DSHW-2016-007094 - 0901a06880610ae1

Div of Waste Management
and Radiation Control
February 29,2015
8200-CY16-059
MAR«20t6 Orbital ATK fy
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Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc. EPA ID number UTD009081357
Annual Report of the Promontory Thermal Treatment Areas Operation Hazardous Waste
Storage Permit Module II.G.3
Dear Mr. Anderson:
Attached is the 2015 Annual Report for the operation of the ATK Launch Systems Inc. (“ATK”)
Promontory Facility Thermal Treatment Areas as required by Hazardous Waste Storage Permit
Module II Condition G.3.
Please contact Blair Palmer at [phone] or myself at [phone], if you have any
questions concerning this report.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility offine and imprisonment for knowing violations.
Sincerely,
Manager, Environmental Services
ATK Launch Systems Inc.
cc: JeffVandel
Orbital ATK, Inc. • 9160 N. Hwy 83, Promontory, UT 84307 • 435-863-3511
ATK Launch Systems Inc.-Promontory 2015 Annual Report of the Promontory
Thermal Treatment Areas Operation
Module II Condition G.3.a: requires an accounting of the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas.
Response: Table 1 and Table 2 shown below report the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 Thermal Treatment Areas in 2015. The
total treated amounts treated in 2015 were 648,111 pounds at M-136 and 7,947 pounds at
M-225.
Table 1: 2015 M-136 Thermal Treatment Totals
Propellant Class Percent of Total Reactivity Group Hazardous Waste
Treated (lb)
1.3 40%240,763
B 12,742
5,350
0
1.1 56%354,071
D 11,972
(1.3) Flare 4%E 23,213
Table 2: 2015 M-225 Thermal Treatment Totals
Propellant Class Percent of Total Reactivity Group Hazardous Waste
Treated (lb)
1.3 34%2692
B 23
0
1.1 65%3,289
D 1,876
(1.3) Flare 1%E 67
Module II Condition G.3.b: requires an estimated quantity of TCDD TEQs, or other
compounds as identified in accordance with Condition H.G.2., released annually. The
quantity shall be calculated based on emission rates to be determined through approval of
the air dispersion model.
Response: A draft human health risk assessment report has been submitted to the Utah
Division of Waste Management and Radiation Control (“UDWMRC”); however it has
not been approved at this time. The estimated quantity of TCDD-TEQ released, based on
the total amounts treated in 2015, as reported above in Module II Condition G.3.a, were
1.47xl0'3 pounds, or 700 milligrams from M-136, and 5.21xl0'5 pounds, or 2.4
milligrams from M-225. These estimates assume dioxins are present even if they were
not detected in the initial emissions tests.
The draft human health risk assessment assumes that a maximum quantity of 10.6 million
pounds of material will be processed at M-136 on an annual basis using approved
emissions factors developed in conjunction the UDWMRC. The UDWMRC approved
air dispersion modeling report provided emissions rates that were used in the risk
assessment model and gave risks lower than the UDWMRC acceptable risk thresholds of
one in one million and hazard indices less than one. The amounts of TCDD-TEQ above
were calculated by interpolating the allowable annual amount used in the risk assessment
model by the actual amounts processed in 2015 that are reported in Module II Condition
G.3.a, above.
Module II Condition G.3.c: requires an evaluation of the emission factors, identified in
Condition II.G.l .a, used in the human health risk assessment to determine whether these
factors are representative of the wastes treated and identified as directed by II.G.3.a, or if
the emission factors need to be updated.
Response: ATK considers the emission factors contained in the draft human health risk
assessment report to be representative of the wastes treated at the M-136 and M-225
Thermal Treatment Areas.
Module II Condition G.3.d: requires a review of the human health risk assessment,
identified in Condition II.G.l .g., to evaluate whether the slope factors and reference dose
for carcinogenic and non-carcinogenic health effects related to chlorinated dioxin,
chlorinated furan and semi-volatile compounds have changed, and a review of the
potential human health risk scenarios that were evaluated in the risk assessment to assure
that these scenarios have not changed.
Response: A draft human health risk assessment report has been submitted to the
UDWMRC; however it has not been approved at this time. Prior to submission of the risk
assessment report in December 2014, the toxicological dose-response factors for all of
the chemicals of potential concern in the risk assessment were evaluated and revised to
the current US EPA’s IRIS database, and the US EPA’s Provisional Peer Reviewed
Toxicity Values. The does-response values for the chemicals responsible for the majority
of the risks were evaluated again in January 2016, and it was determined that they had
not changed. Therefore, at this time, it is assumed that no changes to the dose-response
factors have occurred.