DSHW-2016-009084 - 0901a06880625e90

April 20,2016
LITD 00^00(357
DSHW-Z0\6- 00^004-
Orbital ATKJ)
Div of Waste Management
and Radiation Control
APR 2 0 2016
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: Emergency Permit Request - Open Bum Section of C-4 Second Stage Rocket Motor
Dear Mr. Anderson:
ATK Launch Systems periodically cuts up intact rocket motors to obtain interior propellant
samples. Such samples are tested to determine how the propellant is aging. As directed by the
U.S. Navy, a C-4 second stage rocket motor was cut up for this purpose in CY 2004. A
remaining piece from this motor is no longer required by the Navy and is scheduled for disposal.
This piece is from the aft dome area of the motor and contains 1,320 pounds of Class 1.1
propellant.
This propellant chunk would normally be sent to the ATK Launch Systems Promontory facility
for disposal. During motor cut up, this chunk of propellant was exposed to significant amounts
of water used to cool the cutting process. Over time this exposure to water has changed the
physical properties of the propellant and it is now significantly more sensitive to friction
initiation than nominal propellant. Rather than subject this motor chunk to additional cutting or
transportation on public highways, it is believed that the safest and quickest method for disposal
of this item is at the NIROP Burning Grounds.
The Subpart X Treatment Permit for the NIROP Burning Grounds (the Permit) limits the amount
of waste that can be placed on a bum pan to 500 pounds (Permit condition IV.C.l .b.). There is
one exception in Permit condition IV.C.l .d. allowing large blocks of propellant greater than 500
pounds to be placed on a bum pan. This permit condition, however, is limited to propellant
blocks removed from a motor in the initial manufacturing process and are known as casting
necks, donuts or slugs. This exception would not apply to the C-4 second stage dome.
ATK Launch Systems is therefore requesting an emergency permit to bum this section of rocket
motor at the NIROP Burning Grounds. Specifically, an emergency permit is necessary to exceed
the pan limit of 500 pounds specified in Permit condition IV.C.l .b. The total weight of the item
including the weight of its wood pallet and other wooden supports will be less than 2,000
pounds. This would be the only item burned on this day. Note that this is less than the daily
Burning Grounds limit of 4,500 pounds as specified in Permit condition IV.C.l.a. All other
applicable Permit conditions would be in effect.
Orbital ATK. Inc. • P.O. Box 98 Magna, UT 84044-0098
Internal Safety review has determined that the C-4 second stage aft dome can safely be burned at
the NIROP Burning Grounds and such burning will comply with quantity distance requirements
identified in Permit condition IV.C.l.e. Please contact Chris Falkenberg of my staff at (801)
251-5313 with any further questions on this issue.
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 of fine and imprisonment for knowing violations.
Sincerely,
George Gooch
Manager, Environmental Services
Orbital ATK, Inc. • P.O. Box 98 Magna, UT 84044-0098