DSHW-2018-002038 - 0901a068807c6fe6

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February 28, 2018
8200-FYl 8-004
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
Orbital Ani)
Div of Waste Management
and Radiation Control
MAR O 1 20i8
DS\-\-W-20l 8-O o Zo 2>B
Re: ATK Launch Systems Inc. EPA ID number UTD009081357
Annual Report of the Promontory Thermal Treatment Areas Operation Hazardous Waste
Storage Permit Module II.G.3
Dear Mr. Anderson:
Attached is the 2017 Annual Report for the operation of the ATK Launch Systems Inc.
Promontory Facility Thermal Treatment Areas as required by Hazardous Waste Storage Permit
Module II Condition G.3.
Please contact Blair Palmer at ( 435) 863-2430 or myself at [phone], if you have any
questions concerning this report.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility affine and imprisonment for knowing violations.
Sincerely,
Kris H. Blauer
Manager, Environmental Services
A TK Launch Systems Inc.
cc: Jeff Vandel
Orbital ATK, Inc. • 9160 N. Hwy 83, Promontory, UT 84307 • 435-863-3511
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orhitatATKLf,
Div of Waste Management
February 28,2018 and Radiation control
8200-FY18-004 MAR 0l20tg
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
195 North 1950 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Re: ATK Launch Systems Inc. EPA ID number UTD009081357
Annual Report of the Promontory Thermal Treatment Areas Operation Hazardous Waste
Storage Permit Module II.G.3
Dear Mr. Anderson:
Attached isthe2}l7 Annual Report for the operation of the ATK Launch Systems Inc.
Promontory Facility Thermal Treatment Areas as required byHazardous Waste Storage Permit
Module II Condition G.3.
Please contact Blair Palmer at [phone] or myself at [phone], if you have any
questions concerning this report.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsiblefor gathering the
information, the information submitted is, to the best of my htowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submittingfalse information,
including the possibility offine and imprisonmentfor lcnowing violations.
Sincerely,tu
Kris H. Blauer
Manager, Environmental Services
ATK Launch Systerns Inc.
cc: Jeff Vandel
OrbitalATK, lnc. o 9160 N. Hwy 83, Promontory, UT 84307 o 435-863-3511
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ATK Launch Systems Inc.-Promontory 2017 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-l36 andM-225 thermal treatment areas, including all
donor material and ignition compounds;
Response: Table I 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-
l36andM-225 ThermalTreatrnentAreas in2017. Thetotalamountstreated in2017
were 1,223,758 pounds at M-136 and7,990 pounds atM-225.
Table lz 2017 M-136 Thermal Treatment Totals
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 treatrnent areas for the annual reporting period;
Response: Table 3 below summarizes, byprofile, the total quantity of propellant,
Explosives and Pyrotechnics (PEP) and Contaminated Waste treated in calendar year
2017. The total amount of donor and ignition materials required to support the thermal
featrnent operations was 51,093 pounds.
Table 2: 2017 M-225 Thermal Treatment Totals
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Table 3z 2017 PEP & Contaminated Waste Treatment Totals
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Module II Condition G.S.c: requires an accounting of the total quantity and types of
reactive metal powders treated at the M-136 andM-225 thermal treatment areas for the
annual reporting period;
Response: ATK Launch Systerns, Inc. (ATK) did not thermally treat any reactive metal
powders in calendar year 2017.
Module II Condition G.3.d: requires an accounting of the types and quantities of flare
molds treated at the M-136 andM-225 thermal treatrnent areas for the annual reporting
period and a summary on the status of waste minimization projects for treatrnent of flare
molds at the thermal treatment areas;
Response: ATK did not treat any flare molds at the M-136 andM-225 teatment areas in
calendar year 2017.
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 in calendar year 2017.
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 l1;
Response: Table 4 below summarizes the burn ground ash sampling and analytical
results for 2017. A11 values are below the EPA Regional Screening Levels (RSLs)
(November 2017 publication) value of 55 mg/kg.
Table 4: Semiannual & Annual An Results
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.1.e., to determine whether
these factors are representative of the wastes treated and identified in the annual report, as
directed by II.G.3., or if the emission factors need to be updated;
Response: The ernission 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
Page | 3
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.1.e., to evaluate changes to dose-response factors
for the three classes of detected COPCs: chromium (total and hexavalent),2,3,7,}-TCDD
TEQ, and detected potentially carcinogenic PAHs (benzo(a)anthracene,
benzo(k)fluoranthene, chrysene and indeno (1,2,3 -cd)p,yrene); and
Response: Please see Attachment I 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 I from Geosyntec Consultants evaluating this permit
condition;
Page | 4
Attachment I
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.
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Geosyntec 1> 5670 Greenwood Plaza Blvd Suite 540
Greenwood Village, Colorado 80111
PH 303.790 1340
www.geosyntec.com
Date:
To:
From:
Subject:
consultants
Memorandum
26 February 2018
Paul Hancock and Blair Palmer OrbitalA TK, Promontory Facility
Anne Woodland, MS, and Stephen Foster, Ph.D., Geosyntec
Annual 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 toxicological dose-response factors for the
compounds identified as risk drivers in the 2016 Promontory Open Burn Open Detonation
(OBOD) human health risk assessment (HHRA) (Geosyntec, 2016) with the goal of
determining if they have changed, and
2. Review the potential human health exposure scenarios that were evaluated in the OBOD
HHRA to assure that these scenarios have not changed.
This work is conducted annually to ensure ATK's compliance with the Promontory Facility RCRA
Subpart X conditions II.G.3.h and II.G.3.i. The detected risk drivers, 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 (P AHs) 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, such as ingestion assumptions, or exposure durations,
or draft documents that have not been finalized by the US Environmental Protection Agency
(EPA).
Consistent with the approved OBOD HHRA, the EPA's hierarchy for the selection of dose-
response values used in this review is as follows:
engineers I scientists I innovators
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HHRA Dose-response Factor Review
26 February 2018
1. Integrated Risk Information System (IRIS) -The EPA's peer reviewed online
toxicological database.
2. Provisional Peer Reviewed Toxicity Values (PPRTVs) -The office of Research and
Development/National Center for Environmental Assessment/Superfund Health 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 potentially carcinogenic 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.
Total Chromium
An online search of the IRIS, PPRTVs databases and the EPA RSLs was conducted in February
2018, to determine whether there have been any changes to toxicity data for total chromium. No
changes were identified in any of the sources. The online IRIS and RS Ls files for total chromium
are consistent with those used in the 2016 HHRA (EPA 2018a). Those values are shown in Table
1.
Hexavalent Chromium
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 2018b). The status of hexavalent chromium in January 2018 is the
same on the IRIS as it was one year ago. There is no known release date for the final assessment.
A search of the PPR TV database revealed that hexavalent chromium is not included in that
database (EPA 2018c). Table 1 shows a summary of the values for hexavalent chromium that were
used in the HHRA, and that remain current as ofJanuary 2018.
2,3, 7 ,8-Tetrachlorodibenzo-p-dioxin
An online search of the IRIS, PPR TVs databases and the EPA RSLs was conducted in February
2018, to determine whether there have been any changes to toxicity data for 2,3,7,8-TCDD since
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HHRA Dose-response Factor Review
26 February 2018
last year. No changes were identified for 2,3,7,8-TCDD in any of the sources. The online IRIS
and RSLs files for 2,3,7,8-TCDD are consistent with those used in the 2016 HHRA (EPA 2018d).
Similarly, a search of the PPRTV database revealed that 2,3,7,8-TCDD is not included in that
database. Table 1 shows a summary of the values for 2,3,7,8-TCDD that were used in the OBOD
HHRA, and that remain current as of January 2018.
Poly-nuclear Aromatic Hydrocarbons
Carcinogenic Dose-Response Factors
The detected PAR risk drivers are benzo[a]anthracene, benzo[k]fluoranthene, chrysene and
indeno[l,2,3-cd]pyrene. The carcinogenic dose-response factors for these PAHs are based on their
relative potency when compared with benzo[a]pyrene (BaP). As stated in last year's memorandum
on this topic, on January 19, 2017 the IRIS program released its final assessment of BaP, which
has been under review for about six years (EPA 2018e). New dose-response factors are 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 P AH is multiplied by the
toxicity value for BaP to get the resulting toxicity values used for the four detected P AH risk
drivers in the HHRA, as shown in Table 1. Table 2 summarizes the current values for BaP (EPA
2017).
The current oral cancer slope factor (CSF) of 1 milligrams per kilogram per day ((mg/kg-dayt1)
is approximately 7 times lower than the 2016 CSF of 7.3 (mg/kg-dayt1• Multiplying the current
CSF by the relative potency factors for the four detected P AH risk drivers results in the values
shown in Table 2. These new CSF values will result in ingestion risks associated with P AHs that
are about 7 times lower than those calculated in the 2016 HHRA.
The current inhalation unit risk (IUR) for BaP is 6E-04 per microgram per cubic meter of air
((ug/m3t1). This value represents the risk per microgram per cubic meter of chemical inhaled, and
it is approximately half that of the 2016 IUR of l.lE-03 (ug/m3t 1• Use of the current IUR will
result in inhalation risks for BaP that are about 50% lower than those calculated in the HHRA. A
search of the EPA Regional Screening Levels (RS Ls) posted in November 2017 (EPA 2017)
reveals IURs for the four risk drivers that were derived by multiplying the current IUR for BaP by
the relative potency factors shown in Table 2. These are the same factors that were applied to the
CSF, described above. This represents a change and an overall decrease from the previous IURs
that originated from the California EPA (Table 1) and that were utilized in the 2016 HHRA. A
decrease in the IUR value translates into a decrease in the inhalation risks. Therefore, the inhalation
risks associated with the benz[ a ]anthracene and indeno[ 1,2,3-cd]pyrene would decrease by a factor
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HHRA Dose-response Factor Review
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of about 1.8 times, and the risks associated with benzo[k]fluoranthene and chrysene would
decrease by a factor of about 18 times.
In conclusion, the summed risk from the four detected P AH risk drivers amounted to less than
three percent (3%) of the total risk for the hypothetical adult farmer at the point of maximum off-
site risk, therefore these changes in toxicity values will not have a noticeable effect on the overall
risk.
Non-Carcinogenic Dose-Response Factors
The non-carcinogenic toxicity values include the Reference Dose (RID) and Reference
Concentrations (RfC). Previously, there was no EPA sanctioned RID 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 P AHs, including the four PAH risk drivers. At this time, there is no EPA guidance to
indicate how to evaluate the non-cancer effects of P AHs 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 P AHs. Given the overall hazard indices presented in
the 2016 HHRA (all less than 0.01), 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. OrbitalA TK 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
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.
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HHRA Dose-response Factor Review
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Conclusion
While hexavalent chromium is being reassessed under the IRIS program, the dose-response factors
for hexavalent chromium remain the same as those utilized in the 2016 HHRA. The dose-response
factors for total chromium also remain the same. 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.
As discussed above, the toxicity values for BaP were updated on the IRIS in January 2017 and
those values are still current. 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 IURs for the four risk drivers that were derived by multiplying the
current IUR for BaP by the relative potency factors shown in Table 2. This represents a change
and an overall decrease from the previous IURs and subsequent inhalation risk calculations for
benz[a]anthracene, benzo[k]fluoranthene, chrysene and indeno[l,2,3-cd]pyrene. However, the
summed risk from the four detected PAH risk drivers amounted to less than three percent (3%) of
the total risk for the hypothetical adult farmer at the point of maximum off-site risk, therefore these
changes in toxicity values will not have a noticeable effect on the overall risk.
As presented in last year's memorandum, there are new BaP toxicity values for the RID 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
other 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.3.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
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HHRA Dose-response Factor Review
26 February 2018
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 11.G.3.i, and indicates that changes to the human health
risk scenarios have not occurred.
References
EPA2005
EPA 2017
EPA 2018a
EPA 2018b
EPA 2018c
EPA 2018d
EPA 2018e
Geosyntec 2016
Supplemental Guidance for Assessing Susceptibility from Early-Life
Exposure to Carcinogens, Risk Assessment Forum, Environmental
Protection Agency, EP A/630R-03/003F March
Regional Screening Levels, November 2017 version;
https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-
november-2017
Chromium; Integrated Risk Information System, EPA Online database;
https://cfpub.epa.gov/ncea/iris2/chemica1Landing.cfm?substance nmbr=28
Chromium Hexavalent; Integrated Risk Information System, EPA Online
database;
https:// cfpub .epa. gov/ncea/iris2/ chemical Landing. cfm ?substance nmbr= 144
EPA Provisional Peer Reviewed Toxicity Values for Superfund;
https://hhpprtv.oml.gov/guickview/pprtv.php
2,3, 7 ,8-Tetrachlorodibenzo-p-dioxin, Integrated Risk Information System,
EPA Online database;
https://cfpub.epa.gov/ncea/iris/iris documents/documents/subst/1024 summ
ary.pdf
Benzo(a)pyrene, Integrated Risk Information System, EPA Online database:
https :// cfpub .epa. gov /ncea/iris/iris documents/ documents/subst/013 6 summ
ary.pdf
Open Burn Open Detonation Human Health Risk Assessment, ATK Launch
Systems Promontory, Utah June 2016.
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HHRA Dose-response Factor Review
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Table 1
Summary of the 2016 Dose-Response Values for Detected Risk Drivers in the OBOD HHRA
Risk Driver Reference Source Reference Source Relative Oral Cancer Source
Dose Concentration Potency Slope Factor
(mg/kg-day) (mg/m3) Factor (mg/kg-dayY1
2,3,7,8-TCDD 7E-10 IRIS 4E-08 C NA 1.3E+05 C
Chromium (total) 1.5 IRIS 5.3 HHRAP NA NA
Chromium (hexavalent) 3E-03 IRIS lE-04 IRIS NA 5E-01 C
Benzo[ a ]anthracene NA NA 0.1 0.73 BaP1
Benzo[k] fluoranthene NA NA 0.01 0.073 BaP1
Chrysene NA NA 0.001 0.0073 BaP1
Indeno[ 1,2,3-cd]pyrene NA NA 0.1 0.73 BaP1
Abbreviations:
mg/kg-day -milligrams per kilogram per day
mg/m3 -milligrams per cubic meter
(ug/m3Y1 -risk per microgram per cubic meter
2,3,7,8-TCDD -2,3,7,8-Tetrachlorodibenzo-p-dioxin
C -California EPA, as cited in the May 2016 Regional Screening Levels
HHRAP -Human Health Risk Assessment Protocol -RfC was calculated in the 2005 Combustion Guidance Database
Inhalation
Unit Risk
(µg/m3y1
3.8E+Ol
NA
8.4E-02
1.lE-4
1.lE-4
1.lE-5
1.lE-4
RSL -Regional Screening Levels, EPA Online tables available at https://www.epa.gov/risk/regional-screening-levels-rsls-generic-tables-
november-2017
IRIS -Integrated Risk Information System (EPA 201 7)
Bap1 -Based on BaP relative potency factor, using 2016 IRIS cancer slope factor of 7.3 (mg/kg-dayy1•
7
Source
C
RSL
C
C
C
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HHRA Dose-response Factor Review
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Table 2
Summary of 2018 Dose-Response Values for Benzo[a]pyrene and Associated PAH Risk Drivers
Risk Driver Reference Source Reference Source Relative Oral Cancer Source Inhalation
Dose Concentration Potency Slope Factor Unit Risk
(mg/kg-day) (mg/m3) Factor (mglkg-dayt1 (ug/m3t'
Benzo[ a ]pyrene 3E-4 IRIS 2E-6 IRIS 1 1 IRIS 6E-04
Benzo[ a ]anthracene NA NA 0.1 0.1 RSL 6E-05
Benzo [k] fl uoranthene NA NA 0.01 0.01 RSL 6E-06
Chrysene NA NA 0.001 0.001 RSL 6E-07
Indeno[ 1,2,3-NA NA 0.1 0.1 RSL 6E-05
cd]pyrene
Abbreviations:
mg/kg-day -milligrams per kilogram per day
mg/m3 -milligrams per cubic meter
(ug/m3Y1 -risk per microgram per cubic meter
Source
IRIS
RSL
RSL
RSL
RSL
RSL -Regional Screening Levels (EPA 201 7) These values for cancer slope factor and inhalation unit risk are based on BaP relative potency
factors.
IRIS -Integrated Risk Information System (EPA 2018e)
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