DSHW-2018-008103 - 0901a068808a7e20

State of Utah
GARYR. HERBERT
Governor
SPENCERJ. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Execatiye Director
DWISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
August 22,2018
Kris Blauer, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham city, Utah 84302-0707
RE: Hazardous Waste Treatment and Storage Permit Class I Modification
ATK Launch Systems - Promontory Facility
uTD0090813s7
Dear Mr. Blauer:
The Division of Waste Management and Radiation Control has completed its review of ATK's proposed
Class I modification for the Hazardous Waste Treatment and Storage Permit that was submitted on
July 26,2018. ATK's modifications to Modules II and IV are appropriate and are hereby acknowledged.
The modified pages for these modules are enclosed. Please update your copy of the permit by inserting these
modification pages.
If you have any questions, please call JeffVandel at [phone].
Sincerely,
Director
Division of Waste Management and Radiation Control
STA/JV/KI
Enclosure: Module II - General Facility Conditions (DSHW-2018-008106)
Module fV-Thermal Treatment of Energetic Wastes (DSHW-2018-008107)
c: Blair Palmer, ATK Launch Systems
Lloyd Berentzen, MBA, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Jesse Newland, USEPA, Region 8
195 North 1950 West. Salt take Ciry, UT
Mailing Address: P.O. Box 144880 . Salt Lake City, UT 841144880
Telephone [phone] . Fax [phone]. T.D.D. (801) 5364284
znaw.deq.utah.goo
Printed on 100% recycled paper
DSHW-2o18-008103
ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
Modified August,2018
uTD00908t357
MODULE II. GENERAL FACILITY CONDITIONS
APPLICABILITY
The requirements of this permit module pertain to allHazardous Waste Management
Units (HWMUs) identified within Modules I, II, IIL IV and V.
DESIGN AND 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 permiued HWMU at the facility shall be
documented by as-built drawings and certified by a registered professional engineer in
accordance with Condition I.R.1. and UAC R315-3-3.10X2XD.
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.
REOTIIRED NOTICE
As required by UAC R315-8-2.3(aX1), the Permittee shall notify the Director in writing
at least four weeks in advance of the date the Permiuee 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 ananges to receive hazardous waste from an off-site source (except
where the Permittee is also the generator), the Permittee shall inform the generator in
writing that he has the appropriate permit(s) for, and will accept, the waste the generator
is shipping. The Permittee shall keep a copy of this written notice as part of the
operating record as required by UAC R315-8-2.3(b).
WASTE ANALYSIS PLAN
The Permittee shall follow the procedures of the Waste Analysis Plan included as
Attachment 1 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 1) 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-I.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 1.
II.A.
II.A.1.
II.B.
II.B.1.
TI.B.2.
II.B.3.
il.c.
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II.C.2.
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ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.D.4.
II.D.5.
II.D.6.
II.D.6.a.
rI.D.6.b.
II.D.6.c.
II.D.7.
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Modified August,2018
urD009081357
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. Characteization 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 analyical 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 15th 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
analvtical laboratorv. the Director will submit written notification to the Permittee. The
Permittee shall notiiy the Utah Department of Health, Bureau of Laboratory
Improvement 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 controVquality
assurance data provided by the laboratory is sufficient to assess the validity of the data.
The Permittee shall inform the laboratory in writingthat 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 remedy requires more than 72 hours to implement from the time that the
II.E
II.E.1.
II.F.
II.F.1.
n.F.2.
ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
TI.F.3.
II.F.4.
II.F.5.
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Modified August,2018
uTD009081357
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 dndanger human health or the
environment, the Permittee shall cease operation of the unit until the problem has been
corrected. The Permiuee shall be allowed to undertake those operations which are part
of corrective activities.
Records of inspections shall be kept as required by UAC R315-S-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 R315-101 and is based on the risk thresholds identified in
Condition IV.C.I1. The operating conditions identified in Module IV 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 20II,Tetra Tech; ADDENDUM
Air Dispersion Modeling Protocol for Open Buming 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 Buming and Open
Detonation Units, ATK Launch Systems Promontory, Utah, August 20l4,Tena Mentis; and
Open Bum 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, April2018, ATK Launch Systems Inc.; and
ATK Launch Systems Inc. - Promontory
Module II - General Facility Conditions
II G.1.h.
II.G.2.
II.G.3.
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Modified August,2018
uTD009081357
Soil Monitoring Plan, Promontory Hazardous Waste Storage and Subpart X Treatment Permit,
April2018, 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 types 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-136 andM-225 thermal treatment areas for the annual
reporting period;
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;
An accounting of the types and quantities of flare molds treated at the M-l36 andM-225
thermal treatment areas for the annual reporting period and a summary on the stafus of waste
minimization projects for treatment of flare molds at the thermal treatment areas;
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;
The semiannual analytical results for the bum ground ash as required by Section 11.8.2.5 of
Attachment 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 .re 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.1.e., to
evaluate changes to dose-response factors for the three classes of detected COPCs: chromium
(total and hexavalent) ,2,3,7,8-T0DD TEQ, and detected potentially carcinogenic pAHs
(benzo(a)anthracene, benzo(k)fluoranthene, ch4rsene and indeno(1,2,3-cd)pyrene); and
A review of the potential human health risk scenarios that were evaluated in the risk assessmenr
to assure that these scenarios have not changed.
If the Director determines after reviewing this annual 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 launch Systems Inc. - Promontory
Module II - General Facility Conditions
II.G.5.
II.H.
II.H.1.
II.H.2.
II.H.3.
II.H.4.
II.H.5.
Modified August,2018
uTD009081357
If the Permittee is required to update the human health risk assessment for the M-136 orM-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
working with or around 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
contingency 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 R315-8-2.7(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 maintain a copy of the Training Plan at the Facility until it is fully
closed and closure is certified
Employees working at the M-136 andM-225 Thermal Treatment Areas shall receive
task-specific, 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 R3l5-8-2.8.
In addition to the requirements of UAC R315-8-2.8., the Permittee shall comply with
the Conditions III.G and III.H pertaining to ignitable, reactive, or incompatible 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 by UAC R315-8-3.3.
The Permifiee 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
il.r.
il.I.1.
II.I.2.
II.J.
II.J.1.
II.K.
II.K.1.
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II.K.4.
IGNITAB
ATK Launch Systems lnc. - Promontory
Module II - General Facility Conditions
II.K.5.
II.K.6.
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II.L.
ILL.1.
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II.M.
II.M.1.
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Modified August,20l8
urD009081357
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 communications 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 arrangem6nts (Coordination Agreements) with
State and local authorities as required by UAC R315-8-3.7. Copies of the Coordination
Agreements shall be kept in the Operating Record. The attempts to make such
agleements, any refusals and all final agreements shall be documented in the Operating
Record.
CONTINGENCY PLAN
The Permittee shall immediately carry out the provisions of Attachment 4, and follow
the emergency procedures described by UAC R315-8-4.7 whenever there is a ftre,
explosion, or release of hazardous waste or hazardous constituents which threatens or
could 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 R315-8-4.4.
The Permittee shall review the Contingency Plan, in accordance with UAC R315-8-4.5
and shall modiff 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.
MANIFEST SYSTEM
The Permittee shall comply with the manifest requirements of UAC R315-5-2 and UAC
R315-8-5. The manifest tracking number shall be recorded in the Operating Record
with each waste load that arrives or leaves the Permittee's facility.
RECORDKEEPING 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
R315-50-2 (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 264.73(b)(9) incorporated by referelce], 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
II.N.3.
II.N.4.
TI.N.5.
II.o.
II.o.1.
II.O.2.
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Modified August,2018
uTD009081357
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
yeat.
The Permittee shall submit additional reports to the Director in accordance with UAC
R315-8-5.8.
A11 reports, notifications, applications, or other materials required to be submitted to the
Director shall be submitted in accordance with Condition I.DD.
CLOSTJRE/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 nanative 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 notiS 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, R315-8-9 and Attachment 5. Facility
equipment, structures and soil which have not been decontaminated shall be disposed of
only at a permitted hazardous waste treatment, storage or disposal facility.
The Permittee shall certify that the facility has been closed in accordance with the
specifications in Attachment 5 as required by UAC R315-8-7, 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 lnc. - Promontory
Module II - General Facility Conditions
II.O.8.
II.O.9.
il.P.
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Modified August,2018
uTD009081357
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
modify 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 R315-101.
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 R315-101.
COST ESTIMATES FOR HWMU CLOSTTRE
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 identiff 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 R315-8-8 (40 CFR 264.142 incorporated
by reference).
On the five year anniversary date of the submittal of the closure cost estimates required
bv Condition II.P.2. above. the Permittee shall conduct a detailed evaluation of the
ciosure 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 davs after the Director has
approved the request to modi$ 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 R315-8-8 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 demonsffating the status of the financial assurance mechanism.
ATK l^aunch Systems Inc. - Promontory
Module II - General Facility Conditions
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Modified August, 2018
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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 REOTIIREMENTS
The Permittee shall demonstrate continuous compliance with the liability requirements
of UAC R315-8-8 (40 CFR 26a.Ia7@) 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 occurence with an annual
aggregate of at least $2 million U.S. dollars, exclusive of legal defense costs. The
Permittee shall submit an approved certificate of hazardous waste liability insurance
worded as required by UAC R315-8-8.
The Permiuee shall demonstrate continuous compliance with the requirements of UAC
R315-8-8 (40 CFR 264.147ft) 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.
INCAPACITY OF OWI{ER OR OPERATORS. GUARANTORS. OR
FINAI\CIAL INSTITUTIONS
The Permittee shall comply with the notification and financial requirements of UAC
R315-8-8 (40 CFR 264.148 incorporated by reference).
ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
IV.A.
TV.A.1.
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Modifred August, 2018
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MODULE IV - 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, designated as the M-13 6 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 Treatrnent Area consists of 4 bum 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.
PERMITTED AI\D PROHIBITED WASTE IDENTIFICATION
The Permittee may treat energetic or reactive hazardous waste at the two Promontory
Thermal 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 1.1 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 laboratorv wastes which mav contain solvents:IV.B.1.f.
Page I
ATK Launch Systems Inc. - Promontory Modified August' 2018
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
IV.B.1.g. Wastewater treatment sludge generated from the processing of explosive ingredients and
propellants defined in UAC R315-2 as a K044listed hazardous waste;
IV.B.1.h. Reactive bag house dust generated from the processing of explosive ingredients and
propellants; and
IV.B.1.i. Waste developmental propellants, explosives and associated contaminated production
materials.
IV.B.2. Only reactive hazardous waste as defined by UAC R315-2 may be treated at the
Promontory Thermal Treatment Areas. Reactive hazardous waste thermally heated 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.
IV.B.3. The Permittee is prohibited from thermally treating reactive hazardous waste classes and
compositions not included in Conditions IV.B.1. and IV.B.2. including wholly inert items,
improvised explosive devices (e.g. homemade bombs) and chemical wastes.
IV.B.4. The Permittee is prohibited from thermally treating any reactive hazardous waste that does
not have a designated waste profile.
IV.B.5. The Permittee is prohibited from thermally treating decoy flare molds with less than4oh
propellant contamination.
IV.B.6. The addition of hazardous waste codes to Condition IV.B.2. requires modification of the
permit as specified in UAC R315-4-1.5 and Condition I.D.
IV.B.7 The Permittee shall comply with the waste compatibility requirements of Condition II.I.
ry.C. GENERAL OPERATING COI\DITIONS
IV.C.1. Based on the results of the Human Health fusk Assessment, identified in Condition
II.G.1.e., the Permittee shall comply with the following treatment limits for the M-136
Thermal Treatment Area:
IV.C.1.a. 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.:
rV.C.1.b. 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 I through 12, at 16,000
pounds in each station, under treatment scenario M-136-A;
IV.C.1.c. The Permittee shall not treat by OB more than 10,000 pounds of reactive hazardous waste
in a calendar day atburn station 13 under treatment scenario M-136-A;
IV.C.1.d. The Permittee shall not treat by OB more than 16,000 pounds of reactive hazardous waste
in a calendar day, atbum station 14 under treatment scenario M-l36-4;
IV.C.I.e. The Permittee shall not treat, by open burning (OB), more than 125,000 pounds total of
reactive hazardous waste in a calendar day at bum station 14 under treatment scenario
M-l36-8: and
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ATK Launch Systems Inc. - Promontory
Module IV - Thermal Treatment of Energetic Wastes
Modified August, 2018
uTD009081357
The Permittee shall not treat by OD more than 600 pounds of reactive hazardous waste in a
calendar day at each burn station 13 and 14.
The Permittee shall not operate more than one treatment scenario, M-136-A, M-l36-8, or
M-136-C in a calendar day.
The Permittee shall operate the M-l36 Thermal Treatrnent Area in accordance with the
quantity-distance requirements identified in Attachment I l, 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.1.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 bum 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 ffeatment scenario I|ld-225-B..
The Permittee shall not operate more than one treatment scenario, M-225-A, or M-225-B in
a calendar day.
The Permittee shall operate theM-225 Thermal Treatrnent 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 Permittee 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 I I and the following conditions:
The Permittee shall conduct all open burn operations within the secure areas designated as
the M-l36 or M-225 Thermal Treatment Areas with controlled access as identified in
Attachment 11:
ry.c.1.f.
\/.c.2.
tv.c.3.
TV.C.4.
ry.c.5.
IV.C.5.a.
ry.c.5.b.
IV.C.5.c.
IV.C.6.
rv.c.7.
rv.c.8.
IV.C.9.
IV.C.9.a.
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ATK Launch Systems Inc. - Promontory
Module fV - Thermal Treatment of Energetic Wastes
Modified August,2018
uTD009081357
The Permittee shall post warning signs around both of the Thermal Treatment Areas to
keep unauth oized personnel out;
The Permittee shall maintain the egress paths for both of the Thermal Treatment Areas
identified in Attachment 4:
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;
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, slqr conditions and
clearing index prior to each burn in the facility operating record;
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 identified in Condition IV.D, E, F, G, H and I;
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. lnspection 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.
rv.c.9.b.
IV.C.9.c.
rv.c.9.d.
IV.C.9.e.
IV.C.9.f.
IV.C.9.g.
rv.c.9.h.
rv.c.9.i.
rv.c.ej.
IV.C.9.k.
IV.C.10.
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ATK Launch Systems Inc. - Promontory
Module [V - Thermal Treatment of Enereetic Wastes
N.C.ll.
IV.C.11.a.
ry.c.11.b.
tv.c.12.
IV.C.12.a.
rv.c.12.b
IV.C.12.c.
rv.c.12.d.
IV.D.
TV.D.I.
IV.E.
tv.E.1.
Modified August, 2018
uTD00908r357
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 l.0xl0a (one
in ten thousand) or aHazard lndex 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 buming grounds shall not exceed the
treatment scenarios outlined in Table l, Attachment l1; 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 hazadto 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 buming 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 heatment 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 bums when the surface wind speed is greater than 3 miles
per hour (mph) and less than l5mph; and
The Permittee may conduct bums 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 Permittee shall track all reactive hazardous waste in accordance with Attachment 1l
and maintain this information in the operating record for both of the Promontory Thermal
Treatment Areas.
PRE.BURN ACTIVITIES
Prior to bringing any reactive hazardous waste into either of the Promontory Thermal
Treatment Areas for thermal treatment, The Permittee shall conduct pre-burn activities in
accordance with the requirements identified in Attachment 11, and the pre-bum 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.E.1.a.
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Module IV - Thermal Treatment of Energetic Wastes Um009081357
fV.E.1.b. Any treatment unit that fails one or more of the inspection criteria shall be removed from
service until the problem is corrected;
IV.E.1.c. No treatment is permitted unless either radio or telephone communication with emergency
services is available:
IV.E.1.d. No treatrnent is permitted if the emergency equipment listed in Attachment 2, Table II-B,
"lnspection Schedule for Thermal Treatment Area at M-136" or Table [I-C, "Inspection. Schedule for Thermal Treatment Areas atM-225" is not available for use at each respective
location:
IV.E.1.e. All leaks or spills of diesel fuel shall be cleaned up before the Promontory thermal
treatment areas can be operated; and
IV.E.1.f. The loss of the flashing ligbt will require that the unit be shut down until the problem is
corrected. If the Permittee must use the freatment 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.
IV.F. PREPARING WASTE FOR THERMAL TREATMENT BURN
IV.F.1. Prior to placing any reactive hazardous waste in a treafinent unit, the Permittee shall
comply with all provisions Conditions IV.C, D and E of this Permit. The Permittee shall
also comply with the following conditions:
IV.F.I.a. 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:
IV.F.I.b. The treatment unit shall be loaded in accordance with all intemal safety procedures and
requirements and the provisions identified in Attachment 11.8.2.2;
IV.F.1.c. All cardboard, wood and diesel used as donor material to assure a complete bum shall be
counted towards the daily treatment limits, and recorded in the operating record;
IV.F.1.d. 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
IV.F.l.e. The Permittee shall document in the operating record the bum station for each container of
reactive hazardous waste freated.
IV.F.2. Prior to beginning the final preparations for an open burn, the Permittee shall comply with
the following conditions:
IV.F.2.a. 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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ATK Launch Systems Inc. - Promontory Modified August, 2018
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
ry.F.2.b. All wiring and ignition operations, described in Attachment 11.8.2.3, shall be conducted by
at least two employees;
IV.F.2.c. The Permittee may reactivate the firing system treatment areas only after all operators have
exited the QD for the treatment unit;
fV.F.2.d. 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;
IV.F.2.e. 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;
ry.F.2.f. 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 treatrnent;
IV.F.2.g. After the warning identified in Condition IV.F.2.f. has been completed, the Permittee 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:
IV.F.2.g.i. Remove the interlock for the firing control system, deactivating the firing control system;
IV.F.2.g.ii. At least two operators shall reenter the treatment area, and correct the problem;
IV.F.2.g.iii. If the resistance problem cannot be immediately corrected, the operators may connect a
separate igniter wire to an adjacent stanchion; and
IV.F.2.g.iv. After the problem with the firing circuit has been corrected the operators shall repeat the
steps described in Conditions IV.F.2.g.
IV.F.2.h. The treatrnent units shall be fred in accordance with the provision of Attachment 11,
Section 8.2.3 of this Permit:
IV.F.2.i. All thermal treatment events shall be observed with a video camera from the firing control
room or immediately outside the firing confiol room;
IV.F.2j. In 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 IV.F.2.c, d, e, f and g, and proceed with activating the firing system;
IV.F.2.k. 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 IV.F.2.c, d, e, f and g,
and proceed with activating the firing system;
IV.F.2.1. Prior to ignition, the area supervisor or designee, shall review the placement of the waste on
the treatment units: and
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ATK Launch Systems Inc. - Promontory
Module fV - Thermal Treatment of Energetic Wastes
Modified August, 2018
uTD009081357
POST-BURN ACTIIWIES
Following treatment, the Permittee shall conduct the post-bum inspection activities
identified in Attachment 2, and clean-up activities identified in Attachment l lof 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-bum inspection shall be conducted within 24 hours of completing a treatrnent
event, and perform the following unless one of the exceptions identified in IV.G.2j.
applies:
Prior to entering the treatment area, the operators shall deactivate the firing control system
and remove the interlock;
Document any treatment unit with an open flame, hot spot or smoldering residue;
Document any treatnent unit with unbumed residue;
Document any treatment unit with unbumed reactive hazardous waste and identiff if
possible in the operating record why the waste did not bum;
lnspect for any unbumed 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 unbumed waste is being stored;
Evaluate the condition of the safety equipment identified in Attachment2,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 tV.G.2.i. prohibit re-entry into the
treatment area. The Permittee shall document the reasons for the delay in the facilitv'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 rv.G.2.i., that prohibit re-entry into the
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 11.6.
IV.G.
IV.G.1.
IV.G.2.
IV.G.2.a.
rv.G.2.b.
IV.G.2.c.
rv. G.2.d.
IV.G.2.e.
IV.G.2.f.
IV.G.2.g.
tv.G.2.h.
IV.G.2.i.
rv.G.2j.
rv.G.3.
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ATK Launch Systems Inc. - Promontory
Module [V - Thermal Treatment of Enereetic Wastes
IV.G.3.a.
rv.G.3.b.
IV.G.3.c.
TV.G.4.
IV.G.4.a.
rv.G.4.b.
IV.G.4.c.
Modified August, 2018
uTD009081357
treatment area within the24 hour period, the Permittee shall document the following
information in the operating record:
The reason for the delay in doing the post-bum 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 bum did not propagate as
expected or any other unexpected event.
Open burn operations at the Promontory Thermal Treatrnent Areas may result in the
generation of untreated residue and unburned wastes. The Permiuee shall manage these
residues and wastes in accordance with the following provisions:
Small amounts of unheated 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 treatrnent unit. The primary option for
managing this waste is to burn it by 6:00 pm of the following calendar day. If the untreated
residue cannot be heated 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 misfire or an intemrpted ignition shall be treated by 6:00
pm of the calendar day following the date of the fnst attempt to treat this waste. For the
purposes of this Permit, an intemrpted ignition occurs when anything greater than 5% 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 treatrnent unit or station in accordance with UAC R315-5. If the
cumulative storage time for the unburned waste both while in storage prior to treatrnent and
while on the freatment unit or in the bum 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 unbumed 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.
IV.G.4.d.
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Module IV - Thermal Treatment of Enereetic Wastes
Modified August, 2018
uTD009081357
STORM WATER MANAGEMENT A}ID RUN.ON AI\D RTIN.OFF CONTROLS
The Permittee shall manage all storm water collected from treatment units in accordance
with this Permit, Attachment 11, Section 11 and UAC R315-5.
The Permittee shall maintain nrn-on diversion structures in accordance \r/ith this Permit and
UAC R3l5-8-16 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 operatingarea of the Promontory Thermal
Treatment Areas shall be managed in accordance with UAC R315-8-16, which incorporates
by reference 40 CFR 264.601, 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 fV.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 11.
INSPECTION SCHEDULES AND PROCEDT]RES
The Permittee shall conduct inspections of the Promontory Thermal Treatment areas in
accordance with Attachment 2 and 11.
ENIVRONMENTAL MONITORING REOUIREMENTS
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.1.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 later than 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.
IV.H.
TV.H.1.
\/.H.2.
tv.H.3.
IV.I.
IV.I.1.
N.r.2.
IV.J.
IV.J.1
IV.K.
IV.K.1.
TV.K.2.
IV.K.3.
TV.K.4.
TV.K.5.
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Module [V - Thermal Treatment of Energetic Wastes
Modified August, 2018
uTD009081357
IV.K.6. 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.
IV.K.7. The Permittee shall conduct groundwater monitoring in accordance with Module IV of the
Permittee' s Post-Closure Permit.
fV.K.8. 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.
IV.K.9. Based on the results of the evaluation required by Condition IV.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.
IV.K.10. 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.
IV.L. ECOLOGICAL RISK
[V.L.1. 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.
IV.L.2. 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,
2017.
IV.M HUMAI\ HEALTII RISK
IV.M.1. 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.
TV.N. FACILITY MODIFICATION/EXPANSION
IV.N.1. Modification of the design plans and specifications in Attachment 6 or construction of
additional treatrnent units shall be allowed only in accordance with UAC R315-4-1.5.
ry.O. CLOSURE AND POST CLOSURE
[V.O.l. The Permittee shall close the Promontory Thermal Treatment Areas in accordance with the
Closure Plan in Attachment 5.
IV.P. PROMONTORY THERMAL TREATMENT AREAS OPERATING RECORD
[V.P.1. 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-l36 and
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ATK Launch Systems Inc. - Promontory Modified August, 2018
Module IV - Thermal Treatment of Energetic Wastes UTD009081357
M-225 Thermal Treatment Areas shall, at a minimum, include the following information:
IV.P.1.a. All information required by UAC R315-8-5.3;
IV.P.1.b. Copies of all inspections required by this module;
IV.P.1.c. A1l waste tracking information maintained in the electronic Waste Tracking Record
identified in Attachment 11:
IV.P.1.d. A description of the meteorological conditions described in Condition IV.C.9.e. during
each burn;
IV.P.1.e. Copies of all reports identified in Condition II.G.1. and required by Condition II.G.3. and
IV.K and IV.L: and
IV.P.1.f. A running total of the type 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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