated annually under the direction of the Emergency Commander.
V. TRAINING PLAN One of the most important objectives of the Contingency Plan is to ensure that the emergency
responders are properly trained. Training should include teaching, exercise and critique phases. Re-training and review should be completed at least annually. The following is an outline of training plan
elements:
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN
B. REVIEW OF LEGAL REQUIREMENTS
1. Authority 2. OSHA requirements
3. State requirements 4. EPA requirements
5. State Fire Marshall requirements 6. Law enforcement requirements 7. Medical Examiner/Coroner requirements
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C. LOCAL ATK REQUIREMENTS
D. CUSTOMER REQUIREMENTS
Contract review
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER

F. EMERGENCY COMMUNICATION SYSTEM
1. Initial notification and follow-up 2. Verification of information 3. Radio discipline 4. Communication intercept
G. FIRE PLANS/FIRE DRILL
1. Use 2. Exercise
3. Evaluate 4. Evacuation
5. Assembly points
H. BOMB SEARCH TECHNIQUES
1. Outside to Inside 2. Left to right
3. Bottom to Top 4. Evacuation 5. Suspect items (Isolate; don't touch or disturb)
I. FIRE BARRICADE/CORDON AREAS
1. Function
2. Initiate/release
J. EMERGENCY MEDICAL TREATMENT
1. EMT training, equipment 2. First response first aid
K. SECURITY OF SITE
1. Purpose
2. Authority 3. Who authorizes access
L. INVESTIGATION
1. OSHA
2. EPA 3. Local Law enforcement
4. Medical Examiner/Coroner 5. Customer 6. ATK
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M. PUBLIC RELEASE OF INFORMATION 1. Who authorizes
2. Importance of controlling 3. Who releases
4. Who reviews 5. Next of kin
N. FACT-FINDING METHODS
1. Initial interview
2. Follow-up interview 3. Recordings 4. Photo Coverage
5. Mapping damage a. Who?
b. How? c. Why? 6. Personnel security checks
7. Drug and alcohol tests 8. Weather conditions
9. Product status 10. Operational status 11. Equipment records and history
12. Facility, tooling, modification and history
O. SAFING THE AREA
1. Electric Power 2. Water
3. Steam 4. Toxic chemicals 5. Falling hazards 6. Explosives
P. CONTROL OF THE CURIOUS
1. Outsider 2. Employees
3. Press
Q. HANDLING OF REMAINS 1. Notification 2. Photo
3. Movement (after authorization by Medical Examiner) 4. Release (after authorization by Medical Examiner)
R. NOTIFICATION PROCEDURES
1. When? 2. Who? 3. How? 4. Verification

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S. RESCUE EFFORTS
1. When? 2. When not to
3. How to determine
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TABLE I COMPATIBILITY INFORMATION
Source of Compatibility Information Location

1. Hazardous Waste Compatibility Chart Available at Table 9-2 of Attachment 9 Environmental Services offices
2. Material Health and Safety Available in hard copy form at
Information (example of informa- approximately 100 locations through- tion found in plan) the plant; also available on 1,000 computer terminals throughout the plant*

3. Material Safety and Data Sheets Located on the internal web Chemical Safety Software EMS-E
4. Work Experience Knowledge of each member of the Response Team when responding to a discharge

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VI. EMERGENCY COORDINATOR

The Emergency Coordinator is the ATK Fire Department’s Emergency Manager. The alternate Emergency Coordinators are the ATK Fire Department Shift Supervisors. A primary or alternate
Emergency Coordinator is on plant or on call at all times. In this plan, the Emergency Coordinator may be referred to as the Incident Commander (IC). The primary and alternate Emergency
Coordinators or ICs are identified in the Operating Record, which is maintained onsite at the Promontory facility. ATK Promontory security headquarters/dispatch can be contacted 24/7 at 435-863-8545. ATK Promontory security headquarters/dispatch can contact the on plant
Emergency Coordinator or IC.

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FIGURE 1. DECONTAMINATION/SPILL SCENE Difficult Decontamination Situations
Some situations, such as a solvent spilled on tiles or large spills on unprotected ground require the removal and disposal of the affected material. Other situations, such as contaminated equipment or
fixtures, require steam cleaning and the use of a detergent. Frequently, the rinse from steam cleaning is best controlled with a wet/dry vacuum. Steam cleaners, detergents, and wet/dry vacuums can be obtained from local rental companies. The rinse should be tested for the contaminant and managed
appropriately.

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The Spill Scene
While each spill is unique, every spill shares common features best referred to as the "Spill Scene." This allows a conceptual illustration of the work area which emphasizes the relationship
of the various components. Complete decontamination of workers, tools, and the spill site must be performed before the spill
response is completed.
It is prudent to establish an area for worker decontamination through which all SPILL TEAM members must pass prior to leaving the site. In this TEAM DECONTAMINATION SITE (TDS) protective clothing can be thoroughly washed with detergent and rinsed with water, if necessary.
The soles of ALL WORKERS SHOES MUST BE RINSED before they leave the area. Outer coveralls (Tyvek, etc.) must be removed in this area. These steps are necessary to prevent
spreading the contamination or introducing toxic substances into workers homes. Tools can be rinsed with detergent and water prior to removal from the spill scene. All
rinses from these decontamination procedures must be treated as hazardous waste. Dry decontamination may be used when appropriate.
It is frequently necessary to test the site for completeness of decontamination prior to declaring the emergency resolved. Spills which contaminate soil, asphalt, concrete, or other absorbent materials will require that samples be obtained and analyzed. After all residual contamination is removed, asphalt and concrete areas must receive a thorough wash-down with fresh water.

FIGURE 2. DECONTAMINATION
Cold Zone
Secure
Supplies
Decontamination Corridor
Dirty Area Hot Zone
Spill
Warm Zone

Area
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APPENDIX I
FACILITY FUNCTION TABLES, SITE MAPS, & EVACUATION PLANS
NORTH PLANT SITE MAP ................................................................................................ 30
MANUFACTURING AREA SITE MAP ............................................................................... 31
TEST AREA SITE MAP ..................................................................................................... 32
PLANT 3 SITE MAP ........................................................................................................... 33 M-136 BURNING GROUNDS FACILITY FUNCTION TABLE .......................................... 34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE ............................... 34
M-136 SITE MAP AND EVACUATION PLAN.................................................................... 35 M-186 SITE MAP AND EVACUATION PLAN.................................................................... 36
E-501 STORAGE YARD FACILITY FUNCTION TABLE ................................................... 37 E-501 SITE MAP AND EVACUATION PLAN .................................................................... 38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE ........................................... 39 M-225 SITE MAP AND EVACUATION PLAN.................................................................... 40
T-29B SATELLITE ACCUMULATION AREA FACILITY FUNCTION TABLE ................... 41
T-29B SITE MAP AND EVACUATION PLAN .................................................................... 42 M-705 WASTEWATER TREATMENT FACILITY FUNCTION .......................................... 43
M-705 HAZARDOUS WASTE CONSOLIDATION ROOM ................................................ 43 M-705 SITE MAP AND EVACUATION PLAN.................................................................... 44
M-629 PROPELLANT STORAGE FUNCTION TABLE .................................................... 45 M-629 SITE MAP AND EVACUATION PLAN.................................................................... 46
S-633 PROPELLANT STORAGE FUNCTION TABLE…………………………………..…. 47
S-633 SITE MAP AND EVACUATION PLAN ………………………………………………...48
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NORTH PLANT SITE MAP

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MANUFACTURING AREA SITE MAP
(South Plant)

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TEST AREA SITE MAP

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PLANT 3 SITE MAP

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M-136 BURNING GROUNDS

FACILITY FUNCTION: Propellant, explosives, unstable and pyrotechnic waste disposal
Method of
Waste Products Into Area Disposal Spill Cleanup/Handling
Class 1.1 and 1.3 propellant Burning Flashing in waste propellant wastes, propellant con- disposal areas taminated wastes, and unstable
waste.

M-186 HAZARDOUS WASTE AREA
FACILITY FUNCTION: Receive hazardous waste materials and store for shipment

Method of Waste Products Into Area Disposal Spill Cleanup/Handling
Methyl Chloroform Store for Six UN Drums
Methyl Ethyl Ketone off-plant Quicksorb, 100 lb Xylene shipment Two shovels Toluene One broom
Paint One fire extinguisher Thinners Emergency shower/eye wash
Oil Store for Two overpack drums Lab Chemicals off-plant Saranex suit (level B) Photographic Fixer Solution shipment
Rags & debris
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M-136AND BURNING PITS
FIRE EXTINGUISHER
LEGEND:
EVACUATE AREA, THEN PROCEED TO ASSEMBLY POINT 200 FEET WEST ON APPROACH ROAD
Date: October 13, 1989
PIT 18
PIT 17
PIT 16
PIT 15
PIT 14
PIT 7
PIT 6
PIT 5
PIT 4
PIT 3PIT 13
PROPELLANT BED
PIT 1 PIT 2
DETONATION PITS
NO. 11 NO. 10 NO. 9 NO. 8
NEWPOND
TANK 1
TANK 2
BURNING PIT 19
M-136
N

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EVACUATE, THEN PROCEED TO ASSEMBLY POINT, SOUTHWEST AT M-381
Date: March 2, 2000
ROADWAY
OFFICE
TUFSHED
SUPPLYSHED
SAMPLESHED
FIXER SHED
EYEWASHSHOWER
GATE
GATE
WASTEOIL
STORAGESHED
WASTEOIL
HAZARDOUS WASTE TREATMENT,STORAGE, DISPOSAL, AND FACILITIES
M-186
FIRE EXTINGUISHER
LEGEND:
N
WASTEOIL
M-186A
M-186B
M-186C
M-186D
M-186E
M-186F
M-186G

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BUILDING E-501 STORAGE YARD

FACILITY FUNCTION: Hazardous Waste Storage Yard
Method of
Waste Products Into Area Disposal Spill Cleanup/Handling
Various Shipment Two fire extinguishers off-plant Absorbent for disposal Two repack drums
Electrical pump
Other assorted materials N/A that may be recycled Telephone/radio Eyewash/shower
Safety gates Safety flags
Six UN 55-gal drums (empty) Saranex suit (level B)
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FIRE EXTINGUISHER
LEGEND:
EVACUATE AREA, THEN PROCEED TO ASSEMBLYPOINT ON 200 STREET, 200 FEET EAST
Date: October 27, 1999
N
E-501andSALVAGE YARD
DRUMSTORAGE

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M-225 BURNING GROUNDS

FACILITY FUNCTION: Disposal of waste products from High Performance Propellant Development Area and miscellaneous rocket motors, igniters, and related materials

Method of Waste Products Into Area Disposal Spill Cleanup/Handling
Composite propellant, uncured Burn Dampened rags (wipes) from M-209
Composite propellant, cured Burn Pick up, soft brush or wet rags (wipes)
from M-221 NG propellant, uncured from Burn Solvent dampened rags followed by NG
M-208, M-241 detector to verify cleanliness
NG propellant, cured from M-221 Burn Pick up, soft brush and/or wet rags HMX from M-208, M-210 Burn with Soft brush and/or water-damp rags.
diesel If possible, wet HMX with water before handling
AP from M-210 (fine only) Burn with Sweep with soft brush. Wipe with propellant composite water-wet rag. Flush with water into sump
Binder premix (NG or other Burn or Contain, absorb into sawdust or pulp,
nitrate, etc.) detonate pick up with wipes, wet rags. Apply NG depending detector to verify cleanliness on materials
and/or condition
PEP contaminated waste (rags, Burn with Pick up, clean with method used for containers, etc.) respective respective propellant propellant or ingredient
Miscellaneous (motor, igniters) Burn or Each case must be dealt with on an
detonate individual basis depending on materials
and/or con- dition
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T-29B SATELLITE ACCUMULATION AREA

BUILDING FUNCTION: Hydrazine Storage and Dilution Facility
Waste Product Method of disposal From Building Disposal Spill Cleanup/Handling
Pure hydrazine Dilute with All areas where normal operations are
Hydrazine-citric water to 5-50% performed have a drainage system which acid solution solution by culminates in a common sump. Spills 5-50% dilute volume. Waste should be flushed thoroughly with large
hydrazine hydrazine is amounts of water. The wash water is contaminated shipped for then drummed and shipped for disposal
waste disposal/Treatment. Contaminated waste is also
shipped for disposal/treatment

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EVACUATE BUILDING, THEN PROCEED TO
T-29B
ASSEMBLY POINT 300 FEET NORTH OF BUILDING HYDRANTN
Date: November 3, 1997

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M-705 WASTEWATER TREATMENT FACILITY

BUILDING FUNCTION: Removal of reactive wastes from sump water
Method of
Waste Products From Area Disposal Spill Cleanup/Handling
Lime Sludge (Heavy Metals) Shipment Two shovels to off- One broom plant Plastic gloves
disposal One bin company Saranex suit (level B)
Potassium Perchlorate Burning
Classifier Decanter Solids Burning

M-705 HAZARDOUS WASTE CONSOLIDATION ROOM

BUILDING FUNCTION: Consolidation and lab packing of hazardous wastes
Method of Waste Products From Area Disposal Spill Cleanup/Handling
Consolidated hazardous wastes Shipment to Two shovels Lab packed hazardous wastes M-186 for One broom eventual Plastic Gloves off-plant One Fire Extinguisher
disposal Emergency shower/eyewash Quicksorb, 100 lb
Two overpack drums Six UN drums Saranex suit (level B)

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S
S S S
S
S
S
SMOKE DETECTORAUDIOVISUAL ALARM
S
ALARM PANEL
FIRE EXTINGUISHERMANUAL ALARM
LEGEND:
EVACUATION HORN
SYSTEM RISER
INSPECTORS TEST
HEAT DETECTORH
H H
H H
H
S
H
H
H
HHH
HMX
LINEROOM
MAINPROCESSAREA
S INDUCT
INDUCT
OFFICE
CHANGE ROOM
M-705
CONTROL ROOM
EVACUATE BUILDING 300 FEET, THEN PROCEED TOASSEMBLY POINT ON �R" AVENUE NEAR M-366
ELECTRIC EQUIPMENT
RESTROOM
SHOWER CHEMICAL CONSOLIDATIONROOM
LAB
BREAKROOM EQUIPMENTROOM
DATE: May 1, 2003
GAS SHUTOFF
TA
N
K
M-705A
CHI
L
L
E
R
EVAPORATOR
H H
H H
N
H
H
H
M-705B
10,000 GallonFuel Oil TankUnderground

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M-629 PROPELLANT and Propellant Waste STORAGE FACILITY

BUILDING FUNCTION: Storage of reactive hazardous waste propellant/propellant contaminated
materials, motors. Non-waste propellant,(donor propellant) and explosive initiation articles are also stored
within the building.
Solid Hazardous Waste Method of Disposal Spill Cleanup Materials
1.3C Propellant/propellant Thermal Treatment Obtain clean up material as needed
contaminated materials 1.3C Rocket Motors Thermal Treatment Obtain clean up material as needed

1.1C Propellant/propellant Thermal Treatment Obtain clean up material as needed contaminated materials
1.1C Rocket Motors Thermal Treatment Obtain clean up material as needed
1.3C Flares and Flare Illuminate Thermal Treatment Obtain clean up material as needed contaminated materials

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S-633 REACTIVE HAZARDOUS WASTE STORAGE PAD

STORAGE PAD FUNCTION: Storage of reactive hazardous waste propellant/propellant
contaminated materials and motors and non-waste propellant
Method of
Waste and non-waste Products Disposal Spill Cleanup Materials 1.3C Propellant/propellant Thermal Treatment Obtain clean up material as needed
contaminated materials
1.3C Rocket Motors Thermal Treatment Obtain clean up material as needed
1.1C Propellant/propellant Thermal Treatment Obtain clean up material as needed contaminated materials
1.1C Rocket Motors Thermal Treatment Obtain clean up material as needed
1.3C Donor Burn Propellant Burn Enhancer Obtain clean up material as needed
1.3C Flares and Flare Material Thermal Treatment Obtain clean up material as needed

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APPENDIX II BULK STORAGE AREAS INFORMATION

A. BULK FLAMMABLE LIQUID STORAGE AREAS .....................................50 B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE ...... 51

APPENDIX III ARRANGEMENTS WITH LOCAL AUTHORITIES………………………..52

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A. BULK FLAMMABLE LIQUID STORAGE AREAS
Type of Capacity Above/Below Location Flammable Liquid (Gallons) Ground
M-4 Butanol 40 Above Ethanol 60 Above
Isopropanol 530 Above Methanol 500 Above Methyl Ethyl Ketone 400 Above
Paint 500 Above Paint Thinner 120 Above
M-53 Acetone 60 Above Ethanol 10 Above
Heptane 10 Above Methanol 50 Above
Methyl Ethyl Ketone 60 Above M-55 Gasoline 17,000 Below
M-66 Assorted 80 Above I-10 Methanol 15 Above
Methyl Ethyl Ketone 50 Above M-585 Acetone 50 Above
Ethyl Acetate 15 Above Methanol 10 Above
Toluene 30 Above M-711 Gasoline 10,000 Below
E-510 Ethanol 100 Above
Isopropanol 1,660 Above Methanol 35 Above
E-512 Acetone 100 Above Isopropanol 50 Above
Paint Thinner 50 Above Polyester Resin 160 Above Toluene 50 Above
Xylene 160 Above
E-517 Isopropanol 170 Above Kerosene 50 Above Methyl Ethyl Ketone 450 T-29B Hydrazine 100 Above

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B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE
Building Number Location Direction of Flow*
I-10 Shed west of building Has self-containment concrete berm
M-4** Building north of M-3 Liquid would run west across asphalt into drain system
M-8** Two sheds west of Spill would drain down west hill
building M-43B Shed south of building Self-contained storage building
M-53A Shed south of building Self-contained storage building
M-66 Shed southwest of Spill would run into ditch (trench building or grading needed to keep surface runoff from
accumulating in containment area)
M-504 Shed south of building Spill would flow into ditch M-585 Shed east of building Spill would drain into ditch
M-605 Waste dock north of Spill would drain into ditch
building E-512 Shed west of building Spill would drain into ditch
E-517 Shed north of building Spill would drain into ditch
* All other storage areas have self-containment
** Fire flows and/or spilled material from these buildings will flow into a gated spill
containment structure below M-2. The gates are hand operated.

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APPENDIX III
Arrangements with Local Authorities
ATK has a well trained and full time Fire Department and Security Department onsite. ATK’s roads and
grounds and Water Operations departments maintains a fleet of trucks, tractors, vacuum trucks and
other equipment that could be used during an emergency response. The facility also has a nursing staff
during normal business hour, and a 24/7 ambulance service operated by ATK firemen with EMT certifications. Due to these capabilities, the need for outside assistance is greatly reduced. The most likely need for outside assistance would be that of hospital service. Arrangement will be made with both the Bear River
Valley Hospital and the Brigham City Community Hospital to accept employees that may have been
injured due to an explosion, chemical exposure or other accident. This arrangement will include
information on the types of chemicals used at ATK Promontory as well as explosive hazards and other
mechanical hazards associated with work performed at ATK.

The most likely scenario that would require assistance from a police agency would be the need to control
traffic on Highway 83. Arrangements for assistance in this area will be made with the Box Elder County
Sheriff’s Department and the Utah Highway Patrol. All on plant traffic control will be handled by
ATK’s security department.

ATK has established contracts with three different emergency response/remediation contractors for use
as needed. While we do not anticipate the need for emergency service assistance, these companies are on
call to provide service if needed.

All emergency response at the plant will be handled by the ATK Fire Department, who will act as the
primary emergency authority. Arrangements will also be made with the Box Elder County Fire
Department and the Tremonton Fire Department. We do not anticipate any need for assistance from the
Utah Department of Environmental Response and Remediation, although notification of emergencies will
be made to this department as required. In addition to those agencies listed above, ATK will also provide
a copy of the contingency plan to the Box Elder County Emergency Planning Committee for review and
comment. Below is a summary list of those agencies/service providers for which service arrangements will be sought: Bear River Valley Hospital
Brigham City Community Hospital
Box Elder County Sheriff’s Department
Utah Highway Patrol
Box Elder County Fire Department
Tremonton Fire Department

The most recent copy of the Contingency Plan will be sent to each of these agencies in order to familiarize them with the layout, description of hazardous wastes handled, and evacuation plans for the plant. All correspondence with these agencies, in regard to the Contingency Plan and service arrangements will be kept in the Operating Record.
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CLOSURE PLAN AND FINANCIAL REQUIREMENTS

This Closure Plan describes the steps that will be taken to close the hazardous waste management units (HWMUs) at the ATK Launch Systems Inc. – Promontory (ATK) facility. Closure Cost estimates are maintained in the Operating Record once approved by the Director.
HWMUs included in this document are: M-186; M-705S; E-501; M-136; M-225; T-29B; M-629
and S-633.
The Closure Plan was developed to comply with R315-8-7 and R315-8-9.9 of the Utah Administrative Code (UAC). UAC R315-8-7 incorporates by reference the requirements of 40
CFR 264 Subpart G. The closure cost estimates were made in accordance with UAC R315-8-8,
which incorporates by reference the requirements of 40 CFR 264
Subpart H. All HWMUs in current operation are being managed in a manner that facilitates clean closure.
Historical sites, such as the LTTAs do require post closure care, and are covered in our Post
Closure Permit.

1.0 Closure Plans [40 CFR 270.14(b)(13), 270.23(a)(2), and 264.112(a)(1) & (2) and UAC R315-3, R315-8]
This Closure Plan identifies the general steps needed to close storage and treatment facilities, as
identified above, at the end of their operating life. Copies of this plan will be maintained at the Promontory Facility. The closure plans will be followed as written, unless modification to the original plans have been submitted and approved by the Utah Department of Environmental
Quality, Division of Solid and Hazardous Waste (DSHW). Upon update/revision approval,
revised pages or complete documents will be sent to all plan addressees.

1.1 Closure Performance Standards [40 CFR 264.111 and UAC R315-8-7] Closure standards specified under RCRA are designed to be protective of human health and the
environment. These goals will be achieved by one of the following closure methods:

 Clean closure – this method refers to residential risk based levels. Cleanup to residential risk based levels, as outlined in UAC R315-101, will be considered clean
closure. Clean closure includes removal of all contaminants, or removal to the risk
based level.
 Site Management – closure where waste remains in place and specific post closure care is required.
For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be “clean
closed”. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(1). All closures will assess real and reasonably likely impacts to human and ecological exposures.
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 5 – Closure Plan UTD009081357
Preliminary remediation goals can be established prior to implementing any of the closure plans.
Screening levels published by USEPA or site-specific risk based levels based on UAC R315-
101-5.2 may be used.
If contamination from hazardous waste or constituents is discovered at a HWMU above risk
based goals, further investigation will be performed to determine the extent of the contamination.
Based on the results of this investigation, a Corrective Measure Study (CMS) may be prepared
for review and approval by the DEQ, prior to implementation.
If investigation suggests that clean closure is not a practicable approach, a Site Management Plan
will be prepared. Upon approval, the unit will be closed by implementing appropriate site
management or post closure requirements. If this approach is necessary, the Post Closure Permit
may be modified to provide post closure care for the sites that are not clean closed.
1.2 Partial Closure and Final Closure Activities [40 CFR 264.112(b)(1) through (b)(7) and UAC R-315-8-7]
This plan is designed to accommodate both partial and final closure. The plan includes separate
steps to close storage, consolidation & disassembly areas, and open burning/open detonation areas. A detailed plan for closing each HWMU will be submitted in accordance with Permit
Condition III.J.2.

Soil monitoring has been conducted at the M-136 and M-225 burn grounds since 1991. Semi-
annual groundwater monitoring is also conducted, in accordance with ATK’s Post-Closure Permit.

1.3 Maximum Waste Inventory and Disposal Method [40 CFR 264.112(b)(3) and UAC
R315-8-7]
The maximum inventory of hazardous waste onsite at any one time during the life of the
facilities is based on permit limitations for inert facilities, and Quantity/Distance(QD) limitations
for live materials, based on Department of Defense Explosive Safety Standard 4145.26M or a
lesser designated amount. If storage capacities change, the Permit will be modified. These
quantity limitations are listed below:
M-186 (inert) ------------------------------ 400 ea. 55 gallon drum equivalent
M-705S (inert) ---------------------------- 32 ea. 55 gallon drum equivalent
E-501 (inert) ------------------------------ 160 ea. 55 gallon drum equivalent
M-136 (live) ------------------------------ 106,500 lbs 1.3 / 20,000 lbs 1.1 M-225 (live) ------------------------------ 55,000 lbs 1.3 / 1,500 lbs 1.1
T-29B (inert) ----------------------------- 1 ea. 55 gallon drum (pure) equivalent
M-629 (live) ----------------------------- 110,000 lbs 1.3 / 55,000 lbs 1.1
S-633 (live) ------------------------------- 75,000 lbs 1.3/20,000 lbs 1.1
ATK treats reactive hazardous wastes on-site at the M-136 and M-225 open burning grounds.
Wastewater is collected and treated on site and discharged through one of two UPDES permitted
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 5 – Closure Plan UTD009081357
treatment facilities. All other hazardous wastes are transported by commercial carrier to fully
permitted disposal or recycling facilities.

1.4 Schedule for Closure [40 CFR 264.112(b)(6) and UAC R315-8-7] Section 1.4.1 of this plan provides an estimated closure schedule for all activities associated with
implementation of this Closure Plan. If sample results indicate the need for additional
investigation or a CMS, the schedule will be modified to accommodate the changes. Final
closure will be certified by an independent professional engineer licensed in Utah.
1.4.1 Time Allowance for Closure [40 CFR 264.113(a) and (b) and UAC R315-8-7]
Final closure is expected to be initiated within 30 days following shipment of the final volume of
hazardous waste. If more time is required, a request will be submitted to the Director. All hazardous wastes will be removed or treated within 90 days of (1) plan approval, or (2) after
receiving the final volume of hazardous waste, whichever is later. Final closure activities will be
completed within 180 days of (1) plan approval, or (2) after receiving the final volume of
hazardous waste, whichever is later.
1.4.2 Extensions for Closure time [40 CFR 264.113(a) and (b) and UAC R315-8-7] If closure activities cannot be completed within the time designated in this Closure Plan, a permit
modification and request for additional time will be submitted to the DSHW. The request will
state the reason for needed additional time and the status of the closure underway. It will also address any added measures that must be followed to minimize any threats to human health or
the environment during the extension period.

1.5 Closure Procedures [40 CFR 264.112 and 264.114 and UAC R315-8-7]
All permitted treatment and storage facilities have been designed and managed to minimize
possible contamination. This includes chemical resistant concrete coatings, blind containment
sumps, regular inspections, regular maintenance, and prompt cleanup of any spilled materials.
These practices should greatly reduce the need for significant remediation efforts upon closure.
1.5.1 Soil and Groundwater Sampling
Groundwater sampling is not covered under this plan. A groundwater monitoring program is
currently in place as discussed above. Soil sampling should not be required for any of the
permitted facilities, except for the two burn ground areas (M-136 and M-225) and S-633.
Detailed sampling plans will be submitted in accordance with Permit Condition III.J.2. Samples
will first be collected at locations most likely to have been affected by waste management
practices – as approved by DSHW personnel. Twenty soil samples will be collected at M-136,
eight soil samples will be collected at M-225 and eight soil samples will be collected at S-633. These samples will be sent to a State of Utah certified laboratory for analysis. Sample collection,
preservation and handling methods will follow those outlined in the Waste Analysis Plan of this
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 5 – Closure Plan UTD009081357
permit, and will be in compliance with all applicable SW-846 methods. All samples will be
processed and analyzed by a Utah Certified Laboratory in accordance with R444-14-3(2) UAC.
Analytical and extraction methods to be used are shown below.

Analytical and Extraction Methods
Parameter Analytical procedure Extraction Procedure
Volatiles SW-846; 8260B SW-846; 5030B(W), 5035S
Semi-Volatiles SW-846; 8270C SW-846; 3510C(W), 3550(S)
RCRA Metals SW-846; 6010B SW-846; 3005A(W),7471A(S)
Mercury SW-846; 7470A/7471A SW-846;7470A(W), 7471A(S)
Explosives SW-846;8330 Modified SW-846; 8330 Modified
Perchlorate EPA 314.0 EPA 314.0

1.5.1.1 Sampling Equipment Decontamination Procedures
All field sampling equipment will arrive on site pre-cleaned, and will be decontaminated following standard protocol and the waste analysis plan in this permit. A mobile
decontamination station will be used to clean all sampling equipment that could come in contact
with soil samples.
1.5.1.2 Sampling Waste Management All waste generated from field sampling and decontamination operations will be managed in
accordance with the current UAC R315 rules. Water used in the decontamination process will be
containerized and sent offsite for treatment or disposal. Soils will be stored in UN containers pending lab results. Any soil determined to be hazardous waste will be managed appropriately.
All non-aqueous hazardous waste generated by the sampling operation will be transported by a
third party contractor off site to a fully permitted TSDF for disposal. Any waste determined not
to be hazardous under EPA regulations will be sent via third party to a non-hazardous landfill for disposal.
A field log will be maintained to track and identify all samples. This log will include sample
numbers, dates, times, sample depth, samplers name, weather conditions, test methods and
constituents for which to analyze. 1.5.1.3 Health and Safety Procedures
Soil and water sampling will be performed by trained and qualified personnel. A determination
of appropriate personal protective equipment (PPE) to be used for this effort will be determined at the time of closure. PPE selection will be based on potential hazards as determined at the time of closure, and in consultation with Industrial Hygiene professionals.

Soil sampling should only be required at the burn grounds, because of well-maintained
secondary containment and waste management practices during the entire life of all other
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 5 – Closure Plan UTD009081357
permitted facilities. Protective clothing appropriate for the task will be used during removal of
waste and during decontamination of containment areas for the permitted storage and treatment
units.
1.5.2 Determining Cleanup Goals
For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be clean
closed. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(1). All closures will assess real and reasonably anticipated potential impacts to human and ecological exposures. It is
anticipated that the HWMUs will be clean closed and will not require post-closure care.

1.5.3 Site Cleanup
1.5.3.1 Inventory Removal [40 CFR 264.112(b)(3) and UAC R315-8-7] The maximum inventory of hazardous waste on hand at any given permitted facility is based on
the maximum allowed under this permit, or a quantity - distance limit for explosives, imposed by
the Department of Defense and ATK. These limitations are specified in Section 1.3 of this Closure Plan.

Transportation and disposal costs of all hazardous waste during closure of a facility will be based
on hiring a third party. The transportation contractor will be licensed and insured, and the
disposal facility will be a permitted facility. Reactive hazardous wastes may be open burned on site. Cost calculations for treatment, disposal and equipment decontamination will be based on
maintaining an ATK staff sufficient to complete these efforts.

1.5.3.2 Disposal or Decontamination of Equipment and Structures [40 CFR 264.112(b)(4),
264,112(e), and 264.114 and UAC R315-8-7]
Decontamination of equipment and structures at the Promontory facilities will follow one of two
plans. These plans cover the open burning units, and all other facilities.

The open burning facilities use burn trays, pipes, concrete vaults or rocket cases to contain the waste to be treated. Most of the material burned is hazardous by characteristic only. Any waste
that may be contaminated with, or contains solvents or hazardous heavy metals is designated as a
derived waste, and the ash collected for offsite disposal. Therefore, except for the derived trays,
all ash in trays, vaults, cases, and on the ground around these units will be collected and disposed
on-site. The burn trays will then be high pressure water washed and the rinsate collected for disposal. After the final rinse, a composite sample from the trays will be collected and analyzed
at a Utah certified lab to verify proper tray decontamination. Each sample will include rinsate
from 5 trays. Samples will be extracted and analyzed as described in 1.5.1.

All facilities except for M-136, M-225, M-629 and S-633 are designed with secondary containment. The secondary containment includes a concrete pad with curbing and blind sump
to simplify cleaning. The containment pads and sumps are coated with a chemical resistant
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 5 – Closure Plan UTD009081357
epoxy to prevent liquid migration through the concrete. Secondary containments are inspected
daily, when in use, and maintained as needed. After removal of all containerized waste, the
liquid chemical containment pads of facilities E-501, M-186, M-705S, and T-29B will be high
pressure water washed, and the rinsate will be collected for disposal. After the final wash, rinse water samples will be collected from each sump and characterized for disposal.
Samples will be sent to a State certified laboratory for analysis.

1.5.3.3 Closure Containers [40 CFR 264.178, 264.112(b)(3), and 270.14(b)(13) and UAC
R315-8-9.9, R315-807, and R315-3-5(b)(13)] Non-reactive hazardous waste requiring off-site disposal will be placed in a UN or a bulk
USDOT authorized containers for offsite shipment to permitted disposal facilities. Empty
containers will be cleaned in compliance with 49 CFR, and sent for disposal.
2.0 Closure Certification [40 CFR 264.115 and UAC R315-8-7] Within 60 days of completion of closure of each facility, ATK will submit a certification to the
DSHW by registered mail, that the hazardous waste management facility was closed in
compliance with this Closure Plan. This certification will be signed by ATK and an independent registered professional engineer licensed in Utah. Documentation supporting the engineer's
registration will be provided upon request.

3.0 Closure Cost Estimate [40 CFR 264.142]
Closure cost estimates are maintained in the operating record once approved by the Director.
Closure cost estimates are based on using a third party except for the thermal treatment and
disposal of reactive waste which will be conducted on site.

4.0 Financial Assurance Mechanism for Closure [40 CFR 264.143 and R315-309]
ATK will maintain current financial assurance meeting the requirements outlined in the above
referenced Federal and State regulations. ATK will provide documentation to DSHW supporting
compliance with financial mechanism requirements.
5.0 Post Closure Plan If it is determined that a HWMU can’t be clean closed, contaminants may be left in place, and a
post closure or site management plan will be developed. Any proposal for post closure care or
site management will be developed in accordance with UAC R315-8-7, UAC R315-8-8 and 40 CFR 264 Subparts G and H, and will be submitted to the Director for approval. If this approach
is necessary, the Post Closure Plan may be modified to provide post closure care for the sites that
are not clean closed.

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ATTACHMENT 7

SECURITY PLAN
ATK Launch Systems Inc. – Promontory November 2015 Attachment 7 - Security UTD009081357
07 HAZARDOUS WASTE MANAGEMENT
07.01.1 SECURITY PROCEDURES

07.01.1 Purpose and Scope The work performed at the ATK Launch Systems, Promontory facility
primarily involves Department of Defense and NASA contracts; therefore,
comprehensive security agreement measures have been instituted. These
security measures meet the requirements of the Division of Solid and Hazardous Waste Administrative Rules R315-8-2.5. No waiver from these requirements is being sought as the facility has both a twenty-four
hour surveillance system and an artificial barrier around the facilities to
minimize the possibility of unknown entry of livestock or personnel.
07.01.2 Surveillance System
Security is maintained by a trained security force which controls entry and
exit from the facility and provides patrol, escort, and other activities
within the plant. The main plant entrances are manned by a minimum of one security officer during normal working hours. All other gates are locked and only used when authorized by Security. All employees
entering the facility must show identification badges at the gate and wear
them in plain sight throughout the day. All visitors and vendors are
required to wear special identification badges. 07.01.3 Artificial Barrier

There are artificial or natural barriers around the entire plant. The primary
barrier consists of a chain link and barbed wire fence with controlled access at the main entrances to the plant. The chain link fence runs along the highway from building A until it runs into the gully formed by Blue
Creek just west of M-46. A natural barrier is provided by the Blue Creek
gully which is approximately 15 feet deep with near vertical sides. This
barrier extends for approximately 8,000 feet to a five-foot, four-strand barbed wire fence. This fence extends to the north, changes to chain link, and runs around the north end of the Plant. The chain link fences are
seven feet high and topped with barbed wire. This fence is continued by a
five-foot, four-strand barbed wire fence, which completes the primary
barrier by encircling North Plant, Test, and South Plant. Plant III is encircled by a five-foot, four-strand barbed wire fence and also has controlled access at the main entrance. Each hazardous waste
management area also has an artificial barrier.

ATK Launch Systems Inc. – Promontory November 2015 Attachment 7 - Security UTD009081357
E-501: The Container Storage Area is surrounded by a seven-foot chain link fence and has controlled access. The gate is locked when no one is present.

M-136: A five-foot, four-strand barbed wire fence surrounds the Burning
Grounds area. It has a gate, which is locked when no one is present. S-633 The storage area is located inside the secured M-136 perimeter fence.
S-633 is also surrounded by a five foot four strand barbed wire fence
in addition to the M-136 fence.
M-186: A five-foot, four-strand barbed wire fence surrounds the Container Storage Area. It has a gate, which is locked when no one is present.

M-225: The Burning Grounds are surrounded by an eight-foot, chain link
fence. It has a gate, which is locked when no one is present. A five-foot, four-strand barbed wire fence surrounds the runoff dispersion area.

M-705S: The hazardous waste management area is inside a building with
lockable doors to provide access control. In addition, the facility uses the plant’s artificial barrier.
M-629: The solid reactive waste storage area is inside the building and
remains locked except when occupied by personnel for placement of
material into storage or removal from storage. T29B: Building T29B remains locked at all times and is controlled by
authorized Test Service personnel.

07.01.4 Signs All hazardous waste management areas (i.e., E-501, M-136, S-633,
M-186, M-225, M-705S, M-629 and T29B) have warning signs placed at
the access approaches. All signs are legible from a distance of at least 25
feet. All signs have a legend which reads “Danger - Unauthorized Personnel Keep Out.”

ATTACHMENT 8

PREPAREDNESS AND PREVENTION PLAN

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8-1 PROCEDURES, STRUCTURES, AND EQUIPMENT

8-1-1 Purpose and Scope

Precautions have been taken to minimize the accidental or sudden release
of hazardous waste or waste constituents into the environment. The
precautions comply with the requirements of R315-8-3.2.

8-1-2 Loading and Unloading Operations

Several precautions have been taken to minimize hazards during the
loading and unloading of hazardous waste. These precautions are divided
into three classes of Waste Management: Open Burning, Drum Storage
and Propellant/Explosives Storage.

Open Burning of hazardous waste explosives and propellants requires
special precautions. Precautions taken during loading and unloading
operations are described in M-136 Burning Grounds Operating procedures
and in M-225 Burning Grounds Operating procedures. Safe loading and
unloading of explosive waste helps to minimize waste release into the
environment and reduce the possibility of unplanned ignition of waste
material.

Waste energetic material received from off-site for storage prior to open
burning, will be handled under the same precautions as all other wastes
accepted for disposal at the burn grounds. Loading/off-loading areas will
be inspected each day waste is received, and at a minimum of once per
week.

Several precautions are also taken at the Drum Storage areas. Spill control
equipment is located at each area and can be used in loading and unloading
operations. All drums are on pallets and are loaded and unloaded by a
forklift. The design of the Drum Storage facilities allows adequate aisle
space for movement of drums with a forklift to minimize the actual
handling of the drums. Permit conditions II.K.6. and III.E.4. state that, at a
minimum, the Permittee shall maintain 30 inches of aisle space between
containers or pallets of containers at storage areas M-186 and E-501. All
forklift truck operators must have a license to operate the forklift truck.
The operator receives this license by attending a training program which
includes an actual driving test that must be passed. The hazardous waste
operators must also participate in the Hazardous Waste Training Program
discussed in Attachment 3.

Waste propellant, explosives and rocket motors are carefully off loaded
from trucks using fork lifts, building cranes or a trailer mounted knuckle

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boom. Small containers, less than 50 lbs, may be off loaded by hand. All
operators of the equipment listed above, under go extensive training in the
proper use of the equipment they operate. This training includes class
room as well as hands on training. All ATK propellant moving, grounding
and bonding procedures will apply.

Many precautions are taken during the transfer of waste hydrazine during
the dilution process that is used to prepare this waste for off-plant disposal.
These precautions include medical certification, operator knowledge of
chemical properties, special safety equipment, and specific operating
instructions.

8-1-3 Prevention of Run-on and Run-off

Run-on and run-off are controlled at the drum storage pads M-186 and
E-501 by a concrete berm around the facility. The M-705 storage and
consolidation room is totally enclosed preventing run-on from entering the
facility and eliminating any possibility for run-off. Details of these
structures and how they control run-off are found in Attachment 6 of this
Permit.

Run-on and run-off at the Burning Grounds, M-225, M-136, and storage
pad S-633 are controlled by diversion, collection ditches, and trenches. A
diversion ditch directs run-on around the Burning Grounds. The run-off at
M-136 is collected in a ditch and dispersed in a dispersion area. The run-
off at M-225 is dispersed in an area directly in front of the burning area.
Both areas will be included in the zone of Engineering Control. Waste
material at the S-633 storage pad is stored in closed or covered
containers/articles. Drawings showing the control systems for M-136 and
M-225 are included in Attachment 6.

Run-on and run-off at building M-629 is controlled since the facility is a
fully enclosed building which is elevated above the surrounding grade to
prevent rain intrusion. Drawings of this building are found in Attachment
6 of this permit.

8-1-4 Prevention of Water Supply Contamination

The drum storage areas, M-186, E-501, and M-705S each have a
containment system which is designed to prevent releases of contaminants
to the environment. Each system is constructed to be leak-proof and divert
run-on. These containment systems are shown in the facility drawings
contained in Attachment 6.

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The propellant/motor storage areas store only solid materials, and do not
require secondary containment. The nature of this solid waste greatly
reduces the potential for contaminating water supplies.

The materials in the trays at the burning grounds are normally destroyed
on a biweekly basis, except those materials too sensitive to store which are
burned the same day. The burn trays are inspected weekly and prior to
loading to look for cracks or holes. Minimizing free liquids and
controlling run-on and run-off prevents water supply contamination. It is
not anticipated that groundwater or surface water will become
contaminated from the storage operations.

Historical management of hazardous waste has resulted in groundwater
contamination at ATK. Semiannual groundwater monitoring is conducted
in the area of the M-136 Burning Grounds, and down-gradient, in
accordance with ATK’s Post-Closure Permit. Groundwater flow and
transport models have been developed to help predict the migration of
contaminant plumes. The Division of Solid and Hazardous Waste has
approved the ATK Promontory groundwater modeling report. The risk
assessments and potential corrective measures are being conducted.

8-1-5 Mitigating Effects of Equipment Failures and Power Outages

A power outage or equipment failure will have little effect on the
hazardous waste storage and treatment areas. Any equipment failures,
such as truck breakdowns, pump repairs, etc.; can be managed by on-plant
maintenance. Power outages can occur, but all critical operations have
backup generators so hazardous waste can be controlled. ATK maintains
an electrical lineman crew that has the necessary equipment and
experience to repair on plant power outages. In the event of a very large
power outage or repair, Rocky Mountain Power will be contacted and
necessary measures taken to restore power.

8-1-6 Prevention of Undue Exposure to Personnel

Exposure to personnel handling hazardous waste is minimized by
containing and safely packaging waste and supplying personnel with
proper protection and safety equipment. Section III F of the Contingency
Plan (Attachment 4) lists the equipment available to all plant personnel.
Specific procedures and requirements for personnel protection during the
handling of hazardous waste are specified in area standard operating
procedures.

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8-1-7 Emergency Equipment

This equipment is inspected on a monthly basis. The emergency
equipment is intended to help respond to small emergencies such as leaks
or spills. It is not intended to respond to major incidents, fires, nor
explosions. It is limited to equipment that is manually operated and is
easily portable. Monthly inspections assure there are adequate supplies of
material on hand and mechanical items are operable so that immediate
response to small emergencies can be safely handled.

ATK maintains a spill response trailer which is used to respond to spills
that are medium to large. The trailer contains safety and spill response
equipment. This trailer is maintained by the fire department and is
inspected weekly or after use to ensure that an adequate supply of material
is on hand.

8-1-8 General Areas

The general area of each hazardous waste storage site is inspected on a
daily basis when in use. These inspections consist of observing the area
for possible spills or mismanagement of hazardous waste. These areas
need daily inspections when in use to minimize potential for
mismanagement of hazardous wastes during loading, unloading, or
handling.

8-1-9 Safety Equipment

Safety equipment is inspected monthly. Monthly inspections include
testing equipment to make sure it is in working order and ensuring that all
equipment is complete and in place. These inspections help to maintain a
safe work environment and minimize human health incidents.

8-1-10 Storage and Containment System

The storage and containment system shall be inspected as directed in
Attachment 2. In some cases, inspections are required, as stated in the
attachment, after each storm event. A storm event is defined as more than
one inch of precipitation in a one-hour period. This is not only a
regulatory requirement, but these inspections help to operate the container
storage area in a safe manner and minimize environmental incidents.
Inclement weather and mismanagement are the primary sources of
deterioration of the containment system and containers.

Standing liquids in the containment system and/or sumps must be
managed according to Section 9-4.3 of Attachment 9 – Container

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Management Procedures. Inspections are conducted in order to effectively
manage standing liquid. These inspections minimize environmental
impacts from the actual storage of hazardous wastes in the storage areas.

If a leaking or deteriorating drum is identified during the inspection, the
contents or the entire container must be immediately transferred into a new
container. The new container must be numbered and labeled with exactly
the same number and label as the old container. The date and time of any
transfer action must be noted in the inspection log. The transfer of the
leaking or deteriorating drum can be handled in two ways: the contents of
the container can be transferred by pump to a new drum, or the drum can
be placed in an 85-gallon over-pack drum with the space between the two
drums filled with an absorbent to control any possible leaks.

8-1-11 Burning Ground Area

Burning of explosives and reactive wastes occurs normally on a biweekly
basis, but can occur more often if conditions necessitate the increased
frequency. Inspections of the area, equipment, and burn trays, are
conducted weekly or as specified in Attachment 2. Items inspected under
this category are subject to general wear or weathering.

In addition, containers stored in burn trays at M-136 are inspected to
ensure that they are in good condition, closed and labeled. Burn trays are
inspected for cracks and gaps and accumulation of leaked liquids or
precipitation. Inspections conducted as described above, provide the time
necessary to correct maintenance and erosion or wear problems. They also
minimize the environmental impact at the Burning Grounds.

8-1-12 General Facility

Equipment and PPE required to properly manage hazardous waste and for
spill clean up is kept at the permitted facilities and regularly inspected.
New materials are purchased as needed to assure an adequate supply.

8-1-13 Fire Department Equipment

The Fire department inspects their equipment on a routine basis and after
each use. This equipment is especially important to aid in minimizing the
effects from fires, explosions, and spills. The inspections are performed
and records are kept by the Fire Department personnel.

8-1-14 Heavy Equipment

Most of the heavy equipment is used on a regular basis for construction

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services and for the management of solid wastes. It is also available for
use in emergencies. This equipment is handled at the heavy equipment
garage and is inspected on an hour-usage basis rate of 100-150 hours
depending on the equipment type and working conditions. A detailed
checklist is covered by Maintenance that is checked thoroughly by trained
personnel. All inspection records on heavy equipment are kept on file at
Maintenance Control and are available for inspection.

8-1-15 Inspection Log

All inspections are recorded. These forms are put into one of three
inspection logs. Each log contains the most recent three years of records
and is available for review. Environmental Services keeps the inspection
logs of the results of all inspections on the security equipment, emergency
equipment, general area, safety equipment, storage and containment
system, burning grounds, and general facility categories. The Fire
department keeps a log of the Fire department categories and Maintenance
Control keeps a log for the heavy equipment category.

8-2 CONTINGENCY PLAN

8-2-1 Purpose and Scope

ATK has developed and supplied a contingency plan as required by R315-
3-2.5(b)(7) and R315-8-4. This plan has been devised as a separate
document so that it can be used independently of this permit.

A copy of the contingency plan is in Attachment 4. The plan has been
designed to minimize hazards to human health and the environment from
fires, explosives, or any unplanned or sudden release of hazardous wastes.
8-3 PREPAREDNESS AND PREVENTION

8-3-1 Purpose and Scope

The hazardous waste treatment and storage facilities have been designed,
constructed, maintained, and operated to minimize the possibility of
unplanned fires, explosions, or discharges of hazardous wastes. In the
event of an emergency, the responsibilities of responders, organizational
structure, and procedures required to ensure effective warning, response,
and control to minimize hazards to human health or the environment are
addressed in detail in the Contingency Plan (Attachment 4).

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8-3-2 Required Equipment

All hazardous waste facilities are equipped to respond effectively to an
emergency situation. Should an emergency situation arise, such as a
discharge of hazardous waste, a fire, or an explosion, employees who are
in hazardous waste management areas should be able to respond according
to the procedures outlined in the Contingency Plan.

All hazardous waste facilities are equipped with internal and external
communication systems. Internal communications are provided by voice
signals and commands specified in the Contingency Plan in Section E. All
hazardous waste facilities are in open-space areas and there are no loud,
industrial noises that could muffle voice commands or signals. These
voice commands provide immediate onsite emergency instructions to
employees in the hazardous waste management areas. An external
communication system using telephones is provided for employees at each
area. These telephones can be used to contact Internal Emergency
Response or initiate the Contingency Plan. Storage buildings not equipped
with alarms or hard wired phones, will utilize cellular phones to contact
ATK’s emergency responders if needed.

To prevent personnel from fighting fires in the waste rocket
motor/propellant storage buildings and adjacent waste docks, fire
extinguishers are not provided. All other hazardous waste storage areas
are equipped with fire extinguishers.

The buildings that have separate electrical rooms, have extinguishers that
are to be used in the electrical rooms only. Spill clean up material will be
provided in each of these buildings as outlined in section III.F of the
Contingency Plan. The location of the fire extinguisher is shown on the
evacutation plan in Appendix 1 of the Contingency Plan. Along with
these portable extinguishers, ATK maintains a Fire department to respond
to fires or explosions. Descriptions of fire equipment, available water, and
the Fire department are described in Section I G of the Contingency Plan.

Building M-629 is equipped with a fire sprinkler system, which is checked
at least annually. ATK’s full time, fully equipped and trained Fire
Department are immediately available for any emergency response action.

8-3-3 Testing and Maintenance of Equipment

All emergency and safety equipment is inspected on a routine basis to
ensure it is in working order and in good repair. These inspections are
documented and are available for inspection.

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8-3-4 Access to Communications or Alarm Systems

All employees who manage hazardous waste have immediate access to
both internal and external communication systems. All employees have
access to telephones or cellular phones and are trained on how to summon
external emergency assistance if required.

8-3-5 Required Aisle Space

Aisle space has been designed into each drum storage pad. This type of
drum storage allows easy access to thoroughly inspect the area around
each drum and allows adequate room to transfer hazardous waste into a
new drum if a drum is found to be leaking or in poor condition. There is
enough aisle space and clearance around each storage pad to allow free
movement of fire protection equipment, spill control equipment, and any
needed decontamination equipment. Detailed drawings of the drum
storage areas are found in Attachment 6 of this Permit. An aisle space of
30 inches minimum between containers or pallets of containers will be
maintained at storage areas M-186 and E-501. Hazardous waste stored in
containers at M-705S, M-629, S-633 and M-136 will be stored so that they
may be readily inspected and hazardous waste labels are visible.

8-4 PRECAUTIONS TO PREVENT IGNITION AND REACTION

8-4-1 Purpose and Scope

Precautions to prevent accidental ignition or reaction are essential to the
safety of all personnel. The precautions taken ensure compliance with
R315-8-2.8. The precautions are a part of everyday manufacturing and
production activities at ATK.

8-4-2 Precautions for Open Burning of Explosives and Propellants

Many precautions are taken to prevent accidental ignition or reaction of
hazardous waste materials at the Burning Grounds at M-136 and M-225.
Because of the extremely sensitive nature of these wastes, special
precautions are taken for each source of ignition.

Safety procedures for handling energetic and sensitive materials are found
in ATK’s Hazardous Operations Standard Manual (AHOPS) and the
internal handling procedures or protocols.

8-4-3 Precautions for Drum Storage of Hazardous Waste

The drum storage buildings have been designed to hold flammable liquids.

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The front and all sides of E-501 are open to ensure that proper ventilation
is maintained in each storage area. Doors are opened as needed at M-186
and M-705S to provide adequate ventilation. Unauthorized personnel are
kept out of the storage areas. The areas are inspected on a weekly or daily
basis and all leaking or damaged containers are replaced as addressed
above and in Attachment 9.

In the event of a spill of hazardous waste or material which, when spilled,
becomes hazardous waste, the person responsible for the material at the
time of the spill shall immediately take appropriate action to minimize the
threat to human health and the environment and comply with UAC R315-9
and implement the Contingency Plan if necessary.

8-4-4 Precautions for Propellant/Motor Storage

All propellants/motors will be safely handled in accordance with AHOPS.
These procedures include, but are not limited to, proper grounding and
bonding protocol. All permitted hazardous waste storage and treatment
facilities are located more than 50 feet from any property line to help
minimize the fire potential of adjoining property. General site maps which
show these buildings, as well as the property lines, are found in
Attachment 6.

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TABLE 8A

Precautions Against Accidental Ignition and Reaction of Hazardous Waste
Explosives and Propellants

IGNITION SOURCE PRECAUTIONS
Smoking Burning grounds are designated as areas
where smoking is a fire hazard and as such
must meet the requirements of company
procedures. Requirements for smoking are
strictly enforced by the Safety department.

Open Flames

The use of a flame, heat, or spark-emitting
device in any area requires a permit.
Requirements for uses and restrictions of
these permits are found in company
procedures. These permits are issued prior to
starting work.

Static Electricity

Static electricity can be an ignition source. To
avoid static charges, all explosive or
propellant waste is packed in a container with
either a conductive or static dissipative liner.
During storage and prior to and/or during
transportation of wastes to the burning
grounds, all conductive waste containers are
grounded to prevent static spark. Upon
placement in the metal burn tray, grounding is
no longer required. Rocket motors for disposal
will not be packaged in these liners, but will
be grounded to the case prior to being placed
into position for open burning.

Incompatible Materials

Incompatible materials are not placed in the
same containers and incompatible wastes are
segregated at each waste pickup dock.

Friction and Sparks

Vehicles hauling waste propellant must have
spark arresters in the exhaust line. Non-
sparking rakes are used in preparing the
trenches for burning or re-burning. A porous,
non-sparking truck bed is also used.

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Electrical Equipment

No electrical work is allowed in areas where
explosives or propellant are present.

TABLE 8B

Precautions Against Accidental Ignition and Reaction of Hazardous Waste in
Drum Storage

IGNITION SOURCE PRECAUTIONS
Smoking The drum storage areas are designed as
areas where smoking is a fire hazard and as
such must meet the requirements of
company procedures. Requirements for
smoking are strictly enforced

Open Flames

The use of a flame, heat, or spark-emitting
device in any area of the plant requires a
permit. Requirements for uses and
restrictions of these permits are found in
company procedures. These permits are
issued prior to starting work.

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ATTACHMENT 9

CONTAINER MANAGEMENT PROCEDURES

ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

CONTENTS
9 USE AND MANAGEMENT OF CONTAINERS ...............................................3
9-1 PURPOSE AND SCOPE .............................................................................3
9-1.1 Facility Description ....................................................................3
9-2 MANAGEMENT OF CONTAINERS ........................................................4
9-2-1 Types of Containers for Storage ................................................4
9-2-2 Waste Compatibility ..................................................................5
9-2-3 Storage of Containers .................................................................6
9-2-4 Inspections .................................................................................8
9-2-5 Operating Record………………………………………… .......8
9-3 LAB PACKS AND WASTE CONSOLIDATION ......................................8
9-3-1 Lab Pack Preparation .................................................................8
9-3-2 Lab Pack Labeling ......................................................................9
9-3-3 Containment Sealer ....................................................................9
9-3-4 Lab Pack Compatibility .............................................................9
9-4 CONTAINMENT ........................................................................................9
9-4-1 Capacity of Containment ...........................................................9
9-4-2 Containment Sealer ..................................................................10
9-4-3 Removal of Free Liquids From
Containment Area ....................................................................10
9-5 RUN-ON AND RUN-OFF CONTROL.....................................................11
9-6 REQUIREMENTS FOR IGNITABLE AND REACTIVE
WASTES ..................................................................................................12

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9 USE AND MANAGEMENT OF CONTAINERS
9-1 PURPOSE AND SCOPE

ATK Launch Systems – Promontory (ATK) currently manages the drum
storage areas at M-186, E-501, M-705S, the solid propellant storage
building M-629, storage pad S-633 and solid propellant storage in burn
trays and at Burn Station 14 at M-136 in accordance with the Division of
Solid and Hazardous Waste Administrative Rules R315-8-9. These waste
storage areas are owned and operated by ATK. All containers are being
temporarily stored waiting thermal treatment on-site, or shipment off-site
for recycling, treatment and/or disposal.

The drum storage site at M-186 is designed to hold 400, 55-gallon drums
of various types of waste intended for treatment or disposal. The drum
storage site at E-501 is designed to hold 160, 55-gallon drums of various
types of waste intended for treatment or disposal. The M-705S storage
and consolidation room is designed to store a maximum of 32, 55-gallon
drums, both rooms include palletainers of various types of waste intended
for consolidation or lab packing. For solid propellant storage capacities,
see Module III section E.

9-1.1 Facility Description

The M-186 storage pad is permitted for the storage of the hazardous
wastes identified in Permit Condition III.B.1. The storage pad is divided
into five storage bays to keep incompatible materials separated. The pad is
a coated concrete floor with secondary containment. The M-186 storage
facility is shown in Figure E-1 of Attachment 6.

The E-501 storage pad is permitted for the storage of the hazardous wastes
identified in Permit Condition III.B.1. The pad is a coated concrete floor
with secondary containment. The E-501 storage facility is shown in
Figure B-1 of Attachment 6.

The M-705S Storage and Consolidation Room is a single room with a
coated concrete floor and secondary containment. It is permitted for the
storage of the hazardous wastes identified in Permit Condition III.B.1.
The room is equipped with plastic containers to keep incompatible
materials separated. Poly-spill pallets are used to provide separate
containment for each consolidation drum and lab pack drum as needed.
The M-705S storage facility is shown in Figure C-1 of Attachment 6.

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M-629 is designed for storage of solid propellant/explosives. This
building is sited for the maximum quantity of propellant/explosives based
on Quantity/Distance, DOD siting criteria found in the contractor safety
manual, 4145.26m. Each building is set up to permit proper grounding
and cross bonding as appropriate. The M-629 storage facility is shown in
Figure 6-D of Attachment 6.

Storage Pad S-633 is designed for storage of solid propellant/ explosives.
It is secured by a perimeter fence, a vehicle access gate that can be locked,
and has the appropriate warning signs for a storage area. It has a road base
surface, and has lighting protection. Precipitation run-on or run-off is
prevented by a combination of diversion ditches, collection ditches and
trenches. The S-633 storage pad is shown in Figure J-1 of Attachment 6.

The storage of solid propellant wastes received from off-site at M-136 is
only permitted for a maximum of 14 days. This includes waste stored in
containers placed in burn trays and waste rocket motors that contain solid
propellant placed on the ground at Burn Station 14. The storage of waste
materials received from off-site at M-136 is permitted in order to facilitate
more efficient and safer waste handling practices, and to accommodate
delays in waste treatment due to weather or other uncontrollable delays.
Storage of this waste will be in compliance with this permit and R315-8-9.

9-2 MANAGEMENT OF CONTAINERS

9-2.1 Types of Containers for Storage

The containers to be used for storage, lab packing, or consolidation at
M-186, E-501, and M-705S will meet the UN or USDOT criteria or will
be a sturdy liquid tight alternative container. No more than 400 drums will
be stored at M-186; 160 drums at E-501; and 32 drums at M-705S.
Substitute containers will reduce the number of drums that can be stored
based on the volume of the container chosen.

The containers that will be used for storing solid, reactive wastes at
M-629 and S-633 include rocket motor cases, covered drums, boxes,
plastic bags, woven bags, slids, and US Department of Transportation
(DOT) approved shipping containers. The standard containers used at the
Facility are described in Attachment 11, Section 11.4.

All solid reactive waste received from off-site and stored at M-136 will be
stored in containers as described in Attachment 11.4. Storage of these
containers is permitted in liquid tight burn trays or on the ground at Burn
Station 14 for intact rocket motors. All containers will be kept closed
during storage.
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

Lab pack and consolidation drums used for different compatibility groups
will be separated using a portable secondary containment system (PSCS)
such as a Poly-spill pallet. The PSCS will have the capacity to hold a
minimum of 55 gallons. Most PSCSs are unsatisfactory for storing most
organic waste; therefore, flammable/combustible waste lab packs or
consolidation drums will be placed on a pallet and stored on the floor
using the room’s containment system. Lab pack and containment drums
with non-hazardous waste will be stored on the floor. Non-hazardous
waste found to be incompatible with solvents would be placed on a PSCS
for which it was found to be compatible. All full consolidation or lab pack
drums will be transferred from M-705S to a permitted storage facility to
stay within M-705S’s storage capacity.

TABLE 9-2 HAZARDOUS WASTE COMPATIBILITY FOR STORAGE AT
M-186, E-501, M-705S, M-629, and S-633

General Compatibility Groups DOT Hazard Class in Group

1. Flammable/combustible liquids a. Flammable Liquids
and non-flammable solvents b. Combustible Liquids

2. Corrosives (acids) a. Corrosive Liquids (acids only)

3. Corrosives (bases) a. Corrosive Liquids (bases only)

4. Reactive Chemicals a. Organic Peroxides
b. Oxidizes

5. Toxic Chemicals a. Toxic
b. Infectious

6. Explosives a. 1.1
b. 1.3

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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

9-2.3 Storage of Containers

M-186, E-501 and M-705S

Before any waste container is accepted at M-705S, E-501, and M-186, it
shall be inspected to determine whether the waste matches the identity of
the waste specified on the accompanying manifest or shipping paper. In
addition, the containers shall be inspected to ensure that they are in good
condition, are closed, and labeled in accordance with 40 CFR 262.34
(incorporated by reference in R315-5-3.34) and R315-5-3.31.

If the drum is found to be unacceptable, it must be immediately repacked
and relabeled or the waste transferred to a new drum. Each drum or
container must be entered into the operator’s log (see Section 9-2.5) when
the drum or the container is accepted in to the drum storage area. A
forklift and/or pallet jack is used to move the pallet into the storage area.

Drums or containers in the holding bays at M-186 and at E-501 will be
sampled according to Attachment 1 of this permit. The wastes are
accumulated until enough containers exist to complete a load. The
containers are then loaded into a truck and shipped to the disposal facility
for proper treatment and/or disposal.

All drums stored at the M-705S, E-501, and M-186 storage areas will be
stored with either both plugs closed or with the top of the drum sealed. No
waste containers will be open unless waste is being added or removed.
Adding or removing waste will only occur at these storage facilities if a
container is damaged, leaking, for sampling, for waste consolidation,
and/or for lab packing. A container may be filled if spilled material is
found in a sump during the transfer of waste containers. A container being
filled or replaced will be located in the containment area. This will
provide containment if any spillage results from an incident during
transferring procedures. Precautions to be taken during the transfer of the
waste include: insuring all transfer equipment (i.e., hoses, pumps, funnels)
is located inside the containment area; ensuring a proper drum is used
when transferring waste material.
An aisle space of 30 inches minimum between containers or pallets of containers will be maintained at storage areas M-186 and E-501. Hazardous waste stored in containers at M-705S, M-629, S-633 and M-136 will be stored so that they may be readily inspected and hazardous waste labels are visible. 55-gallon drums may be stacked at a maximum of two high at storage areas M-186 and E-501 only. Containers stored at M-629 and S-633 that can be safely stacked, such as flare or munition boxes, may be stacked to a maximum height of 6 feet.

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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

All storage containers shall have hazardous waste labels attached that meet
the requirements of 40 CFR 262.34 (incorporated by reference in R315-5-
3.34). All personnel required to complete RCRA labeling shall receive
training as appropriate.

M-629 and S-633

All waste propellant/explosives stored at M-629 and S-633 must be
entered into the operating record. Building and storage pad inspections
must begin upon first receipt of material and end when all hazardous waste
has been removed from the building or storage pad. All containers must
be kept closed except when adding or removing waste. Adequate aisle
space must be provided to permit proper container inspection. Total
quantity limitations are as outlined in module III section E.

All containers shall have hazardous waste labels attached that meet the
requirements of 40 CFR 262.34 (incorporated by reference in R315-5-
3.34).

M-136 Burn Trays and Burn Station 14

All solid reactive wastes received from off-site shall be inspected prior to
placement into burn trays or Burn Station 14 at M-136 to determine
whether the waste matches the identity of the waste specified on the
accompanying manifest or shipping paper. In addition, the containers shall
be inspected to ensure that they are in good condition, are closed, and
labeled in accordance with 40 CFR 262.34 (incorporated by reference in
R315-5-3.34) and R315-5-3.31.

If a container holding hazardous waste is not in good condition, e.g.,
apparent structural defects, or if it has begun to leak, ATK personnel shall
take steps as appropriate to prevent a release from the container to the
environment.

Prior to placement of hazardous wastes into burn trays, the tray shall be
inspected as outlined in Attachment 2. Once the container or waste rocket
motor received from off-site is placed in a burn tray or Burn Station 14,
the date of the placement shall be added to the hazardous waste label,
beginning the 14 day maximum period which the waste may be stored.

Containers stored in burn trays at M-136 shall remain closed during
storage, except when it is necessary to add or remove waste. A container
holding hazardous waste shall not be handled or stored in a manner which
may rupture the container or cause it to leak. Containers shall be stored
such that the hazardous waste labels may be readily inspected.

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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

9-2.4 Inspections

All container storage areas are inspected on at least a weekly basis.
Details of inspection requirements for the storage areas are outlined in
Attachment 2. If a container is found with severe corrosion, structural
defects, rusty bungs, or leaking, the contents or the entire container must
be immediately transferred into a new container. The new container must
be numbered and labeled with exactly the same number and label as the
old container. The date and time of any transfer action must be noted in
the inspection log.

9-2.5 Operating Record

All waste brought into the M-186, E-501, M-705S, M-629, S-633 and
M-136 storage areas are entered into a hazardous waste log compliant with
R315-8-5.3. This log is kept for all wastes.

If a waste material is consolidated, the consolidation drum is recorded in
the hazardous waste log in such a way as to allow the consolidated
material to continue to be tracked. Waste materials to be lab packed are
placed in a lab pack drum and recorded in a hazardous waste log in such a
way as to allow the material and the drum to also be tracked.

The operating record is kept for all hazardous wastes. These records are
used to track wastes as they come in from on and off-plant generators and
satellite generator facilities.

9-3 LAB PACKS AND WASTE CONSOLIDATION

9-3.1 Lab Pack Preparation

ATK disposes of several hazardous wastes in lab packs. Completed lab
packs are stored in the drum storage bays. Before a lab pack is accepted at
the drum storage bay, it must be prepared, labeled, and documented in
accordance with 40 CFR 262 Subpart C (incorporated by reference in
R315-5-3.34) and R315-5-3.31.

Materials in small containers may be stored at the lab packing and
consolidation room at M-705S or at M-186 for lab packing or waste
consolidation. The materials are separated into compatibility groups based
on DOT hazard classification. The materials are generally in small
containers ranging from one or two ounces to 5-gallon cans. The small
containers are then stored in palletainers or on a shelf until ready to lab
pack or consolidate. Incompatible materials are not allowed to be stored
in the same palletainer, or containment bay.
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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

9-3.2 Lab Pack Labeling

Each waste container must be labeled with a complete hazardous waste
label.

9-3.3 Containment Sealer

The concrete containment area where consolidation and lab packing occur
at M-186 and M-705S, is sealed with a high build polyamide epoxy
coating system or equivalent. The Material Safety Data Sheet and
compatibility chart for this material can be found on the manufacturer’s
web site.

9-3.4 Lab Pack Compatibility

Under no circumstances will a lab pack contain wastes that are
incompatible. Compatibility of wastes will be determined by using the
MSDS or other reference sources. If a waste is not found in the reference
material, then the material will be assumed incompatible with all wastes
and lab packed separately unless research by Environmental Waste
Disposal’s technical staff documents compatibility. Lab packing will be
done in accordance with USDOT regulations and the requirements of the
disposal company.

9-4 CONTAINMENT

9-4.1 Capacity of Containment

All the container storage areas and consolidation/lab packing areas at
M-186, E-501, and M-705S are designed to hold a minimum of ten
percent of the volume of waste stored in the area or the volume of the
largest container, which ever is greater. Table 9-5A summarizes the
calculations.

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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357
TABLE 9-5A

Containment Capacity of Drum Storage Areas Storage Container Number of Drums
to be Stored
Needed
Containment
Containment
Available M-186 Storage Bay 80 Drums 440 Gal 980 Gal E-501 Storage Pad 160 Drums 880 Gal 895 Gal M-705S Room 16 Drums* 88 Gal 830 Gal M-705S Poly-spill pallet 4 Drums 55 Gal 85 Gal * Includes Palletainers

Storage building M-629 and storage pad S-633 are not permitted to store
liquids. Each container will be inspected to assure no liquids are present
upon arrival at the storage facility. Storage building M-629 is fully
enclosed to prevent contact of waste with rain water, and does not require
secondary containment. Roof leaks must be repaired as soon as is
practicable. Storage pad S-633 is located within the M-136 Thermal
Treatment Area. Any rain water falling on the pad is collected in the
M-136 storm water run-on/run-off control system.

9-4.2 Containment Sealer

The containment area at the M-186 and M-705S storage facilities are
coated with an epoxy resin to resist liquid penetration. No leakage or
spillage is anticipated during waste storage; however, in the event spills or
leaks do occur, the epoxy will prevent the material form penetrating the
concrete.

The containment system at E-501 is coated with an epoxy sealer that is a
high-build chemical resistant coating. The chemical compatibility and
properties of this epoxy are available from the manufacturer.

9-4.3 Removal of Free Liquids From Containment Area

Removal of free liquids at M-186, E-501, and M-705S must be done with
a pump or vacuum truck. When free liquids are found in the sump, a
portable drum pump, either electric or hand operated, is used to transfer
the liquid to a UN 55 gallon drum. A vacuum truck can also be used to
pump out collection of rain water and snow melt. Water pumped with the
vacuum truck will be taken to a UPDES permitted waste water treatment
facility (M-705) for processing. All free liquids taken from the sumps will
be managed as hazardous wastes until waste analysis or inspection dictates
otherwise.

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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

Precautions will be taken to avoid spills. All spills are cleaned
immediately, unless the size demands spill response. After the liquids are
transferred into drums, a sample will be taken form each drum according
to the sampling procedure in the Waste Analysis Plan, contained in
Attachment 1. The drums will be managed as hazardous waste until a
determination has been made classifying the contents. If the analysis
indicates the liquid is a hazardous waste as defined by the Division of
Solid and Hazardous Waste Administrative Rules R315-2, then the drums
will continue to be managed as a hazardous waste. If the liquid is a
wastewater, the liquid will be taken to M-705 Wastewater Treatment
Facility.

Occasionally, small amounts of liquid such as nitroglycerine can drip from
rocket motors onto the concrete floor. These drips are typically less than
1-inch in diameter and may drip as much as once per week. Any sign of
out-of-place waste will be checked during the regular inspections outlined
in Attachment 2. Clean up of dripped materials will be completed as soon
as is practicable using rags and acetone or other appropriate cleaners.

M-136 Burn Trays

Although the burn trays at M-136 are permitted for the storage of off-site
solid reactive wastes in containers for no more than 14 days, some of these
containers contain small amounts of desensitizing fluid (e.g. diesel,
shingle oil, etc.). Therefore, the containment requirements of R315-8-9.6,
as discussed below, apply to the storage of wastes in the burn trays.

The burn trays shall be free of cracks or gaps and be sufficiently
impervious to contain leaks, spills, and accumulated precipitation until the
collected material is detected and removed.

Spilled or leaked waste and accumulated precipitation shall be removed
from the burn trays in as timely a manner as is necessary to prevent
overflow of the tray. Inspection requirements for burn trays and the
accumulation of liquids are outlined in Attachment 2.

If the collected material is a hazardous waste under R315-2, it shall be
managed as a hazardous waste in accordance with all applicable
requirements of the State of Utah Hazardous Waste Management Rules. If
the collected material is discharged through a point source to waters of the
United States, it is subject to the requirements of section 402 of the Clean
Water Act, as amended.

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ATK Launch Systems Inc. – Promontory November 2015 Attachment 9 – Container Management UTD009081357

9-5 RUN-ON AND RUN-OFF CONTROL

Run-on and run-off water is prevented form entering the M-186 and E-501
drum storage pads. Three sides of each pad contain a curb that is six
inches in height and a sloped grade in the front that is three inches above
the ground surface. Each pad has sufficient height to prevent run-on from
entering the drum storage containment system. Detailed drawings of these
facilities are contained in Attachment 6.

The storage facility at M-705S is totally enclosed to prevent any run-on
water from entering the building.

Calculations have been performed for the M-186 storage pad and these
indicate that no run-on or run-off should enter the storage building and
affect the capacity of the containment area. The calculations were based
on a 24-hour, 25-year storm event and were submitted with the Part B
Permit Application.

The terrain around the burn grounds and storage pad S-633 has been
graded and drainage ditches surround the area in order to minimize run-
on/run-off. The topography and drainage ditches at M-136, M-225, and
S-633 are shown in Attachment 11 Figures 11-1 and 11-2, and Attachment
6 Figure J-1.

In addition, all waste will be in water tight burn trays to prevent run-on
and run-off. Waste Rocket motors will be covered to eliminate contact
with rain water.

9-6 REQUIREMENTS FOR IGNITABLE AND REACTIVE WASTES

All container storage areas are located more then 50 feet from facility
property lines. The aerial photograph contained in Attachment 6
(Figure 6A) shows the property boundaries and facility location.

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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015

ATTACHMENT 11

M-136 and M-225 Thermal Treatment Operations
11-1
ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015
11.0 PROCESS INFORMATION All reactive waste management operations at the facility are conducted and are under
the management of ATK. The reactive waste management process is described in the following text.

11.1 Facility Description The ATK Promontory facility is located in a remote area of west Box Elder County,
Utah, approximately 30 miles northwest of Brigham City, and approximately 11 miles
north of the Great Salt Lake. The facility was purchased by Thiokol in 1956, with the exception of a 1,500-acre tract that was sold to the U.S. Air Force in 1958 and then
repurchased in 1995. The facility has been held in its entirety since purchase.
ATK Launch Systems conducts thermal treatment of reactive hazardous wastes at two
treatment units: (1) the main facility, M-136, located centrally to the two main manufacturing sites; and (2) M-225 located in a remote development location called Plant III.
M-136 is the primary treatment area for conducting open burning at the Promontory
facility. Open detonation is also conducted at M-136 which is a secured fenced facility
within the main facility fence. The M-225 treatment area receives small amounts of the reactive hazardous waste
materials from the Plant III propellant development area. The M-225 treatment unit is surrounded with an 8-foot high chain link fence. The waste materials are treated via
open burning or open detonation.
The M-136 and M-225 treatment areas are fenced and are located within a controlled and
fenced facility that is patrolled and maintained by a security department. The treatment
areas have warning signs posted around the perimeter. The vegetation is controlled within the treatment areas through application of herbicide and putting in place loads of gravel
and road base. Surrounding both treatment areas are a large system of fire breaks that are
constructed using large equipment to till and cultivate a large strip of land removing any vegetation. The system of fire breaks are designed to contain a fire within its boundaries.
Contained within the boundaries of the M-136 treatment area are twelve former surface impoundments called Liquid Thermal Treatment Areas (LTTAs). These impoundments
were used for the disposal of hazardous waste and wastewater and then capped and closed. The units are currently under post closure care and managed through a Post Closure Permit
which includes requirements for groundwater monitoring and corrective action. The Post-
Closure groundwater monitoring program includes all wells around the M-136 and M-225 treatment areas as part of the groundwater monitoring system. These wells are routinely
monitored thorough the permit requirements which includes the Sampling and Analysis
and Quality Assurance Plans.
The Promontory facility is located in the Blue Spring Valley which is bounded on the
east by the Blue Spring Hills and on the west by Engineer Mountain and the Promontory Mountain ranges. Within the Blue Spring Valley, the terrain is
characterized by topography that slopes down from the mountain crest at an elevation
of approximately 6,050 feet above mean sea level (AMSL) toward the center of the
11-2
ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 Blue Creek Valley at an elevation of 4,250 feet AMSL. As a result, the surrounding
environment extending out to 6.2 miles (10 kilometers) from both treatment units can
be characterized as complex terrain.
GEOLOGY The ATK facility is located in the Southern Blue Creek Valley, northwest of the Salt Lake Valley, which is the eastern most structural valley of the Basin and Range
physiographic province, which includes parts of Utah, Idaho, Nevada, Arizona, and New Mexico. The Basin and Range province consists of a number of north-south aligned mountain ranges and valleys bounded by high-angle normal faults. The Blue Creek
Valley, in which ATK is located, is bounded on the east and west by the Blue Springs Hills and the Engineer and Promontory Mountain ranges, respectively. Movement along the faults has displaced the mountains upward relative to the adjacent valley. Likewise,
the mountains immediately west of ATK are bounded on their eastern margin by one or more faults which are partly buried by recent deposits.

Bedrock, composed of Middle Paleozoic shale, sandstone, and limestone, is exposed in the ranges adjacent to the site. The bedrock is highly fractured with some folding.

During the Mississippian and Permian Periods, marine sediments consisting of sand, clay, and calcareous detritus were deposited in shallow marine environments. In the late
Cretaceous Period, compressional forces from the west resulted in folding and thrust faulting in conjunction with uplift of the region into mountain ranges. Extensive jointing and fracturing of the bedrock were caused by this folding and faulting episode. Tensional
stresses in the early to middle Tertiary Period resulted in north south trending normal faults that formed a series of high linear mountain ranges with intervening basins which received sediment from adjacent highlands. This activity was associated with volcanism
and ancient lake deposition. In the late Tertiary Period, a series of geologic units tentatively identified as the Salt Lake
Group were formed from deposition of sediments in large lakes which developed within the valleys. These lake deposits are composed primarily of silts and clays with minor
amounts of sand and gravel and are characterized by low to moderate permeabilities;
extensive deposits of volcanic ash are also present in the Salt Lake Group. The alluvial fan deposits were overlapped by more recent lake sediments of Pleistocene Lake
Bonneville, the predecessor to the present Great Salt Lake. Lake Bonneville covered
much of western Utah and parts of Idaho and Nevada between about 23,000 and 12,000 years ago. Deposits associated with the lake consist of lakebed and alluvial materials
reworked by lake bottom and shoreline processes. Lake Bonneville sediments thicken southward.
The most recent sedimentary deposits consist of stream alluvium and mud and debris flows. The stream alluvium consists primarily of silty and clayey sand and gravel. The mud and debris flow deposits are characterized by a broad gradation of sediments from
clay-size fines to boulders as large as 3 feet in diameter. HYDROGEOLOGY
Ground water in Blue Creek Valley occurs under unconfined and confined conditions. These two conditions exist in fractured and faulted bedrock, lake clays and gravels,
unconsolidated alluvium, gravel, and sandy deposits. Precipitation, surface water
infiltration, and plant discharges that infiltrate into sediments may migrate slowly,
11-3
ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 vertically, and horizontally to form perched water tables above the 50- 150-foot depth of
the regional water zone. The perched ground water may eventually migrate to the deeper
regional system. The regional system ranges from 50- 600 feet in depth depending on the topographical location. Blue Creek may recharge shallow aquifers in the center of the
Blue Creek Valley. The direction of movement within the faulted and fractured bedrock will be controlled by the connection of faults and fractures. Regionally, the ground water flow trend is from north to south. Depth to groundwater at the M-136 treatment units is
an average 300 feet. Depth to groundwater at the M-225 treatment unit is 600 feet. The ground water quality in Blue Creek Valley is generally poor due to naturally
occurring chlorides and total dissolved solids. Levels of dissolved solids range from 400 to over 12,000 mg/l. The quality of ground water depends upon the sediments, which it has contacted. Quality is quite good in local, up gradient areas of water recharge, but
degrades rapidly as it moves from mountain to the valley axis. High levels of total dissolved solids in lowland areas are probably due to slow migration through Tertiary
sediments. Down gradient from the ATK sites, quality deteriorates rapidly as it enters the
mudflats of the Great Salt Lake.
CLIMATE
ATK has a 10-meter meteorological tower and instruments to measure and record air temperature, barometric pressure, relative humidity, solar radiation, precipitation, vertical
and horizontal wind speed, and direction. The ATK plant site is classified as semiarid, with an average annual total precipitation of
14.88 inches at the ATK meteorology station. During the winter months, the average total snowfall amounts to 24 inches. Precipitation typically occurs on 95 days out of the year (includes trace precipitation). During the year, it would be expected that 35 percent of the
days would be clear, 30 percent of the days would be partly cloudy, 34 percent would be cloudy, and fog would be expected to occur about 1 percent of the time. According to interpreted weather data for the ATK facility, the 25-year storm with 24-hour duration
would result in 2.4 inches of precipitation.
Evaporation rates are high throughout the year, with the Great Salt Lake averaging 66 in.
a year. The average area evapotranspiration rate is 46.6 inches. The consistently low precipitation and high evaporation allow little if any percolation into subsurface soils.

The average annual temperature in the ATK Promontory area is in the 45 to 50 degree range, with generally hot, dry summers. Relative humidity averages between 20 and 30
percent during summer afternoons. Nights are usually cool, but daytime maximums occasionally exceed 100 degrees F. On clear nights, cold air usually drains from the slopes of the adjacent ranges and accumulates on the valley floor, while the foothills and
bench areas, such as at Thiokol, remain relatively warm. The average daily temperature ranges from about 11 to 32 degrees F in January and from about 54 to 91 degrees F in July.
On an annual basis, the winds for the valley tend to prevail from the north during the earlier morning hours and south to southeast, averaging about 10 mph, during the
afternoon.

11-4
ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 Blue Creek is the only perennial stream in the valley drainage basin and is the closest
water body to the M-136 treatment unit. Blue Creek originates some 15 miles north of
the Promontory facility from a warm saline spring, which flows along the western boundary of the facility.
The Promontory area is characterized as a very sparsely populated rural region, with primarily dry farms and ranching activities. Low growing perennial grasses and shrubs
characterize the vegetation in the area. The ecological habitat found at the Promontory facility includes many head of mule deer and large populations of various birds, rabbit, and predator species.
11.2 WASTE CHARACTERIZATION
Wastes will be characterized to identify hazardous properties to ensure they are properly managed. The Waste Analysis Plan (see Attachment 1) will be used to
characterize and classify reactive wastes.

11.3 REACTIVE WASTE DESCRIPTION
The primary products produced at the facility include solid rocket motors, military and aviation flares, and high explosive/high energy compounds. Solid rocket motors are
typically cast with composite propellants. Composite propellants are classified as a
DOT 1.3 material, and typically contain a non-explosive liquid binder mixed with aluminum powder and ammonium perchlorate. Flares are generally classified as a
DOT 1.3 material, and typically contain an inert binder, a metal powder, and an oxidizer. High explosive compounds are generally classified as DOT 1.1 material and are generally nitramine compounds developed for specific military requirements.
Reactive wastes are produced from the manufacturing process include, but are not limited to the following: cured and uncured propellants; rocket motors; small initiating devices; explosives articles, propellant scrap; and explosive ingredients such as HMX,
RDX, CL-20, explosive contaminated metal powders such as aluminum and magnesium and oxidizers such as ammonium perchlorate and potassium perchlorate. The facility also contains both quality assurance and research and development
laboratories. The quality assurance laboratories generate wastes similar to manufacturing wastes. The Research and Development laboratories generate a small
quantity, but a wide variety of both explosive compounds and precursors to explosive
compounds.
Reactive wastes are characteristic hazardous wastes for reactivity (D003). Nearly all of
the reactive wastes are reactive due to the presence of propellants and explosives. Some reactive wastes, such as those from laboratory operations, may contain solvents
which would also be a listed waste defined by R315-2 of the UAC. Wastewater treatment sludge generated from the processing of explosives is a K044 listed hazardous waste. Reactive wastes also include materials such as rags, gloves, other
personal protective equipment, plastics, rubber and paper contaminated with explosive materials during the manufacturing process.
Reactive wastes may also be received from off-site sources. With one exception, off-
site wastes are rocket motors, propellants or explosives with similar formulations and ingredients to those generated on site. The exception is wastes received from Autoliv Automotive Safety Products Inc. (Autoliv) which are generally DOT Class 1.3
11-5
ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 materials containing compounds similar in nature to flare products. Ingredients include
oxidizers (e.g. ammonium nitrate, copper nitrate, potassium nitrate, strontium nitrate
and potassium perchlorate), reactive metal powders (e.g. boron, zirconium, aluminum and magnesium), nitrogen rich fuels (e.g. tetrazole or triazole compounds) and
polyacrylimide binders. Many of the Autoliv products were initially developed at Promontory when Thiokol Chemical Corporation operated the site. Autoliv and ATK are co-located, and a working relationship continues between the two companies,
which includes open burning reactive wastes generated by Autoliv that can’t be commercially disposed.
11.4 REACTIVE WASTE GENERATION AND COLLECTION ATK uses a variety of containers to store reactive wastes at the Facility. The standard
containers used at the Facility are described in this section. However, due to the nature of our business, new types of containers may be required in the future, and can’t be
described in this application. To ensure that all containers are safe to use, containers
will be selected using the DOD Contractor’s Safety Manual for Ammunition and Explosives (DOD 4145.26-M). All containers for reactive waste that are currently
used, or will be used in the future, will meet the DOD 4145.26-M requirements. Operating buildings generating reactive wastes use a variety of collection containers as
described below:
• Conductive Containers –Electrically conductive containers are typically bags
made of opaque, volume-conductive carbon-impregnated polyolefin or polypropylene. They can be grounded to prevent he build up of static electricity.
The bags are available in a variety of sizes from small containers to large than one
cubic yard. They are typically used to line other containers, but can be used without an outside container. Typical conductive containers include Velostat®
bags, Velostat® sheet material, and conductive sling bag and Super Sack® containers.
• Static Dissipative Containers –Static dissipative containers are typically bags made of a polyethylene material. The material prevents the build-up of static
electricity by continually dissipating the charge. These bags are typically used to
line other containers, but may be used without an outside container. Typical static dissipative containers include pink poly bags, pink poly sheet material and static
dissipative Cromhmiq™ sack containers.
• Fiberboard drums – Wastes may be collected directly into commercially available 30-gallon fiberboard drums. These drums have a removable lid that can be sealed in place with a locking chime after the drum is filled. Fiberboard drums selected
for this application are approved by DOT for highway transportation of hazardous materials and can be used to ship these wastes off-site for treatment and disposal.
• Sumps- Explosive contaminated wastewater is collected in sumps at the point of generation. When appropriate, propellant “chips” and other suspended solids are
filtered out before the wastewater reaches the tank, and when the wastewater is pumped out of the tanks. The wastewater is pumped into tanker trucks where it is treated at M-705 and discharged under a UPDES permit. Filters containing “chips
11-6
ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 and other suspended solids are accumulated , and treated and disposed of in
accordance with the applicable hazardous waste management rules.

• Other Containers – Large blocks of cured propellant are containerized by wrapping
the waste in plastic and placing it on wood pallets. Ammunition cans are used to hold initiating and ordnance items. Waste rocket motors are generally large
enough to be their own container. Plastic buckets are used to hold conductive and
static dissipative bags. The buckets are reused and become contaminated with reactive material. The buckets are cleaned by removing the contaminated material
using a rag. The contaminated rag is then collected for disposal and managed as
directed in UAC 315-5. If a bucket cannot be cleaned, it is managed as a hazardous waste and treated by open burning. Laboratory waste may come in a variety of
sizes and types of containers such as plastic, metal or glass. DOT containers for Class 1.1 and 1.3 reactive materials may also be used. A plastic cover secured to a tray may be used as a container for unburned residue or containers of off-site waste
stored in a tray for up to 14 days from its receipt to thermal treatment. Operating personnel accumulate reactive waste in these containers as it is generated.
When a reactive waste container is full or at the end of an operating shift, it is closed or sealed as applicable for the container. A hazardous waste label is filled out and attached to the container. Operators at the buildings that generated the waste enter
pertinent information into the electronic waste tracking system described in Section 11.5.
Most operating buildings that generate reactive waste have an explosive waste collection area located approximately 50 feet from the operating building. Except as
described below, waste containers are placed in the collection area to facilitate removal
of waste propellant, explosive and reactive wastes from the operating buildings. The collection sheds are constructed of wood or corrugated metal and are secured to a
concrete floor.
When managing reactive wastes, ATK building operators use the temporary collection
sheds as 90-day or satellite accumulation stations. Reactive wastes are placed in the collection area either as they are generated or at the end of each operating shift. Waste containers that are not full at the end of a shift are sealed, a hazardous waste label is
attached to the container and they are moved to the temporary collection area.
Containerized explosive wastes are picked up from the collection location using a
vehicle approved for the transport of explosive wastes. Extreme care is used when handling all explosive wastes. Wastes are transported directly to either the M-136 or
M-225 burning ground. Reactive wastes generated at Plant 3 are transported to M-225.
All other reactive wastes are transported directly to M-136.
Propellant and explosive operating buildings at the facility, including explosive waste
90-day storage and satellite accumulation areas, are designed and constructed in accordance with strict federal standards. These standards identify the criteria that must
be used to construct buildings where reactive material will be used and/or stored.
These standards also require that explosive buildings to be separated by sufficient distance, or a quantity-distance relationship, to prevent an explosive event in one
building from propagating to another building. Quantity-distance rules also control the
location of propellant and explosive operating buildings with regard to public property
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 (highways, parks, etc,) and private property. All buildings used for temporary storage
of waste explosives, including the temporary storage sheds, are correctly sited with
respect to the applicable quantity-distance rules.

11.5 QUANTITY DISTANCE DETERMINATION The facility uses the Department of Defense (DOD) guidance to calculate quantity
distance relationships. The evaluation was conducted according to NAVSEA OP5, Volume 1, Revision 4, Paragraph 11-3.2. The method used to determine safe quantity distance relationships for both Class 1.1 and 1.3 propellants is provided below.
The quantity distance relationship for Class 1.3 propellant is determined by the following formula: D = 5W1/3. Where W is the weight of Class 1.3 propellant and D is the safe
distance. The formula applies to Class 1.3 propellant and Class 1.3 propellant ingredients. The safe distance is defined as the interline protection for mass fire for Class 1.3
propellant.
The quantity distance relationship for Class 1.1 propellant is determined by the
following formula: D = 18W1/3. Where W is the weight of a Class 1.1 explosive and D
is the safe distance. The formula applies to Class 1.1 propellant and Class 1.1 propellant ingredients. The safe distance is defined as the unbarricaded interline protection for Class
1.1 propellant.

11.6 WASTE TRACKING ATK maintains an electronic waste tracking record to collect and manage information about reactive wastes generated at the facility. This tracking system uses a
combination of paper records and an electronic database.
Wastes being accumulated in containers at operating areas within the facility are
labeled and managed in accordance with R315-5 of the UAC for either a satellite accumulation or less than 90-day hazardous waste storage area. The electronic tracking system maintains the following information to monitor cradle to grave waste handling
practices:
• ID# - container identification number
• Date – accumulation date
• Building # - identifies where the waste was generated;
• RWDI# - identifies the reactive waste disposal instruction
• Profile # - identifies the profile
• Quantity of PEP – quantity of propellant, explosive or pyrotechnic material ;
• Quantity of Contaminated waste - Explosive and total weight of the container;
• Material Description – description of the material
• Propellant name – describes the propellant by type, program other identifier
• Log Date – date logged into the system
The electronic tracking system maintains information on all containers of reactive
waste in 90- day storage at M-136 and M-225. It also tracks the total weight of waste placed on each burn tray, and the total weight of waste burned on any given day.

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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 In the event reactive waste is shipped off-site for treatment, the system maintains the
following information: the manifest number, transporters, manifest ship date, and
manifest return date.
In the event the electronic tracking system is not operable, the information will be tracked using paper copies until the electronic system is operable. In the event this occurs, ATK will transfer all information to the electronic system within 72 hours of
the system becoming operational again.
11.7 REACTIVE WASTE STORAGE ATK may store hazardous wastes prior to disposal. Solid reactive wastes are stored in designated facilities as described in this section, and are segregated according to
compatibility requirements.

• M-629 - This building can be used to store any of the explosive wastes listed in Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be provided to permit proper container inspection. All containers will be labeled and managed in accordance with R315-5 of the UAC. This building is equipped with a
fire sprinkler system, which is checked annually. Employees are not permitted to fight fires inside an explosive storage building. This building is totally enclosed, so
there are no precipitation run-on or run-off concerns.

• M136- trays at M-136 can be used to store waste received from off-site for up to 14
days. All containers of waste must be closed, labeled and managed in accordance with R315-5 of the UAC.

• S-633- This storage pad can be used to store any of the explosive wastes listed in
Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be provided to permit proper container inspection. S-633 is approximately 100’ x 100’
in size. It is secured by a perimeter fence, a vehicle access gate that can be locked,
and has the appropriate warning signs for a storage area. It has a road base surface, and has lighting protection. All waste containers will be labeled, and managed in
accordance with R315-5 of the UAC. This area does not have water immediately
available, and relies on the Fire Department for any emergency action. Employees are not permitted to fight fires inside a reactive waste storage area. Precipitation run-
on or run-off is prevented by a combination of diversion ditches, collection ditches
and trenches.
11.8 TREATMENT OF REACTIVE WASTE The facility utilizes thermal treatment methods to safely dispose reactive hazardous
wastes. Thermal treatment methods include both open burning and open detonation. Reactive hazard wastes may also be shipped off-site and treated at other permitted treatment storage and disposal facilities.

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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 11.8.1 OFF-SITE TREATMENT OF REACTIVE WASTE All hazardous reactive wastes treated off-site will comply with all applicable local,
State and Federal regulations.

11.8.2 ON-SITE TREATMENT The M-136 and M-225 facilities are thermal treatment units designed to treat reactive
hazardous wastes using open burning or open detonation. Treatment by open burning at M-136 is limited to a maximum of 106,500 pounds per day. Each burn station 1-12 and 14 may treat all or a portion of the 106,500 pounds. Burn station 13 can treat a
maximum of 50,000 pounds per day. Treatment by open detonation will be conducted at burn stations 13 and 14 only, and is limited to 600 pounds per event. Figure 11-2 shows the security fence, control bunker, and vehicle access points for M-136.
Treatment by open burning at M-225 is limited to a maximum of 4,500 pounds per day.
Each burn station 1-4 may burn all or a portion of the 4,500 pound limit. Treatment by
open detonation is limited to the 600 pounds per day in the M-225 open detonation area. Figure 11-2 shows the security fence and vehicle access points for M-225.

The process flow for open burning at both treatment areas is identified below:
1. Pre-planned Activities 2. Placement of Waste in Treatment Units, Wiring and Ignition 3. Post-burn Inspection and Cleanup
The following precautions are used to ensure operator safety while working at the M-136 and M-225 burn grounds:
1. Emergency egress routes are always maintained while employees are working in the treatment areas.
2. The firing systems are disabled using an interlock to prevent accidental ignition. 3. Weather conditions are monitored to assure operators are not exposed to risks from
lightning strikes.
11.8.2.1 PRE- PLACEMENT ACTIVITIES OBOD operations at the facility are a continuous process. Wastes are transported from
the generation areas and brought into the treatment areas on a daily basis. Wastes are off-loaded and placed in trays and managed under 90-day rules until treatment occurs.
When treatment is completed, the trays are cleaned, inspected and the loading process begins again. Pre-placement inspections occur during the post-burn inspection and clean-up phase of the treatment process.
Prior to placing reactive waste for treatment at the OBOD facilities, operators visually verify the following tasks were completed during post-burn inspection and cleanup
activity: 1. Any untreated waste and/or unburned residue has been identified, collected and is
being properly managed; 2. Storm water accumulated in the trays has been removed.
3. Trays which do not meet the inspection criteria have been removed from service.

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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015
11.8.2.2 PLACEMENT OF WASTE IN TREATMENT UNITS
Reactive hazardous waste is transported to the OBOD facilities using a vehicle which meets explosive safety requirements. Reactive hazardous waste may be offloaded by
hand or mechanical means including a knuckle boom, forklift, crane, or other appropriate equipment. Reactive hazardous waste is not collected, transported, or unloaded during a lighting warning, which is defined as lightning within 30 miles of
the facility. If collection, transportation, or unloading operation has started, the operation is brought to a safe halt.
Treatment units used to treat and contain waste are listed below but are not limited to, the following:
• Burn Trays – Metal trays constructed in several different sizes including, 4’X10’, 5’X16’, 8’X8’, and 8’X20’. Typical construction is out of steel plate A36 grade
steel ranging thicknesses of 3/8”, ½”, ¾”, and 1 inch.
• Clamshell Disposal Trays– Used for the disposal of items that have the potential
to be propulsive. Typical construction is a square welded box 1-inch thick, A36 steel plate with a vented lid that enables treatment of potentially propulsive items,
while safely containing the propulsive energy.
• Restraining Trays are typically constructed of 1-inch thick A36 steel plate welded into a square box that is filled with sand. There are several different designs for restraining trays which include: (1) steel tubes sitting on end in the sand
are used to hold potentially propulsive items which are secured to the tube allowing
the exhaust to vent out of the open end of the steel tubes, and (2) used without steel tubes where propulsive items are secured at the base for items where the exhaust
will vent from the side of the item.
• Small Motor Disposal Vaults– Constructed from a concrete 10x10 foot sump filled with sand. Small rocket motors such are placed into the sand with the aft end exposed perpendicular to the ground. Motors are treated with the propulsive force
directed into the concrete sump and the sand. The vehicle containing hazardous waste is to be parked near the receiving tray with any
side rails lowered to facilitate offloading of the waste. Containers are transferred directly from the truck and carefully placed into the burn tray. Items to be open detonated are offloaded from the vehicle by hand, knuckle boom, or by forklift and
then placed on the ground for treatment
Items that have the potential to be propulsive are off-loaded into the clamshell,
sandbox, or small motor disposal vault by hand, knuckle boom, or by forklift. After offloading, items are restrained using engineered restraints allowing for safe treatment.
Potentially propulsive items (e.g. rocket motors) may also be off-loaded into station 14
using the knuckle boom, forklift, or crane. The case may be placed on the ground, sand/dirt mounds, chocks, or other support media for treatment.
PEP waste which generates ash or residue which is listed or characteristic is segregated from PEP waste which generates non-regulated ash. Ash and residue is managed as
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 described in 11.8.2.5.

11.8.2.3 WIRING AND IGNITION After waste has been placed on a tray, the next step is to complete a resistance check on the ignition system. As a safety precaution, a physical interlock (e.g. key) is used to prevent the firing panel from being accidently engaged during the resistance check.
The key remains in under the control of the operators during the resistance check and all subsequent operations until the operators return to the control bunker to complete treatment. Each firing stanchion must have 10 ohms or less. A firing stanchion that
has a resistance of 10 ohms or greater must be tagged out until repairs are made. Once the resistance check is completed igniter installation is performed. The igniter is
attached to the firing system by connecting the lead wire from the initiating device to the firing stanchion. Igniter installation operations are performed by a minimum of two
operators. The types of igniters commonly used are listed below:
1. Burn Grounds Igniter –Propellant with a hot wire
2. Bag Igniters – Propellant, explosive, pyrotechnic with electric match or other
electric initiation device. 3. Blasting Caps – Small amount of primary explosive
4. Electric Matches – wire attached to small explosive device 5. Fuse – a tube, cord, or the like, filled or saturated with combustible matter 6. EBW – Exploding Bridge Wire, a wire that contacts explosives fired by a high
voltage electricity source 7. TBI – Through Bulkhead Initiator, shock initiation of an energetic material provided through an integral barrier
Linear shaped charge may also be used to facilitate thermal treatment of potentially propulsive wastes and items contaminated with reactive hazardous wastes.
Reactive hazardous wastes may be desensitized by adding one of the liquids listed
below. The addition of these liquids modifies the reactive nature of the waste making it
safer to store, handle and transport. It also slows the burning rate of the material during treatment.

1. Oils 2. Water
3. Alcohol 4. Triacetin 5. Physical Media (e.g. Conductive and static dissipative packaging)
When necessary, additional burn enhancers may be used to promote a more complete burn. Additives include, but are not limited to, the following:
1. Diesel Fuel 2. Wood (e.g. Pallets)
3. Propellant
The burning ground operators verify the treatment area has been evacuated of all
personnel before proceeding with ignition. The burning ground operators retreat to the
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 control bunker and close the door. The lockout key is inserted into the control system
which allows power to the firing panel. Circuit continuity is checked at the firing panel
which verifies that igniters were properly installed. A flashing red light is activated once the firing system is operational to alert personnel inside the area that a treatment
operation is about to begin. The appropriate stanchion is chosen and the igniter fired by pressing the ignition buttons. Two operators are required for this operation.
In the event of a misfire, operators must wait a minimum period before reentering the treatment area to correct the problem. If a misfire occurs on the first tray, being burned the process stops, and personnel are required to stay in the bunker for at least 30
minutes. After 30 minutes, the igniter which failed is uninstalled. This process requires two employees and is done by: (1) the two employees performing the task remove the physical interlock and keep it in their possession, (2) the igniter wires are
removed from the stanchion where the misfire occurred then twisted together to short the circuit. The igniter is not physically removed from its position. A new igniter is
installed, and the operators return to the control bunker and repeat the process.
If a misfire occurs and it is not the first tray in the burn sequence, the operators return
after 16 hours and repeat the process described above.
The Box Elder County Dispatch is notified prior to each treatment. This notification
can be made by telephone, fax or email, and may be made immediately prior to ignition or an undefined number of hours prior to igniting the waste. Notification must be made the same day as the waste is treated.
11.8.2.4 POST-BURN INSPECTION AND CLEANUP
Following a treatment event, the area where the burn or detonation occurred cannot be re-entered for at least 16 hours after completion of the event without specific approval from ATK management. A preliminary inspection is performed before the cleanup
begins. This inspection includes checking for hot spots and checking for unburned reactive hazardous waste. Hot spots include visual indications of hot material (flame,
smoke, high temperature). If these conditions exist, post-burn clean is postponed until
the hot spots are gone.
All residues remaining on the burn trays are visually inspected to determine if there is
any unburned reactive material. Unburned reactive material will be reburned.
Depending on the nature of the material that did not burn, donor material or burn enhancers such as diesel or wood may be used to ensure the material will completely
burn. Unburned waste ejected from the tray will be collected and placed on a burn tray, and treated in the same manner.
Small amounts of untreated residue will be considered as newly generated waste and
will be tracked as such in the tracking system. A small amount is defined as less than or equal to 5% of the total volume placed on the tray or treatment area. The primary option for managing this waste is to burn it by 6pm the following calendar day. If
untreated residue cannot be treated by 6pm the following calendar day then it will be managed in accordance with R315-5 of the UAC.
Unburned waste that results from a misfire or an interrupted ignition can remain on a
burn tray. An interrupted ignition occurs when anything greater than 5% of the waste
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 on the tray fails to ignite. In this situation, the waste is considered unreacted waste
instead of newly generated residue. ATK will attempt to reburn the waste by 6 pm of
the following calendar day. If unforeseen circumstances prevent the burn from occurring by 6pm of the following day, the waste will be covered and the burn tray will
be labeled and managed as a 90-day storage area in accordance with the requirements of R315-5 of the UAC. The cumulative storage time for the waste both in storage prior to burning and on the burn tray may not exceed 90-days. If it is necessary to storage
this waste for greater than 90-days, an emergency permit would be requested.
Typically, the post-burn and cleanup activities described in this section will be conducted the next calendar day following treatment. The clean process begins after
the preliminary inspection is completed. Cleaning is accomplished using a variety of tools and equipment such as rakes, shovels, a forklift and a tractor. Ash is classified for disposal as described in 11.8.2.5. The majority of the waste treated is classified as
EPA waste number D003 reactive only. The ash resulting from treating D003 reactive waste is collected, and transported to the on-site landfill where it is disposed.
Ash classified as hazardous is collected and managed in accordance with the
requirements of R315-5 of the UAC. Ash resulting from the treatment of K044 is collected and disposed in the on-site landfill. After the tray is cleaned, it is inspected
for holes, weld cracks, and 6 inches of wall height. If a tray fails the inspection criteria,
it is removed from service. These inspections are maintained onsite in the operating record. In the event a tray is not going to be used for an extended period, it is stored in
a manner to prevent stormwater accumulation (e.g. stored upside down or with a lid). If accumulated liquid is present in a burn tray it is removed and delivered for treatment at a UPDES permitted facility.
11.8.2.5 Ash Classification A waste assessment is conducted prior to receiving waste for treatment. The waste assessment is made using generator knowledge of the production process, the raw
materials used to produce the material, and the chemical composition of the materials. If the assessment identifies that, at the point of generation, the waste meets any of the following three criteria, all ash from the initial treatment is collected, and the ash is
sampled and analyzed using the protocol described in Attachment 1.
1. It could potentially contain 40 CFR 261.31 listed constituents.
2. It could potentially contain toxicity characteristic constituents above the 40 CFR 261.24 regulatory level.
3. It could potentially contain underlying hazardous constituents above the 40
CFR 268.48 treatment standards.
Based on the analytical results, the ash is managed using the logic in Attachment 1 Figure 3-2. All ash classified as hazardous based on the above criteria is managed in accordance with the requirements of R315-5 of the UAC.
11.9 RECEIVING HAZARDOUS WASTE FROM OFF-SITE ATK periodically receives reactive hazardous waste from off-site sources. All
hazardous waste received from an off-site source will be managed at one of the permitted storage units. All off-site generated hazardous waste will be reviewed and approved prior to being accepted using the following criteria:
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015
• EPA hazardous waste number(s);
• Physical description;
• Chemical description;
• Source of the waste;
• Sampling frequency;
• Parameter for analysis;
• Handling code;
• Tracking system number;
• DOT shipping description; and
• Safe handling instructions
Upon receipt, all off-site generated hazardous waste will be visually inspected to ensure
that it meets the acceptance criteria, the manifest is correct, and the containers are labeled, closed, in good condition and compatible with the waste. All deficiencies will
be resolved with the generator before the waste is received. After the waste has been
accepted, it will be managed using the tracking systems described in Sections 11.6.

11.10 ENVIRONMENTAL PERFORMANCE STANDARDS 40 CFR 264.600 contains requirements for treatment, storage and disposal facilities to
meet environmental performance standards to ensure operations are conducted in a manner that ensures protection of human health and the environment. The follow areas of concern have been or are in the process of being addressed to ensure compliance
with the performance standard requirements.
Prevention of Releases Due to Migration of Waste Constituents in the Ground Water or the Subsurface Environment - this standard requires actions to prevent releases that may have adverse effects on human health or the environment due to
migration of waste constituents in the ground water or subsurface environment. Topics
that must be considered are:
• The volume and physical and chemical characteristics of the waste in the unit, including its potential for migration through soil, liners, or other containing
structures;
• The hydrologic and geologic characteristics of the unit and the surrounding area;
• The existing quality of ground water, including other sources of contamination and their cumulative impact on the ground water;
• The quantity and direction of ground-water flow;
• The proximity to and withdrawal rates of current and potential ground-water users;
• The patterns of land use in the region;
• The potential for deposition or migration of waste constituents into subsurface
physical structures, and into the root zone of food-chain crops and other vegetation;
• The potential for health risks caused by human exposure to waste constituents; and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and physical structures caused by exposure to waste constituents;
Prevention of Releases Due to Migration of Waste Constituents in Surface Water, Wetlands or on the Soil Surface -This standard requires actions to prevent releases
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 that may have adverse effects on human health or the environment due to migration of
waste constituents in surface water, or wetlands or on the soil surface. Topics that must
be considered are:
• The volume and physical and chemical characteristics of the waste in the unit;
• The effectiveness and reliability of containing, confining, and collecting systems
and structures in preventing migration;
• The hydrologic characteristics of the unit and the surrounding area, including the topography of the land around the unit;
• The patterns of precipitation in the region;
• The quantity, quality, and direction of ground-water flow;
• The proximity of the unit to surface waters;
• The current and potential uses of nearby surface waters and any water quality
standards established for those surface waters;
• The existing quality of surface waters and surface soils, including other sources
of contamination and their cumulative impact on surface waters and surface soils;
• The patterns of land use in the region;
• The potential for health risks caused by human exposure to waste constituents;
and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents.
Prevention of Releases Due to Migration of Waste Constituents in the Air - this standard requires actions to prevent releases that may have adverse effects on human
health or the environment due to migration of waste constituents in the air. Topics that
must be considered are:
• The volume and physical and chemical characteristics of the waste in the
unit, including its potential for the emission and dispersal of gases, aerosols and particulates;
• The effectiveness and reliability of systems and structures to reduce or prevent emissions of hazardous constituents to the air;
• The operating characteristics of the unit;
• The atmospheric, meteorologic, and topographic characteristics of the unit
and the surrounding area;
• The existing quality of the air, including other sources of contamination and
their cumulative impact on the air;
• The potential for health risks caused by human exposure to waste
constituents; and
• The potential for damage to domestic animals, wildlife, crops, vegetation,
and physical structures caused by exposure to waste constituents.

11.10.1 Compliance With Environmental Performance Standard Requirements All of these factors have been and will continue to be evaluated until closure of the
facility to ensure waste treatment methods are conservative and will not adversely affect human health or the environment. Control measures include, but are not limited to the
following:
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 Human Health Risk Assessment - a Human Health Risk Assessment (HHRA) is being
conducted to evaluate the risk to the public from open burning and open detonation
operations at the facility. Tasks associated with the HHRA include developing an air dispersion model, evaluating sources, source parameters, and waste materials, and
characterizing emissions. The HHRA will address the following environmental performance related concerns:
 The volume and physical and chemical characteristics of the waste in the unit,
including its potential for the emission and dispersal of gases, aerosols and particulates;
 The effectiveness and reliability of systems and structures to reduce or prevent
emissions of hazardous constituents to the air;
 The operating characteristics of the unit;
 The atmospheric, meterologic, and topographic characteristics of the unit and the
surrounding area; and
 The potential for health risks caused by human exposure to waste constituents.
The methods used in the HHRA are based on United States Environmental Protection
Agency (U.S. EPA) risk assessment guidance documents, and to the extent possible, the dispersion modeling methodology within the Human Health Risk Assessment Protocol
(HHRAP) for Hazardous Waste Combustion Facilities (U.S. EPA, September 2005). The
completed HHRA Protocol and Report will be reviewed by the Utah Division of Solid and Hazardous Waste. Limits on OBOD operations will be based on this assessment, as
appropriate, once approval of the HHRA Report is given by the Director of the Utah
Solid and Hazardous Waste Control Board.
Ecological Risk assessment – an Ecological Risk Assessment (ERA) will be conducted to determine potential risks to ecological receptors that may be affected by OBOD operations. It will evaluate the potential for damage to domestic animals, wildlife, crops,
vegetation, and physical structures. The completed ERA will be submitted to the Utah Division of Solid and Hazardous Waste for review. Limits on the OBOD operations will be based on this assessment, as appropriate, once approval of the ERA Report is given by
the Director of the Utah Solid and Hazardous Waste Control Board.
Soil Monitoring Plan – a Soil Monitoring Plan (SMP) will be developed to verify the
air dispersion and deposition models that were developed for the HHRA. The SMP will
be used to evaluate the existing quality of surface waters and surface soils, and to determine what impact continued operations at the thermal treatment areas has on surface
soil and surface water quality. Risks to human health and the environment will be
evaluated using the data collected during implementation of the SMP.
Groundwater Monitoring Plan – a groundwater monitoring program has been in place
at the facility since 1986 to monitor contaminants that were released from past disposal
practices. The sampling methods, constituents of concern, sampling frequency, sampling results and analytical methods are closely reviewed and monitored by the DSHW.
The groundwater monitoring program addresses the following concerns:
• The hydrologic and geologic characteristics of the unit and the surrounding area
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015
• The existing quality of groundwater, including other sources of contamination and
their cumulative impact on the groundwater;
• The quantity and direction of groundwater flow; and
• The proximity to and withdrawal rates of current and potential groundwater users.
A Groundwater Monitoring Plan will be developed to evaluate the impact of thermal
treatment operations on groundwater down gradient of the M-136 and M-225 Thermal Treatment Areas. The plan will identify analytes, sampling protocols and data quality
objectives. In addition, the plan will propose a statistical method for determining if existing groundwater contamination concentrations increase due to ongoing thermal treatment operations.
Annual Review of Limits – the operating permit requires ATK to conduct an annual review of emission factors established by the HHRA, the reference doses for selected health effects, and to review the potential health risk scenarios to assure that the scenarios
have not changed. An annual accounting of the types and quantities of reactive waste treated is also required.
Stormwater Management – Stormwater run-on and run-off is controlled by a
combination of soil grading and drainage ditches. The terrain around M-136 and M-225 has been graded and drainage ditches surround the areas in order to minimize stormwater
run-on and run-off. The topography is shown in Attachment 6, Figures F-1 and I-1.
Stormwater collection and drainage is shown in Attach 11 Figure 11-1 and Figure 11-2. The combination of controlling run-on and run-off, containing waste in water-tight burn
trays, lack of precipitation, high evaporation rate and depth to groundwater prevents waste constituents from being released to the groundwater and or subsurface environment. Ongoing soil and groundwater monitoring are used to verify these controls
are effective in preventing adverse effects to human health and the environment.
Actions to Prevent Releases to the Environment – all spills of hazardous materials are promptly cleaned up. Internal procedures require that chemicals be properly
containerized, labeled, stored, used and disposed. The workplace is routinely audited to ensure compliance with procedures. When spills do occur, the released material is
promptly cleaned up and R315 reporting requirements are followed.
Open Burning is Conducted in Steel Containers – Open burning is conducted in containers which minimizes the potential for waste constituents to migrate to the ground
water, surface water or related environments. The Operating Permit requires routine
inspections to ensure the containers are properly maintained. Containers requiring repair are removed from service until repairs are completed.
Ash Management – ash and residue from OBOD operations are promptly collected and
disposed. Ash is managed and classified as described in sections 8.2.4, and 8.2.5 of this attachment.
Storage and Inspections – All PEP and residues from OBOD treatment are stored in
accordance with Section 4 of this attachment and R315-5 Hazardous Waste Generator Requirements. Storage and treatment areas are inspected as required by Attachment 2,
and operated in accordance with Attachment 9 of this permit.
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ATK Launch Systems Part B Operational Plan Promontory Facility Process Information UTD 009081357 November 2015 Regulatory Oversight- the facility is subject to strict regulatory oversight by the Utah
Division of Solid and Hazardous Waste. All aspects of hazardous waste management
described in this Attachment are subject to their review. When necessary, deficiencies are identified and corrective action is taken by the permittee.

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