DSHW-2018-007073 - 0901a06880887522

GRI'D'DANNOfrTHROP
July 17,2018
8200-FY18-017
Mr. Scott T. Anderson, Director
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O. Box 144880
salt Lake city, Utah 841144880
Northrop Grumman Corporation
lnnovation Systems
ATK Launch Systems lnc.
P.O. Box 707
Brigham City, Uf 84321-0707
DS HIV- Lolb-ool 017
Div c: T,'a ;r:,: \:1::- l ii'1i-::r, e n r,
and iRaor'siicn Coltroi
JUL 2 6 2OIB
Re: ATK Launch Systems Inc. EPA ID number UTD009081 357 /
ATK Launch Systems Inc. Promontory Facility Hazardous Waste Storage Permit Class I
Modification
Dear Mr.
As allowed under 40 CFR 270.42 (A.a.a) and as required under permit condition IV.K.3, ATK
Launch Systems Inc. (ATK) is requesting a modification to the Promontory Facility's Hazardous
Waste Storage Permit. The updated pages are enclosed with this notification, and the proposed
changes are shown in red font.
ATK requests the following changes to implement the approved requirements of the Soil Monitoring
Plan.
o Module II; conditions II.G.1.f, g, h. references add for the Ecological Risk Assessment Waiver,
Groundwater Monitoring Plan, and Soil Monitoring Plan.
o Module [V; conditions IV.K.I - 10. language updated to reflect the monitoring and reporting
required by the Soil Monitoring Plan and Groundwater Monitoring Plan.
o Module [V; conditions IV.L.l, 2.langaage updated to reflect the Ecological Risk Assessment
waiver and its justifications.
Please contact Blair PaLner at [phone] or myself at [phone] if you have any questions
concerning this submittal.
Sincerelv..l /' i,*Pu tlz"""*a- / ren
Kris H. Blauer
Manager, Environmental Services
ATK Launch Systems Inc.
cc: Jeff Vandel
ATK I-aunch Systems [nc. - Promontory
Module II - General Facility Conditions
July I l,2018
uTD009081357
II.A.
II.A.I.
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, UI, IV and V.
DESIGN AI\D 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 bngineer in
accordance with Condition I.R.l. and UAC R315-3-3.10X2)(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
satisff the operating requirements specified in this permit.
REOUIRED NOTICE
As_required by UAC R315-8-2.3(a)(1), the Permittee shall notifz 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 uuranges to receive hazardous waste from an off-site source (except
where the Permittee is also the generator), the Permittee shall inform the generator in -
yrililg that he has the appropriate permit(s) for, and will accepfi, the waste the generator
is shipping. The Permittee shall keep a copy of this written nolice as part of the
operating record as required by UAC R315-8-2.3(b).
WASTE ANALYSIS PLAII
The Permittee shall follow the procedures of the Waste Analysis Plan included as
Attachment I of this Permit. In 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 l) 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, may be 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 l.
II.B.2.
II.B.3.
II.c.
[.c.1.
il.c.2.
II.D.
II.D.1.
\.D.2.
II.D.3.
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urD009081357
ATK launch Systems Inc. - Promontory
Module II - General Facility Conditions
TI.D.4.
II.D.5.
II.D.6.
II.D.6.a.
rr.D.6.b.
II.D.6.c.
II.D.7.
II.D.8.
The waste characteization 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 characteization is still accurate. These
evaluations shall be kept in the operating record until the next annual evaluations are
completed. Characterization 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 a minimum, 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 l5m ofeach calendar year.
Whenever the Director determines that the Permittee needs to update the analytical
methodologies or the version(s) of SW-846 that are being used by the Permittee's
analytical laboratory, the Director will submit written notification to the Permittee. The
Permittee shall notiff the Utah Department of Health, Bureau of Laboratory
Improvernent 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 rernedy requires more than 72 hours to implement from the time that the
II.E
II.E.I.
II.F.
II.F.I.
II.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.l.b.
ILG.1.c.
II.G.l.d.
II.G.1.e.
II.G.l.f.
II.G.1.g.
July I l,2018
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problem is detected, the Permittee shall submit to the Director, before the expiration of
the 72 hour period, a proposed time schedule for correcting the problem.
Any problem which could endanger human health or the environment shall be corrected
as soon as possible after the problem 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 THRESHOLDS
The thermal 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 to human health
was evaluated, in accordance with R3l5-101 and is based on the risk thresholds identified in
Condition tV.C.l1. 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 Characterization of Open Burning Waste Propellant Materials,
October 2009;
ATK Launch Systems Waste Charactenzation and Air Dispersion Modeling Protocol for use in
the Human Health and Ecological Risk Assessments, April Z}ll,TetraTech; ADDENDUM
Air Dispersion Modeling Protocol for Open Burning and Open Detonation at ATK Launch
Systems in Promontory, Utah, February 2013, CBI;
Air Dispersion Modeling Report for Open Burning and Open Detonation at ATK Launch
Systems in Promontory, Utah, July 2014, CBI;
Human Health Risk Assessment Protocol for Evaluation of the Open Burning and Open
Detonation Units, ATK Launch Systems Promontory, Utah, August 2}l4,TenaMentis;
Open Burn Open Detonation Human Health Risk Assessment, ATK Launch Systems
Promontory, Utah, June 2016, Geosyntec;
Ecological Risk Assessment Waiver Thermal Treatment Operations UTD009081357, August
29,2017, Utah Division of Waste Management and Radiation Control;
Thermal Treatment Units M-136 andM-225 Groundwater Monitoring Plan, ATK Launch
Systems Promontory Facility, April 2018, ATK Launch Systems Inc.; and
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uTD009081357
ATK launch Systems Inc. - Promontory
Module II - General Facility Conditions
II G.l.h.
II.G.2.
TI.G.3.
II.G.3.a.
rr.c.3.b.
II.G.3.c.
rI.G.3.d.
II.G.3.e.
II.c.3.f.
II.G.3.g.
rr.G.3.h.
Ir.G.3.i.
II.G.4.
Soil Monitoring Plan, Promontory Hazardous Waste Storage and Subpart X Treatment Permit,
April20l8, Orbital ATK Launch Systems Inc.
Reserved
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 tlpes of reactive hazardous waste treated at the M-l36 and
M-225 thermal treatment areas, including all donor material and ignition compounds;
An accounting of the total quantity of Propellant, Explosives and Pyrotechnics (PEP) and
Contaminated Waste treated at the M-l36 andM-225 thermal treatment areas for the annual
reporting period;
An accounting of the total quantity and tlpes of reactive metal powders treated at the M-136
andM-225 thermal treatment areas for the annual reporting period;
An accounting of the types and quantities of flare molds treated at the M-136 andM-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;
A list and description ofany new waste profiles that have been generated for new energetic
materials that have been treated at the Promontory Thermal Treatment Areas;
The semiannual annual analytical results for the burn ground ash as required by Section 1 1.8.2.5
ofAttachment 11;
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;
A review of the of the human health risk assessment, identified in Condition II.G.I.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)anthlacene, benzo(k)fluoranthene, chrysene and indeno(I,2,3-cd)pyrene); and
A 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 deterrnines after reviewing this arurual 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.
ATK Laurch Systems Inc. - Promontory
Module II - General Facility Conditions
II.G.5.
II.H.
II.H.1.
II.H.2.
II.H.3.
TI.H.4.
II.H.5.
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II.I.
II.I.1.
tI.t.2.
II.J.
II.J.1.
II.K.
II.K.1.
II.K.2.
II.K.3.
II.K.4.
If the Permittee is requfued to update the human health risk assessment for the M- 1 3 6 or M-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
wgTlqng. witlr or argund 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
continggncy 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 R3l5-8-2.7(e) [40 CFR 264.16(d) and264.l6(e)], in accordance with the
Training Plan in Attachment 3. These records shall indicate the type and amount of
training received.
The Permittee shall maintaina copy of the Training Plan at the Facility until it is fully
closed and closure is certified.
Employees working at the M-l36 andM-225 Thermal Treatment Areas shall receive
la;k-specffic, on-the-job-training in addition to the training outlined in Attachment 3.
This training 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 R3l5-8-2.8., the Permittee shall comply with
the Conditions III.G and III.H pertaining to ignitable, reactive, or incompatibie-waste.
LOCATION STANDARDS
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 6y UAe ml5-8-3.3.
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
FOR IGNIT
July I l, 2018
uTD009081357
ATK launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.K.5.
II.K.6.
II.K.7.
II.L.
II.L.1.
U.L.2.
TI.L.3.
tr.L.4.
II.M.
II.M.1.
II.N.
II.N.1.
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 cofirmunications or alarm system as required
by UAC 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 R3 1 5-8-3.7. Copies of the Coordination
Agreements shall be kept in the Operating Record. The attempts to make such
agreements, any refusali and all final agreements shall be documented in the Operating
Record.
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 or hazardous constifuents which threatens or
coirld 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
may be 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 R31,5'8-4.4.
The Permittee shall review the Contingency Plan, in accordance with UAC R315-8-4.5
and shall modify 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.
MAIIIFEST SYSTEM
The Permittee shall comply with the manifest requirements of UAC R315-5-2 and UAC
R3l5-8-5. The manifest tracking number shall be recorded in the Operating Record
with each waste load that arrives or leaves the Permittee's facility.
RE,CORDKEEPING AND REPORTING
The permittee shall maintain an accurate written Operating Record at the facility in
accoidance with UAC R315-8-5.3 (40 CFR 264.73 incorporated by reference) and
R3l5-50-2 (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 264.73b)e) incorporated by refereqce], 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
II.N.2.
ATK launch Systems Inc. - Promontory
Module II - General Facility Conditions
TI.N.3.
II.N.4.
TI.N.5.
II.o.
II.o.1.
II.O.2.
II.O.3.
II.O.4.
II.o.5.
II.O.6.
July I l,2018
u-rD009081357
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 1 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
R3l5-8-5.8.
All reports, notifications, applications, or other materials required to be submitted to the
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 R315-8-7. The Permittee shall notifr 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 R315-8-7, R3l5-8-9 and Attachment 5. Facility
equipment, structures and soil which have not been decontaminated shall be disposed of
onlyat a permitted hazardous waste treatment, storage or disposal facility.
The Permittee shall certi$z that the facility has been closed in accordance with the
specifications in Attachment 5 as required by UAC R3l5-8-7, and shall provide a
certification by an independent, Utah registered professional engineer qualified by
experience and education in the appropriate engineering field.
II.O.7.
ATK launch Systems [nc. - Promontory
Module II - General Facility Conditions
II.O.8.
rI.o.9.
II.P.
il.P.1 .
r[.P.2.
II.P.3.
II.P.4.
il.P.5.
II.Q.
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July I 1,2018
t]TD009081357
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
modifr the Closure/Post-Closure Plan for that hazardous 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 R3l5-101.
COST ESTIMATES FOR HWMU CLOSURE
The Permittee's closure cost estimate for each HWMU shall be prepared and maintained
at the 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 Permittee shall maintain the latest adjusted closure cost
estimate in the operating record. The closure cost estimates shall identifr 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 R3l5-8-8 (40 CFR 264.142 incorporated
by reference).
On the 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 R3l5-8-8 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.
ATK [-aunch Systems [nc. - Promontory
Module II - General Facility Conditions
rr.Q.2.
II.R.
II.R.I.
II.R.2.
II.R.3.
II.s.
II.s.1.The Permittee shall comply
R3rs-8-8 (40 CFR 264.148
with the notification and financial
incorporated by reference).
requirements of UAC
July 11,2018
uTD009081357
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
byUAC R315-8-8.
LIABILITY REOUIREMENTS
The Permittee shall demonstrate continuous compliance with the liability requirements
of UAC R315-8-8 (40 CFR 26ala7@) incorporated by reference). The Permittee shall
have and maintain hazardous waste liability coverage for sudden accidental occurrences
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-136 andM-225 Thermal Treatment
Areas.
Changes in liability coverage mechanisms shall be approved by the Director 60 days
prior to such a change.
'ATK Launch Systems rr.. - n..-t
Module IV - Thermal Treatment of Energetic Wastes
IV.A.
rv.A.1.
IV.A.2.
TV.A.3.
TV.A.4.
IV.B.
TV.B.1.
IV.B.1.a.
IV.B.1.b.
IV.B.l.c.
ry.B.1.d.
IV.B.1.e.
July I 1, 2018
uTD009081357
MODTTLE TV - 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 Permittee shall comply with UAC R315-8 and all conditions of this
module and Permit.
The permit conditions of this module allow thermal treatment at the two Hazardous Waste
Management Units, desiguated as the M-136 andM-225 Thermal Treatment Areas, as
designed and described in the drawings and specifications in Attachments 6 and 11. The
M-l36 Thermal Treatment Area consists of 14 burn stations and 2 open detonation areas.
TheM-225 Thermal Treatment Area consists of 4 burn stations and 1 open detonation area.
Thermal treatment at both of the Promontory Thermal Treatment Areas shall only be
accomplished by properly trained ATK personnel in accordance with ATK's Standard
Operating Procedures, the conditions of this Permit and its attachments.
This Permit has been developed in accordance with the applicable requirements of UAC
R315-1 through 101. All conditions in this Permit shall supersede conflicting statements,
requirements, or procedures found in UAC R315-1 through 101 or attachments to this
Permit.
PBRMITTED AI\D PROIIIBITED WASTE IDENTIT'ICATION
The Permittee may treat energetic or reactive hazardous waste at the two Promontory
Therrnal 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 government and private
facilities (e.g. cured and uncured propellants, excess propellants and propellant scraps);
Production materials contaminated with class 1.1 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 l. 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.B.1.f.
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oATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
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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;
tV.B.l.h. Reactive bag house dust generated from the processing of explosive ingredients and
propellants; and
IV.B.I.i. Waste developmental propellants, explosives and associated contaminated production
TV.B.2.
materials.
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, D008, D030, D038, F001, F002, F003, F004, F005 and K044.
The Permittee is prohibited from thermally treating reactive hazardous waste classes and
compositions not included in Conditions [V.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 any reactive hazardous waste that does
not have a designated waste profile.
The Permittee is prohibited from thermally treating decoy flare molds with less than 4%o
propellant contamination.
The addition of hazardous waste codes to Condition fV.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
Based on the results of the Human Health Risk Assessment, identified in Condition
II.G.1.e., the Permittee shall comply with the following treatment limits for the M-l36
Thermal Treatment Area:
The Permittee shall not treat, by open burning (OB), more than a combined amount of
122,000 pounds of reactive hazardous waste in a calendar day, under treatment scenario
M-136-4;
The Permittee shall not treat by OB more than 96,000 pounds total of reactive hazardous
waste in a calendar day at any six burn stations of burn stations 1 through 12, at 16,000
pounds in each station, under treatment scenario M-l36-4;
The Permittee shall not treat by OB more than 10,000 pounds of reactive hazardous waste
in a calendar day at burn station 13 under treatment scenario M-l36-4;
The Permittee shall not treat by OB more than 16,000 pounds of reactive hazardous waste
in a calendar day, at burn station 14 under treatment scenario M-136-A;
The Permittee shall not treat, by open burning (OB), more than 125,000 pounds total of
reactive hazardous waste in a calendar day at burn station 14 under treatment scenario
M-l36-8; and
TV.B.3,
TV.B.4.
IV.B.5.
IV.B.6.
TV.B.7
IV.C.
TV.C.1.
IV.C.1.a.
IV.C.1.b.
IV.C.1.c.
IV.C.1.d.
IV.C.1.e.
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'ATK Launch Systems Ir.. - P-#..y
Module IV - Thermal Treatment of Energetic Wastes
ry.c.1.f.
\r.c.2.
TV.C.3.
IV.C.4.
tv.c.5.
IV.C.5.a.
ry.c.5.b.
IV.C.5.c.
IV.C.6.
IV.C.7.
TV.C.8.
TV.C.9.
July I l, 2018
uTD009081357
The Permittee shall not treat by OD more than 600 pounds of reactive hazardous waste in a
calendar day at eachburn station 13 and 14.
The Permittee shall not operate more than one treatment scenario, M-136-A, M-136-B, or
M-136-C in a calendar day.
The Permittee shall operate the M-l36 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11, Section 5.
The Permittee shall not treat more than 10,000,000 pounds of reactive hazardous waste at
the M-136 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.
Based on the results of the Human Health Risk Assessment, identified in Condition
II.G.I.e., the Permittee shall comply with the following treatment limits for theM-225
Thermal Treatment Area:
The Permittee shall not treat, by open burning (OB), more than 4,500 pounds of reactive
hazardous waste per calendar day under treatment scenario M-225-A;
The Permittee shall not treat by OB more than 4,500 pounds total of reactive hazardous
waste in a calendar day at burn stations 1 through 4, at 1,125 pounds in each station under
treatment scenario M-225-A; and
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-225-8.
The Permittee shall not operate more than one treatment scenario, M-225-A, orM-225-B in
a calendar day.
The Permittee shall operate theM-225 Thermal Treatment Area in accordance with the
quantity-distance requirements identified in Attachment 11 section 5.
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 Perrnittee 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 1l and the following conditions:
The Permittee shall conduct all open burn operations within the secure areas designated as
the M-136 orM-225 Thennal Treatment Areas with controlled access as identified in
Attachment 11;
IV.C.9.a.
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IV.C.Q.b. The Permittee shall post warning signs around both of the Thermal Treatment Areas to
keep unauthorized personnel out;
IV.C.9.c. The Permittee shall maintain the egress paths for both of the Thermal Treatment Areas
identified in Attachment 4;
tv.C.g.d. 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.e;
IV.C.9.e. 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-136 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;
IV.C.p.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 identifred in Condition fV.D, E, F, G, H and I;
tV.C.9.g.
rv.c.9.h.
rv.c.9.i.
rv.c.9j.
TV.C.9.k.
IV.C.10.
The Permittee shall provide operators with access to a telephone that can be used to contact
support personnel, including security, safety and fire-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. Inspection 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 Thermal
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
Treatment Areas. The Permittee shall maintain compliance with the environmental
performance standards listed in UAC R315-8-16.
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Module IV - Thermal Treatment of Energetic Wastes
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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 cumulative carcinogenic risk to on-site workers shall not exceed 1.0x10-a (one
in ten thousand) or aHazard Index of 1.0 for the potential workers positioned at the point
of on-site maximum exposure, as calculated according to the methodology in the approved
HHRA. The maximum amount treated at the burning grounds shall not exceed the
treatment scenarios outlined in Table 1, Attachment 11; and
The excess cumulative carcinogenic risk to actual or potential off-site receptors shall not
exceed 1.0x10-6 (one in a million). The cumulative non-carcinogenic hazardto actual or
potential off-site receptors shall not exceed ahazard index of 1.0 for any 24-hour period
following initiation of a burn or detonation, as calculated according to the methodology in
the approved HHRA.. The maximum amount treated at the burning grounds shall not
exceed the annual maximum quantities outlined in Table 1, Attachment 11.
Based on the air dispersion and deposition modeling and the human health risk assessment,
identified in Section II.G., the Permittee shall adhere to the following conditions:
The Permittee shall notiff the Box Elder County Fire Marshall's Office and obtain a
clearing index before each treatment operation involving reactive material;
The Permittee may conduct burns and open detonations only between the hours of 9:00 am
Mountain Time (MT) and 6:00 pm MT;
The Permittee shall only conduct burns when the surface wind speed is greater than 3 miles
per hour (mph) and less than 15mph; and
The Perrnittee may conduct burns and open detonations only when the Clearing Index (CI)
is greater than 500 unless, approved by agreement with the Utah Division of Air Quality,
Box Elder County and the Director.
WASTE TRACKING
The Permiuee shall track all reactive hazardous waste in accordance with Attachment I I
and maintain this information in the operating record for both of the Promontory Thermal
Treatment Areas.
PRE-BI]RN ACTTYITIES
Prior to bringing any reactive hazardous waste into either of the Promontory Thermal
Treatment Areas for therrnal treatment, The Permittee shall conduct pre-burn activities in
accordance with the requirements identified in Attachment I l, 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 treatment
unit shall be inspected prior to placing reactive waste in the treatment unit;
IV.C.11.
IV.C.11.a.
IV.C.l l.b.
rv.c.t2.
\r.C.12.a.
rv.c.12.b
IV.C.12.c.
IV.C.l2.d.
IV.D.
tv.D.1.
IV.E.
IV.E.1.
IV.E.1.a.
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Module IV - Thermal Treatment of Energetic Wastes
IV.E.I.b. Any treatment unit that fails one or more of the
service until the problem is corrected;
luty t t, ZOtA
urD009081357
IV.E.l.c.
rv.E.1.d.
IV.E.1.e.
tv.E.1.f.
IV.F.
TV.F.1.
IV.F.1.a.
rv.F.1.b.
IV.F.1.c.
rv.F.1.d.
IV.F.1.e.
TV.F.2.
IV.F.2.a.
inspection criteria shall be removed from
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-8,
"Inspection Schedule for Thermal Treatment Area at M-136" or Table II-C, "Inspection
Schedule for Thermal Treatment Areas atM-225" is not available for use at each respective
location;
A11 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 of the treatment unit
and assure that no unauthorized employees are present in the area. If any 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 WASTB FOR THERMAL TREATMENT BT]RN
Prior to placing any reactive hazardous waste in a treatment unit, the Permittee shall
comply with all provisions Conditions [V.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 being
loaded with reactive hazardous wastes as defined in Condition IV.B.1;
The treatment unit shall be loaded in accordance with all internal safety procedures and
requirements and the provisions identifred in Attachmerrt 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 be
inspected after use. If there is any contamination in the containers they shall be cleaned or
decontaminated in accordance with the procedures identified in Attachment 11 before being
reused; and
The Permittee shall document in the operating record the burn station for each container of
reactive hazardous waste treated.
Prior to beginning the final preparations for an open burn, the Permittee shall comply with
the following conditions:
Reactive waste shall not be prepared for ignition, as described in Attachment 1 1.8.2.3, until
all non-essential personnel leave the treatment area;
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All wiring and ignition operations, described in Attachment 11.8.2.3, shall be conducted by
at least two employees;
The Permittee may reactivate the firing system treatment areas only after all operators have
exited the QD for the treatment unit;
As the operators leave the treatment area following operations described in Attachment 11,
Section 8.2.3, they shall close the gate to the treatment area;
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;
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 should
vacate the QD area for the treatment area. If the flashing light is not operational, the
Permittee shall comply with Condition IV.E.1.f. before initiating the thermal treatment;
After the warning identified in Condition IV.F.2.f. has been completed, the Perrnittee shall
conduct a pre-ignition continuity check of the firing system to assure 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:
Remove the interlock for the firing control system, deactivating the firing control system;
At least two operators shall reenter the treatment area, and correct the problem;
If the resistance problem cannot be immediately corrected, the operators may connect a
separate igniter wire to an adjacent stanchion; and
After the problem with the firing circuit has been corrected the operators shall repeat the
steps described in Conditions IV.F.2.g.
The treatment units shall be fired in accordance with the provision of Attachment 11,
Section 8.2.3 of this Permit;
All thennal treatment events shall be observed with a video camera from the firing control
room or immediately outside the firing control room;
ln the event that none of the treatment units ignite, 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 fV.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 [V.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
rv.F.2.b.
IV.F.2.c.
rv.F.2.d.
IV.F.2.e.
;
rv.F.2.f.
IV.F.2.g.
IV.F.2.g.i.
IV.F.2.g.ii.
IV.F.2.g.iii.
IV.F.2.g.iv.
rv.F.2.h.
rv.F.2.i.
rv.F.2j.
tv.F.2.k.
rv.F.2.l.
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Module IV - Thermal Treatment of Energetic Wastes
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uTD009081357
IV.G.
TV.G.1.
TV.G.2.
tv.G.2.b.
IV.G.2.c.
rv. G.2.d.
IV.G.2.e.
tv.G.2.f.
IV.G.2.g.
rv.G.2.h.
rv.G.2.i.
IV.F.2.m. 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-BI.IRN ACTITVTIES
Following treatment, the Permittee shall conduct the post-burn inspection activities
identified in Attachment2, and clean-up activities identified in Attachment 11of this
Permit, and shall comply with Conditions fV.C.1, 5 and 9, 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.
applies:
N.G.2.a. Prior to entering the treatment area, the operators shall deactivate the firing control system
rv.G.2j.
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 identiff 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;
Identiff the treatment unit where unburned waste is being stored;
Evaluate the condition of the safety equipment identified in Attachmeri2,Table II-B and
Table II-C;
The Permittee 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
The Permittee may delay the post-burn inspection for burns involving bulk propellant and
bulk explosives that occurred on a Thursday, if it is the end of the work week or Friday.
The post-burn inspection shall be conducted on the following Monday, unless the
meteorological conditions identified in Condition IV.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
TV.G.3.
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IV.G.3.a.
rv.G.3.b.
IV.G.3.c.
IV.G.4.
IV.G.4.a.
rv.G.4.b.
IV.G.4.c.
treatment area within the 24 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
Except 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 propagate 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
defined 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
reslidue 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
purposes of this Permit, an interrupted ignition occurs when anything greater thara5Yo 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
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.
rv.G.4.d.
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oATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
July I l, 20i 8
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IV.H.STORM WATER MANAGEMENT AND RTIN.ON AND RTIN.OFF CONTROLS
tV.H.1. The Permittee shall manage all storm water collected from treatment units in accordance
with this Permit, Attachment 11, Section l l and UAC R315-5.
TV.H.2.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 operating area of the Promontory Thermal
Treatment Areas shall be managed in accordance with UAC R315-8-16, which incorporates
by reference 40 CFR 264.60l,using berms, and ground slope.
TREATMENT RESIDUE AI\D ASH MANAGEMENT
All treatment residue and ash generated from the Promontory Thermal Treatment
operations shall be managed in accordance with Condition tV.G.4.d. 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 I and 1 1.
INSPECTION SCHEDT]LES AND PROCEDURES
The Permittee shall conduct inspections of the Promontory Thermal Treatment areas in
accordance with Attachment 2 and 11.
ENTVRONMENTAL MONITORING REOI]IREMENTS
The Permittee has completed a Human Health Risk Assessment based on the results of
emissions sampling and air dispersion modeling. The primary. Director approved
documents that were completed in the risk assessment process are listed in Section II.G. of
this Permit.
The Permittee shall conduct soil monitoring in accordance with the Soil Monitoring Plan
(referenced in Condition II.G.l.h.), in order to further assess the risk to human health from
thermal treatment operations at the Promontory facility. The results of the soil monitoring
will be compared to the maximum off-site concentrations predicted by the air dispersion
model, EPA Regional Screening Levels and background soil concentrations.
The Permittee shall complete the initial sampling event, as directed by the Soil Monitoring
Plan, and submit a report in writing on the soil monitoring results to the Director for
approval no laterthan January 31,2019.
The Soil Monitoring Report shall contain the validated analytical data, soil sampling
location map, a detailed analysis of the data (as described in Condition IV.K.2. and the Soil
Monitoring Plan) and a recommendation on the need for additional monitoring.
The Director may require the Permittee to conduct additional soil monitoring based on the
results of the Soil Monitoring Report.
tv.H.3.
TV.L
N.I.1.
\/.t.2.
IV.J.
TV.J.1
TV.K.
TV.K.1.
TV.K.2.
IV.K.3.
TV.K.4.
tv.K.5.
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Module IV - Thermal Treatment of Energetic Wastes
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uTD009081357
The Permittee shall submit a Soil Monitoring Plan addendum in writing to the Director for
approval within 90 days of being notified by the Director in writing that additional
monitoring is required.
The Permittee shall conduct groundwater monitoring in accordance with Module IV of the
Permittee' s Post-Closure Permit.
The Permittee shall evaluate the potential impacts to groundwater from thermal treatment
operations at the Promontory facility in accordance with the Groundwater Monitoring Plan
as approved by the Director on May 21,2018.
Based on the results of the evaluation required by Condition [V.K.8., the Director may
require the Permittee to conduct additional work to demonstrate that thermal treatment
operations at the Promontory facility do not impact groundwater.
The Permittee shall submit a Groundwater Monitoring Plan addendum in writing to the
Director for approval within 90 days of being notified by the Director in writing that
additional work is required to demonstrate that thermal treatment operations at the
Promontory facility do not impact groundwater.
ECOLOGICAL RISK
The Permittee requested a waiver from the Director for assessing the ecological risk
associated with thermal treatment operations at the Promontory facility on December 19,
20t6.
Based on the justifications presented by the Permittee in support of the waiver application
(referenced in Condition II.G.1.f.), the Director approved the waiver request on August 29.
20t7.
HT]MA}[ HEALTII RISK
The Human Health Risk was evaluated as identified in Condition II.G.1. Emission factors,
dose-response factors and human health risk scenarios are evaluated annually as directed by
Conditions II. G.3. g., II.G.3.h. and II.G.3.i.
FACILITY MODIFICATIONiEXPAIISION
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.
CLOST]RE A}[D POST CLOST]RE
The Permittee shall close the Promontory Thermal Treatment Areas in accordance with the
Closure Plan in Attachment 5.
PROMONTORY TIIERMAL TREATMENT AREAS OPERATING RECORI)
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-136 and
TV.K.6.
tv.K.7.
tv.K.8.
tv.K.9.
rv.K.l0.
TV.L.
IV.L.1.
IY.L.2.
IV.M
IV.M.1.
IV.N.
rv.N.1.
IV.O.
N.O.1.
TV.P.
IV.P.1.
Page I I
ATK Launch Systerns fn". - Oro.o?ry
Module IV - Thermal Treatment of Energetic Wastes
July I l, 2018
uTD009081357
M-225 Thermal Treatment Areas shall, at a minimum, include the following information:
IV.P.I.a. All inforrnation required by UAC R3l5-8-5.3;
N.P.1.b. Copies of all inspections required by this module;
IV.P.1.c. All waste tracking information maintained in the electronic Waste Tracking Record
identified in Attachment 11;
ry.P.1.d. A description of the meteorological conditions described in Condition IV.C.9.e. during
each burn;
IV.P.I.e. Copies of all reports identified in Condition II.G.I. and required by Condition II.G.3. and
IV.K and [V.L; and
IV.P.I.f. A running total of the tlpe and quantity of reactive hazardous waste that has been treated at
both of the Promontory Thermal Treatment areas during the calendar year.
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