DSHW-2016-011913 - 0901a06880656fae

DSHW-2016-011913 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director

August 12, 2016

George Gooch, Manager
Environmental Services
ATK Launch Systems – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Class 1 Modification, Hazardous Waste Storage and Post-Closure Permits
ATK Launch Systems – Promontory Facility
UTD009081357

Dear Mr. Gooch:

The Division of Waste Management and Radiation Control has completed its review of your request to
modify ATK Promontory’s Permits due to a change in ownership of the facility. Based on Appendix I
to 40 CFR §270.42, this requested change is classified as a Class 1 modification with prior approval
from the Director. The specific changes outlined in your letter dated July 5, 2016 are hereby approved.

The changes have been incorporated into Module 1 of ATK’s Hazardous Waste Storage Permit to reflect
that Orbital ATK, Inc. is the owner of the facility and ATK Launch Systems Inc. will continue to
function as the operator of the facility. A copy of the revised Module 1 is enclosed with this letter. In
addition, amended signature pages for the Hazardous Waste Storage and Post-Closure Permits are also
enclosed.

If you have any questions, please call Jeff Vandel at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control

(Over)
STA/JV/jr

Enclosures: Revised Module 1 (DSHW-2014-004375)
Amended signature pages for the Hazardous Waste Storage and Post-
Closure Permits (DSHW-2016-011919 and DSHW-2016-011920)

c: Blair Palmer, ATK Launch Systems
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department
David Duster, USEPA Region 8
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MODULE I - STANDARD PERMIT CONDITIONS

I.A. EFFECT OF PERMIT

I.A.1. The Permittee is allowed to store hazardous waste in containers, treat hydrazine, by
dilution, in containers and treat reactive hazardous waste by open burning or open
detonation at the ATK Launch Systems-Promontory (ATK) Facility, Box Elder County,
Utah in accordance with the conditions of this Permit. In addition, the Permittee is
allowed to store waste solid rocket motors at the facility in accordance with the
conditions of this Permit. The facility owner is Orbital ATK, Inc., and the facility
operator is ATK Launch Systems Inc., a wholly owned subsidiary of Orbital ATK, Inc.
Any treatment, storage, or disposal of hazardous waste not authorized in this Permit, is
prohibited.

I.A.2. Compliance with this Permit, during its term, constitutes compliance for purposes of
enforcement with applicable sections of Utah Administrative Code (UAC) R315 only
for those management practices specifically authorized by this Permit.

I.A.3. Issuance of this Permit does not convey property rights of any sort or any exclusive
privilege; nor does it authorize any injury to persons or property, any invasion of other
private rights, or any infringement of State or local law or regulations.

I.A.4. This Permit has been developed in accordance with the applicable requirements of UAC
R315-1 through 101 of the Utah Hazardous Waste Management Rules. All conditions
within this Permit will supercede conflicting statements, requirements, or procedures
found within UAC R315-1 through 101 or attachments to this Permit.
I.B. ENFORCEABILITY I.B.1 Violations documented through the enforcement process pursuant to Utah Code Annotated (UCA) 19-6-112 may result in penalties assessed in accordance with UAC R315-102, the Penalty Policy. I.C. OTHER AUTHORITY I.C.1. The Director expressly reserves any right of entry provided by law and any authority to order or perform emergency or other response activities as authorized by law. I.D. PERMIT ACTIONS I.D.1. This Permit may be modified, revoked and reissued, or terminated for cause, as specified in UAC R315-3-4. If the Director determines that cause exists to modify, revoke, and reissue, or terminate this Permit, the action will proceed in accordance with UAC R315-4-1.5. The filing of a request for a permit modification, revocation, reissuance, termination, or the notification of planned changes or anticipated noncompliance on the part of the Permittee does not stay the applicability or enforceability of any permit condition.
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I.D.2. The Director may modify this Permit, in accordance with UAC R315-3-4.2, when the
standards or regulations on which the Permit was based have been changed by statute,
through promulgation of new or amended standards or regulations, or by judicial
decision after the effective date of this Permit.

I.D.3. The Permit may be modified at the request of the Permittee according to the procedures
of UAC R315-3-4.3.

I.D.4. All Permit conditions supersede conflicting statements, requirements or procedures
found in the Attachments to the Permit.

I.D.5 If a conflict exists between conditions in this Permit, the most stringent condition, as
determined by the Director, shall be met.

I.D.6. In accordance with the Utah Solid and Hazardous Waste Act, UCA, 19-6-108(13), this
Permit shall be reviewed no later than five (5) years from the date of issuance or
renewal and subsequently modified, if necessary.

I.E. SEVERABILITY

I.E.1. The provisions of this Permit are severable and if any provision of this Permit, or the
application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances and the remainder of this Permit
shall not be affected thereby. Invalidation of any State or federal statutory or regulatory
provision which forms the basis for any condition of this Permit does not affect the
validity of any other state or federal statutory or regulatory basis for said condition.

I.F. DUTIES TO COMPLY

I.F.1. The Permittee shall comply with all conditions of this Permit, except to the extent and
for the duration such noncompliance is authorized by an Emergency Permit issued in
accordance with UAC R315-3-6.2. Any permit noncompliance, other than
noncompliance authorized by an Emergency Permit, constitutes a violation of the Utah
Solid and Hazardous Waste Act, and is grounds for enforcement action; for Permit
termination, revocation and reissuance, or modification; or for denial of a Permit
renewal application; or a combination of enforcement action and any of the other listed
remedies.

I.F.2. Compliance with the terms of this Permit does not constitute a defense to any order
issued or any action brought under Sections 3007, 3008, 3013, or 7003 of RCRA (42
U.S.C. Sections 6927, 6928, 6934 and 6973), Section 106(a), 104, or 107 of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (42
U.S.C. 9606(a), 9604, and 9607, commonly known as CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), or any other State or
federal law providing for protection of human health or the environment from any
imminent and substantial endangerment.

I.G. DUTY TO REAPPLY

I.G.1. If the Permittee wishes, or is required by the Executive Secretary, to continue an
activity allowed by this Permit after the expiration date of this Permit, the Permittee
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shall submit a complete application for a new permit, in accordance with UAC R315-3-
2.1g and UAC R315-3-3.1(b), at least 180 days before this Permit expires.

I.H. PERMIT EXPIRATION

I.H.1. This Permit shall be effective for ten years from the date it is issued.

I.I. CONTINUATION OF EXPIRING PERMIT

I.I.1. This Permit and all conditions herein shall continue in force until the effective date of a
new permit, if the Permittee has submitted a timely and complete application, in
accordance with applicable requirements of UAC R315-3 and R315-4, and through no
fault of the Permittee, the Director has neither issued nor denied a new permit under
UAC R315-3-5.2 on or before the expiration date of this permit.

I.J. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE

I.J.1. It shall not be a defense for the Permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the conditions of this Permit.

I.K. DUTY TO MITIGATE

I.K.1. In the event of noncompliance with the Permit, the Permittee shall take all reasonable
steps to minimize releases of hazardous waste, hazardous waste constituents, and
perchlorate salts to the environment resulting from the noncompliance, and shall carry
out such measures as are reasonable to prevent significant adverse impacts on human
health or the environment.

I.L. PROPER OPERATION AND MAINTENANCE

I.L.1. The Permittee shall, at all times, properly operate and maintain all facilities and systems
of treatment and control (and related appurtenances) which are installed or used by the
Permittee to achieve compliance with the conditions of this Permit. Proper operation
and maintenance includes effective performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary equipment or similar systems only when necessary to achieve
compliance with the conditions of this Permit.

I.M. DUTY TO PROVIDE INFORMATION

I.M.1. The Permittee shall furnish to the Director, within a reasonable time, any relevant
information which the Director may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this Permit, or to determine
compliance with this Permit. The Permittee shall also furnish to the Director upon
request, copies of records required to be kept by this Permit.

I.N. INSPECTION AND ENTRY

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I.N.1. Pursuant to the UCA 19-6-109, the Permittee shall allow the Director, or an authorized
representative, upon the presentation of credentials and other documents, as may be
required by law, to:

I.N.1.a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or
activity is located or conducted, or where records are kept as required by the conditions
of this Permit;

I.N.1.b. Have access to and copy, at reasonable times, any records that are kept as required by
the conditions of this Permit;

I.N.1.c. Inspect at reasonable times any portion of the Facility, equipment (including monitoring
and control equipment), practices, or operations regulated or required under this Permit;

I.N.1.d. Sample or monitor, at reasonable times, for the purposes of assuring permit compliance
or as otherwise authorized by the Utah Solid and Hazardous Waste Act, any substances
or parameters at any location; and

I.N.1.e. Make record of inspection by photographic, electronic, videotape, or any other
reasonable medium. No audio recording devices shall be used without notice to all
individuals in recording range prior to activation of the recording device. Photographic
and video recording shall comply with the safety and security requirements of the
Permittee.

I.O. MONITORING AND RECORDS

I.O.1. The Permittee shall retain records of all monitoring information, including all
calibration and maintenance records and, where applicable, all original strip chart
recordings (or equivalent recordings) for continuous monitoring instrumentation, copies
of all reports and records required by this Permit, the waste minimization certification
required by UAC R315-8-5.3. (40 CFR § 264.73(b)(9) incorporated by reference), and
records of all data used to comply with the conditions of this Permit, including any and
all data to support human health and ecological risk assessments for cleanup and closure
activities. All of the above referenced material shall be retained for a period of at least
three years from the date of the sample, measurement, report, certification, or recording
unless a longer retention period for certain information is required by other conditions
of this Permit. The three-year period may be extended by the Director at any time by
written notification to the Permittee. The retention times are automatically extended
during the course of any unresolved enforcement action regarding the facility to three
years beyond the conclusion of the enforcement action. Recordkeeping may be
accomplished using original documents, xerographic copies, document replicas, electronic
facsimiles, electronic disk, CD-ROM computer drive files, microfilm, microfiche, photograph,
magnetic tape or any other reasonable medium or similar recordkeeping technique. Any
recordkeeping system shall be capable of reproducing complete, accurate and legible records.

I.O.2. Pursuant to UAC R315-3-3.1(j)(3), records of monitoring information shall specify at a
minimum:

I.O.2.a. The date(s), exact place, and times of sampling or measurements;

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I.O.2.b. The name(s), title(s), and affiliation of individual(s) who performed the sampling or
measurements;

I.O.2.c. The date(s) analyses were performed;

I.O.2.d. The individual(s) who performed the analyses;

I.O.2.e. The analytical techniques or methods used; and

I.O.2.f. The results of such analyses.

I.O.3. Samples and measurements taken for the purpose of monitoring shall be representative
of the monitored activity. The method used to obtain a representative sample of the
waste to be analyzed shall be the appropriate method from UAC R315-50-6 or as
specified or modified by this Permit.. Laboratory methods shall be those specified in
“Test Methods for Evaluating Solid Waste; Physical/Chemical Methods SW-846 (Third
Edition, November 1986)” or most currently promulgated edition, “Standard Methods
for Examination of Water and Wastewater (17th Edition, 1989)” or most currently
promulgated edition; or an equivalent method as approved by the Director. The
analysis of all samples shall be conducted by laboratories certified by the State of Utah.

I.O.4. When requesting substitute or additional analytical methods, the Permittee shall submit
to the Director a request for substitution of analytical methods which are equivalent to
the methods specifically approved for use in this permit, in accordance with UAC
R315-3-4.3. The request shall provide information demonstrating that the proposed
methods are equivalent or superior in terms of sensitivity, accuracy, and precision (i.e.
reproducibility).

I.P. REPORTING PLANNED CHANGES

I.P.1. The Permittee shall give written notice to the Director 60 days prior to any planned
physical alterations or additions to any Hazardous Waste Management Unit (HWMU)
or system being permitted or previously permitted in accordance with UAC R315-3-
3.1(l) and R315-3-4.3. Planned physical alterations or additions shall include all
changes in any hazardous and solid waste activities, and to any non-waste underground
storage tanks regulated under UAC R315-202 (40 CFR 280). Construction or operation
of new or modified HWMUs shall not begin unless the provisions of UAC R315-4-1.5
are met.

I.Q. REPORTING ANTICIPATED NONCOMPLIANCE

I.Q.1. The Permittee shall give written notice to the Director 30 days prior to any planned
changes in the permitted Facility or activity which may result in noncompliance with
requirements of this Permit. Advance notice shall not constitute a defense for any
noncompliance.

I.R. CERTIFICATION OF CONSTRUCTION OR MODIFICATION

I.R.1. The Permittee shall not commence storage, treatment, or disposal of hazardous waste in
a new hazardous waste management unit or in a modified portion of an existing
permitted hazardous waste management unit, except as provided in UAC R315-3-4.3,
until:
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I.R.1.a. The Permittee has submitted to the Director by certified mail, express mail or hand
delivery:

I.R.1.a.i. A letter signed by the Permittee and an independent, Utah registered professional
engineer qualified by experience and education in the appropriate engineering field
certifying that the unit has been constructed or modified in accordance with the
approved modification request and this Permit; and

I.R.1.a.ii. As-built engineering drawings and specifications as appropriate.

I.R.1.b.. The Director or designated representative has reviewed and inspected the modified or
newly constructed unit and has notified the Permittee in writing that the unit was found
in compliance with the conditions of this Permit.

I.R.2. If within fifteen (15) calendar days of the date of receipt of the letter required by Permit
Condition I.R.1.a.i., the Permittee has not received notice from the Director, of the
intent to inspect, prior inspection is waived and the Permittee may commence treatment,
storage, or disposal of hazardous waste in the permitted unit, if certified in accordance
with Condition I.R.1.a.i.

I.S. TRANSFER OF PERMIT

I.S.1. This Permit may be transferred to a new owner or operator only if it is modified or
revoked and reissued pursuant to UAC R315-3-4.1 and R315-3-4.2(b)(2). Prior to
transferring ownership or operation of the Facility during its operating life, the
Permittee shall notify the new owner or operator, in writing, of the applicable
requirements of UAC R315-1 through R315-101, and this Permit. Failure by the
Permittee to notify the new owner or operator of these requirements and this Permit in
no way relieves the new owner or operator of his obligation to comply with all
applicable requirements of the Rules and this Permit.

I.T. TWENTY-FOUR HOUR REPORTING

I.T.1. In accordance with UAC R315-3-3.1(l)(6)(i), the Permittee shall orally report to the
Director any noncompliance with this Permit which may endanger human health or the
environment. Any such information shall be reported as soon as possible, but not later
than twenty-four (24) hours from the time the Permittee becomes aware of the
noncompliance.

I.T.2. In accordance with UAC R315-9-1(b), the Permittee shall immediately report to the
Director any spill of any hazardous waste or material which, when spilled becomes a
hazardous waste, if the spilled quantity exceeds 100 kilograms or a lesser amount if
there is a potential for endangerment to human health or the environment, or exceeds 1
kilogram if the material is an acute hazardous waste as defined by UAC R315-9-1(b)(2).

I.T.3. The Permittee shall immediately report to the Director any spill that contains
perchlorate, if the spilled quantity exceeds 100 kilograms and the perchlorate
concentration of the spilled material is greater than 15 ug/L. Any such information
shall be reported as soon as possible, but not later than 24 hours from the spill
occurrence.

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I.T.4. The non-compliance and spill reports shall include, but not be limited to, the following:

I.T.4.a. Information concerning the release of any hazardous waste which may endanger public
drinking water supplies; and

I.T.4.b. Any information of a release or discharge of hazardous waste, or of a fire, or explosion
at the Facility, which could threaten human health or the environment.

I.T.4.c. A description of the occurrence and its cause;

I.T.4.d. The name, title, and telephone number of the individual reporting;

I.T.4.e. The name, address, and telephone number of the owner or operator;

I.T.4.f. The name, address, and telephone number of the Facility;

I.T.4.g. The date, time, and type of the incident;

I.T.4.h. The location and cause of the incident;

I.T.4.i. The name and quantity of materials involved;

I.T.4.j. The extent of injuries, if any;

I.T.4.k. An assessment of actual or potential hazard to the environment and human health,
where this is applicable;

I.T.4.l. A description of any emergency action taken to minimize threat to human health and the
environment;

I.T.4.m. An estimated quantity and disposition of the recovered material that resulted from the
incident; and

I.T.4.n. Any other information necessary to fully evaluate the situation and to develop an
appropriate course of action.

I.T.5. Within 15 days of the time the Permittee is required to provide the reports specified in
Conditions I.T.1. through I.T.4., the Permittee shall submit to the Director a written
report.

I.T.6. The written report shall include, but not be limited to the following:

I.T.6.a. The name, title, address, and telephone number of the individual reporting;

I.T.6.b. A description including the date, time, location and nature of the reported incident;

I.T.6.c. The extent of injuries, if any;

I.T.6.d. The name and quantity of material(s) involved in the spill;

I.T.6.e. An estimated quantity and disposition of the recovered material;

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I.T.6.f. An assessment of actual or potential hazards to human health and the environment,
where this is applicable. The report shall also include whether or not the results of the
incident remain a threat to human health and the environment (whether the
noncompliance has been corrected and the release has been adequately cleaned up); and

I.T.6.g. If the release or noncompliance has not been adequately corrected or cleaned up, the
anticipated time that the noncompliance or remediation is expected to continue; the
steps taken or planned to reduce, eliminate, and prevent recurrence of the
noncompliance; and/or the steps taken or planned to adequately remediate the release.

I.U. MONITORING REPORTS

I.U.1. Monitoring information shall be recorded and maintained as specified in Condition I.O.

I.V COMPLIANCE SCHEDULES

I.V.1. Reports of compliance or noncompliance with, or any progress reports on, interim and
final requirements contained in any compliance schedule of this Permit shall be
submitted no later than 14 days following each scheduled date.

I.W. MANIFEST DISCREPANCY REPORT

I.W.1. Manifest discrepancies shall be defined as differences between the quantity or type of
hazardous waste designated on the manifest or shipping paper, and the quantity or type
of hazardous waste the permittee actually receives. Significant discrepancies in
quantity are: (1) for batch waste, any variation in piece count, such as a discrepancy of
one drum in a truckload, and (2) for bulk waste, variations greater than 10 percent in
weight. Significant discrepancies in type are obvious differences which can be
discovered by inspection or waste analysis, such as waste solvent substituted for waste
acid, or toxic constituents not reported on the manifest or shipping paper. If a
significant discrepancy is discovered in a manifest, the Permittee shall attempt to
reconcile the discrepancy. If not resolved within 15 days, the Permittee shall submit a
written report, including a copy of the manifest and efforts to reconcile the discrepancy,
to the Director in accordance with UAC R315-8-5.4.

I.X. UNMANIFESTED WASTE REPORT

I.X.1. The Permittee shall submit to the Director an Unmanifested Waste Report within 15
days of receipt of unmanifested waste in accordance with UAC R315-8-5.7.

I.Y. BIENNIAL REPORT

I.Y.1. The Permittee shall submit to the Director a Biennial Report covering facility activities
during odd numbered calendar years. This report shall be submitted by March 1 of the
following even numbered year in accordance with UAC R315-8-5.6.

I.Z. OTHER NONCOMPLIANCE

I.Z.1. The Permittee shall report all other instances of noncompliance with this Permit not
otherwise required to be reported in accordance with Condition I.T., within seven days
of discovering the noncompliance. The reports shall contain the information listed in
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Condition I.T. of this Permit. Reporting shall not constitute a defense for any
noncompliance.

I.AA. OTHER INFORMATION

I.AA.1. Whenever the Permittee becomes aware that it failed to submit any relevant facts in a
permit application, or submitted incorrect information in a permit modification, or in
any report submitted to the Director, the Permittee shall submit such facts or corrected
information within seven working days.

I.BB. SIGNATORY REQUIREMENT

I.BB.1. All reports, notifications, submissions or other information required by this Permit,
requested by or submitted to the Director, shall be signed and certified in accordance
with UAC R315-3-2.2.

I.CC. CONFIDENTIAL INFORMATION

I.CC.1. The Permittee may claim confidential any information required to be submitted by this
Permit in accordance with Utah Code Annotated 63-2-101 et seq. and Utah Code
Annotated 19-1-306.

I.DD. REPORTS, NOTIFICATIONS, AND SUBMISSIONS

I.DD.1. All reports, notifications, or other submissions which are required by this Permit to be
transmitted to the Director should be sent by certified mail or other means of proof of
delivery to:

Director, Division of Solid and Hazardous Waste
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
Phone [phone]

Normal business hours are 7 am to 6 pm, Monday through Thursday, except Utah State
holidays. Required oral notifications shall be given only to the Director or an
authorized representative of the Director. Notifications made at other times shall be
made to the 24-hour answering service at [phone]. Notifications made to the
24-hour answering service shall include all applicable information required by this
Permit. The Permittee shall give oral notification to the Director or an authorized
representative of the Director on the first business day following notification to the 24-
hour answering service.

I.EE. DOCUMENTS TO BE MAINTAINED AT THE FACILITY SITE

I.EE.1. The Permittee shall maintain at the facility, for the periods specified, current copies of
the following documents and amendments, revisions and modifications to these
documents:

I.EE.1.a. A copy of the Permit until closure is certified in accordance with Condition II.O.;

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I.EE.1.b. Waste Analysis Plans (Attachment 1), and all associated analytical data, as required by
UAC R315-8-2.4. and this Permit until closure is certified in accordance with Condition
II.O.;

I.EE.1.c. Inspection schedules and logs (Attachment 2), as required by UAC R315-8-2.6(b) and
this Permit for a period of three years in accordance with UAC R315-8.2.6(d);

I.EE.1.d. Personnel training documents (Attachment 3), and records, as required by UAC R315-
8-2.7(d) and this Permit until closure for current employees, or for a period of three
years for former employees in accordance with UAC R315-8.2.7(e);

I.EE.1.e. Contingency Plan (Attachment 4), as required by UAC R315-8-4 and this Permit until
closure is certified in accordance with Condition II.O;

I.EE.1.f. Operating record, as required by UAC R315-8-5.3, and this permit until closure is
certified in accordance with Condition II.O;

I.EE.1.g. Closure Plans (Attachment 5), as required by UAC R315-8-7 and this permit, until
closure is certified in accordance with Condition II.O;

I.EE.1.h. Cost estimates (Attachment 5) for the closure and post-closure of the Hazardous Waste
Management Units covered by this Permit, in accordance with UAC R315-8-8 and
Condition II.P. of this Permit;

I.EE.1.i. Manifest copies, as required by UAC R315-8-5 and this Permit for at least three years
from the date the waste shipment was accepted at the facility or shipped off-site to an
approved hazardous waste management facility; and

I.EE.1.j. A copy of the Permittee's waste minimization statement until closure is certified in
accordance with Condition II.O.

I.FF. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

I.FF.1. Pursuant to Section 3005(C)(3) of RCRA (Section 212 of HSWA) and UAC R315-3-
3.3(b)(2) [40 CFR 270.32(b)(2)], this Permit contains those terms and conditions
determined necessary to protect human health and the environment.
Addendum to the Signature Page to the ATK Launch Systems Inc., Promontory Facility
Hazardous Waste Storage Permit

As of July 21, 2016, the Signature Page to the Part B, Hazardous Waste Storage Permit, issued to
the ATK Launch Systems Inc. Promontory Facility on September 30, 2008, is revised to reflect a
change in ownership. This Addendum is created in accordance with a Permit Modification
submitted to the Division of Waste Management and Radiation Control on July 5, 2016; Division
tracking number DSHW-2016-011165.

This Permit is transferred to Orbital ATK, Inc. as the facility owner and ATK Launch Systems
Inc. as the facility operator.

The Permit issue date of September 30, 2008 does not change due to the transfer of ownership.

Addendum to the Signature Page to the ATK Launch Systems Inc., Promontory Facility
Post-Closure Permit

As of July 21, 2016, the Signature Page to the Post-Closure Permit, issued to the ATK Launch
Systems Inc. Promontory Facility on September 20, 2007, is revised to reflect a change in
ownership. This Addendum is created in accordance with a Permit Modification submitted to
the Division of Waste Management and Radiation Control on July 5, 2016; Division tracking
number DSHW-2016-011165.

This Permit is transferred to Orbital ATK, Inc. as the facility owner and ATK Launch Systems
Inc. as the facility operator.

The Permit issue date of September 20, 2007 does not change due to the transfer of ownership.