DSHW-2017-001932 - 0901a068806c9764

Orbital ATK
February 28, 2017
8200-FY17-011 Div of Waste Management
and Radiation Control
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
DSBW-Z£t7-00\^Z
Re: ATK Launch Systems Inc. EPA ID number UTD009081357 v'
Annual Report of the Promontory Thermal Treatment Areas Operation Hazardous Waste
Storage Permit Module II.G.3
Dear Mr. Anderson:
Attached is the 2016 Annual Report for the operation of the ATK Launch Systems Inc.
Promontory Facility Thermal Treatment Areas as required by Hazardous Waste Storage Pennit
Module II Condition G.3.
Please contact Blair Palmer at [phone] or myself at [phone], if you have any
questions concerning this report.
/ certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility offine and imprisonment for knowing violations.
Sincerely,
Manager, Environmental Services
ATK Launch Systems Inc.
cc: JeffVandel
Orbital ATK, Inc.9160 N. Hwy 83, Promontory, UT 84307 • 435-863-3511
ATK Launch Systems Inc.-Promontory 2016 Annual Report of the Promontory
Thermal Treatment Areas Operation
Module II Condition G.3.a: requires an accounting of the quantities and types of reactive
hazardous waste treated at the M-136 and M-225 thermal treatment areas, including all
donor material and ignition compounds;
Response: Table 1 and Table 2 shown below reports the quantities and types of reactive
hazardous waste including all donor material and ignition compounds treated at the M-
136 and M-225 Thermal Treatment Areas in 2016. The total amounts treated in 2016
were 1,175,207 pounds at M-136 and 8,277 pounds at M-225.
Table 1: 2016 M-136 Thermal Treatment Totals
. ’ Propellant Class Percent of Total Reactivity Group . Hazardous Waste .
' ’ .' . "A.;-C '* '■ '' Treated (lb.) 7 :
1.3 73%A 852,441
B 244
F 1962
G 83
1.1 24%C 279,103
D 4467
(1.3) Flare 3%■ E 36907
Table 2: 2016 M-225 Thermal Treatment Totals
't] (Propellant Class Percent of Total < Reactivity Group - Hazardous Waste
M-: ■ • .r.-VCT. ' Treated (lb.) /i
1.3 62%A 4765
B 328
F 0
G 1
1.1 38%C 94
D 3089
(1.3) Flare 0%E 0
Module II Condition G.3.b: requires an accounting of the total quantity of Propellant,
Explosives and Pyrotechnics (PEP) and Contaminated Waste treated at the M-136 and M-
225 thermal treatment areas for the annual reporting period;
Response: Table 3 below summarizes, by profile, the total quantity of Propellant,
Explosives and Pyrotechnics (PEP) and Contaminated Waste treated in calendar year
2016. The total amount of donor and ignition materials required to support the thermal
treatment operations was 51,348 pounds.
Table 3: 2016 PEP & Contaminated Waste Treatment Totals
Profile.Propellant, Explosives & Pyrotechnics (PEP)(lb.)Contaminated Waste (lb.)
001 AT 26042 3040
002AT 23230 480
004AT 7738 6198
005AT 1242 18428
006BW 2062 529
PROS 0 1
PR06 4 31
PR07 16 33
PR11 80 122
PR12 209 350
PR13 23333 11826
PR16 0 0
PR17 544 1174
PR18 17 52
PR19 208946 48825
PR20 461 529
PR22 498482 43150
PR23 2633 979
PR28 105 31
PR30 9181 10031
PR31 124346 50336
PR34 1 1
PR35 127 37
PR37 36 21
PR38 1171 617
PR39 3 23
PR40 1 12
PR41 23 25
PR42 32 13
PR44 487 757
PR45 336 1036
PR47 3 2
PR48 1 9
PR49 15 155
PR57 0 1
PR60 7 7
PR64 1 1
PR67 0 1
PR68 117 141
PR70 2 2
PR74 6 100
PR75 4 10
PR76 1 3
PR77 2 10
PR78 284 1678
PR80 0 1
Total 931329 200807
Module II Condition G.3.c: requires an accounting of the total quantity and types of
reactive metal powders treated at the M-136 and M-225 thermal treatment areas for the
annual reporting period;
Response: ATK Launch Systems, Inc. (ATK) did not thermally treat any reactive metal
powders since the effective date (November 23, 2016) of this permit condition.
Module II Condition G.3.d: requires an accounting of the types and quantities of flare
molds treated at the M-136 and M-225 thermal treatment areas for the annual reporting
period and a summary on the status of waste minimization projects for treatment of flare
molds at the thermal treatment areas;
Response: ATK did not treat any flare molds at the M-136 and M-225 treatment areas
since the effective date (November 23, 2016) of this permit condition.
Module II Condition G.3.e: requires a list and description of any new waste profiles that
have been generated for new energetic materials that have been treated at the Promontory
Thermal Treatment Areas;
Response: ATK did not generate any new waste profile for new energetic materials for
treatment at the Promontory Thermal Treatment Areas since the effective date
(November 23, 2016) of this permit condition;
Module II Condition G.3.f: requires reporting of the semiannual annual analytical results
for the bum ground ash as required by Section 11.8.2.5 of Attachment 11;
Response: Since the effective date (November 23, 2016) of this permit condition, ATK
attempted to collect a representative sample of bum ground ash. However; due to winter
air quality restrictions for available bum days, ATK was unable to collect a representative
sample of bum ground ash resulting from the typical treatment of D003 reactive waste containing
perchlorate. Analytical sample results will be reported in the 2017 annual report;
Module II Condition G.3.g: requires an evaluation of the emission factors used in the
human health risk assessment, identified in Condition II.G.l.e., to determine whether
these factors are representative of the wastes treated and identified in the annual report, as
directed by H.G.3., or if the emission factors need to be updated;
Response: The emission factors that were used in the human health risk assessment
represent a hybrid, conservative, set of emission factors developed from the 1997 Bang
Box class 1.1 testing emission factors and the 2006 ODOBi class 1.3 testing emission
factors. No ingredients or material changes have occurred in the ingredients, formulation
process or ancillary materials used by ATK. Therefore ATK considers the emission
factors used in the human health risk assessment to be representative of the wastes
currently treated at the Promontory Thermal Treatment Areas.
Module II Condition G.3.h: requires a review of the of the human health risk
assessment, identified in Condition II.G.l.e., to evaluate changes to dose-response factors
for the three classes of detected COPCs: chromium (total and hexavalent), 2,3,7,8-TCDD
TEQ, and detected potentially carcinogenic PAHs (benzo(a)anthracene,
benzo(k)fluoranthene, chrysene and indeno(l,2,3-cd)pyrene); and
Response: Please see Attachment 1 from Geosyntec Consultants evaluating this permit
condition;
Module II Condition G.3.i: requires a review of the potential human health risk scenarios
that were evaluated in the risk assessment to assure that these scenarios have not
changed.
Response: Please see Attachment 1 from Geosyntec Consultants evaluating this permit
condition;
Attachment 1
Review of the human health risk assessment changes to dose-response factors.
Review of the potential human health risk scenarios that were evaluated in the risk assessment.
Geosyntec^
consultants
5670 Greenwood Plaza Blvd Suite 540
Greenwood Village, Colorado 80111
PH 303.790 1340
www.geosyntec.com
Memorandum
Date: 17 February 2017
To: Paul Hancock and Blair Palmer OrbitalATK, Promontory Facility
From: Stephen Foster, Ph.D. and Anne Woodland, Geosyntec
Subject: Literature Review of Toxicological Dose-response Factors for Human
Health Risk Assessment Drivers and Exposure Scenarios for the
Promontory Open Burning Permit
Introduction
The purpose of this memorandum is twofold:
1. Provide the results of an annual review of risk assessment dose-response factors for the
compounds identified as risk drivers in the 2016 Promontory Open Bum Open
Detonation (OBOD) human health risk assessment (HHRA) (Geosyntec, 2016) to
determine if they have changed, and
2. Review the potential human health scenarios that were evaluated in the OBOD HHRA to
assure that these scenarios have not changed.
This work was necessary to ensure ATK’s compliance with the Promontory Facility RCRA
Subpart X conditions II.G.3.h and II.G.S.i. The detected risk drivers, that is, the short list of
chemicals identified to have the highest fraction of the risk, in the 2016 HHRA (Geosyntec,
2016) are the chemical constituents chromium (total and hexavalent), 2,3,7,8 tetrachlorodibenzo-
p-dioxin (2,3,7,8-TCDD), and the polynuclear aromatic hydrocarbons (PAHs)
benzo[a]anthracene, benzo[k] fluoranthene, chrysene and indeno[l,2,3-cd]pyrene. This
memorandum does not address or review changes in potential exposure assessment scenario
assumptions, or draft documents that have not been finalized by the US Environmental
Protection Agency (EPA).
The hierarchy used in this review is consistent with that utilized in the approved HHRA and it is
as follows:
engineers I scientists I innovators
HHRA Dose-response Factor Review
17 February 2017
1. Integrated Risk Information System (IRIS) - The EPA’s peer reviewed on-line
toxicological database.
2. Provisional Peer Reviewed Toxicity Values (PPRTVs) - The office of Research and
Development/National Center for Environmental Assessment/Superfimd Flealth Risk
Technical Support Center (STSC) develops PPRTVs on a chemical specific basis when
requested by EPA’s Superfund program.
3. Other Toxicity Values - including the Health Effects Assessment Summary Tables
(HEAST) (EPA, 1997), Regional Screening Levels (RSL) tables and the California EPA.
Dose-response factors from these sources were further modified in the HHRA for compounds
considered to have a mutagenic mode of action (MOA), as defined in the Supplemental
Guidance for Assessing Susceptibility from Early-Life Exposure to Carcinogens (EPA, 2005).
An age-dependent adjustment factor was calculated and multiplied by the dose-response factor to
determine the final toxicity value used in the HHRA. The detected risk drivers with a mutagenic
MOA include hexavalent chromium and the PAHs listed above. This memorandum presents the
dose-response factors as they are listed in the source files, such as IRIS, and the final mutagenic
values used in the HHRA are not included.
Chromium
An online search of the IRIS, PPRTVs databases and the EPA RSLs was conducted in February
2017, to determine whether there have been any changes to toxicity data for both total chromium
and hexavalent chromium. No changes were identified for chromium in any of the sources. The
on-line IRIS and RSLs files for chromium are consistent with those used in the 2016 HHRA
(EPA 2017a). Hexavalent chromium is being reassessed under the IRIS program, and Step 1 of
the seven-step process began in 2014 with the release of Problem Formulation Materials and
Preliminary Assessment Materials (EPA 2017b). There is no known release date for the final
assessment. A search of the PPRTV database revealed that total and hexavalent chromium are
not included in that database (EPA 2017c). Table 1 shows a summary of the values for both total
and hexavalent chromium that were used in the HHRA, and that remain current as of February
2017.
2,397,8-Tetrachlorodibenzo-p-dioxin
An online search of the IRIS, PPRTVs databases and the EPA RSLs was conducted in February
2017, to determine whether there have been any changes to toxicity data for 2,3,7,8-TCDD since
last year. No changes were identified for 2,3,7,8-TCDD in any of the sources. The on-line IRIS
and RSLs files for 2,3,7,8-TCDD are consistent with those used in the 2016 HHRA (EPA
2017d). Similarly, a search of the PPRTV database revealed that 2,3,7,8-TCDD is not included
HHRA Dose-response Factor Review
17 February 2017
in that database. Table 1 shows a summary of the values for 2,3,7,8-TCDD that were used in the
OBOD HFIRA, and that remain current as of February 2017.
Poly-nuclear Aromatic Hydrocarbons
Carcinogenic Dose-Response Factors
The detected PAH risk drivers are benzo[a]anthracene, benzofk]fluoranthene, chrysene and
indeno[l,2,3-cd]pyrene. The carcinogenic dose-response factors for these PAHs are based on
their relative potency to benzo[a]pyrene (BaP). On January 19, 2017 the IRIS program released
its final assessment of BaP, which has been under review for about six years. New dose-
response factors are now available for BaP, and it is now considered a less potent carcinogen by
the oral route of exposure. New toxicity factors are also included that address carcinogenicity via
inhalation as well as the potential for non-cancer health effects.
The relative potency factor for each PAH is multiplied by the toxicity value for BaP to get the
resulting toxicity values used for the four detected PAH risk drivers in the HHRA, as shown in
Table 1. Table 2 summarizes the January 2017 values for BaP (EPA 2017e). The 2017 oral
cancer slope factor (CSF) of 1 milligrams per kilogram per day ((mg/kg-day)"1) is approximately
7 times lower than the 2016 CSF of 7.3 (mg/kg-day)'1. Multiplying the 2017 CSF by the relative
potency factors for the four detected PAH risk drivers results in the values shown in Table 2.
These new CSF values will result in ingestion risks associated with PAHs that are about 7 times
lower than those calculated in the 2016 HHRA.
The 2017 inhalation unit risk (IUR) for BaP is 6E-04 per microgram per cubic meter of air
((ug/m3)'1). This value represents the risk per microgram per cubic meter of chemical inhaled,
and it is approximately half that of the 2016 IUR of 1.1E-03 (/ig/m3)'1. Use of the 2017 IUR will
result in inhalation risks for BaP that are about 50% lower than those calculated in the HHRA.
Applying the BaP IUR to the other PAHs would result in an overall reduction in inhalation risks
associated with PAHs. However, at this time, the IUR values for the four detected PAH risk
drivers are consistent with those used in the HHRA. These IUR values originate from the
California EPA, as posted in the EPA RSLs tables, and it is not known if these IUR values will
be updated based on the January BaP IUR. The current version of the EPA RSLs is from May
2016, and the November 2016 update is still pending. Therefore, the inhalation risks associated
with carcinogenic PAHs would either stay the same as those presented in the HHRA, or they
would decrease, if the January 2017 IUR for BaP were applied.
Non-Carcinogenic Dose-Response Factors
3
HHRA Dose-response Factor Review
17 February 2017
The non-carcinogenic toxicity values include the Reference Dose (RfD) and Reference
Concentrations (RfC). Previously, there was no EPA sanctioned RfD nor RfC posted on IRIS for
BaP, and therefore, it was not possible to calculate non-carcinogenic hazards for BaP, or any of
the other PAHs, including the four PAH risk drivers. At this time, there is no EPA guidance to
indicate how to evaluate the non-cancer effects of PAHs other than BaP. Therefore, non-cancer
hazard quotients (HQs) could now be calculated for BaP, but no additional hazard quotient
calculations are recommended for the other PAHs. Given the overall hazard indices presented in
the 2016 HHRA, it is not likely that the additional contribution from BaP would increase those
hazards, and the conclusions of the HHRA would not change.
Human Health Risk Scenarios
Subsection II.G.3.i of the Promontory RCRA Subpart X permit stipulates an annual review of the
human health risk scenarios that were included in the 2016 HHRA to assure that they have not
changed. The on-site receptor evaluation included exposure via inhalation of vapors and
particulate matter to full-time workers at the North and South Plant Main Buildings, the Autoliv
facility, and the point of maximum on-site risk. OrbitalATK conducted a review of on-site work
activities, and there are no new on-site worker locations or scenarios identified that would result
in any higher exposure that those presented for the hypothetical worker at the point of maximum
on-site risk in the 2016 HHRA.
The off-site receptors included adult and child residents and farmers at six existing homes,
ranches and nearby towns, as well as at seven hypothetical property boundary lines, including the
point of maximum off-site risk. Exposure pathways for the resident included inhalation of
particulate matter and vapors, and ingestion of soil and aboveground produce. In addition, the
farmer exposure pathways included ingestion of homegrown milk, beef, poultry, pork and eggs.
Infant exposure to dioxins and furans in breast milk was also evaluated. There are no new
residential or fanning locations or additional exposure scenarios or pathways identified that
would result in any higher exposure than those presented for the hypothetical farmer at the point
of maximum off-site risk in the 2016 HHRA.
Conclusion
While hexavalent chromium is being reassessed under the IRIS program, the dose-response
factors for both total and hexavalent chromium remain the same as those utilized in the 2016
HHRA. The EPA has not developed or published a revised 2,3,7,8-TCDD cancer potency factor
since the 2016 HHRA, and the process for calculating 2,3,7,8-TCDD-TEQs in the EPA’s IRIS
database has not changed. Therefore, the toxicological dose-response information for TCDD-
TEQ identified in the 2016 HHRA is accurate and up-to-date.
4
HHRA Dose-response Factor Review
17 February 2017
As discussed above, the toxicity values for BaP were updated on the IRIS in January 2017. The
CSF has decreased by a factor of approximately seven, meaning ingestion risks calculated using
the new slope factor will be approximately seven times lower than those calculated using the old
slope factor. Also, the IUR has decreased from the value used in the 2016 HHRA, by a factor of
approximately two, meaning that inhalation risks calculated using the new IUR will be
approximately two times lower than those calculated using the old IUR.
In addition, there are new toxicity values for the RfD and RfC, meaning non-cancer hazards due
to both ingestion and inhalation can now be calculated for BaP, however there is no EPA
guidance on how to evaluate the non-cancer dose-responses for the PAHs evaluated in the
HHRA. No additional calculations are recommended at this time.
This review of the EPA’s toxicological literature complies with conditions specified in the
Promontory RCRA Subpart X, Subsection II.G.S.h, and indicates that changes have occurred to
dose-response values used in the 2016 HHRA.
The human health risk scenarios that were evaluated in the 2016 HHRA were reviewed and
found to be consistent with the HHRA. The assumptions utilized in the on-site worker, off-site
farmer and residential scenarios remain conservative and protective of human health. There are
no new on-site worker locations or scenarios identified that would result in any higher exposure
than those presented for the hypothetical worker at the point of maximum on-site risk in the 2016
HHRA. Similarly, for the off-site areas, there are no new residential or farming locations or
additional exposure scenarios or pathways identified that would result in any higher exposure
than those presented for the hypothetical farmer at the point of maximum off-site risk in the 2016
HHRA. This review of the human health risk scenarios complies with conditions specified in the
Promontory RCRA Subpart X, Subsection II.G.S.i, and indicates that changes to the human
health risk scenarios have not occurred.
References
EPA 2005 Supplemental Guidance for Assessing Susceptibility from Early-Life
Exposure to Carcinogens, Risk Assessment Forum, Environmental
Protection Agency, EPA/630R-03/003F March
EPA 2016 Regional Screening Levels, May 2016 version;
https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-mav-
2016
5
HHRA Dose-response Factor Review
17 February 2017
EPA 2017a Chromium; Integrated Risk Information System, EPA On-line database;
httDs://cfbub.eDa.£ov/ncea/iris2/chemicalLanding.cfm?substance nmbr=28
EPA 2017b Chromium Hexavalent; Integrated Risk Information System, EPA On-line
database;
httDs://cfbub.eDa.£ov/ncea/iris2/chemicalLandin£.cfm?substance nmbr=144
EPA 2017c EPA Provisional Peer Reviewed Toxicity Values for Superfund;
https: //hhpprt v. oml. eov/a uickvi ew/pprt v. php
EPA 2017d 2,3,7,8-Tetrachlorodibenzo-p-dioxin, Integrated Risk Information System,
EPA On-line database;
httDs://cfbub.epa.£Ov/ncea/iris/iris documents/documents/subst/1024 summ
arv.odf
EPA 2017e Benzo(a)pyrene, Integrated Risk Information System, EPA On-line
database:
https://cfbub.eDa.gov/ncea/iris/iris documents/documents/subst/0136 summ
arv.pdf
Geosyntec 2016 Open Bum Open Detonation Human Health Risk Assessment, ATK Launch
Systems Promontory, Utah June 2016.
6
HHRA Dose-response Factor Review
17 February 2017
Table 1
Summary of the 2016 Dose-Response Values for Detected Risk Drivers in the OBOD HHRA
Risk Driver Reference
Dose
(mg/kg-day)
Source Reference
Concentration
(mg/m3)
Source Relative
Potency
Factor
Oral Cancer
Slope Factor
(mg/kg-day)"1
Source Inhalation
Unit Risk
Og/m3)"1
Source
2,3,7,8-TCDD 7E-10 IRIS 4E-08 C NA 1.3E+05 C 3.8E+01 C
Chromium (total)1.5 IRIS 5.3 HHRAP NA NA NA
Chromium (hexavalent)3E-03 IRIS IE-04 IRIS NA 5E-01 J 8.4E-02 RSL
B enzo [a] anthracene NA NA 0.1 0.73 BaP1 1.1E-4 C
Benzo [k] fluoranthene NA NA 0.01 0.073 BaP1 1.1E-4 C
Chrysene NA NA 0.001 0.0073 BaP1 1.1E-5 C
Indeno[l ,2,3-cd]pyrene NA NA 0.1 0.73 BaP1 1.1E-4 C
2,3,7,8-TCDD - 2,3,7,8-Tetrachlorodibenzo-p-dioxin
C - California ERA, as cited in the May 2016 Regional Screening Levels
HHRAP - Human Health Risk Assessment Protocol - RfC was calculated in the 2005 Combustion Guidance Database.
J - New Jersey, as cited in May 2016 Regional Screening Levels
RSL -Regional Screening Levels
IRIS - Integrated Risk Infonnation System (EPA 2017)
Bap1 - Based on BaP relative potency factor, using 2016 IRIS cancer slope factor of 7.3 (mg/kg-day)"1.
7
HHRA Dose-response Factor Review
17 February 2017
Table 2
Summary of 2017 Dose-Response Values for Benzo[a]pyrene and Associated PAH Risk Drivers
Risk Driver Reference
Dose
(mg/kg-day)
Source Reference
Concentration
(mg/m3)
Source Relative
Potency
Factor
Oral Cancer
Slope Factor
(mg/kg-day)'1
Source Inhalation
Unit Risk
Cug/m3)'1
Source
Benzo[a]pyrene 3E-4 IRIS 2E-6 IRIS 1 1 IRIS 6E-04 IRIS
B enzo [ a] anthracene NA NA 0.1 0.1 BaP1 1.1E-4 C
Benzo [k] fluoranthene NA NA 0.01 0.01 BaP1 1.1E-4 C
Chrysene NA NA 0.001 0.001
BaP1 1.1E-5 C
Indeno[ 1,2,3-
cdjpyrene
NA NA 0.1 0.1 BaP1 1.1E-4 C
C - California EPA, as cited in May 2016 EPA
RSL- Regional Screening Levels (EPA 2016)
IRIS - Integrated Risk Information System (EP/
BaP1 - Based on BaP relative potency factor, usi
Regional Screening Levels
k 2017e)
ng 2017 IRIS cancer slope factor of 1 (mg/kg-day)'1.
8