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ATK Launch Systems Inc. - Promontory
August 21st and 22"d,2018
30 miles northwest of Brigham City, Utah
P.O. Box 707
Brigham Ciry, UT 84302-0707
Box Elder
Kris Blauer, Manager
Environmental Services
(80r) 2st-2r66
uTD00908l3s7
LQG, TSD
CEI
Jeff Vandel, Inspection Leader, DWMRC
Hao Zh:u, DWMRC
Karen Wallner, DWMRC
Kris Blauer, ATK
Blair Palmer, ATK
Paul Hancock, ATK
Paul White, ATK
Randy Fullmer, ATK
21 August 2018: 9:00 AM/3:45 PM
22 August 2018: 9:00 AM/3:30 PM
Jeff Vandel
Division of Waste Management and Radiation Control
HAZARDOUS WASTE INSPECTION REPORT
INSPECTION REPORT FOR:
DATES OF INSPECTION:
FACILITY ADDRESS:
FACILITY COTINTY:
FACILITY CONTACT:
EPA ID #:
CTIRRENT NOTIFICATION:
TYPE OF INSPECTION:
PARTICIPANTS:
TIME IN/TIME OUT
REPORT PREPARED BY:
WEATHER CONDITIONS:
APPLICABLE REQUIREMENTS:
Sunny but smoky skies, 83o F
RCRA Permits for Storage, Treatment and Post-
Closure, UAC R315
FACILITY DESCRIPTION:
The ATK Launch Systems Inc. - Promontory (ATK) facility is located in northem Utah,
approximately 30 miles northwest of Brigham City, Utah. ATK is a 20,000 acre facility that is
remotely situated in the arid Blue Creek valley, north of the Great Salt Lake mudflats in Box
Elder County. In 2018, ATK became a wholly owned subsidiary of Northrup Grumman
Corporation, but ATK will remain the operator of the facility.
Manufacturing operations first began at the ATK facility in 1956. ATK and its predecessors
have been primarily involved in the research, testing and production of rocket motor propellants.
The manufacturing processes include the preparation and mixing of high-energy ingredients,
casting and curing of the propellant formulations, assembly of rocket motor segments and
military flares, and quality control testing of finished products. These activities have included
the production and testing of motors for the Space Shuttle, wash-out and reloading of Minuteman
ICBMs, and many other projects for the National Aeronautics and Space Administration
(NASA), and the Department of Defense (DOD).
The ATK plant is divided into four major areas designated as: North Plant, Administrative and
Manufacturing Area (or South Plant), Test Area, and High Performance Propellant Development
Area (or Plant IIf . There are approximately 675 buildings located on the four areas that
comprise the ATK plant.
Currently, the primary manufacturing activities consist ofl work on the next generation of the
Space Launch System, 5 segment solid rocket motor; the common booster rocket segment;
rocket motor casing work for Castor, GEM 40 and GEM 60 motors;production work on Trident
D-5 motor nozzles; and military flare production. Rocket motor wash out operations are not
currently being conducted.
WASTE STREAM MANAGEMENT:
ATK generates, treats, and stores characteristic and listed hazardous wastes as defined by R315-
261 of the Rules as a result of its manufacturing and demilitaization activities. ATK has RCRA
Part B permits for hazardous waste storage, treatment and post-closure care. Reactive hazardous
waste is primarily generated from the mixing and casting of propellant and wastewater treatment
sludges. Chemical hazardous wastes are generated from rocket motor case preparation, painting
and machining. ATK treats reactive (and/or ignitable) hazardous wastes at the facility primarily
by open burning, although wastes are also occasionally treated by open detonation. These
treatment activities are conducted at two separate sites at the facility.
The OB/OD sites are designated as M-136, which is located north of the Administration and
Manufacturing Areas andM-225, which is located in the southeast area of the facility at Plant III.
The permit module containing conditions for open burning and open detonation - "Thermal
Treatment of Energetic Wastes" - was modified in November,20l6 after the approval of the
Human Health Risk Assessment for open burning activities at the site. The Permit modification
added treatment scenarios and maximum quantities to the Module that are based on the results of
the HHRA. There are three primary treatment scenarios that are allowed by the Permit for the
M-136 Burn Grounds and two scenarios that are permitted for the M-225 Burn Grounds. Based
on extensive experience at the facility, open burning and open detonation are the RCRA
regulated activities conducted at the facility that have the highest potential for impacting the
environment. Therefore the CEI and this report are focused primarily on this activity.
There are six permitted storage areas at the ATK facility: M-l86, M-705S, E-501, S-633, M-136
andM-629. ATK is permitted to store only solid reactive waste in containers at the M-136 Burn
Grounds, 5-633 storage area and M-629 storage building. Liquid hazardous wastes may be
stored in containers at the M-186, M-705S and E-501 storage buildings.
ATK is also permitted to treat waste hydrazine at building T-298 by dilution in accordance with
Module V of ATK's Storage Permit. Dilution of waste hydrazine with water is a DOT
requirement for shipping this highly volatile material off-site to a waste disposal facility. This
inspection report covers these hazardous waste management activities at the Promontory facility.
CREDENTIALS, PURPOSE AIID SCOPE
The purpose of this inspection was to evaluate ATK's compliance with R315 of the Utah
Adminishative Code and its two Part B Permits. This inspection evaluated the permitted
hazardous waste storage and treatment units, waste generation areas and 90-day storage areas.
The scope and purpose of the inspection was discussed during the pre-inspection briefing with
ATK. The inspectors had their credentials with them at the time of the inspection, but they were
not presented because they have known the ATK personnel for many years. A copy of the pre-
inspection checklist is included with this report in Appendix A.
NARRATIVE:
M-136 Burn Grounds
The M-136 Burn Grounds is the primary thermal treatment area at Promontory. The burn
grounds consist of three key areas; a large areathat contains Burn Stations 1 through 12, Burn
Station 13, and Burn Station 14. The burn grounds are located in an isolated area within the
Promontory facility. Access to the grounds is controlled by a fence and gate across the road at
the entrance.
The inspection of the Burn Grounds and their operation was focused on eight salient aspects:
o Treatment scenarios and quantities
o Wastecharacterization
Meteorological Conditions (clearing index, wind speed and direction)
Burn grounds maintenance and inspection
Laboratory analysis ofburn ash and residue
Laboratory analysis of soil samples collected from the burn grounds
Run-on and run-off control
o Post-closure care of surface impoundment caps
ATK maintains a Burn Grounds database that tracks the primary items that are regulated by
Conditions in the Thermal Treatment Module. A "screen shot" copy of the database is included
with this report in Appendix B. The items recorded in the database include: burn date; bum
station; quantity of reactive material (PEP); quantity of contaminated waste; waste description;
source of waste; waste profile#; HCI emissions; quantity of donor material and diesel fuel used;
wind speed; wind direction; sky conditions; temperature; clearing index; Box Elder County
approval; and total amount of PEP, contaminated waste and HCI emissions for the burn.
The Permit also requires ATK to submit an Annual Report of the Promontory Thermal
Treatment Areas Operation. The information that is required in the Report is outlined in Permit
Conditions II.G.3. through II.G.3.i. The edocs # for the 2017 Annual Report is DSHW-2018-
002038.
ATK conducts inspections of the M-136 Bum Grounds waste containers and labels, burn pans,
unloading areas, etc. daily when in use or weekly if not in use. Other items like fences, gates,
first-aid kit are inspected weekly or monthly. The LTTA caps and drainage ditches are inspected
quarterly in accordance with ATK's Post-Closure Permit. Copies of the inspection records are
included in Appendix C.
Based on the information contained in the Burn Grounds database, the 2017 Annual Report and
the inspection records, it appears that ATK is in compliance with the treatment scenarios and
maximum quantities allowed; the waste characteization requirements; meteorological conditions
and Burn Grounds maintenance and inspection.
The permitted open burning scenarios and maximum quantities are detailed in Section IV.C. of
the Thermal Treatment Module. The maximum quantities allowed by the permit for the different
scenarios and the maximum quantities burned in2017 are shown below in Table 1. The
quantities burned, which are taken from the Burn Ground database record for 2017, are well
below the maximum quantities allowed by the Permit.
Burn
Station
Treatment
Scenario
Maximum Daity Quantity
Burned 21412017 (lbs)
Maximum Daily Permitted
Quantity (lbs)
I M-136A 4l 16,000
)M-1364 4,173 16,000
3 M-136A 0 16,000
4 M-136A 10,839 16,000
5 M-136A 0 16,000
6 M-136A 6,589 16,000
7 M-136A 7,069 16,000
8 M-136A 9,945 16,000
9 M-136A 10,441 16,000
10 M-136A 0 16,000
11 M-136A 0 16,000
t2 M-136A 0 16,000
1-l2totrl M-136A 49,097 96,000
13 M-1364.3,237 10,000
t4 M-1368 40,000 (max. burned on 5ll5ll7)125,000
13 M-136C No detonations in 2017 600
t4 M-136C No detonations in 2017 600
Table I Maximum Daily Ouantity Burned in 2017
by Burn Station and Treatment Scenario
The treatment standard for reactive (D003) wastes burned at the Burn Grounds is deactivation.
ATK makes the determination that burned waste is deactivated by visual inspection. If it is
determined that any waste is not completely deactivated, it is re-burned. After the bum is
complete, the pans are cleaned out and the ash is disposed of in the solid waste landfill located
on the east end of the burn grounds (see Photograph #1 below). The landfill is a Class IIIb,
Subtitle D landfill permiued by the Division.
The Permit requires that burn ground ash and residue be analyzed semiannually. The perchlorate
results for the 2017 semiannual burn ash for M-136 was 4.56 mdkg and 4.80 mg/kg. For
M-225, the perchlorate results were 1.90 mg/kg and <0.01 mdkg. The EPA Regional
Screening Level (RSL) for perchlorate in residential soil is 55 mg/kg. No soil to groundwater
screening level is listed for perchlorate. The perchlorate levels detected in ash are well below the
residential RSL but the potential for migration to groundwater may be a concern. Groundwater
below the solid waste landfill at M-136 is approximately 320 feet deep.
Photograph #1 - Solid Waste, Class IIIb, Landfill at the East End of the M-136 Bum Grounds
ATK generally collects soil samples from the M-l36 Bum Grounds every two years. ATK is
required by the Permit to collect soil samples at the off-site maximum location, but there is no
requirement for sampling the burn grounds soil. These samples are collected from randomly
selected locations except for at Burn Station 14. Soil samples are typically collected from the
berm adjacent to the nozzle end of motors that are bumed at this station.
At the time of the inspection, the most recent soil sample results available for the M-136 Burn
Grounds were from September,2016. These samples were analyzed for VOCs, metals,
perchlorate and explosives. Samples were collected from the burn grounds in August, 2018, but
the results were not available at the time this report was prepared. Based on the September, 2016
results, it appears that some high concentrations of cobalt were detected. Several of the results
obtained exceed background concentrations and residential RSLs. One of the samples also
exceeds the industrial RSL.
ATK has stated that the elevated cobalt concentrations are most likely from burning HACN
(hexamine cobalt nitrate) waste that was accepted from the Autoliv facility in years past. ATK
no longer accepts or burns HACN waste. Elevated concentrations are occasionally detected from
the random soil sampling at M-136.
Based on the M-136 Quarterly Post-Closure Inspection Checklists that were reviewed, no
problems were identified with the drainage ditches and culverts that are used to direct surface
water run-on around the active areas of the burn grounds. Surface water run-off is directed to a
bermed area downhill of the burn grounds where it seeps into the ground.
In addition, based on the Post-Closure Inspection Checklists, it appears that no problems were
identified with the LTTA caps at M-136. The caps are inspected for erosion, burrows,
significant vegetation and settling. Copies of the inspection documents for March and June,
2018 are enclosed in Appendix C.
Burn Stations 1 through 12
Most of the containerized waste is burned in metal pans at Burn Stations 1 through 12. Liquid
wastes are not burned in the pans, however, desensitizing liquid (e.g. shingle oil) is added to
some waste containers to prevent accidental ignition. A variety of containers are used to hold the
reactive wastes that are burned in the pans. These containers include super sacks, plastic bags,
slids, cardboard boxes and drums. Open burning is currently conducted about once per week.
Waste containers are received from ATK Bacchus for open burning one or two times per month.
At the time of the inspection, the Bum Station 1 pan contained super sacks of waste water
treatment filters contaminated with perchlorate (see Photograph#2 below). The containers were
closed and labeled. ATK uses a bar code system on labels to track information on each waste
container. Photograph #3 below is a picture of the label that was on the super sack containing
the wastewater treatment filters. The pans are managed to minimizethe collection of
precipitation by either turning them upside down or covering them with lids.
Burn Station 14
Rocket motor segments are burned on the ground within a bermed area at Burn Station 14.
Currently, GEM 46 filament-wound motors are the primary motors bumed at this station. ATK
burns approximately nine of these per year. Third stage Minuteman motors are also burned at
Bum Station 14. After the burn is complete, the ash and remaining debris is disposed of in the
on-site, solid waste landfill.
Photograph #2 - Super Sacks in burn pan, Burr Station #1, M-136 Bum Grounds
:f:$-T:;;ffiffii
Photograph #3 -Hazadous Waste Label on Super Sack, M-136 Burn Grounds
Burn Station 13
Reactive laboratory waste and potentially propulsive items are burned at Burn Station 13 in
"clam shells." These are metal pans that are constructed with lids to contain the waste being
burned but allow.emissions to escape (see Photograph#4 below). These pans are currently used
approximately once every two to three weeks.
Photograph #4"Clam Shell" burnpans at Bum Station #13
The reactive laboratory waste typically contains listed constituents. The ash and residue
removed from the trays after the burn is complete is put into drums that are managed as satellite
accumulation containers until they are taken to the M-l86 Permitted Storage facility and then
shipped off-site for disposal. Only a couple of drums of listed waste are generated at Bum
Station #13 per year. No issues'were identified at the M-136 Burn Grounds during the
inspection.
5-633 Permitted Storage Area
Permiued storage area 5-633 is a road-base pad approximately 100' by 120' in size located
adjacent to the M-136 Bum Grounds. Solid reactive wastes are stored on the pad prior to
treatment at the bum grounds. The area is enclosed with a fence and access is controlled by a
gate.
During the inspection, reactive hazardous wastes stored at 5-633 included two rocket motor
ignitors that were stored in a palletainer (a large plastic crate with a lid and pallet-like bottom).
The ignitors were each labeled appropriately. In addition, donor propellant and a section of
linear shaped charge were stored at 3-633. These items are used to assist with open burning the
reactive waste. No problems with the storage area were observed during the inspection.
M-186 Hazardous Waste Storage Building
Building M-l86 is the primary hazardous waste storage facility at Promontory. ATK is
permitted to store 22,000 gallons, or 400 55-gallon containers at the facility. The containers
observed during the inspection were closed, in good condition and labeled appropriately
(including the new labeling requirements under the R315-262-31rules). In addition, the
different classes of waste were properly segregated with adequate aisle space between the rows
of containers. No problems were observed at the storage facility.
M-705 South Hazardous Waste Storage Building
This storage facility is a relatively small room at the south end of Building M-705. It is used for
storing hazardous waste, accumulating small quantities of hazardous waste for packaging in
drums and compacting rags contaminated with hazardous waste. Waste containers were covered
and properly labeled during the inspection. The storage facility appears to be well managed. No
problems were observed.
In addition to the hazardous waste storage facility and wastewater treatment plant, the new grain-
former batch leach process will also be located at Building M-705. The grain-formers are solid
plastic parts that form the grain, or surface configuration, of the propellant in LUU-19 flares that
are produced by ATK at the plant. Once the propellant is cured, the grain-former is removed
from the flare. A small amount of propellant sticks to the surface of the grain-former which
makes it reactive hazardous waste.
ATK has been testing a process to leach the propellant off of the grain former in a tank to
deactivate the reactive characteristic. ATK is seeking approval to send the non-hazardous grain
formers back to their supplier to have them recycled. The main objective of this treatment
process is to responsibly manage the waste stream without burning large chunks of plastic at the
open burning grounds.
The Division is in the process of renewing ATK's Hazardous Waste Storage and Treatment
Permit. If ATK's testing is successful, a Module will be added to the permit to address the grain-
former treatment process. The wastewater generated from the process would be treated in the
wastewater treatment plant and discharged to Blue Creek in accordance with ATK's UPDES
Permit.
M-629 Hazardous Waste Storage Building
The M-629 storage facility was added to the Permit in Novemb er,2017. ATK is not permitted to
store liquid hazardous waste at this facility; it is primarily used in the winter to store waste solid
10
propellant prior to being burned at the bum grounds. The building was empty at the time of the
inspection.
M-721 Ammonium Perchlorate Production Building
In the past, ATK bought AP for their propellant mixtures from off-site vendors. ATK is now
looking at producing their own AP on the plant. ATK is currently testing bench-scale production
of AP at Building M-721. The building was visited during the inspection. It is unknown at this
time if hazardous waste will be generated from this process.
M-225 Burn Grounds
Reactive hazardous wastes that arb generated at Plant III are treated by open burning at the
M-225 Burn Grounds. Open burning is currently conducted once or twice per month. The
quantity of hazardous waste treated is typically 500 pounds or less. Due to the small quantity
being treated lately, ATK has primarily been using just one burn pan (see Photograph #5 below).
Ash and residue generated from open burning are transported to the solid waste landfill located
at the M-136 Bum Grounds for disposal. Reactive wastes that have an F-listed code attached to
them are infrequently generated. Ash and residue generated from burning these wastes are
collected separately and shipped off-site for disposal. No issues were observed at the burn
grounds during the inspection.
Photograph #5 - Burn Pan with lid at the M-225 Burn Grounds
lt
T-298 Hydrazine Dilution Building
Waste hydrazine is generated from static tests of rocket motors at ATK's Test Area. In the past,
all of the waste hydrazine was shipped off-site for disposal. Due to the extreme volatility of
hydrazine, the DOT requires that it be diluted with water before it can be shipped. This dilution
process is considered treatment of hazardous waste and is regulated by the Permit Conditions in
Module V of ATK's Permit.
In recent years, ATK has been reusing waste hydrazine if it meets specifications after it is
filtered. [n general, most of the waste hydrazine is now reused, although hydrazine that doesn't
meet specifications or is left over from sample analysis is still diluted and sent off-site. No
problems were observed at BuildingT-29B during the inspection.
M-26 Propellant Mix Building
A significant portion of the reactive hazardous waste generated at ATK comes from the
propellant mix buildings. Most of the composite propellants mixed consist of ammonium
perchlorate or other oxidizers (e.g. potassium nitrate or ammonium nitrate), aluminum powder as
fuel, and polymer binder. These ingredients are mixed in a large bowl which is then taken to the
motor casting building.
ATK has implemented a robust waste reduction program for this process over the years. The
quantity of hazardous waste generated from the mix buildings has been significantly reduced
over the last ten years. The building was visited during the inspection, but it was not in
operation. No issues were identified.
Operating Record
A review of records was conducted following the inspection of the facilities discussed above.
ATK explained how records are kept for the burn grounds and demonstrated how information
could be looked up in the database. Inspection records, training records, hazardous waste
manifests and T-29B hydrazine dilution records were also reviewed.
ln addition, ATK provided soil sample data, ash and residue data and burn quantity and scenario
records upon request following the on-site visit. This information was reviewed and is discussed
above.
COMPLIA}ICE STATUS:
The inspection evaluated ATK's compliance with its Hazardous Waste Treatment and Storage
Permit, its Post-Closure Permit, and R3l5 of the Utah Administrative Code.
No compliance issues were discovered.
t2
ISSUES:
o Although the perchlorate levels detected in the 2017 semiannual ash analysis are well
below the residential RSL, the potential for migration to groundwater may be a concern.
Groundwater below the solid waste landfill at M-136 is approximately 320 feet deep.
This is an issue that has been discussed with ATK in the past. In an effort to determine if
continued operation of the burn grounds is having any impact on groundwater, ATK has
conducted statistical trend analysis on monitoring well data at the M-136 Burn Grounds
to determine if increasing or decreasing trends can be identified in perchlorate
concentrations.
Increasing trends (as well as decreasing trends and no trend), were identified in a few
wells near M-136. ATK suspects that the increasing trends that have been observed are
the result of paleo contaminants migrating from an up-gradient source. ATK has recently
completed, detailed groundwater modeling for the area to see if the results support this
explanation. This groundwater modeling is currently being evaluated.
Based on the September, 2016 results, it appears that some high concentrations of cobalt
were detected. Several of the results obtained exceed background concentrations and
residential RSLs. One of the samples also exceeds the industrial RSL.
ATK has stated that the elevated cobalt concentrations are most likely from burning
HACN (hexamine cobalt nitrate) waste that was accepted from the Autoliv facility in
years past. ATK no longer accepts or burns HACN waste. Elevated concentrations are
occasionally detected from the random soil sampling at M-136.
Since ATK is no longer burning the HACN waste, the burn grounds will remain active
into the future, and cobalt oxide appears to have a very low solubility, no action on the
elevated cobalt detected is recommended at this time. The Division will be renewing
ATK's Operating Permit next year. It is recommended that conditions be added to the
Thermal Treatment Module to make the biannual sampling at the burn grounds a
requirement.
INSPECTOR SIGNATURE:ATE 1 lz't lzpt\
Environmental S cientist
lnspection Lead
t3
APPENDIX A
t4
Facility:
EPA ID #:
Address:
Type of lnspection:
Date of lnspection:
Team Leader:
Team Members:
Pre-Insnection Checklist
ATK Launch Systems Inc. - Promontory Facility
uTD0090813s7
ATK Launch Systems lnc.
Promontory Facility
P.O. Box 707
Brigham City, UT 84302-0707
Compliance Evaluation Inspection (CEI)
August 2l &22,2018
Jeff Vandel
HaoZhl
Karen Wallner
Pre-Inspection Conference
Date:
lnspection Scope:
M-l 36 and M-225 Open Burning Grounds:
Treatment scenarios and quantities (Permit Conditions IV.C.1.a. through IV.C.1.f.)
Waste characteization (Permit Condition IV.B.4.)
Meteorological conditions (Permit Conditions IV.C. 1 2.c. and IV.C. I 2.d.)
Inspect condition of burn trays, operating record for inspections (Permit Condition IV.E.l)
Semiannual analytical results for burn ash and residue (Permit Condition IV.I.2.)
Analytical results for soil samples collected from the M-l36 Burn Grounds (Attachment 11, l1.l0.l)
M-136 Burn Grounds - LTTA cap and drainage ditch inspections (P.C. Permit Condition III.C.I.)
M-186, M-705S, E-501, M-629 and 5-633 Permitted Hazardous Waste Storage Areas - inspect the
site, condition of containers, sumps, operating record for inspections (Permit Condition II.F. I .)
Look at process for leaching propellant residue from flare grain formers
Personnel Training - look at records. New employees trained within 6 months? Annual review for
contingency and hazardous waste management procedures? (Conditions II.H.1. and II.H.2.)
Inspect main sources of reactive and non-reactive hazardous wastes.
Manifests - look at a number of manifests for wastes received and wastes shipped
Safety Equipment:PPE
Inspection Notification: (indicate the contact and the date and time of contact)
' Facility: Kris Blauer. ATK Launch Systems - Promontory. July 10. 2018
' Local Health Department: Bear River Health Dept.. August 15. 2018
Team Leader:
Time:
15
Supervisor:
APPENDIX B
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