DSHW-2016-011678 - 0901a06880652bfa

Orbital AT
Div of W ... lagement
and Radiation Control
July 26, 2016
8200-CY16-075
JUL 2 6 2016
DSHW-Zoi&-otl4>7£>
Mr. Scott T. Anderson, Executive Secretary
State of Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 N. 1950 W.
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
Class 2 Permit Modification Request
Dear Mr. Anderson:
As required by ATK Launch Systems, Inc. (ATK) Hazardous Waste Storage and Treatment
Permit, condition IV.M.3, ATK is requesting a class 2 permit modification to implement permit
conditions and associated language as a result of the completion of the Human Health Risk
Assessment (HHRA) for the Open Burning and Open Detonation Treatment Units at the
Promontory Facility. Enclosed are the modified sections of the permit in a red-line/strike-out
Please contact me if you have any questions concerning this report. My telephone number is
[phone] or you can contact Blair Palmer at [phone].
Sincerely
George E. Gooch, Manager
Environmental Compliance
cc: Jeff Vandel
format.
Orbital ATK, Inc.9160 N. Hwy 83, Promontory, UT 84307 • 435-863-3511
ATK Iaunch Systerns Inc. - Promontory
Module tr - General Facility Conditions
Modifi ed+ebruaryJuly, 20 165
1rTD009081357
II.A.
II.A.1.
II.B.
II.B.1.
MODULE II. GENERAL FACILITY CONDITIONS
APPLICABILITY
The requirements of this permit module pertain to allHazardous Waste Management
Units (HWMUs) identified within Modules I, II, III, IV and V.
DESIGN AND OPERATION OF FACILITY
The Permittee shall design, construct, maintain and operate all of the HWMUs and
surrounding areas to minimize the possibility of a fire, explosion, or any sudden or non-
sudden release of hazardous waste or hazardous waste constituents to the air, soil,
groundwater or surface water which could threaten human health or the environment.
Any construction changes associated with a permitted HWMU at the facility shall be
documented by as-built drawings and certified by a registered professional engineer in
accordance with Condition I.R.l. and UAC R315-3-3.1(l)(2)(i).
After review of the as-built drawings and field verification of the facility's HWMUs, the
Director will notify the Permittee in writing of any change which he concludes does not
satisfu the operating requirements specified in this permit.
REOUIRED NOTICE
As required by UAC R315-8-2.3(aXl), the Permittee shall notify the Director in writing
at least four weeks in advance of the date the Permittee expects to receive hazardous
waste from a foreign source. Notice of subsequent shipments of the same waste from
the same foreign source in the same calendar year is not required.
When the Permittee arranges to receive hazardous waste from an off-site source (except
where the Permittee is also the generator), the Permittee shall inform the generator in
writing that he has the appropriate permit(s) for, and will accept, the waste the generator
is shipping. The Permittee shall keep a copy of this written notice as part of the
operating record as required by UAC R315-8-2.3(b).
WASTE ANALYSIS PLAN
The Permittee shall follow the procedures of the Waste Analysis Plan included as
Attachment I of this Permit. ln addition, the Permittee shall comply with any other
conditions involving waste analysis in Modules I, II, III, IV and V.
The Permittee shall use the test methods described in the Waste Analysis Plan
(Attachment 1) or an equivalent procedure that satisfies Condition I.O.3. Changes in a
test method described in the Waste Analysis Plan, as a result of an improvement or
refinement of that method, maybe adopted by the Permittee and incorporated into this
Permit, in accordance with UAC R315 -4-1.5 and Condition I.D.
The Permittee shall characteize, using analytical techniques if necessary, all waste
streams generated on or off-site in accordance with UAC R315-8-2.4 and Attachment 1.
II.c.
[.c.1.
II.B.2.
II.B.3.
l.c.2.
II.D.
II.D.1.
\.D.2.
II.D.3.
ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.D.4.
II.D.5.
II.D.6.
II.D.6.a.
II.D.6.b.
II.D.6.c.
II.D.7.
II.D.8.
Modifi ed+ebruaryluly, 20 l[5
1rTD0090813s7
The waste charucteization profiles shall be kept in the operating record.
An annual evaluation of each waste stream shall be performed, as outlined in the waste
analysis plan, to verify that the waste characterization is still accurate. These
evaluations shall be kept in the operating record until the next annual evaluations are
completed. Characteization of waste streams shall also be done each time the process
generating the waste changes.
Any waste analysis used to evaluate off-site waste for acceptance by the Permittee shall
be accomplished using a laboratory that has been certified by the Utah State Division of
Laboratories.
At aminimum, the Permittee shall:
Maintain properly functioning sampling and analytical equipment;
Use approved sampling and analytical methods; and
Submit an updated list of parameters, analytical methods, and sample preparation
methods on an annual basis. The updated list shall be submitted to the Director on or
before January 15tr ofeach calendai year.
Whenever the Director determines that the Permittee needs to update the analytical
methodologies or the version(s) of SW-8 46 tl'Lat are being used by the Permittee's
analytical laboratory, the Director will submit written notification to the Permittee. The
Permittee shall notifu the Utah Department of Health, Bureau of Laboratory
Improvement of the requested update within 30 days of receipt of the Director's
determination. The Permittee shall have 180 days from the receipt of the Director's
written notification to complete the requested update. If it is not possible to complete
the update within the prescribed time, the Permittee shall submit a written request for
extension to the Director for approval.
If the Permittee uses a contract laboratory to perform analyses, the laboratory must be
certified by the State of Utah to perform the contracted analyses. For parameters for
which certification is unavailable, the Permittee shall ensure that quality control/quality
assurance data provided by the laboratory is sufficient to assess the validity of the data.
The Permittee shall inform the laboratory in writing that it must operate under the
Waste Analysis Plan conditions set forth in this Permit.
SECURITY
The Permittee shall comply with the security conditions and procedures contained in
Attachment 7 of this Permit.
GENERAL INSPECTION REOUIREMENTS
The Permittee shall conduct inspections in accordance with UAC R315-8-2.6 and shall
follow the inspection schedule found in Attachment2.
The Permittee shall remedy any deterioration or malfunction as required by UAC R315-
8-2.6(c). If the remedy requires more than 72 hours to implernent from the time that the
II.E
II.E.1.
II.F.
II.F.1.
It.F.2.
ATK launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.F.3.
II.F.4.
II.F.5.
II.G.
II.G.1.
II.G.1.a.
II.G.1.b.
II.G.1.c.
II.G.1.d.
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rr.G.1.f.
II.G.1.g.
II.G.2.
Modified+ebruaryJuly, 20 165
urD009081357
problem is detected, the Permittee shall submit to the Director, before the expiration of
the72 hour period, a proposed time schedule for correcting the problem.
Any problern which could endanger human health or the environment shall be corrected
as soon as possible after the problern is discovered. The Permittee shall make every
effort to eliminate the threat to human health or the environment within 24 hours.
If, upon determination by the Director or the Permittee, continued operation of the
waste management unit involved in the inspection could endanger human health or the
environment, the Permittee shall cease operation of the unit until the problem has been
corrected. The Permittee shall be allowed to undertake those operations which are part
of corrective activities.
Records of inspections shall be kept as required by UAC R315-8-2.6(d).
RISK TIIRESHOLDS
The therrnal treatment operations at the M-136 andM-225 Thermal Treatment Areas shall be
conducted to minimize the risk to human health and the environment. The risk thresholds
identified in Condition II.G. and the operating conditions identified in Module [V for the
treatment areas shall be based on the information provided or referenced in Attachments to this
Permit and the following site specific documents available for review in the Department of
Environmental Quality, Division of Solid and Hazardous Waste files:
Sampling Results for Emissions Characterizationof Open Burning Waste Propellant Materials,
October 2009;
The Waste Characteization and Air Dispersion Modeling Protocol for use in the Human Health
and Ecological Risk Assessments - ATK Launch Systems - Promontory, November 2009,
January 2010;
The response to the Division of Solid andHazardous Waste comments on the Waste
Characteizatron and Air Dispersion Modeling Protocol for use in the Human Health and
Ecological Risk Assessments, July 2010;
The Waste Characteization and Air Dispersion Modeling Report, to be completed in
accordance with Condition IV.M.l.
The Human Health Risk Assessment Protocol for OB/OD Operations at the ATK Promontory
Facility, February 2010;
The response to the Division of Solid and Hazardous Waste comments on the Human Health
Risk Assessment Protocol for OB/OD Operations, August 2010; and
The Human Health Risk Assessment Report, to be completed in accordance with Condition
IV.M.2.
Based on the findings of the Human Health Risk Assessment which shall be completed in
accordance with Condition IV.M.2., the Permittee shall modiff this section of the permit, in
ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.G.3.
II.G.3.a.
II.G.3.eb.
II.G.5.
II.H.
II.H.1.
Modifi ed $ebruaryJuly, 20 I 65
urD009081357
accordance with Condition IV.M.3., to establish annual risk thresholds that minimize the risk to
human health and the environment and ensure compliance with Permit Condition IV.C.S.
The Permittee shall submit to the Director by March l't of each calendar year, an annual report
on the operation of the Promontory Thermal Treatment areas. This report shall at a minimum
include the following:
An accounting of the quantities and types of reactive hazardous waste treated at the M-136 and
M-225 thermal treatment areas, including all donor material and ignition compounds;
II.G.3.dq.
An evaluation of the emission factors, identified in Condition II.G.1.a., used in the human
health risk assessment to determine whether these factors are representative of the wastes
treated and identified as directed by II.G.3.a., or if the emission factors need to be updated; and
A review of the of the human health risk assessment, identified in Condition II.G.1.g., to
evaluate chanqes to dose-response factors for the three classes of detected COPCs: chromium
(total and hexavalent). 2.3.7.8-TCDD TE. and detected potentially carcinogenic PAHs
(benzo(a)anthracene" benzo(k)fluoranthene. chrvsene and indeno(1.2.3-cd)pyrene) whetherthe
,anda
review of the potential human health risk scenarios that were evaluated in the risk assessment to
assure that these scenarios have not changed.
If the Director determines after reviewing this annual report that any component of the risk
assessment needs to be updated, he will inform the Permittee in writing which components of
the human health risk assessment to update.
If the Permittee is required to update the human health risk assessment for the
M-136 orM-225 Thermal Treatment areas, the Permit shall be modified in accordance with
Condition I.D. of this Permit.
PERSONNEL TRAINING
The Permittee shall conduct personnel training as required by UAC R315-8-2.7. This
training program shall follow the outline found in Attachment 3. New personnel
working with or around hazardous waste shall complete the required personnel training
within six (6) months of their hire date, assignment to the facility or assignment to a
new position at the facility.
Facility personnel shall take part in an annual review of their initial training for
contingency and hazardous waste management procedures relevant to the positions in
which they are employed.
The Permittee shall maintain training documents and records as required by UAC R315-
8-2.7(d) and R315-8 -2.7(e) [40 CFR 264.16(d) and264.l6(e)], in accordance with the
II.G.4.
TI.H.2.
II.H.3.
I etf fauncnsystems Inc.-Promontory
Module II - General Facility Conditions
II.H.4.
II.H.5.
Modifi ed+ebruaryJuly, 20 I 65
[ITD009081357
Training Plan in Attachment 3. These records shall indicate the type and amount of
haining received.
The Permittee shall maintain a copy of the Training Plan at the Facility until it is fully
closed and closure is certified.
Employees working at the M-136 andM-225 Thermal Treatment Areas shall receive
task specific on-the-job-training in addition to the training outlined in Attachment 3.
This haining shall be documented and maintained in the operating record.
The Permittee shall comply with the requirements of UAC R315-8-2.8.
In addition to the requirements of UAC R315-8-2.8., the Permittee shall comply with
the Conditions III.G and III.H pertaining to ignitable, reactive, or incompatible waste.
LOCATION STAIIDARDS
The Permittee shall comply with the location standards specified by UAC R315-8-2.9.
PREPAREDNESS AND PREVENTION
The Permittee shall follow the Preparedness and Prevention Plan, Attachment 8.
At a minimum, the Permittee shall equip and maintain in good operating condition at
the facility the equipment set forth in Attachment 8, as required by UAC R315-8-3.3.
The Permittee shall test and maintain the equipment specified in Condition II.K.2 as
necessary to assure its proper operation in time of emergency.
The Permittee shall maintain records of the preventative maintenance and repair
activities specified in Condition II.K.3. and shall keep schedules, reflecting minimum
and planned frequency for the performance of preventative maintenance activities in the
Operating Record at the facility.
The Permittee shall maintain access to the communications or alarm system as required
byUAC R315-8-3.5.
At a minimum, the Permittee shall maintain 30 inches of aisle space between containers
or pallets of containers at storage areas M-186 and E-501.
The Permittee shall attempt to make arrangements (Coordination Agreements) with
State and local authorities as required by UAC R315-8-3.7. Copies of the Coordination
Agreernents shall be kept in the Operating Record. The attempts to make such
agreements, any refusals and all final agreernents shall be documented in the Operating
Record.
II.
ILr.1.
il.r.2.
II.J.
II.J.1.
II.K.
II.K.1.
II.K.2.
II.K.3.
II.K.4.
II.K.5.
II.K.6.
II.K.7.
ATK launch Systems Lrc. - Promontory
Module II - General Facility Conditions
II.L.
II.L.1.
tr.L.2.
II.L.3.
il.L.4.
II.M.
II.M.I.
II.N.
II.N.1.
II.N.2.
TI.N.3.
II.N.4.
II.N.5.
Modifi ed+ebruaryJuly, 20 165
uTD009081357
CONTINGENCY PLAN
The Permittee shall immediately carry out the provisions of Attachment4, and follow
the emergency procedures described by UAC R315-8-4.7 whenever there is a fire,
explosion, or release of hazardous waste orhazardous waste constifuents which
threatens or could threaten human health or the environment. The Permittee shall
comply with Condition I.T. in reporting releases to the Director.
The Permittee shall provide copies of the Contingency Plan to emergency agencies who
maybe called in an emergency, shall maintain a copy of the Plan at the facility, and
shall provide a copy upon request in accordance with UAC R3l5 -8-4.4.
The Permittee shall review the Contingency Plan, in accordance with UAC R315-8-4.5
and shall modifu it in accordance with Condition I.D., if necessary.
A trained emergency coordinator shall be available at all times in case of an emergency,
in accordance with UAC R315-8-4.6 and identified in Attachment 4.
MANIFEST SYSTEM
The Permittee shall comply with the manifest requirements of UAC R315-5-2 and UAC
R315-8-5. The manifest tracking number shall be recorded in the Operating Record
with each waste load that arrives or leaves the Permittee's facility.
RECORDKEEPING AND REPORTING
The permittee shall maintain an accurate written Operating Record at the facility in
accordance with UAC R315-8-5.3 (40 CFR 264.73 incorporated by reference) and
R315-50-2 (Appendix I to Part 264 incorporated by reference).
The Permittee shall, by March 1 of each year, submit to the Director a certification
pursuant to UAC R315-8-5.3 [40 CFR 264.73@)(9) incorporated by reference], signed
in accordance with UAC R315-3-2.2, that the Permittee has a program in place to
reduce the volume and toxicity of hazardous waste that he generates to the degree
determined by the Permittee to be economically practicable; and that the proposed
method of treatment, storage, or disposal is the most practicable method currently
available to the Permittee which minimizes the present and future threat to human
health or the environment.
The Permittee shall comply with the biennial report requirements of UAC R315-8-5.6,
by March I of each even-numbered reporting year. The report shall include wastes
generated, treated or stored at the Permittee's facility during the previous odd-numbered
year.
The Permittee shall submit additional reports to the Director in accordance with UAC
R315-8-5.8.
All reports, notifications, applications, or other materials required to be submitted to *re
ATK Iaunch Systems Inc. - Promontory
Module II - General Facility Conditions
II.o.
II.o.1.
[.o.2.
II.O.3.
II.O.4.
u.o.5.
rr.o.6.
II.O.7.
II.O.8.
Modifi ed+ebn*aryJuly, 20 165
uTD009081357
Director shall be submitted in accordance with Condition I.DD.
CLOSURE/POST-CLOSURE
The Permittee shall close the facility as required by UAC R315-8-7, UAC R315-101
and Attachment 5.
For all HWMUs, minor deviations from the approved closure plan procedures,
necessary to accommodate proper closure, shall be described in narrative form with the
closure certification statements. The Permittee shall describe the rationale for
implementing minor changes as part of this narrative report. Within 60 days after
completion of closure of each HWMU, the Permittee shall submit the certification
statements and narrative reports to the Director.
The Permittee shall amend the closure/post-closure plan in accordance with UAC R315-
8-7 and Condition I.D. whenever necessary, or when required to do so by the Director.
The Permittee shall notiff the Director in writing of the partial closure of any portion of
the facility in accordance with UAC R3l5-8-7. The Permittee shall notiff the Director
at least 180 days prior to the commencement of final facility closure. The closure plan
contained in Attachment 5 will be reviewed before commencing partial or final facility
closure. If the closure plan requires modification, the plan shall be modified and
submitted to the Director for approval in accordance with Condition I.D.
After receiving the final volume of hazardous waste, the Permittee shall treat or remove
from the site all hazardous waste and complete closure activities in accordance with the
schedule specified in Attachment 5.
The Permittee shall decontaminate or dispose of all facility equipment, structures, soil
and rinsate as required by UAC R3l5-8-7, R3l5-8-9 and Attachment 5. Facility
equipment, structures and soil which have not been decontaminated shall be disposed of
only at a permitted hazardous waste treatment, storage or disposal facility.
The Permittee shall certifu that the facility has been closed in accordance with the
specifications in Attachment 5 as required by UAC R315-8-7, and shall provide a
certification by an independent, Utah registered professional engineer qualified by
experience and education in the appropriate engineering field.
In the event that any of the hazardous waste management units covered by this permit
cannot be clean closed by decontaminating or removing contaminated structures or soil,
or releases have occurred which have impacted soil or groundwater, the Permittee shall
modiff the Closure/Post-Closure Plan for thathazardous waste management unit in
accordance with Condition I.D. Within 30 days of the date that the Director approves
the modification, the Permittee shall close the unit in accordance with the applicable
provision of UAC R315-8-7 and R3l5-101.
If a HWMU cannot be clean closed, the Permittee shall submit a survey plat and
property description for the HWMU with the submission of the certification of closure
for the HWMU, in accordance with UAC R315-8-7 and R315-101.
II.O.9.
I eff fauncn Systems Inc. - Promortory
Module II - General Facility Conditions
II.P.
il.P.1.
II.P.2.
II.P.3.
II.P.4.
II.P.5.
II.Q.
rr.Q.1
rr.Q.2.
II.R.
II.R.1.
Modifi ed+ebruaryJuly, 20 I 65
uTD009081357
COST ESTIMATES FOR HWMU CLOSURE
The Permittee's closure cost estimate for each HWMU shall be prepared and maintained
at lhe facility in accordance with UAC R315-8-8 (40 CFR 264.142 incorporated by
reference) and Attachment 5.
By July 30 of each calendar year, the Permittee shall adjust the closure cost estimate
for inflation or submit the latest adjusted closure cost estimate for review and approval
by the Director. After approval, the Perrnittee shall maintain the latest adjusted closure cost
estimate inthe operating record. The closure cost estimates shall identift the costs, in
current dollars, of the steps necessary to perform final closure for each HWMU in
accordance with UAC R315-8-9.9 and UAC R315-8-8 (40 CFR 264.142 incorporated
by reference).
pn lhe five year anniversary date of the submittal of the closure cost estimates required
by Condition II.P.2. above, the Permittee shall conduct a detailed evaluation of the
closure cost estimates for each HWMU and determine whether the annual adjustments
for inflation have been adequate to update the closure cost estimates. The Permittee
shall submit a report on this assessment and if necessary, a modification of the Permit in
accordance with Condition I.D. to the Director 90 days after the report is submitted.
The Permittee shall revise the closure cost estimate within 30 days after the Director has
approved the request to modifu the affected closure plan(s).
For each new HWMU placed into operation, an updated closure cost estimate to the
facility must be prepared which includes the new unit, 60 days prior to waste being
placed on or into the new unit.
FINANCIAL ASSURANCE FOR FACILITY CLOSURE
The Permittee shall demonstrate continuous compliance with UAC R315-8-8 by
providing documentation of financial assurance, as required by UAC R315-8-8.
Changes in financial assurance mechanisms shall be approved by the Director at least
60 days prior to such a change. On ten day notice from the Director, the Permittee shall
direct any entity that is responsible for payment of closure costs, to provide copies of
documents demonstrating the status of the financial assurance mechanism.
The Permittee shall revise the financial assurance for facility closure whenever there is
a change in the facility's closure plan that would change the cost estimate as required
by UAC R31s-8-8.
LIABILITY REOUIREMENTS
The Permittee shall demonstrate continuous compliance with the liability requirements
of UAC R315-8-8 (40 CFR 26al47(a) incorporated by reference). The Permittee shall
ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.R.2.
IT.R.3.
II.s.
II.s.1.
Modified+ebruarylgly, 20 165
LnD009081357
have and maintain hazardous waste liability coverage for sudden accidental occulrences
in the amount of at least one $1 million U.S. dollars per occurrence with an annual
aggregate of at least $2 million U.S. dollars, exclusive of legal defense costs. The
Permittee shall submit an approved certificate ofhazardous waste liability insurance
worded as required by UAC R315-8-8.
The Permittee shall demonstrate continuous compliance with the requirements of UAC
R315-8-8 -(40 CFR 264.147,b") incorporated by reference) to have and maintain liability
coverage for non-sudden accidental occurrences arising from operations of the two
Hazardous Waste Management Units, designated as the M-l36 afiM-225 Thermal Treatment
Areas.
Changes in liability coverage mechanisms shall be approved by the Director 60 days
prior to such a change.
The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (40 CFR 264.148 incorporated by reference).
ATK launch Systems Inc. - Promontory
Module III - Storage in Containers
III.A.
III.A.I.
III.A.2.
III.B.
III.B.1.
TII.B.2.
III.B.3.
III.B.34.
III.B.45.
fulyNsvenabe+ 20165
uTD009081357
MODULE III _ STORAGE IN CONTAINERS
APPLICABILITY
The requirements of this permit Module pertain to the operation of hazardous waste
container.storag^e areas at the facility. The Permittee shall comply with R3l5-8-9 andall conditions of this Module.
Ilr._9:tiryqt9lhgzqrdous waste storage areas are the bays of Buildings M-705S, E-501,
M-929_, M-I86, theburn trays at M-136, Burn Station14 atM-136, and Storage Fad S- '
633. Drawings of these storage areas are presented in Attachment 6.
WASTE IDENTIFICATION
The Permittee shall, tybj.-"! to tle terms of this Permit, store only the following
hazardous Y?stgs, a9 lislgd by EPA hazardous waste code, in containers at storige areasM-l86, M-705S and E-501:
Pg0!, p902, D003, p004, D005, D006, D007, D008, D009, D010 D011, D016, D018,
Pq 1 2, p92!, 0022, ry)23, D024, D026, D027,D028, D029, D03 5, D03 6, D03 S ; D03 9;
P010,_D012,D043, F001, F002, F003, F004, F005, F006, F007, F00g, F009, K044,
!gq?, y912,p022, p028, p029, p030, p047, p048, p064,p067,p077, p087, p}g2, '
_P093, l9g-5, poggz pt02, p105, p106, pllz, p116, p119, U001, u002, u004,u006,qggq,qgg?,u019, u025,u028, tJ029,U031, rJ037,U041, tJ044,U048, U053, U056,
y057, q0q?, u070, u072,u077,U079, U090, u095, u0gg, rJogz, u093, u0g5; u0gs;q1q1,u102, ul03,u105, ul09, u112,u113, tJtt7,Ul1g, Ut2O,tJt2t,rJl22,rJl23,qli1,l]1il,u134, ul40, ut47,u148, ut49,u151, tJt54,U156, U159, U160, rJt6i,y!6?, !1165,Ul68, U169, Ut70,Ut7I, U185, Ul96, U1gg, Ul90, tJt96,rJz}t,tJ209',
y ?r 9, u ? l l, u 2 l g, u 2 l g, u 220, u 22 I, rJ 223, tJ 224, tJ 225, rJ 226, ll 22g, tJ 23 g', tJ 23g',u240, u243, U244, U 246, U 253, U 329, U3 53, U3 59, U 404.
The Permittee may store solid reactive hazardous waste, EPAhazardous waste code
D003, in storage Building M-629 subject to the terms of this permit.
The Permittee may store waste rocket motors, EPA hazardous waste code D003
received from off-site that contain solid propellant, one at a ii-" ", th";;"il;
M-136, Burn Station 14 for up to 14 days prior to thermal treatment. Thi waste rocket
motors shall be labeled and managed as specified in Attachment 9.
The Permittee may store solid reactive hazardous waste, EPAhazardous waste code
D003, on Storage Pad 5-633 subject to the terms of this permit.
I aff faunch Systems Inc. - Promontory
Module III - Storage in Containers
I ttr.s.5o.
III.C.
m.c.1.
III.D.
III.D.1.
III.E.
III.E.1.
I[r.E.2.
III.E.2.a.
III.E.2.b.
III.E.2.c.
III.E.3.
III.E.3.a.
III.E.3.b.
JulyNevember 20165
1rTD009081357
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.l. requires modification of the permit in accordance with Condition I.D.3.
CONDITION OF CONTAINERS
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
thehazatdous waste, or the container itself, to a UN approved container in accordance
with Section 8-l-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.
COMPATIBILITY OF WASTE WITH CONTAINERS
The Permittee shall assure that the waste is compatible with the containers as required
by R315-8-9.3. The Permittee shall follow the compatibilityplan as indicated in
Section 9-2.1 and Table 9-2 of Attachment 9.
MAI\AGEMENT OF CONTAINERS
The Permittee shall manage containers in accordance with this module of the Permit,
UAC R3l5-8-9.4 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 rernoving waste from the container. The Permittee shall not open, handle, or
store containers in a manner which may cause the containers to leak.
The Permittee shall store liquid hazardous wastes in containers only at storage areas
M-I86, 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:
E-501 - 8,800 gallons, which is 160 55-gallon containers or the equivalent;
M-186 - 22,000 gallons, which is 400 55-gallon containers or the equivalent; and
M-705S - 1,760 gallons, which is 32 55-ga11on containers or the equivalent.
The Permittee shall store solid reactive hazardous waste in containers at storage areas
M-629, M-136 and 5-633. Drawings of the storage .reas are shown in Attachment 6.
At capacity, the Permittee may store the following amounts of wastes:
M-629 - 1 10,000 lbs 1 .3 or 55,000 lbs I .1 solid reactive hazardous waste;
M-l36 - 1258F,5900 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 bum trays or in a rocket case placed on the
ground; and
5-633 - 75,000 lbs of 1.3 or 20,000 lbs of 1.1 solid reactive hazardous waste.III.E.3.c
ATK I-aunch Systems Inc. - Promontory
Module III - Storage in Containers
III.E.4.
III.E.5.
III.E.6.
III.E.7.
TII.E.8.
III.E.9.
III.F.
III.F.1.
III.F.2.
III.F.3.
III.F.4.
July}+evember 20165
LrtD009081357
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.
The Permittee shall store hazardous wastes at M-705S, M-629, 5-633 and M-136 so that
the container or waste rocket motor may be readily inspected andhazardous waste
labels are visible.
Tlr: ly."itt:eg?y stack 55-gallon drums at a maximum of two high at storage areasM-l86 and E-501.
Hazardous waste containers shall not be stacked at storage areas M-705s,
M-629, 5-633 and M-136 except as described in Attachmentg-2.3.
The Permittee shall unload any transport vehicle hauling containers of hazardous wastefor stora-geyithin l0 days following arrival at the site. Arrivat for purposes of thispermit shall be the day the vehicle arrives at the facility.
The Permittee shall plovide_ storage for and maintain on-site, 85 gallon over-pack drums
at areas where liquid hazardous waste is stored.
CONTAINMENT SYSTEMS
The Permittee shall maintain the containment systems in accordance with the attached
plans and specifications contained in Attachmeirt 9 and as specified in UAC R315-8-
9.6.
Container mal?gement areas shall be inspected for the presence of free liquids in
accordance with Attachmer:,I-2. If free liquids are discovered in the sumpi or other
99nflinryent areas, the Permittee shall identit/ the location in the inspection log. Anyliquids discovered shall be removed immediately, but in no case latei than tweity-four
hours after t4e liquid is discovered and managed according to the spill contingency plan
specified in Section 9-4.3 of Attachment 9.
For purposes of inspectiong, all containers stored in the liquid hazardous waste storage
area shall be considered full to their respective capacities ivith 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.
The burn trays at M-l36 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 bum trays. Inspection of the burn trays shall be conducted in accordance with
Attachment 2.
ATK Iaunch Systems Inc. - Promontory
Module III - Storage in Containus
III.G.
III.G.1.
III.G.2.
III.H.
III.H.1.
III.H.2.
III.H.3.
IIIJ.
m.I.l.
III.I.2.
III.J.
III.J.1 .
LIJ.J.2.
fu$.Ievember 201S5
LnD009081357
SPECIAL REOUIREMENTS FOR IGNITABLE OR REACTIVE WASTE
The Permittee shall not locate containers holding ignitable or reactive waste within 15
meters (50 feet) of the facility boundary.
The Permittee shall take precautions to prevent accidental ignition or reaction of
iryitgb^t" ot reactive waste and follow the procedures specified in Attachment 8, UAC
R315-8-2.8 and UAC R315-8-9.7.
SPECIAL REOUIREMENTS FOR INCOMPATIBLE WASTE
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-e.8(a).
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 R31s-8-9.8O).
A.storage container holdin_g ahazardous waste that is incompatible with any waste or
other materials stored learb-y shall be separated from the oth-er materials or protected
from thern by means of a dike, berm, wall, or other device.
INSPECTION SCIIEDULES AND PROCEDURES
The Permittee shall inspect thehazardous waste storage and treatment facilitiesidentified in Condition III.B. of this Permit as specifiei in the Inspection Schedules
contained in Attachment .?. \" purpose ofthis inspection shall be to detect leaking
collairiers, standing liquids, deterioration of containers, and to detect deterioration6f
or liquids.in.the secondary containment systern caused by corrosion and other factors asspecified in R3 I 5-8-9.5.
If problems are observed -dulng the inspections, the Permittee shall correct the problem
in accordance with Module II, Section F.
CLOSURE,/PO ST.CLOSURE
The Permittee shall close the storage areas in accordance with UAC R315-8-7, UACR3l5-8-9.9, Condition II.O. and Attachment 5 of this permit.
Clo_sureplans for each individual hazardous waste management area shall be submitted
to !h9 Director for approval no less than 180 days prior to the coflrmencement of closureactivities. No closure activities shall take placethat have not received prior approval
from the Director.
I aff Launch Systerns fn.. - f.ornoQ
Module IV - Thermal Treatment of Energetic Wastes
Modifi ed Jglyanuory, 20 14d
uTD009081357
MODULE IV - THERMAL TREATMENT OF ENERGETIC WASTES
APPLICABILITY
The requirements of this permit module apply to the thermal treatment of energetic or
reactive hazardous waste at the ATK Launch Systems - Promontory facility, Box Elder
County, Utah. The Permiffee shall comply with UAC R315-8 and all conditions of this
module and Permit.
The pennit conditions of this module allow thermal treatment at the two Hazardous Waste
Management Units, designated as the M-l36 andM-225 Thermal Treatment Areas, as
designed and described in the drawings and specifications in Attachments 6 and 11. The
M-136 Thermal Treatment Area consists of 14 burn stations and 2 open detonation areas.
TheM-225 Thermal Treatment Area consists of 4 bum stations and 1 open detonation area.
Thermal treatment at both of the Promontory Therrnal Treatment Areas shall only be
accomplished by properly trained ATK personnel in accordance with ATK's Standard
Operating Procedures, the conditions of this Pennit and its attachments.
This Permit has been developed in accordance with the applicable requirements of UAC
R3l5-1 through 101. All conditions in this Permit shall supercede conflicting statements,
requirements, or procedures found in UAC R315-1 through 101 or attachments to this
Pennit.
PERMITTED AI\D PROHIBITED WASTE IDENTIFICATION
The Permittee may treat energetic or reactive hazardous waste at the two Promontory
Thennal Treatment Areas by open burning and detonation. These energetic and reactive
hazardous wastes are generated from the following sources:
Class 1.1 and 1.3 propellants and explosives manufactured at the Promontory, Bacchus, and
other ATK facilities as well as Autoliv ASP, DOD, NASA or other goven:ment and private
facilities (e.g. cured and uncured propellants, excess propellants and propellant scraps);
Production materials contaminated with class 1 .l and 1 .3 propellants and explosives and
reactive residues (e.g., rags, gloves, other personal protective equipment, plastics, rubber
and paper that were contaminated with explosive materials during the manufacturing
process);
Large and small class 1.1 and 1.3 rocket motors and initiating devices;
Class 1.3 Pyrotechnic, Illuminants, Metal Powders, or Autoliv ASP Products
Production materials contaminated with class 1.3 Pyrotechnic, Illuminants, Metal Powders,
or Autoliv ASP Products and other reactive residues (e.g., rags, gloves, other personal
protective equipment, plastics, rubber and paper that were contaminated with explosive
materials during the manufacturing process);
Reactive laboratory wastes which may contain solvents;
IV.A.
tv.A.1.
TV.A.2.
IV.A.3.
IV.A.4.
IV.B.
TV.B.1.
IV.B.1.a.
rv.B.1.b.
IV.B.1.c.
rv.B.1.d.
IV.B.1.e.
rv.B.1.f.
Page I
ATK Launch Systems rn". - P.o-ot
Module IV - Thermal Treatment of Energetic Wastes
Modifi ed Jqlyanuary, 20 1 ag
uTD009081357
IV.B.1.g. Wastewater treatment sludge generated from the processing of explosive ingredients and
propellants defined in UAC R315-2 as a K044 listed hazardous waste;
ry.B.1.h. Reactive bag house dust generated from the processing of explosive ingredients and
propellants; and
IV.B.1.i. Waste developmental propellants, explosives and associated contaminated production
materials.
TV.B.2.Only reactive hazardous waste as defined by UAC R315-2 may be treated at the
Promontory Thermal Treatment Areas. Reactive hazardous waste thermally treated at the
Promontory Thermal Treatment Areas may contain the follow EPA waste codes: D001,
D003, D005, D007, D009, D030, D039, F001, F002, F003, F004, F005 and K044.
The Permittee is prohibited from thermally treating reactive hazardous waste classes and
compositions not included in Conditions IV.B.1. and IV.B.2. including wholly inert items,
improvised explosive devices (e.g. homemade bombs) and chemical wastes.
The Permittee is prohibited from thermally treating, by open burning, energetic reactive
hazardous wastes that will detonate under open burning conditions.
The addition of hazardous waste codes to Condition IV.B.2. requires modification of the
permit as specified in UAC R315-4-1 .5 and Condition I.D.
The Permittee shall comply with the waste compatibility requirements of Condition II.I.
GENERAL OPERATING CONDITIONS
The Permittee shall comply with the following treatment limits for the M-l36 Thermal
Treatment Area:
IV.B.3.
IV.B.4.
IV.B.5.
IV.B.6.
IV.C.
rv.c.1.
Fl€-+-a'
@
[V.C.1.bq. The Permittee shall not treat" by open burnine (OB)" more than a combined amount of
12A6,5900 pounds of reactive hazardous waste in a calendar day under treatment scenario
M-136-A
IV.C.1.ea.1 The Permittee shall not treat- lyQL more than 5e96,000 pounds total of reactive hazardous
waste in a calendar day at any six -bum stations of burn stations I throush 12. at 16.000
pounds in each station. under treatment scenario M-136-413;
N.C.1.d4.2 The Permittee shall not treat by OB more than 106,5000 pounds of reactive hazardous
waste in a calendar day at burn stationl43 under treatment sffi;
IV.C.1.ea.3 The Permittee shall not treat by OB more than 16-Q00 pounds of reactive hazardous waste
in a calendar day at burn station 14 under treatment scenario M-I36-A+y-op€ndetonatien
pereven+;
N.C.l.{b. The Permittee shall not treat. by open burnine (OB). more than 125.000 pounds total of
reactive hazardous waste in a calendar day at burn station 14 under treatment scenario M-
136-8:
Page2
ATK Launch Systems rn.. - e.o-ofi
Module IV - Thermal Treatment of Energetic Wastes
Modifi ed Jqlyanuary, 20 lag
uTD00908l3s7
IV.C.l .c. The Permittee shall not treat. by open detonation (OD). more than 1.200 pounds total of
reactive hazardous waste in a calendar day under treatment scenario M-l36-C:
fV.C.l .c.l The Permittee shall not treat by OD more than 600 pounds of reactive hazardous waste in a
calendar day at each burn station 13 and 14:
lV.C.l.d The Permittee shall not operate more than one treatment scenario. M-l36-4. M-I36-8. or
M-136-C in a calendar day:
IV.C.l.e The Permittee shall operate the M-l36 Thermal Treatment Area in accordance with the
IV.C.1.ef.
quantity-distance requirements identified in Attachment 11 section 5; and
The Permittee shall not treat more than 10,000,000 pounds of reactive hazardous waste at
the M-l36 Thermal Treatment Area in a calendar year. This 10,000,000 pound limit shall
be established by adding the Net Explosive Weight (NEW) and all donor and initiator
materials. Donors shall include all pallets, cardboard, packaging material, absorbents and
diesel fuel.
N.C.2. The Permittee shall comply with the following treatment limits for theM-225 Thermal
Treatment Area:
TY.C.2.a. The Permittee shall not treat" by open burnine (OB). more than 4,500 pounds of reactive
hazardous waste per calendar day under treatment secanario M-225-A;
IV.C.2.a.l The Permittee shall not treat by OB more than 4.500 oounds total of reactive hazardous
waste in a calendar day at any four burn stations of burn stations I through 4. at I .l 25
pounds in each station. under treatment scenario M-225-A:
ry.C.2.b. The Permittee shall not treat. by open detonation (OD). more than 600 pounds of reactive
hazardous waste in a calendar day under treatment scenario M-225-B$y-epen{etenatien
perevent;
lV.C.2.b.l The Permittee shall not treat by OD more than 600 pounds of reactive hazardous waste in a
calendar day at the open detonation area of M-225:
1V.C.2.b.2 The Permittee shall not operate more than one treatment scenario. M-225-A" or M-225-B in
IY.C.2.c.
a calendar dav:
The Permittee shall operate theM-225 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11 section 5; and
The Permittee shall not treat more than 55,000 pounds. by open burning. and 10.000
pounds. by open detonation. of reactive hazardous waste at theM-225 Thermal Treatment
Area in a calendar year. This limit shall be established by adding the Net Explosive Weight
(NEW) and all donor and initiator materials. Donors shall include all pallets, cardboard,
packaging material, absorbents and diesel fuel.
The Permittee shall maintain the integrity of the Promontory Thermal Treatment Areas to
ensure that they meet the performance standards of UAC R315-8-16 and minimize the
potential impacts to human health and the environment. The Permittee shall adhere to
applicable provisions of Attachments 2 and 11 and the following conditions:
rv.c.2.d.
IV.C.3.
Page 3
I ex -Laynch Systems r*. - a--0,, O Modified Jqlyanuary,2014!Module IV - Thermal Treatment of Energetic Wastes UTD0090gl357IV.C.3.a. The Permittee shall conduct all open burn operations within the secure areas designated as
the M-136 orM-225 Thermal Treatment Areas with controlled access as identified in
Attachment 1l;
The Permittee shall post warning signs around both of the Thermal Treatment Areas to
keep unauthorized personnel out;
The Permittee shall maintain the egress paths for both of the Thermal Treatment Areas
identified in Attachment 4;
The Permittee shall disable the firing system whenever operators are in the QD for this
treatment unit. The firing system shall only be active or armed when operators are
conducting a pre-burn continuity check, as specified in Attachment 11, Section 8.2.3, or
when the firing system is being maintained and no waste is present in the treatment area, or
after all operators have exited the treatment unit and retreated to the firing control room in
preparation of initiating an ignition as specified in Condition IV.F.2.i;
The Permittee shall assess and monitor meteorological conditions to ensure operators are
not exposed to risks from lightning strikes or other adverse weather conditions that would
preclude the safe operation of the M-l3 6 orM-225 Thermal Treatment Areas. The
Permittee shall record the temperature, wind speed, wind direction, sky conditions and
clearing index prior to each burn in the facility operating record;
rv.c.3.f.The Permittee shall comply with all requirements for pre-placement of waste, placement of
waste in treatment units, wiring and ignition and the post-burn inspection and clean up
activities identified in Condition fV.D, E, F, G, H and I;
The Permittee shall provide operators with access to a telephone that can be used to contact
support personnel, including security, safety and fre fighting units, whenever the operators
are inside the M-136 orM-225 Thermal Treatment Areas;
The Permittee shall maintain the integrity of the two Promontory Thermal Treatment Areas
and support equipment through regular inspections and in accordance with the inspection
plan in Attachment 2. lnspection records shall be maintained at the facility;
The Permittee shall train all operators of the Promontory Thermal Treatment Areas in
accordance with Condition II.H. and Attachment 3 of this permit;
The Permittee shall not operate either of the Promontory Thermal Treatment Areas without
containment measures (e.g. firebreaks) to assure the confinement and control of any fire
resulting from the open burn and open detonation operations at the Promontory Thirmal
Treatment Areas;and
The Permittee shall not treat propulsive items at the Promontory Thermal Treatment Areas,
unless the item has been rendered non-propulsive or is contained in accordance with
Attachment 11.
The Permittee shall operate the Promontory Thermal Treatment Areas to prevent
unacceptable risk ofcancer and non-cancer effects to on-site workers and off-site residents
and to minimize significant effects to the ecosystem surrounding the Promontory Thermal
IV.C.3.g.
rv.c.3.h.
rv.c.3.b.
IV.C.3.c.
rv.c.3.d.
IV.C.3.e.
rv.c.3.i.
rv.c.3 j.
rv.c.3.k.
IV.C.4.
Page 4
ATK Launch Systems fr.. - P.o-oil,
Module IV - Thermal Treatment of Energetic Wastes
rv.c.5.
IV.C.5.a.
ry.c.s.b.
TV.C.6,
IV.C.6.a.
Modified Jqlyanuary, 20 I !
uTD009081357
Treatment Areas. The Permittee shall maintain compliance with the environmental
performance standards listed in UAC R315-8-16 and comply with Permit Condition II.G.2.
The Permittee shall adhere to the following conditions to prevent unacceptable risk of
cancer and non-cancer effects due to exposure to emissions from the open burning
operations:
The excess carcinogenic risk to on-site workers shall not exceed l OxI0-o (one in ten
thousand) or a Hazard Index of l 0 for the potential workers positioned at the point of on-
site maximum exposure. as calculated according to the methodoloqlu in the approved
HHRA for Promontory. The maximum treated at the burning grounds shall not exceed
129.500 lbs. per burn.@
. The risk shall be calculated in accordance-with
Section II.G.; and
1.0x10 o (one in a million). The cumulative non-carcinogenic hazard to actual or potential
off-site receptors shall not exceed a hazard index of l 0 for an), 24-hour period followine
initiation of a bum or detonation. as calculated according to the methodology in the
approved HHRA for Promontory. The maximum treated at the Promontory Burnins
Grounds shall not exceed 10.065.000 lbs. per year.
aetBat er Betentta
Ue-ealeu+a+e+in aeeerdanee witlr Seet
Based on the air dispersion and deposition modeling and the human health risk assessment
tebe-completed in accordance with Conditions IV.M.1. and IV.M.2. for the Promontory
Thermal Treatment Areas, the Permittee shall adhere to the following conditions:
ATK shall notif,i the Box Elder County Fire Marshall's Office and obtain a clearing index
before each treatment operation involving reactive material;
IV.C.6.sb.
IV.C.6.{e.
TV.D.
rv.D.1.
The Permittee mav conduct n detonat the hou
Mountain Time (MT) and 6:00 pm MT.
The Permittee shall only conduct burns when the surface wind speed is netgreater than 3
miles per hour (mph) and less than l5-mitesaerheuruqpb; and
The Permittee may conduct burns and open detonations only when the Clearing Index (CI)
is sreater than 500 unless. approved by agreement with Utah Division of Air Ouality. and
Box Elder County .
WASTE TRACKING
The Permittee shall track all reactive hazardous waste in accordance with Attachment 11
and maintain this information in the operating record for both of the Promontory Thermal
Treatment Areas.
PRE-BURN ACTIVITIESIV.E.
Page 5
I err Launch Systems In". - r.o*ofi,
Module IV - Thermal Treatment of Energetic Wastes
TV.E.I.
IV.E.1.a.
rv.E.1.b.
IV.E.1.c.
rv.E.1.d.
IV.E.1.e.
rv.E.l.f.
rv.F.
tv.F.1.
IV.F.1.a.
rv.F.1.b.
IV.F.1.c.
rv.F.1.d.
Modifi ed Jqryanuary, 20 I aS
uTD00908l3s7
Prior to bringing any reactive hazardous waste into either of the Promontory Thermal
Treatment Areas for thermal treatment, The Permittee shall conduct pre-burn activities inaccordance with the requirements identified in Attachment 11, and the pre-burn inspection
requirements in accordance with the inspection schedule included in Attachment 2. The
Permittee shall also comply with the following conditions:
If the treatment units have not been inspected the same day the unit is loaded, the treatmentunit shall be inspected prior to placing reactive waste in the treatment unit;
Any treatment unit that fails one or more of the inspection criteria shall be removed from
service until the problem is corrected;
No treatment is permitted unless either radio or telephone communication with emergency
services is available;
No treatment is permitted if the emergency equipment listed in Attachment 2, Table II-B,"Inspection Schedule for Thermal Treatment Area at M-136" or Table II-C, ,.Inspection
Schedule for Thermal Treatment Areas at M-225- is not available for use at each respective
location;
All leaks or spills of diesel fuel shall be cleaned up before the Promontory thermal
treatment areas can be operated; and
The loss of the flashing light will require that the unit be shut down until the problem is
corrected. If the Permittee must use the treatment unit when the flashing light is not
working, the supervisor shall visually inspect the area within the QD ofihelreatment unit
and assure that no unauthorized employees are present in the area. Ifany unauthorized
employees are found within this area, they will be escorted from the area. Treatment
operations can commence once the supervisor verifies in the operating record that the area
is clear.
PREPARING WASTE FOR THERMAL TREATMENT BURN
Prior to placing any reactive hazardous waste in a treatment unit, the Permittee shall
comply with all provisions Conditions IV.C, D and E of this Permit. The permittee shall
also comply with the following conditions:
There shall be at least two operators present when a treatment unit is in the process of beingloaded with reactive hazardous wastes as defined in condition rV.B.1;
The treatment unit shall be loaded in accordance with internal safety procedures and theATK Hazardous Operation Standard 1-3 Handling & Disposal of Explosives & Other
Hazardous Wastes, an internal and confidential document which is part of the operating
record, and the provisions identified in Attachment 11.8.2_2;
All cardboard, wood and diesel used as donor material to assure a complete burn shall be
counted towards the daily treatment limits, and recorded in the operating record;
All reusable propellant buckets used as accumulation containers for reactive waste shall beinspected after use. If there is any contamination in the containers they shall be cleaned or
Page 6
I exlaunchSystemst. -r.".t O ModifiedJglyantary,2olaoModule IV - Thermal Treatment of Energetic Wastes UTD0090gl357decontaminated in accordance with the procedures identified in Attachment 11 before being
reused;
IV.F.I.e. The Permittee shall document in the operating record the burn station for each container of
reactive hazardous waste treated.
tV.F.2. Prior to beginning the final preparations for an open burn, the Permittee shall comply with
the following conditions:
IV.F.2.a. Reactive waste shall not be prepared for ignition, as described in Attachment
all non-essential personnel leave the treatment area.
I 1.8.2.3, until
IV.F.2.b. All wiring and ignition operations, described in Attachment 11.8.2.3, shall be conducted by
at least two employees;
IV.F.2.c' The Permittee may reactivate the firing system treatment areas only after all operators have
exited the QD for the treatment unit;
fV.F.2.d. As the operators leave the treatment area following operations described in Attachment l l,
Section 8.2.3,they shall close the gate to the treatment area;
IV.F.2.e. After all operators have exited the treatment area and retreated to the firing control room,
the operators may replace the firing system interlock in the firing system control console
and activate the firing system;
;IV.F.2.f. After activating the firing system, the operators shall confirm that the flashing red light was
activated to alert all personnel that a treatment event is about to start and that they s-hould
vacate the QD area for the treatment area. If the flashing light is not operational, tiie
Permittee shall comply with Condition IV.E.1.f. before initiating the tlierrnal treatment;
IV.F.2.g. After the wanring identified in Condition IV.F.2.f. has been completed, the permittee shall
conduct a pre-ignition continuity check of the firing system to aisure that the igniters have
been installed correctly into the hard-wired portion of the firing system. If any firing
circuit fails this test, the Permittee shall perform the following tasks:
IV.F.2.g.i. Remove the interlock for the firing control system, deactivating the firing control system;
IV.F.2'g.ii. At least two operators shall reenter the treatment area, and correct the problem;
IV.F.2.g.iii. If the resistance problem cannot be immediately corrected, the operators may connect a
separate igniter wire to an adjacent stanchion; and
IV.F.2.g.iv. After the problem with the firing circuit has been corrected the operators shall repeat the
steps described in Conditions IV.F.2.g.
IV.F.2.h. The treatment units shall be fired in accordance with the provision of Attachment 11,
Section 8.2.3 ofthis permit;
IV.F.2.i. All thermal treatment events shall be observed with a video camera from the firing control
room or immediately outside the firing control room;
PageT
I ,CTK Launch Systems t.. - a-r"oQ,
Module IV - Thermal Treatment of Energetic Wastes
rv.F.2j.
IV.F.2.k.
rv.F.2.l.
IV.F.2.m.
TV.G.
TV.G.I.
TV.G.2.
IV.G.2.a.
rv.c.2.b.
IV.G.2.c.
rv. c.2.d.
IV.G.2.e.
rv.G.2.f.
IV.G.2.g.
rv.G.2.h.
rv.G.2.i.
Modifi ed Jglyam.ary, 20 I 4f,
uTD009081357
In the event that none of the treatment units ienite, the operators shall wait 30 minutes
before removing the firing system interlock and reentering the treatment area to correct the
problem. After correcting the problem, the operators shall repeat the steps described in
Conditions [V.F.2.c, d, e, f and g, and proceed with activating the firing system;
If at least one treatment unit ignites, then the operators shall wait at least 16- hours before
reentering the treatment area , and correcting the problem. After the problem has been
corrected, the operators shall repeat the steps described in Conditions fV.F.2.c, d, e, f and g,
and proceed with activating the firing system;
Prior to ignition, the area supervisor or designee, shall review the placement of the waste on
the treatment units; and
All treatment data shall be maintained in accordance with the requirements of UAC R315-
8-5.3 and shall be entered into the operating record for the Promontory facility in
accordance with attachment I 1.6.
POST.BT]RN ACTITVTIES
Following treatment, the Permittee shall conduct the post-burn inspection activities
identified in Attachment 2, and clean up activities identified in Attachment 11of this
Permit, and shall comply with Conditions fV.C.1, 2 and3, and shall have completed and
complied with all provisions of Conditions, fV.E and F.
The post-burn inspection shall be conducted within 24 hours of completing a treatment
event, and perform the following unless one of the exceptions identified in IV.G.2j or k
applies:
Prior to entering the treatment area, the operators shall deactivate the firing control system
and remove the interlock;
Document any treatment unit with an open flame, hot spot or smoldering residue;
Document any treatment unit with unburned residue;
Document any treatment unit with unburned reactive hazardous waste and identif,, if
possible in the operating record why the waste did not burn;
Inspect for any unburned waste that was ejected from a treatment unit during the last
treatment event. Such waste shall be picked up and placed in a treatment unit;
Record on the inspection form the date that the treatment units were cleaned, or the reason
why the units were not cleaned within 24 hours after completing the treatment event;
Identifu the treatment unit where unburned waste is being stored;
Evaluate the condition of the safety equipment identified in Attachment2,Table II-B and
Table II-C;
The Pennittee may postpone post-burn activities if lightning strikes or adverse weather
conditions prohibit the safe operation of the treatment areas. Lightning strikes closer than
30 miles restrict attended operations at the Promontory Facility. The Permittee shall
document the reasons for the delay in the facility's operating record; and
Page 8
I aTK Launch systerns rr.. - p.o.#.v
Module IV - Thermal Treatment of Energetic Wastes
rv.G.2j.
TV.G.3.
IV.G.3.a.
IV.G.3.b.
IV.G.3.c.
TV.G.4.
IV.G.4.a.
rv.G.4.b.
Modifi ed Jqlya+tlary, 20 149
uTD009081357
The Permittee may delay the post-burn inspection for burns involving bulk propellant andbulk explosives that occurred on a Thursday or Friday. The post-burn inspection shall be
conducted on the following Monday, unless the meteorological conditions identified in
Condition fV.G.2.i. prohibit re-entry into the treatment area. The Permittee shall document
the reasons for the delay in the facility's operating record.
Within 24 hours of completing an open burn that generates a characteristic or listed ash or
residue, the Permittee shall remove all characteristic or listed residues from the treatment
area and manage the waste in accordance with R315-5 of the UAC. If meteorological
conditions exist, as identified in Condition IV.G.2.i., that prohibit re-entry into the
treatment area within the24 hour period, the Permittee shall document the following
information in the operating record:
The reason for the delay in doing the post-burn clean up;
The date when the treatment unit was cleaned; and
Fxcept as delayed by the conditions described in Condition IV.G.2.i, the area supervisor, or
designee, shall review the Promontory Thermal Treatment Areas log and post-burn
inspection forms within 24 hours of completing a thermal treatment event. The review
shall assure that all of the recorded information is correct and identiff any items that may
require corrective action including any treatment unit that failed to ignite, had an ignition
problem or misfired, had an unplanned detonation, where the burn did not propagui" as
expected or any other unexpected event.
Open burn operations at the Promontory Thermal Treatment Areas may result in the
generation of untreated residue and unburned wastes. The Permittee shall manage these
residues and wastes in accordance with the following provisions:
Small amounts of untreated residue shall be considered newly generated waste and shall be
logged and tracked as such in the explosive waste tracking system. This small amount is
defured as less than 5%o of the total volume placed treatment unit. The primary option for
managing this waste is to burn it by 6:00 pm of the following calendar day. If the untreated
residue cannot be treated by 6:00 pm of the following calendar day then it shall be managed
in accordance with UAC R315-5;
Unburned waste resulting from a misfre or an intemrpted ignition shall be treated by 6:00
pm of the calendar day following the date of the first attempt to treat this waste. For the
puposes of this Permit, an intemrpted ignition occurs when anything greater than5o/o of
the waste placed on in a treatment unit or in a station fails to ignite. This unreacted waste
shall not be considered a newly generated residue. If the Permittee is unable treat the
unburned waste by 6:00 pm of the following calendar day, the Permitttee shall cover the
waste and manage the treatment unit or station in accordance with UAC R315-5. If the
cumulative storage time for the unburned waste both while in storage prior to treatment and
while on the treatment unit or in the burn station is greater than 90 days, the Permittee shall
request an emergency storage permit in accordance with UAC R315-3-6.2;
For reactive hazardous wastes that have been in storage for greater than 90 days when they
are placed on in a treatment unit or in a burn station and which do not completely burn, the
Permittee shall treat all unburned or unreacted waste by 6:00 pm of the calendar day
following the date of the initial attempt to treat the waste. If the Permittee is unable to treat
the unburned or unreacted waste by 6:00 pm of the following calendar day, then the
IV.G.4.c.
Page 9
I err Launch Systems rn.. - r.o*oQ,
Module IV - Thermal Treatment of Energetic Wastes
TV.G.5.
IV.H.
tv.H.1.
TV.H.2.
TV.H.3.
TV.H.4.
IV.I.
IV.I.1.
N.t.2.
w.J.
TV.J.I
TV.K.
IV.K.1.
IV.K.1.a.
Modified Julyanuary, 20 14[
uTD009081357
Permittee shall request an emergency storage permit in accordance with UAC R315-3-6.2;
and
The Permittee shall manage all treatment residues generated from the treatment of listed
and/or characteristic wastes during post-burn activities in accordance with this Permit and
UAC R315-5.
STORMWATER MANAGEMENT AND RIIN.ON AND RTiN-OFF CONTROLS
The Perrnittee shall manage all stormwater collected from treatment units in accordance
with this Permit, Attachment 11, Section l1 and UAC R315-5.
The Permittee shall maintain run-on diversion structures in accordance with this Permit and
UAC R315-8-16 which incorporates by reference 40 CFR 264.601. The Permittee shall
inspect the condition of those structures annually to assure that they are in good repair. The
annual inspection shall be documented in the operating record for Promontory Thermal
Treatment Areas.
Run-off from precipitation that falls within the operatingarea of the Promontory Thermal
Treatment Areas shall be managed in accordance with UAC R3l5-8-16, which incorporates
by reference 40 CFR 264.601, using berms, and ground slope.
The Permitee will submit a proposal for managing run-off precipitation within 1 80 days
from the issue date of this permit.
TREATMENT RESIDUE AND ASH MANAGEMBNT
Ail treatment residue and ash generated from the Promontory Thermal Treatment
operations shall be managed in accordance with Condition tV.G.s. and the procedures
identified in Attachment 11.
Sampling and analysis of treatment residues and ash generated during operations at the
thermal treatment areas shall be performed in accordance with Attachment 1 and 11.
INSPECTION SCHEDULES AND PROCEDT]RES
The Permittee shall conduct inspections of the Promontory Thermal Treatment areas in
accordance with Attachment 2 arrd ll.
ENTVRONMENTAL MONITORING REOUIREMENTS
Within 180 days of issuance of this Permit or completion of the Human Health Risk
Assessment, whichever occurs later, the Permittee shall submit a Soil Monitoring Plan to
the Director for approval. The Soil Monitoring Plan shall, at a minimum, address the
following:
The impact of thermal treatment operations on soils within the treatment zone as identified
by the air dispersion and deposition model contained in the human health risk assessment
identified in Condition II.G.1.;
Risks to human health from exposure to media impacted by emissions from the Promontory
Thermal Treatment Areas operations shall be assessed. Acceptable risks are specified in
tv.K.1.b.
Page l0
I eff Launch Systerns fn.. - l.orno?ry
Module IV - Thermal Treatment of Energetic Wastes
Modified Jqlyanlary, 20 14!
uTD009081357
Conditions IV.C.S.a. and IV.C.5.b. The receptors to be evaluated are listed in the Human
Health Risk Assessment identified in Condition II.G.I. The risk assessment methodology
shall be consistent with UAC R315-101; and
The plan shall identiff analytes, sampling protocols and data quality objectives for the soil
monitoring program.
If the Director does not approve the Soil Monitoring Plan, he shall provide written
comments to the Permittee identifuing the deficiencies in Soil Monitoring Plan. The
Perrnittee shall address the comments and submit a revised Soil Monitoring Plan to the
Director for approval within 60 days of receipt of written comments.
ECOLOGICAL RISK
Within 180 days of issuance of this Permit or completion of the human health risk
assessment, whi€h-evertryhichgygl occurs later, the Permittee shall submit an Ecological
fusk Assessment Protocol document for evaluating thermal treatment operations to the
Director for approval. If the Director does not approve the Ecological Risk Assessment
Protocol document, he shall provide written comments to the Permittee identifuing the
deficiencies in Ecological Risk Assessment Protocol document.
The Permittee shall address the comments and submit a revised Ecological Risk
Assessment Protocol document to the Director for approval within 60 days of receipt of
written comments.
Within one year of receiving approval of the Ecological Risk Assessment Protocol
document, the Permittee shall submit an Ecological Risk Assessment for evaluating thermal
treatment operations to the Director for approval. If the Director does not approve the
Ecological Risk Assessment, he shall provide written comments to the Permittee
identiffing the deficiencies in Ecological Risk Assessment. The Permittee shall address the
comments and submit a revised Ecological Risk Assessment to the Director for approval
within 60 days of receipt of written comments.
IV.K.3. Within 30 days of receipt of the Director's approval of the Soil Monitoring Plan, the
Permittee shall submit a request to modifu the Permit in accordance with Condition I.D. to
incorporate the requirements of the Soil Monitoring Plan into this Permit.
fV.K.4. Within 180 days of the issuance of this Permit, or completion of the Human Health Risk
Assessment, whichever occurs later, the Permittee shall submit a Groundwater Monitoring
Plan to the Director for approval. The Groundwater Monitoring Plan shall, at a minimum,
address the following:
IV.K.4.a. The impact of thermal treatment operations on groundwater up and down gradient of the
M-136 andM-225 Thermal Treatment Areas; and
tV.K.4.b. The plan shall identifu analytes, sampling protocols and data quality objectives for the
groundwater monitoring program. ln addition, the plan shall propose a statistical method
for deterrnining if existing groundwater contamination concentrations increase due to
ongoing thermal treatment operations.
IV.K.1.c.
tv.K.2.
IV.L.
IV.L.1.
tY.L.2.
Page I I
I err Launch Systems rn". - r.o-o?ry
Module IV - Thermal Treatment of Energetic Wastes
Modifi ed Jqlyanuary, 20 laS
uTD009081357IV.L.3. Within 30 days of receiving approval of the Ecological Risk Assessment, the permittee
shall submit a request to modifi, Condition II.G. of this Permit in accordance with
Condition I.D. to add performance standards for the acceptable ecological risk associated
with the operation of both of the Promontory Thermal Treatment areas.
ir
ih€n
ef the prorrrentery
ilFeit8r
Iv.N!4.
rv.NM.1.
rv.eN.
rv.eN.1.
Iv.Pq.
IV.PQ.l.
IV.PQ.l.a.
ry.PO.1.b.
F'ACILITY MODIFICATION/EXPAI\SION
Modification of the design plans and specifications in Attachment 6 or construction of
additional treatment units shall be allowed only in accordance with UAC R315-4-1.5.
CLOSIIRE AI\D POST CLOSTIRE
The Permittee shall close the Promontory Thermal Treatment Areas in accordance with the
Closure Plan in Attachment 5.
PROMONTORY THBRMAL TREATMENT AREAS OPERATING RECORD
The Permittee shall maintain an operating record at the Promontory facility that describes
the operation of the Thermal Treatment areas. The operating records for the M-l36 and
M-225 Thermal Treatment Areas shall, at a minimum, include the following information:
All information required by UAC R315-8-5.3;
Copies of all inspections required by this module;
IV.PQ.1.c. All waste tracking information maintained in the electronic Waste Tracking Record
identified in Attachment 1 1;
Page 12
Modified Jslyanuary, 20146
uTD009081357
in Condition IV. C.3.e during
I W.eq.t.e. Copies of all reports identified in Condition II.G.1. and required by Condition tr.G.2. and
IV.K and IV.L; and
I W.eq.t.f. A running total of the type and quantity of reactive hazardous waste that has been treated at
both of the Promontory Thermal Treatment areas during the calendar year.
ATK Launch Systerns rn.. - p.orn#.v
Module tV - Thermal Treatment of Energetic Wastes
IV.PQ.1.d. A description of the meteorological conditions described
each burn;
Page l3
ATTACHMENT 5
CLOSURE COSTS
I err Launch Systems t". - a-,,* ,O fuUltevember2ot6sAttachment 5 - Closure Plan uTD009081357
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 approria Uy the Direcior.HWMUs included in this document are: M-l86; M-705S; E-501; M-136; M-225;T-298;M-621
and 5-633.
The Closure Plan was developed to comply with R315-8-7 and R3l5-8-9.9 of the Utah
Administrative Code (UAC). UAC R3 15-8-7 incorporates by reference the requirements of 40
CFR 264 Subpart G. The closure cost estimates were made in accordance withUAC R3l5-8-g,
which incorporates by reference the requiranents of 40 cFF.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)e), and,264.tt2(a)(1) & e) and uAC
R315-3, R315-81
This Closure Plan identifies the general steps needed to close storage and treatment facilities, as
identified above, at the end of their operating life. Copies of this pian 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 andHazardous 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 R3l5-g-71
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 R3 I 5- 1 01 , will be considired 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)(l). All closures will
assess real and reasonably likely impacts to human and ecological exposures.
I arr Launch Systems t.. -a.o*to Jqlyl+evember 20165
uTD009081357Attachment 5 - Closure Plan
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 implernenting 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-315-8-7I
This plan is designed to accommodate both partial and final closure. The plan includes separate
steps to close storage, consolidation & disassembly areas, and open buming/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 andM-225 burn grounds since 1991. Semi-
annual groundwater monitoring is also conducted, in accordance with ATK's Post-Closure
Permit.
1.3 Maximum Waste Inventory and Disposal Method [40 CFR 264.112(b)(3) and UAC
R31s-8-7I
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-l86 (inert) ----
M-l36 (live)
M-225 (live)
T-298 (inert)
M-629 (live)
5-633 (live)
ATK treats reactive hazardous wastes on-site at the M-136 andM-225 open burning grounds.
Wastewater is collected and treated on site and discharged through one of two UPDES permitted
M-705S (inert
E-501 (inert)
400 ea. 55 gallon drum equivalent
32 ea.55 gallon drum equivalent
160 ea. 55 gallon drum equivalent
1506,5Q00lbs 1.3 I 20,000lbs 1.1
55,000lbs 1.3 / l,500lbs 1.1
1 ea. 55 gallon drum (pure) equivalent
110,000lbs 1.3 / 55,000lbs 1.1
75,000 lbs 1.3/20,000 lbs 1.1
I arr Launch Systems Ir,". -p.o,ntv fuly+.le+ember 201!5
uTD009081357Attachment 5 - Closure Plan
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 214.tt2(b)(6) and uAC R315-8-7]
Section 1.4.1 of this plan provides an estimated closure schedule for all activities associated with
implernentation 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 R3t5-S-71
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. A1l
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 R3l5-S-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 2$4.ll2 andz64.ll4 and UAC R]15-g-7J
All permitted treatment and storage facilities have been designed and managed to minimize
possible contamination. This includes chemical resistant concrete coatings, blind containment
sumps, regular inspections, regular maintenance, and prompt cleanup of any spilled materials.
These practices should greatly reduce the need for significant remediation efforts upon closure.
1.5.1 Soil and Groundwater Sampling
Groundwater sampling is not covered under this plan. A groundwater monitoring program is
currently in place as discussed above. Soil sampling should not be required for any of the
permitted facilities, except for the two burn ground areas (M-136 and M-225) and 5-633.
Detailed sampling plans will be submitted in accordance with Permit Condition III.J.2. Sampleswill 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 atM-225 and eight soil samples will be collected at 3-633.
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
I err Launch Systems Ir". -P--ty
Attachment 5 - Closure Plan
JulyNeve+nber 20165
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.
Analyical and extraction methods to be used are shown below.
1.5. 1.1 Sampling Equipment Decontamination Procedures
A11field 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 tobehazardous 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. Arry waste determined not
to be hazardous under EPA regulations will be sent via third party to anon-hazardous landfill for
disposal.
A field log will be maintained to track and identifiz 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
Analytical and Extraction Methods
Parameter Analvtical procedure Extraction Procedure
Volatiles SW-846;82608 SW-846; 5030B(W), 50355
Serni-Volatiles SW-846;8270C SW-846; 35 1 OC(W), 3550(3)
RCRA Metals SW-846;6010B SW-846: 3 005A(W).747 1 A(S)
Mercury SW-846; 7470N7471A SW-846:7470A(W). 7 47 | A$\
Explosives SW-846;8330 Modified SW-846; 8330 Modified
Perchlorate EPA 314.0 EPA 314.0
I Aff Launch Systems fr". -P.o.t JulyNeven+b€r 20105
uTD009081 3s7Attachment 5 - Closure Plan
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-l0l-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-S-7]
The maximum inventory of hazardous waste on hand at any glven 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 willbe 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), and264.114 and UAC R315-8-7I
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 buming 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 analyzedas described in 1.5.1.
All facilities except for M-136, M-225,M-629 and 5-633 are designed with secondary
containment. The secondary containment includes a concrete pad with curbing and blind sump
to simplifu cleaning. The containment pads and sumps are coated with a chemical resistant
I aff Launch Systems rr". -n*rnt,y fu.lyN€vemb€r 20165
uTD009081357Attachment 5 - Closure Plan
epoxy to prevent liquid migration through the concrete. Secondary containments are inspected
daily, when in use, and maintained as needed. After rernoval of all containerized waste, the
liquid chemical containment pads of facilities E-501, M-186, M-705S, andT-298 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 characteized 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
Ri15-8-9.9, R315-807, and R315-3-5(bX13)l
Non-reactivehazardous waste requiring off-site disposal will be placed in a UN or a bulk
USDOT authorized containers for offsite shipment to permiffed 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 Rt15-8-7]
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 engineei's
registration will be provided upon request.
3.0 Closure Cost Estimate [40 CFR264.142]
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 PIan
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 R3 l5-8-l , 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.
ATTACHMENT 9
CONTAINER MANAGEMENT PROCEDURES
I arr Launch Systons In.. - ton,o.y
Attachment 9 - Container Managernent Jg.lyN€vemb€r 20165
uTD009081357
CONTENTS
USE AND MANAGEMENT OF CONTAINERS.. .........39-1 PURPOSE AND SCOPE .......................39-1.1 Facility Description ..............39-2 MANAGEMENT OF CONTAINERS ,.....,.............49-2-l T1,pes of Containers for Storage ............49-2-2 Waste Compatibility............. .................59-2-3 Storage of Containers............. ................69-2-4 Inspections .........g9-2-5 Operating Record. .... .......99-3 LAB PACKS AND WASTE CONSOLIDATION ....................89-3-1 Lab Pack Preparation ...........g9-3-2 Lab Pack Labeling.... ............99-3-3 Containment Sealer........ ........................99-3-4 Lab Pack Compatibility............. ............99-4 CONTAINMENT ................99-4-l Capacity of Containment ............ ...........99-4-2 Containment Sealer... .........109-4-3 Removal of Free Liquids From
Containment Area......... .....10
RLIN-ON AND RLTN-OFF CONTROL .................I1
REOUIREMENTS FOR IGNITABLE AND REACTIVEWASTES ........12
9-5
9-6
I err Launch Systems rn.. -ton,oo
Attachment 9 - Container Management
9-1
fulyllevember 201S5
uTD00908l3s7
USE AND MANAGEMENT OF CONTAINERS
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 5-633 and solid propellant storage in burn
trays and at Burn station 14 atM-L36 in accordance with the Division of
Solid and Hazardous waste Administrative Rules R315-g-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
tlpes 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.
Facility Description
The M-186 storage pad is permitted for the storage of the hazardous
wastes identified in Permit condition III.B.l. 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-l96 storage
facility is shown in Figure E-l 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.l.
The room is equipped with plastic containers to keep incompatibre
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-l of Attachment 6.
9-1.1
ATK Launch Systems ln". -torao,y
Attachment 9 - Container Management
9-2
9-2.1
fulyN€vemb€r 20165
uTD00908 r 3s7
M-629 is designed for storage of solid propellant/explosives. This
building is sited for the maximum quantity of propellanUexplosives based
on Quantity/Distance, DoD siting criteria found in the contractor safety
manual, 4145.26m. Each building is set up to permit proper gounding
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 irea. 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 5-633 storage pad is shown in Figure J-1 of Attachment 6.
The storage of solid propellant wastes ffit M-136 +
is includes waste stored in
containers placed in bum 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.
MANAGEMENT OF CONTAINERS
Types of Containers for Storaee
The containers to be used for storage, lab packing, or consolidation at
M-186, E-501, and M-705S will meet the IIN 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; md32 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 5-633 include rocket motor cases, covered drums, boxes,
plastic bags, woven bags, slids, and US Department of Transportation
(Dor) approved shipping containers. The standard containers used at the
Facility are described in Attachment 1 1, Section 1 1.4.
AllsolidreactivewasteffindstoredatM-136willbe
stored in containers as described in Attachment 1 1.4. Storage of these
containers is permitted in liquid tight burn trays or on the ground at Bum
Station 14 for intact rocket motors. All containers will be kept closed
during storage.
4
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Attachment 9 - Container Management
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uTD00908l3s7
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 5-633
General Compatibility Groups
1. Flammable/combustibleliquids
and non-fl ammable solvents
2. Corrosives (acids)
3. Corrosives (bases)
4. Reactive Chemicals
5. Toxic Chernicals
6. Explosives
DOT Hazard Class in Group
a. Flammable Liquids
b. Combustible Liquids
a. Corrosive Liquids (acids only)
a. Corrosive Liquids (bases only)
a. Organic Peroxides
b. Oxidizes
Toxic
Infectious
1.1
1.3
a.
b.
a.
b.
I arr Launch Systems rn.. - tn.oo
Attachment 9 - Container Managernent
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uTD00908l3s7
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-l86, 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 R3 I 5-5-3.34) and R3 I 5-5-3.3 I .
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 andlor pallet jack is used to move the pallet into the storage area.
Drums or containers in the holding bays at M-l86 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.
A11drums 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 spac-e 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, 5-633 and
M-136 will be stored so that they may be readily inspected and hazardous
waste labels are visible. 55-gallon drums maybe stacked at a maximum of
two high at storage areas M-186 and E-501 only. Containers stored at
M-629 and 5-633 that can be safely stacked, such as flare or munition
boxes, maybe stacked to a maximum height of 6 feet.
ATK Launch Systems rn". - tonro.,
Attachment 9 - Container Management
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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
haining as appropriate.
M-629 and 5-633
All waste propellant/explosives stored atM-629 and 5-633 must be
entered into the operating record. Building and storage pad inspections
must begin upon first receipt of material and end when allhazardous 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 CFR262.34 (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 Station14 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
R3 15-5-3.34) and R3 I 5-5-3.3 1.
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 Attachment2. Once the container or waste rocket
motor !r received +em-ef+siteil is placed in a burn tray or Bum Station
14, the date of the placement shall be added to the hazardous waste label;
.
Containers stored in burn trays at M-I36 shall rernain 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.
I arr Launch Systems rr". -ton,ooAttachment 9 - Container Management
9-2.4
9-2.5
9-3
9-3.1
fuly}',levember 201[5
uTD0090813s7
lnspections
All container storage areas are inspected on at least a weekly basis.
Details of inspection requirements for the storage areas are outlined in
Attachment2. lf 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.
Operatinq Record
A1l waste brought into the M-186, E-501, M-705S, M-629, 5-633 and
M-l36 storage areas are entered into a hazardous waste log compliant with
R315-8-5.3. This 1og 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.
LAB PACKS AND WASTE CONSOLIDATION
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 cFR262 Subpart c (incorporated by reference in
R3 I 5-5-3.3 4) andR3 1 5-5-3.3 1.
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 Dor hazard classification. The materials are generalry 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.
8
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Attachment 9 - Container Managernent
9-3.2 Lab Pack Labelins
fu$'levember 201f5
uTD00908l3s7
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-l86 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 byusing 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 requirernents of the
disposal company.
9.4 CONTAINMENT
9-4.1 Capacit.v of Containment
A1l the container storage areas and consolidationllab 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.
ATK Launch Systems rn". -tor,oo
Attachment 9 - Container Management
9-4.2
9-4.3
fu\Novemb€r 20165
uTD00908l3s7
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-I36 Thermal
Treatment Area. Any rain water falling on the pad is collected in the
M-l36 storm water run-on/run-off control systern.
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 ftorm 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.
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 ashazardous wastes until waste analysis or inspection dictates
otherwise.
TABLE 9-5A
Containment Capacity of Drum Storage Areas
Storage Container Number of Drums
to be Stored
Needed
Containment
Containment
Available
M-l86 Storase Bav 80 Drums 440 Gal 980 Gal
E-501 Storaee 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* lncludes Palletainers
lo
ATK Launch Systems ,n.. - tonroo
Attachment 9 - Container Management
July}'{eveneber 201!5
uTD00908r 3s7
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 classif,iing the contents. If the analysis
indicates the liquid is ahazardous waste as defined by the Division of
Solid and Hazardous waste Administrative Rules R3l5-2, then the drums
will continue to be managed as ahazardous 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 tlpically less than
l-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 Attachmertt2. 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-l36 are permitted for the storage of eff,site-solidreactivewastesincontainers@,Someofthese
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 hay. lnspection requirements for burn trays and the
accumulation of liquids are outlined in Attachment2.
If the collected material is a hazardous waste under R315-2, it shall be
managed as ahazardous waste in accordance with all applicable
requirements of the state of UtahHazardous 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.
ll
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9-5
Attachment 9 - Container Managernent
lt yl^lov€mber 201[5
uTD009081357
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 systern. 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-l86 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
ona24-hotr,25-year storm event and were submitted with the part B
Permit Application.
The terrain around the burn grounds and storage pad 5-633 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 ll-2, andAttachment
6 Figure J-l.
ln 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.
REOUIREMENTS FOR IGNITABLE AND REACTIVE WASTES
All container storage areas are located more then 50 feet from facility
property lines. The aeial photograph contained in Attachment 6
(Figure 6A) shows the property boundaries and facility location.
9-6
12
ATK launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
July}+evember 20165
ATTACHMENT 11
M-136 and M-225 Thermal Treatment Operations
I l-1
ATK Launch Systems
Promontory Facility
UTD 009081357
11.0
11.1
Part B Operational Plat
Process Information
JUlyltevember 20165
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 followingGxt.
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-l36, located centrally to the two main
manufacturing sites; and (2) M-225 located in a remote development location called
Plant Itr.
M-l36 is the primary treatrnent area for conducting open buming at the Promontory
facility. Open detonation is also conducted at M-136 which is a secured fenced facility
within the main facility fence.
TheM-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 e.rrdM-225 teatnent areas are fenced and are locatod within a contolled and
fenced facility that is patolled and maintaind by a seurity departnent. The teatnent
areas have waming signs posted aroturd the perimeter. The vegetation is contoolled within
the treatnent areas through application of herbicide and putting in place loads of gravel
and road base. Surrotrnding both teatnnent areas are a large systerr of fire breals that are
constucted using large equipment to till and cultivate a large sfrip of land removing any
vegetation The systern of fire breaks are designed to contain a fire within its boundaries.
Contained within the boundaries of the M-136 freatment area are twelve fonner surface
impotmdments called Liquid Thennal Treatnent Areas (LI-IAs). These
were used for the disposal of hazardous waste and wastewater and then capped and closed
The units are currenfly under post closure care and managed ttrough a Post Closure Permit
which includes requirerrents for groundwater and corrective action The Post-
Closure groundwater monitoring program includes all wells around the M-136 andM-225
teatnent areas as part of the monitoring systern. These wells are routinely
monitorod thorough the permit requiranents 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
characteized 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
1t-2
ATK launch Systems
Promontory Facility
LI"ID 009081357
Part B Operational Plan
Process Information
JulyNevenaber 20165
Blue Creek Valley at an elevationof 4,250 feet AMSL. As a result, the surrounding
environment extending ontto 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, Aizona, 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 gavel and are characteized 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 characteizedby a broad gradation of sediments from
clay-size fines to boulders as large as 3 feet in diameter.
ITYDROGEOLOGY
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,
I 1-3
ATK launch Systems
Promontory Facility
UTD 009081357
Part B Operational Plan
Process Information
July}+evember 20165
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 ofdissolved solids range from 400
to over 12,000 mgll. 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 forthe ATK facility,theZl-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.
ayear. The average area evapotranspiration rate is 46.6 inches. The consistently low
precipitation and high evaporation allow little ifany 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 srunmer aftemoons. 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 ll 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.
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Blue Creek is the only perennial stream in the valley drainage basin and is the closest
water body to the M-l36 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 fanns and ranching activities. Low growing perennial grasses and shrubs
characteize 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.
WASTE CHARACTERIZATION
Wastes will be characterized to identifu hazardous properties to ensure they are
properly managed. The Waste Analysis Plan (see Attachment 1) will be used to
characteize and classifu reactive wastes.
REACTIVE WASTE DESCRIPTION
The primary products produced at the facility include solid rocket motors, military and
aviation flares, and high explosiveArigh 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
quantrty, 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 ofpropellants 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
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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.
II.4 REACTIVE WASTE GENERATION AI\D 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:
o 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.
o 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 tlpically 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 CromhmiqrM sack containers.
o f iberboard 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.
o 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
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and other suspended solids are accumulated , and treated and disposed of in
accordance with the applicable hazardous waste management rules.
o Other Containers -Large blocks of cured propellant are containenzedby 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 rn a tray for up to 1 4 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
I 1.5.
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 ald reactive wastes from the operating buildings. The
collection sheds are constructed of wood or comrgated 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 IV[1Q9-IV[1!]3
for storaqe. or to the M-l36 or M-225 burning ground. @
M-+36
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 identifu 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
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location of propellant and explosive operating buildings with regard to public property
(highways, parks, etc,) and private property. Atl buildings used for temporarystorage
of waste explosives, including the temporary storage sheds, are correctly sited with
respect to the applicable quantity-distance rules.
QUATITITY DISTAI\CE DETERMINATION
The facility uses the Departrnent of Defense (DOD) guidance to calculate quantity
distance relationships. The evaluation was conducted according to NAVSEA op5,
Volume 1, Revision 4,ParagraphlI-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 = 5w18. where w is the weight orbhss 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 fonnula: D:18w1/3. where w is tlie weight of a class 1.1 explosive and D
is the safe distance. The fomrula 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.
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 R3l5-5 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:
o ID# - container identification numbero Date - accumulation dateo Building # - identifies where the waste was generated;o RWDI# - identifies the reactive waste disposal instructiono Profile # - identifies the profileo Quantity of PEP - quantity of propellant, explosive orpyrotechnic material ;o Quantity of Contaminated waste - Explosive and total weight of the container;o Material Description - description of the materialo Propellant name - describes the propellant by type, progrcm other identifiero 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-l36 andM-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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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
trackedusingpapercopiesuntilthe electronic system is operable. Inthe eventthis
occurs, ATK will transfer all infonnation to the electronic system within 72 hours of
the system becoming operational again.
REACTTVE 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.
o 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.
o M136- trays at M-l36 can be used to store waste received from off-site for up to 14
days. A11 containers of waste must be closed, labeled and managed in accordance
with R315-5 of the UAC.
o 5-633- 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. 5-633 is approximately 100' x 100'
in size. It is secured by a perimeter fence, a vehicle access gatethatcan 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.
TREATMENT OF REACTTYE 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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11.8.1 OF'F.SITE TREATMENT OF REACTTVE WASTB
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-l36 andM-225 facilities are thermal treatment units designed to treat reactive
hazardous wastes using open burning or open detonation. Treatment by open burning
at M-l36 is limited to a maximum of 1506,5Q00. 122.000. or 1.200 pounds per day
dependins on the treatment scenario.
per{a}k Treatment by open detonation will be conducted at burn stations 13 and 14
only, and is limited to 600 pounds per burn stationer*ent. Figure l1-2 shows the
security fence, control bunker, and vehicle access points for M-l36.
Treatment by open burning atM-225 is limited to a maximum of 4,500 pounds per day.
Each burn station l-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 intheM-225 open detonation
area. Figure 11-2 shows the security fence and vehicle access points forM-225.
The process flow for open burning at both treatment areas is identified below:
1. Pre-plannedActivities
2. Placement of Waste in Treatment Units, Wiring and Ignition3. 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.
1T.8.2.1 PRE- PLACEMENT ACTTWTIES
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
veriff 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.
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3. Trays which do not meet the inspection criteria have been removed from service.
II.8.2.2 PLACEMENT OF'WASTE IN TREATMENT I]NITS
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:
o 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 4.36 grade
steel ranging thicknesses of 3/8", y2",3/4", and 1 inch.
o Clamshell Disposal Trays- Used for the disposal of items that have the potential
to be propulsive. Typical construction is a square welded box l-inch thick, 4.36
steel plate with a vented lid that enables treatment of potentially propulsive items,
while safely containing the propulsive energy.
o Restraining Trays are typically constructed of l-inch thick 4.36 steel plate
welded into a square box that is filled with sand. There are several different
designs for restraining trays which include: (l) 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 ofthe open end ofthe 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.
o 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 bum 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 offJoaded 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.
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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
described in 1 1.8.2.5.
11.8.2.3 WIRING AI\D 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 gleater 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 wire2. Bag Igniters - Propellant, explosive, pyrotechnic with electric match or other
electric initiation device.
3. Blasting Caps - Small amount of primary explosive4. Electric Matches - wire attached to small explosive device5. 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 source7. 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:
l. Diesel Fuel
tr-2. Alcohol
*3-Wood (e.g. Pallets)
3-.4. Propellant
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The burning ground operators veri8/ the treatment area has been evacuated ofall
personnel before proceeding with ignition. The burning ground operators retreat to the
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 perfonning 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 retum 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 retum
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 priorto igniting the waste. Notification must be made
the same day as the waste is treated.
II.8.2.4 POST-BT]RN INSPECTION AI\D CLEAI\I]P
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 prelimilary inspection is perforrned before the cleanup
begins. This inspection includes checking for hot spots and checking for unbumed
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 detennine if there is
any unburned reactive material. Unburned reactive material will be rebumed.
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
bum. 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 5Yo 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.
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Unburned waste that results from a misfire or an interrupted ignition can remain on a
burn tray. An intemrpted ignition occurs when anything greater than 5olo of the waste
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 bum from
occurring by 6pm of the following day, the waste will be covered and the bum 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 9O-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 I 1.8.2.5. 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. lf atray 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 ir;.:ay 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 andanalyzed using the protocol described in Attachment 1.
l. It could potentially contain 40 CFR 26I.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.
RECEIYING 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
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permitted storage units. A1l off-site generated hazardous waste will be reviewed and
approved prior to being accepted using the following criteria:
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 EIYVIRONMENTAL PERFORMAI\CE STAI\DARDS
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
ofconcern have been or are in the process ofbeing 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 environmeut due to
migration of waste constituents in the ground water or subsurface environment. Topics
that must be considered are:
o
o
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 strroundrngarca;
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;
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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
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:
o The volume and physical and chemical characteristics of the waste in the unit;
o The effectiveness and reliability of containing, confining, and collecting systems
and structures in preventing migration;
o The hydrologic characteristics of the unit and the surrounding area, including the
topography ofthe land around the unit;
o The patterns of precipitation in the region;
o The quantity, qualrty, and direction of ground-water flow;
o The proximity of the unit to surface waters;
o The current and potential uses of nearby surface waters and any water quality
standards established for those surface waters;
o The existing quality of surface waters and surface soils, including other sources
of contamination and their cumulative impact on surface waters and surface
soils;
o The patterns of land use in the region;
o The potential for health risls caused by human exposure to waste constituents;
and
o 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:
o 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;o The effectiveness and reliability of systems and structures to reduce or
prevent emissions of hazardous constituents to the air;o The operating characteristics of the unit;o The atmospheric, meteorologic, and topographic characteristics of the unit
and the surrounding area;o The existing quality of the air, including other sources of contamination and
their cumulative impact on the air;o The potential for health risks caused by human exposure to waste
constifuents; ando The potential for damage to domestic animals, wildlife, crops, vegetation,
and physical structures caused by exposure to waste constituents.
I 1.10.1 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 conseryative and will not adversely affect
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human health or the environment. Control measures include, but are not
following:
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limited to the
Human Health Risk Assessment - a Human Health Risk Assessment (HHRA) has been
is$eing:conducted to evaluate the risk to the public from open burning and open
detonation operations at the facility. Tasks associated with the HHRA included
developing an air dispersion model, evaluating sources, source parameters, and waste
materials, and characteizing emissions. The HHRA willaddresses the following
environmental performance related concerns:
t
I
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
(IillRAP) for Hazardous Waste Combustion Facilities (U.S. EPA, September 2005). The
completed HHRA Protocol and Report willbas beq reviewed and approved by the Utah
Division of Waste Manasement Selid and Radiation Controll{azaCeusW*ste. Limits on
OBOD operations have beenwillbe based on this assessment;e+apprepriate,-enee
ffi
Bcological 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 verifr 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 DSI{W.
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The groundwater monitoring program addresses the following concerns:
o The hydrologic and geologic characteristics ofthe unit and the surrounding areao The existing quality of groundwater, including other sources of contamination and
their cumulative impact on the groundwater;o The quantity and direction of groundwater flow; andr 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 andM-225 Thermal
Treatment Areas. The plan will identif, analytes, sampling protocols and data quality
objectives. ln 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, an annual report indicating chanses
to dose-response factors for the three classes of detected COPCs: chromium (total and
hexavalent)" 2.3.7.8-TCDD TE. and detected potentially carcinogenic PAIIs
(benzo(a)anthracene. benzo(k)fluoranthene. chrvsene and indeno( 1.2.3-cd)p),rene)the
, 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-l36 andM-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 ofprecipitation, 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 verifu 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.
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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.
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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