DSHW-2019-014270 - 0901a06880b56eb0

Attachment 1
WASTE ANALYSIS PLAN

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1.0 WASTE ANALYSIS PLAN 1.1 INTRODUCTION This Waste Analysis Plan (WAP) is used to ensure that all reactive and ignitable waste will be properly characterized prior to being stored and/or treated. The WAP also outlines how chemical wastes that are being stored prior to shipment to an offsite disposal
facility will be characterized. Information on these waste chemicals is obtained from process knowledge, SDSs, and chemical analysis. The WAP is intended to provide guidance and assistance in sampling and testing of the two general categories of hazardous waste for the ATK Promontory facility (ATK). These two hazardous waste categories include "reactive and ignitable waste", and "chemical waste". The term "reactive waste" consists of propellant and explosive waste, as defined in R315-261-23. The term "ignitable waste" consists of propellant/explosive oxidizer containing waste, as defined in R315-261-21(4).The term "chemical waste" is the term used to describe all non-reactive RCRA hazardous waste, or unknown potential RCRA hazardous waste. This category could include drummed waste, lab packs, bulk
wastes, waste from offsite ATK facilities, etc. The plan outlines a process for making a hazardous waste determination for both of these general waste categories. This plan will be on file with the Environmental Services and Operations group.
1.1.1 Site History ATK-Promontory (ATK) has been manufacturing explosives at this site for over 50
years. The facility manufactures rocket motors, military flares and related items. 1.2 WASTE ACCEPTANCE PROTOCOL 1.2.1 Acceptance of On-Site Reactive Waste for Storage and Treatment All reactive wastes must be characterized before they can be accepted for storage or treatment. The characterization will be accomplished through a profiling process which will identify the type of reactive waste as defined in R315-261-23 and determine whether the waste exhibits any additional hazardous waste characteristics, and if it is listed in accordance with R315-261-20 and R315-261-30. The reactive waste profile is completed through process/generator knowledge, SDS and testing, if needed. These profiles must be completed and approved before any waste is accepted at the burn grounds. Each
profile includes the following information:
 Reactive material family name and general formulation type
 Chemical composition with percentage ranges
 US DOT hazard classification or suspected classification for developmental materials
 EPA codes
 Physical characteristics
 Underlying hazardous constituents (if any)
 Reactive waste category as defined in Figure 3-5
 Packaging type and other applicable information The profile approval process includes approval by the Generator, Safety and Environmental Services.
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Any new propellants or other reactive wastes will be characterized as described above
before they are accepted for storage or treatment. Any waste that does not fit an existing profile, must be profiled before the waste can be accepted. In the event that a reactive waste cannot be properly characterized with existing information, additional information
will be obtained, which may include laboratory analysis. Laboratory wastes can be characterized using generator knowledge. Upon receipt of the
reactive waste at permitted storage facilities, all containers are inspected to verify proper labeling, and packaging. The total quantity and type of propellant is then recorded in the facility operating record. 1.2.2 Acceptance of Hazardous Chemical Waste for Storage and Offsite Disposal Hazardous chemical waste generated at the facility, and other ATK facilities are accepted for storage at M-186, M-705S and E-501. Upon receipt of all hazardous waste at these facilities, all containers are visually inspected to verify proper labeling, packaging and paper work. Upon acceptance, a unique container number is recorded in the chemical waste tracking system.
All wastes received from an off-site source have been characterized in advance, and are assigned a container number at the time of delivery. These shipments are visually inspected to verify that the type and quantity of the waste matches the profile and
manifest. The manifest numbers for off-site generated hazardous waste are entered into the chemical waste tracking system upon acceptance.
Most waste generated on-site is characterized through generator/process knowledge before arrival at the permitted facility. However, some waste may be received at the TSDF without characterization. When this occurs, sampling and testing of the waste stream is conducted to properly characterize the waste. Whenever a waste is accepted, all of the pertinent information on the waste is entered into the operating record. This information shall, at a minimum, include the waste profile description, EPA codes, quantity, date of generation, date received, storage location and date it was shipped off site for disposal. The chemical waste tracking system will also include the manifest number(s) for all hazardous waste received from an off-site source and all off-site shipments of hazardous waste to a TSDF. At a minimum the following
resources are used to help characterize chemical waste:
 R315-261
 Generator process knowledge
 SDS
 Laboratory analysis
 National Institute for Occupational Safety and Health: Pocket Guide to Chemical Hazards 1.2.3 Acceptance of Off-site Generated Reactive Waste ATK periodically receives reactive waste from off-site ATK Launch Systems and non-ATK Launch Systems facilities. This waste is accepted by ATK for storage prior to on-site treatment at the M-136 burn grounds. All off-site generated wastes must be approved in advance through a waste acceptance and profiling process. The waste profile for wastes received from off-site contains the same information as profiles for wastes generated on-site (described above).
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Before the waste is accepted, ATK reviews the shipping papers and visually inspects the container(s) to confirm that container(s) and shipping papers agree and that the waste description meets the previously approved waste profile. Discrepancies will be resolved
with the generator before the waste is accepted. After the waste has been visually inspected and accepted by ATK, it will be entered into the reactive waste tracking system. Buildings/areas authorized to store reactive waste, and quantity limits are
specified in Module III. 3.3 TESTING CRITERIA 3.3.1 Parameters and Rationale for Testing Reactive Wastes Reactive waste may carry several waste codes, but will always carry a D003 waste code for reactivity and such wastes are generally classified as explosives. Due to the inherent hazardous nature of reactive wastes, this material is not routinely sampled or analyzed as part of this WAP. In addition to classifying and characterizing the reactive waste managed at the ATK facility, in accordance with R315-261, ATK will assess emission hazards associated with the open burning of these hazardous wastes as required in R315-264-601, Environmental Performance Standards. Figure 3-2 the Reactive Waste
Treatment and Disposal Decision Matrix, diagrams the steps and decisions that are addressed whenever reactive wastes are treated and subsequently disposed.
3.3.2 Parameters and Rationale for Testing Chemical Waste ATK generates two general categories of solid waste that can be defined as hazardous in accordance with R315-261: 1) off-specification commercial chemical products, and 2)
spent materials. These wastes may be disposed of individually or consolidated with other hazardous waste streams. Figure 3-3 the Chemical Waste Characterization and Disposal Decision Matrix, identifies how ATK will decide whether a waste is hazardous as defined by R315-261. Off-specification commercial chemical products are chemicals that have not been altered from their original manufactured formulation but are discarded for some reason. The most common reason for discarding these chemicals is because they are no longer needed or the shelf life has been exceeded. Under this scenario, generator knowledge can be used to characterize these wastes. Detailed information on commercial chemical products is available on the SDSs.
A spent material is any material that has been used and as a result of contamination can no longer serve the purpose for which it was produced without being processed or reclaimed. ATK has process knowledge for most of its spent material waste streams. Annual evaluation will be performed to verify chemical composition and concentration ranges. All new or modified spent material waste streams will be initially assessed at the
point of generation and annually thereafter to maintain proper characterization of all waste streams.
3.3.3 Parameters and Rationale for Testing Treated Leached Oxidizer Waste ATK operates a simple leaching process to remove the oxidizer from 1.3 propellants/explosives and contaminated production materials in place of open burning. ATK may evaluate some reactive and/or ignitable waste streams for potential oxidizer leaching removal. Prior to creating a Waste Profile for each waste stream treated by the oxidizer leaching process, a Waste Analysis Plan for these types of waste streams will be developed by 1) evaluating waste composition, physical state and size, and other
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characteristics. 2) Conducting “bench top” testing in a laboratory type process evaluating
treatment feasibility, including the ideal leaching time needed, the ideal leaching temperature, and an evaluation to determine if air agitation is necessary to complete the leaching process. 3) This is then followed by analytical laboratory testing to confirm the
amount of oxidizer removed and that the material is inert.
3.4 TEST METHODS AND SAMPLING 3.4.1 Test Method [R315-264-13 (b)(2)] ATK will make a hazardous waste determination for all waste streams generated, stored or treated onsite. This waste stream evaluation will be made utilizing process knowledge and/or analytical testing. All analytical testing will be completed at a Utah certified laboratory. Only EPA approved test methods, selected from the most current version of SW-846 list ("Test Methods for Evaluating Solid Waste, Physical and Chemical Methods"), will be used. Test method selection will be made, based on the most applicable method as described in Chapter Two of the SW-846 publication. New test methods will be used only after they have been approved by the EPA. The laboratory
will certify new methods during the annual certification process. Specific methods which may be used to characterize wastes are listed in Figure 3-4.
3.4.2 Sampling Methods [R315-264-13(b)(3), R315-261-1090 and R315-264-13] Waste sampled at the ATK facility consists of new waste, unknown waste, waste from changed processes, and waste sampled for annual re-verification analysis. Representative
samples will be collected and handled in accordance with the procedures and protocols identified in Table 3-1. At a minimum the following safety precautions are used when sampling waste materials:
 Chemical resistant gloves and safety glasses will be used while sampling all waste. Based on the chemical hazards and splash potential, protective clothing and a splash shield or respirator may also be utilized.
 Non-sparking tools will be used to sample any waste that presents a fire hazard.
 All necessary equipment and materials will be available prior to sampling

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Table 3-1
Container/Containment Type
Waste Matrix Drums, Totes Boxes, Bags, Sacks Storage Tanks
Ponds, Lagoons, Pits Tankers Roll-Off Bins
Free Flowing Liquids/Slurries Coliwasa N/A Pump/Dipper Dipper Dipper N/A
Sludges Trier/Spoon N/A N/A N/A N/A Trier/Bucket/Shovel
Moist Powder/Granules Trier/Spoon Trier/Spoon N/A N/A N/A Trier/Shovel
Dry Powder/Granules Thief/Spoon Thief/Spoon N/A N/A N/A Thief/Shovel
Sand/Packed Powder Auger/Spoon Auger/Spoon N/A N/A N/A Auger/Shovel
Large Grained Solids Large Trier/Spoon Large Trier/Spoon N/A N/A N/A Large Trier/Shovel
Debris (i.e. Rags, Gloves, Towels, etc.) Rag1 Rag1 N/A N/A N/A Rag1
1 The rag technique is used for sampling solid material such as rags, gloves and paper towels. After a container has been selected, it is opened and a representative sample collected and placed in the sample
container. One or more of the varied materials (e.g. gloves, tongue depressors, rags, paper, plastic, etc.) is sampled depending on the mix of the container.
A variety of sampling equipment and materials will be used to collect waste samples. All reusable equipment will be washed with a detergent solution and thoroughly rinsed before re-use. Disposable equipment may also be used. This equipment and specified
sampling methods are described in the SW-846 publication. Drummed consolidation waste will be randomly sampled each year as outlined in the table below. "Average Monthly Drum Number" will be based on the previous calendar years average monthly drum inventory, for each waste stream. Samples will be obtained during each calendar year.
Table 3-2
Average Monthly Drum Number Aliquots Selected
2 to 8 2
9 to 27 3
28 to 64 4
65 to 125 5
126 to 216 6
217 to 343 7
344 to 512 8
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Table 3-2 above is based on a table found in ASTM D 140-70, "Standard Methods of
Sampling Bituminous Materials," ASTM D 140-70. All sample containers used during a sampling event will be new, and certified clean from
a reliable source. Container selection will be based on the chemical/container compatibility, physical state and sample volume. A label will be attached to each sample container which will include the following minimum information:

 Sample number
 Samplers name
 Date
 Time
 Location In addition to the information included on the label, the chain of custody, which accompanies all waste characterization samples, will also include the following:
 Composite or grab sample
 Number of containers
 Remarks section
 Relinquishment signature block
All samples will be preserved as specified in SW-846 while in storage at ATK and while in transit to the testing laboratory.
3.5 FREQUENCY OF ANALYSIS 3.5.1 Frequency of Analysis for Reactive Waste [R315-264-13(b)(4)] Reactive waste treated at the ATK burn grounds come from various ATK Launch Systems facilities, and occasionally from other Department of Defense facilities or contractors. These reactive wastes are derived from energetic materials that have been manufactured to strict specifications. Therefore, the chemical composition of each formulation is well known. As discussed above, ATK characterizes all reactive waste streams using generator knowledge. While these energetic waste streams are not analyzed prior to being treated, ATK does review the reactive waste profile on an annual basis or any time the manufacturing process changes.
3.5.2 Frequency of Analysis for Chemical Waste The industrial processes at ATK generate a number of routine waste streams. Figure 3-1 shows major waste streams and processes generating those wastes. These waste streams will be evaluated annually to verify waste characterization is still accurate. The waste characterization will also be re-evaluated whenever the process that generated the waste
changes to determine if the process change altered the characteristics of the waste stream. Off specification commercial chemical products are well characterized by the information on their SDSs. These wastes are not analyzed on a routine basis.
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ATK- Promontory Waste Generation Figure 3-1
Propellant Mix/CastPropellant Mix/Cast Case Prep/FinishingCase Prep/Finishing Facility/Vehicle Maint.Facility/Vehicle Maint.Lab WasteLab Waste Ground WaterGround WaterMajor Gen. Source
Propellant Mixing& Casting
Propellant Mixing& Casting NDTNDT Liner InstallationLiner Installation Finish WorkFinish Work Parts Cleaning
& Painting
Parts Cleaning& Painting Oil ChangeOil Change Chem. AnalysisChem. Analysis Ground WaterProgram
Ground WaterProgram
Process Gen. Waste
Scrap Propellant …D003
Scrap Propellant …D003
ContaminatedSolid Waste D003
ContaminatedSolid Waste D003
Fixer/Developer
D011
Fixer/DeveloperD011
Solvent/Liner WasteNone
Solvent/Liner WasteNone
Alodine RagsD007, F002, F003
Alodine RagsD007, F002, F003
Solvent/PaintWaste D001, F002, F003, F005
Solvent/PaintWaste D001, F002, F003, F005
Solvent/Paint Rags F001, F002, F003, F005
Solvent/Paint
Rags F001, F002, F003, F005
Resin CurativesNone
Resin CurativesNone
Non-Haz Used
Oil
Non-Haz UsedOil
Organic WasteD001, F002F003, F005
Organic WasteD001, F002F003, F005
Acid WasteD002
Acid WasteD002
Lab PacksVarious codes
Lab PacksVarious codes
ContaminatedGWF001, F002
ContaminatedGWF001, F002
Note: The EPA codes included above are primary codes only; The above list includes major waste streams only.
Burn Grounds AshF005
Burn Grounds AshF005
Offspec OilNone
Offspec OilNone
Carbon/CarbonCarbon/Carbon
Carbon Parts Manuf.Carbon Parts Manuf.
WW
F001, 2, 3, 5
WWF001, 2, 3, 5
Offspec OilNone
Offspec OilNone
Explosive lab WasteD003, F005
Explosive lab WasteD003, F005

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Reactive Waste Treatment and Disposal Decision Matrix Figure 3-2

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Chemical Waste Disposal Decision Matrix Figure 3-3
RCRA Solid Waste
Yes No
Non-Hazardous DisposalIs this an Exempt Solid Waste
Yes
Based on Process Knowledge / MSDS, is the waste listed in Part 261 subpart D?
No
Based on processknowledge / MSDS,does the waste exhibit any characteristics specifiedin 261 subpart C?
No
No
Hazardous waste managementand disposal
Yes Yes
Based on Lab analysis
Unknown
Based onLab analysis
Unknown
Is the waste listedor characteristic
Non-hazardous disposal
No
Yes

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Figure 3-4
Analytical Methods for Metals
Parameter Analytical Method1 Preparation Method 2
Arsenic EPA 6010 EPA 3005 (W) & 3050 (S)
Barium EPA 6010 EPA 3005 (W) & 3050 (S)
Beryllium EPA 6010 EPA 3005 (W) & 3050 (S)
Boron EPA 6010 EPA 3005 (W) & 3050 (S)
Cadmium EPA 6010 EPA 3005 (W) & 3050 (S)
Chromium EPA 6010 EPA 3005 (W) & 3050 (S)
Copper EPA 6010 EPA 3005 (W) & 3050 (S)
Lead EPA 6010 EPA 3005 (W) & 3050 (S)
Manganese EPA 6010 EPA 3005 (W) & 3050 (S)
Mercury EPA 7470 (W) & 7471 (S) EPA 7470 (W) & 7471 (S)
Molybdenum EPA 6010 EPA 3005 (W) & 3050 (S)
Nickel EPA 6010 EPA 3005 (W) & 3050 (S)
Selenium EPA 6010 EPA 3005 (W) & 3050 (S)
Silver EPA 6010 EPA 3005 (W) & 3050 (S)
Thallium EPA 6010 EPA 3005 (W) & 3050 (S)
Vanadium EPA 6010 EPA 3005 (W) & 3050 (S)
Zinc EPA 6010 EPA 3005 (W) & 3050 (S)

Analytical Methods for Organics
Parameter Analytical Method Preparation Method
Volatle Organics EPA 8260 EPA 5030 (W) & 5035 (S)
Semivolatile Organics EPA 8270 EPA 3510 (W) & 3550 (S)
TPH EPA 8015 EPA 3510 (W) & 3550 (S)
TOC EPA 9060 (W only) EPA 9060 (W only)
Oil & Grease EPA 1664 (W only) EPA 1664 (W only)

Miscellaneous Test Methods
Parameter Analytical Method Preparation Method
pH EPA 9040 (W) & 9045 (S) EPA 9040 (W) & 9045 (S)
Ignitability EPA 1010 (W only) EPA 1010 (W only) Toxicity EPA 6010/7470 (Metals/Hg) EPA 8260 (Volatile Organics) EPA 8270 (Semivolatile Organics)
EPA 1311 Followed by 3010/74703
EPA 1311 Followed by 5030 EPA 1311 Followed by 3510
Explosives EPA 8330 EPA 8330
Perchlorate EPA 314.0 EPA 314.0
Anions EPA 9056 EPA 9056 (W) & 5050 (S)
TSS SM 2540 SM 2540
TS SM 2540 SM 2540
1. The laboratory shall utilize methods referenced in the latest edition EPA Publication, SW-
846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (referred to as EPA SW-846), or other methods accepted by Utah DEQ, unless otherwise noted. The
latest revision to the analytical method will be used for waste analysis for each parameter. Samples will be collected in accordance with R315-261-1090.
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2. The 'W' indicates a water matrix. Samples that are water soluble liquids (or aqueous phase) fit
into this category. Non-aqueous liquids are usually treated as solids depending on the test method. In the case of an oil matrix that cannot be analyzed by the solid preparation method, a waste dilution is often performed. The ‘S” indicates a solid matrix. 3. Mercury will be prepared using Method 7470.
Figure 3-5
REACTIVE WASTE CATEGORY
Group Description
A Class 1.3 Composite Propellant without HMX, RDX or CXM-3
B Class 1.3 Composite Propellant with HMX, RDX or CXM-3
C Class 1.1/1.3 Nitrate Ester Containing Material D High Explosive Material E Class 1.3 Pyrotechnic, Illuminants, Metal Powders, or Autoliv ASP Products
F Oxidizers (does not include high explosives such as HMX, RDX or CXM-3)
G Developmental Materials-R&D Lab Use Only(small quantity)
H Unique Waste (small quantity)