DSHW-2024-007118

ATTACHMENT 8

CLOSURE AND POST-CLOSURE PLAN
Utah Test and Training Range
Attachment 8-Closure and Post-Closure Plan
Issued DRAFT
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Contents
1.0 Closure Plans [UAC R315-270-14(b)(13), R315-270-23(a)(2), R315-264-112] ......................... 8-2
1.1 Closure Performance Standard [UAC R315-264-111] .................................................... 8-2
1.2 Partial Closure and Final Closure Activities [UAC R315-264-112] ............................... 8-2
1.3 Maximum Waste Inventory [UAC R315-264-112(b)(3)] ................................................ 8-3
1.4 Schedule for Closure [UAC R315-264-112(b)(6)] .......................................................... 8-3
1.4.1 Time Allowed for Closure [UAC R315-264-112(b)(2) and 113(a)and(b)] ........ 8-3
1.4.2 Extensions for Closure Time [UAC R315-264-113(a) and (b)] ......................... 8-3
1.5 Closure Procedures [UAC R315-264-112 and 114] ........................................................ 8-3
1.5.1 Geophysical Survey ............................................................................................ 8-4
1.5.2 Soil and Groundwater Sampling ......................................................................... 8-4
1.5.3 Determining Cleanup Goals ................................................................................ 8-6
1.5.4 Site Cleanup ........................................................................................................ 8-6
2.0 Closure Certification and Required Notices [UAC R315-264-115 and 116] ............................... 8-8
3.0 Closure Cost Estimate [UAC R315-264-142] .............................................................................. 8-8
4.0 Financial Assurance Mechanism for Closure [UAC R315-264-143] ........................................... 8-8
5.0 Post-Closure Plan [UAC R315-270-14, R315-270-23(a), R315-264-118,
and R315-264-603] ....................................................................................................................... 8-8
5.1 Post-Closure Use of Property........................................................................................... 8-9
5.2 Post-Closure Care [UAC R315-270-23(a)(3) and R315-264-603] .................................. 8-9
5.3 Post-Closure Security [UAC R315-264-117(b)].............................................................. 8-9
5.4 Post-Closure Contact [UAC R315-264-118(b)(3)] .......................................................... 8-9
5.5 Monitoring Plan [UAC R315-264-118(b)(1)].................................................................. 8-9
5.6 Maintenance and Inspection Requirements [UAC R315-264-118(b)] ............................ 8-9
5.7 Amendment of Post-Closure Plan [UAC R315-264-118(d)] ......................................... 8-10
5.8 Post-Closure Notices [UAC R315-264-116 and 119] .................................................... 8-10
5.9 Certification of Completion of Post-Closure Care [UAC R315-264-120] .................... 8-10
5.10 Financial Requirements for Post-Closure [UAC R315-264-144 and 145] .................... 8-11
6.0 Burn Pan Closure Process ........................................................................................................... 8-13

Tables

Table 1 Estimated Closure Schedule
Table 2 Inspection and Maintenance Plan for TTU

Appendices
Appendix A Site 3 Partial Closure Activities: Miscellaneous Munition Burn Pan

Utah Test and Training Range
Attachment 8-Closure and Post-Closure Plan
Issued DRAFT
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CLOSURE PLANS, POST-CLOSURE PLANS, AND FINANCIAL REQUIREMENTS

1.0 Closure Plans [UAC R315-270-14(b)(13), R315-270-23(a)(2), R315-264-112]
This Closure Plan identifies all steps necessary to achieve closure of the TTU at the end of its
operating life, or partial closure of a specific area of the TTU that is no longer utilized It also
includes closure requirements for the temporary storage pads located in the Missile Storage Area
(MSA Pads 1 and 2). Copies of the plan will be maintained by 75 CEG/CEIE, HAFB, Utah,
until closure is completed, certified by the permittee, and signed by an independent qualified
Utah-licensed professional engineer practicing within the scope of his/her education and training.
This plan will be updated as necessary in accordance with Section II.P of the Permit. Partial
closure activities conducted prior to initiation of final site closure will be documented as
appendices to this plan.
1.1 Closure Performance Standard [UAC R315-264-111]
RCRA closure requirements are intended to protect human health and the environment as well as
to minimize the need for post-closure maintenance. These goals can be achieved through either:
● Clean closure - closure to screening or risk-based cleanup standards, accomplished by
removing all hazardous wastes and hazardous waste residues from the unit, or
● Non-clean closure - closure where wastes remain in place and specific post-closure care is
performed in order to monitor waste containment.
For clean closure, if any contamination in the form of hazardous wastes or constituents contained
in soils or groundwater is determined to be the direct result of past operations of the TTU or is
shown to be present in concentrations above cleanup goals, background concentrations, or other
standards or guidance levels, further study will be done to determine the nature and extent of this
contamination and what remediation requirements are needed. If warranted, an appropriate
Corrective Measures Study (CMS) will be prepared and submitted to the Director of the Utah
Department of Environmental Quality Division of Waste Management and Radiation Control
(DWMRC) for approval in accordance with Module IV of the Permit. Upon approval, the CMS
will then be implemented to remedy any identified contamination in soils and/or groundwater.
However, if data suggests clean closure is not a practicable alternative, the TTU will be closed in
accordance with the closure standards for a landfill. The closure activities associated with each
closure option are discussed in Section 1.5. The temporary storage pads in the MSA are operated
in a manner that is unlikely to allow contamination and will be clean closed.
1.2 Partial Closure and Final Closure Activities [UAC R315-264-112]
Partial closure of operational areas within the TTU may be accomplished as deemed necessary.
In the case of final closure, for the purposes of determining the maximum extent of operations
during the life of the facility, the area of closure will be defined as the TTU described in
Attachment 1. This will not only include the current operational areas but also those areas that
may have been impacted by past hazardous waste thermal treatment and/or disposal operations
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(such as areas used for burial of spent munitions). These areas are now within the TTU fence.
Because closure will be performed for the entire TTU, none of it will remain open.
1.3 Maximum Waste Inventory [UAC R315-264-112(b)(3)]
The maximum inventory of hazardous waste ever on-site at the TTU over the active life of the
facility is 340,000 lb NEW.1 This is the maximum quantity of propellant allowed under AF
explosive safety rules to be treated at the TTU in a single event by OB. The maximum quantity
of high explosives allowed to be treated at the TTU at one time by OD is 149,900 lb NEW. This
is also the upper explosive safety limit prescribed by AF explosive safety rules. No hazardous
waste treatment processes, other than OB/OD thermal treatment, have ever taken place at the
TTU.
1.4 Schedule for Closure [UAC R315-264-112(b)(6)]
The extent of requirements to fully or partially close the TTU will not be known until closure
activities reveal the nature and extent of any contamination in soils and groundwater. However,
ongoing soil and ground water sampling will be conducted as discussed in Attachment 9 of this
permit.
1.4.1 Time Allowed for Closure [UAC R315-264-112(b)(2) and 113(a) and (b)]
An estimated closure schedule that includes the time needed to complete all required closure
activities for final closure is provided in Table 1. Should final or partial closure activities
determine a CMS is required, the procedures and schedule specified in Module IV of the Permit
will be followed. The CMS schedule will include all activities necessary to complete final or
partial closure, including post-closure monitoring. Final or partial closure will be supervised and
certified by an independent qualified Utah-licensed professional engineer practicing within the
scope of his/her education and training.
1.4.2 Extensions for Closure Time [UAC R315-264-113(a) and (b)]
If for any reason closure cannot be completed within the specified time frame outlined in the
closure schedule, a request or petition for an extension of the closure time will be submitted to
the Director. This petition will identify the need for the extension, the status of the facility, and
the actions required to prevent threats to human health or the environment during the extension
period. The written request will include a copy of the amended closure plan.
1.5 Closure Procedures [UAC R315-264-112 and 114]
Clean closure of the TTU or areas within the TTU is preferred, but unrecoverable past releases of
hazardous waste may make clean closure unachievable. To determine the nature and extent of
these past releases, certain actions must be taken. These are described in subsequent sections.
Upon completion of all closure activities, the TTU or partial areas thereof will be deemed closed
under RCRA requirements.

1Munitions are reported in units of pounds NEW. The NEW is the weight of the reactive filler material.
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1.5.1 Geophysical Survey
The locations of all areas within the TTU used to treat and/or bury munitions are not precisely
identified or mapped. To date, no investigations have been performed to delineate their possible
locations, dimensions, or orientations. To assist in identifying and determining the areal
boundaries of TTU OB/OD treatment and burial sites, and to protect soil and groundwater
sampling teams from encountering any UXO, a geophysical survey will be included as part of
closure activities. The geophysical survey may be conducted using a variety of potential
technologies, including aerial or ground-based techniques, and may be conducted by either
HAFB EOD or contractor personnel. The geophysical survey procedures will be presented in the
final closure plan developed in accordance with Section II.P of the Permit. A geophysical survey
is not required for partial closure activities that do not involve subsurface clearance or corrective
action. These areas would remain subject to further investigation upon final closure of the TTU.
The survey will be designed to discover munitions debris, consisting of metal fragments and
inert munitions casings lying on the surface, partially buried, buried close to the surface, deeply
buried by itself, or contained in old burial pits. After locating and excavating them, if required,
each item will be inspected by EOD or contractor personnel in accordance with TO 11A-1-60,
“Inspection of Reusable Munitions Containers and Scrap Material Generated from Items
Exposed to, or Containing Explosives.” Items determined to be inert will be certified, collected,
and transported to the Oasis Resource, Recovery, and Recycling (R3) yard for further
disposition. Any UXO or munitions fragments suspected of still containing reactive components
will either be treated in situ or at one of the TTU sites, depending on its type, size, and condition.
If the UXO or munitions fragments constitute an imminent threat to human health and the
environment, and if it is necessary to treat outside the permitted TTU, such activities will be
considered emergency treatment, and an emergency treatment permit will be requested from the
Director of the Utah Division of Waste Management and Radiation Control. All inspection,
certification, and treatment activities will be conducted only by qualified EOD or contractor
personnel.
Once the TTU is cleared of hazardous scrap metal and UXO, soil and groundwater samples can
be safely collected for analysis. If a decision is made by the EOD team that an area cannot be
safely cleared of UXO, the location of the contaminated soil will be duly noted for future
reference. This will result in a non-clean closure of the TTU.
1.5.2 Soil and Groundwater Sampling
Baseline soil and groundwater sampling will be conducted as part of this permit (Attachment 9,
Attachment 15). This sampling will establish the extent of surface and subsurface soil and
groundwater contamination due to past operations. Closure activities must include similar soil
and groundwater sampling. The results of the closure sampling will be used to establish cleanup
requirements.
● Site-specific sampling locations, quantities, sample collection and analytical methods,
and QA/QC issues will be addressed and presented in the final closure plan or any
partial closure plan developed in accordance with Section II.P of the Permit. Surface
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sampling for characterization of potential contamination at the temporary storage
pads in the MSA will be included in the plan.
1.5.2.1 Sampling Equipment Decontamination Procedures
All field sampling equipment will be precleaned prior to arrival on-site and decontaminated in
accordance with standard procedures. A decontamination area will be established and maintained
on-site for all decontamination activities. The site will be selected by the sampling team based on
the location’s ability to isolate the decontamination area and assist in preventing cross-
contamination of sampling equipment.
1.5.2.2 IDW Management
All wastes generated from field sampling and decontamination activities will be treated as
contaminated media until data are available to determine their actual characteristics. This
material will be drummed and stored at the TTU pending the outcome of sampling analysis.
Specifics such as date, time, equipment being decontaminated, and the associated sample
identification number for the equipment being decontaminated will be recorded in a field
logbook. Liquids will be drummed separately from solids, and the drums will be properly
labeled. It is anticipated that investigative-derived waste (IDW) will consist of decontamination
fluids and rinsates, contaminated PPE, and soil cuttings.
Segregation, minimization, handling, and labeling of IDW will be performed. Solid IDW will be
placed in DOT 17H drums or other DOT approved container. All groundwater, decontamination
fluids, and rinsates will be placed in DOT 17E drums or other DOT approved container. Each
drum will be clearly labeled and dated the day it is filled using indelible ink and have the
following source identification:
● Date;
● Material contained;
● Location;
● Number of drums from location; and
● Possible contaminant
Contaminated media will be managed in accordance with the current Utah and federal hazardous
waste rules. For instance, if concentrations of samples collected from decontamination/rinsate
fluids exceed the Universal Treatment Standards (UTS) of UAC R315-268-40 or the maximum
contaminant levels (MCLs), whichever is lower, the drummed waste will be considered a
hazardous waste and will be managed accordingly. All soils with hazardous constituent
concentrations exceeding the UTS or the soil screening levels (SSLs) (i.e., cleanup goals),
whichever is lower, are considered hazardous waste and similarly managed. Wastes determined
to be hazardous will be picked up by a contractor for transport to a permitted disposal facility.
If the results indicate none of the UTS or SSL/MCL concentrations have been exceeded,
wastewater and/or soils are not considered hazardous waste and will be managed in accordance
with DWMRC-approved BMPs. Such BMPs will be submitted by 75 CEG/CEIE prior to
initiating any disposal activities at the TTU involving potentially contaminated media.
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All sanitary trash and uncontaminated PPE will be discarded in accordance with applicable solid
waste regulations.
1.5.2.3 Health and Safety Procedures
Personnel performing sampling will use appropriate PPE deemed necessary to accomplish
sampling tasks. The PPE to be used will be specified in the closure Health and Safety Plan.
Sampling personnel will be properly trained in hazardous waste sampling procedures and will
have appropriate medical monitoring and certification. Sampling personnel will also be briefed
by the EOD RSO on the hazards of sampling in a potential explosively-contaminated
environment. It should be noted that subsurface UXO can only be reliably detected down to
approximately 15 ft, depending on other metallic contamination, soil type, etc. Although no
subsurface soil sampling is anticipated below that depth, should additional groundwater sampling
and monitoring wells be required, down-hole fluxgate gradiometer checks will be taken at
regular intervals to ensure no UXO are encountered by groundwater well drilling crews. If
instruments indicate the presence of UXO, the sampling site will be relocated to a nearby, UXO-
free location and appropriate annotations made in the sampling logbook.
1.5.3 Determining Cleanup Goals
The analytical results of all soil and groundwater samples taken from the TTU during closure
sampling will be compared to background concentrations. Those compounds exceeding
background levels will be identified as potential contaminants of concern to be investigated as
possible candidates for remediation/removal. For each contaminant of concern, a review of
existing standards and guidelines (in terms of soil and groundwater concentrations) will be
completed. These screening criteria, which are very conservative by nature, may be used to
define the clean closure requirements for the site.
In lieu of the screening criteria, risk-based cleanup levels may be developed in accordance with
UAC R315-101. This decision will be driven by the availability of screening criteria for each
contaminant of concern, as well as future land use and expected institutional controls. The risk-
based criteria will most likely justify a reduction in the extent of remediation/removal actions
needed for the site but will still allow the site to achieve clean closure. The Director must concur
with the cleanup levels and remediation strategy HAFB selects for the TTU.
If site investigation results indicate clean closure is not practicable, a non-clean closure option
will be considered. Under this option, the wastes will remain in place and strict post-closure
monitoring activities (e.g., groundwater monitoring) will be completed to ensure the wastes are
not migrating from the site and do not, therefore, pose a risk to human health or the environment.
1.5.4 Site Cleanup
1.5.4.1 Inventory Removal [UAC R315-264-112(b)(3)]
The TTU hazardous waste inventory may consist of (1) ash residue left over from OB/OD
treatment activities; (2) untreated UXO; and (3) soil cuttings, decontamination fluid, and other
IDW. Ash will be drummed and managed in accordance with Section 1.5.4.3. UXO and
contaminated scrap will be treated as described in Section 1.5.1. IDW will be managed in
accordance with Section 1.5.2.2.
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1.5.4.2 Disposal or Decontamination of Equipment and Structures [UAC R315-264-112
and 114]
Note: The burn pan described below was decommissioned and partially closed in
accordance with this plan on May 2, 2018.
To the extent possible, decontamination and disposal will be performed on existing man-made
structures at the TTU. These include the burn pan, burn pan cover, and burn pan supporting
structure. Additionally, once the final drums of contaminated fluids and soil cuttings are
removed from the TTU hazardous waste accumulation facility, this will also be decontaminated
and removed. Decontamination activities will be done in such a way as to allow for reuse or
recycling of those components suitable for that purpose (e.g., metal structures that could be
certified clean).
All components of the burn pan will be visually inspected, and any visible waste and debris will
be physically removed. The burn pan concrete pads and support columns will be scraped and
brushed of all loose waste and debris. Upon removal of all loose waste and debris, the burn pan
and its cover will be pressure-washed to remove any remaining residue. A bermed
decontamination pad constructed of 30 mil plastic and large enough to contain the burn pan and
lid will be used to contain all wash water. The decontamination pad will be positioned adjacent
to the burn pan.
Following decontamination, rinsate samples and concrete chips will be collected from the burn
pan and analyzed for Toxic Characteristic Leaching Procedure metals and explosive compounds
to verify their cleanliness. If rinsate or concrete chip analysis indicates additional
decontamination is necessary, the decontamination process and accompanying analysis will be
repeated until each component is verified as clean. Once the treatment structures are certified
clean, they will be either transported to the Oasis R3 yard to be stored until contracted for
disposal/recycling or disposed of at the UTTR-North sanitary landfill. All waste generated from
the decontamination process will be containerized in drums for characterization and
disposal/recycling.
Soils adjacent to each pad will be characterized as part of the subsurface investigation of the
TTU. To provide continued protection against unauthorized visitors to the TTU, the fence and
gates will remain in place and be routinely maintained as required (see Table 2).
1.5.4.3 Closure of Containers [UAC R315-264-178, R315-264-110 through 120, and R315-
270-14(b)(13)]
All ash and contaminated debris identified as treatment residue, solid IDW, and decontamination
fluids and rinsates will be placed in DOT 17E and 17H drums or other DOT approved container,
as previously described. Should sampling analysis determine these to be contaminated, each
container will be closed and transported to a hazardous waste disposal facility. Remaining
containers will be decontaminated and removed from the facility.
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1.5.4.4 Remediation
In the event contamination is detected after HAFB and DWMRC agree to pursue clean closure,
activities necessary to remediate the site to predetermined cleanup levels will be conducted.
These activities will be documented in the CMS as discussed in Section 1.1.
2.0 Closure Certification and Required Notices [UAC R315-264-115 and 116]
Within 60 days of the completion of closure for the TTU and the MSA temporary storage pads,
75 CEG/CEIE will submit in writing (by registered mail) a closure certification to the Director.
The certification will verify that the hazardous waste treatment facility was closed in accordance
with the specifications outlined in the approved closure plan, including the completion of all
required corrective action measures. The certification will be signed by an authorized official of
the HAFB 75th Air Base Wing and an independent qualified Utah-licensed Professional Engineer
practicing within the scope of his/her education and training. Documentation supporting the
Professional Engineer's certification will be furnished to the Director upon request.
No later than the submission of closure certification, 75 CEG/CEIE will also submit to the local
zoning authority, or the authority with jurisdiction over local land use, and the Director, a survey
plat indicating the location and dimensions of the facility with respect to permanently surveyed
benchmarks. The survey plat will be prepared and certified by a professional land surveyor
licensed in Utah. The survey plat will contain a note, prominently displayed, which states the 75
CEG/CEIE is obligated to restrict disturbance of the hazardous waste disposal unit in accordance
with UAC R315-264-110 through 120.
3.0 Closure Cost Estimate [UAC R315-264-142]
The TTU is a federal government facility, owned and operated by the HAFB 75th Air Base Wing
for the AF and the DoD. As such, it is exempt from the requirements for closure cost estimates
under UAC R315-264-140(c).
4.0 Financial Assurance Mechanism for Closure [UAC R315-264-143]
The TTU is a federal government facility, owned and operated by the HAFB 75th Air Base Wing
for the AF and the DoD. As such, it is exempt from the requirements for financial assurance for
closure under UAC R315-264-140(c).
5.0 Post-Closure Plan [UAC R315-270-14, R315-270-23(a), R315-264-118, and R315-264-
603]
This plan identifies all necessary activities to be implemented following closure of the TTU.
Post-closure care will include all planned monitoring and maintenance activities, as required,
along with their respective frequencies. The post-closure plan will be based on the general
requirements of R315-264-118 and the post-closure care requirements of R315-264-603. Should
it be impracticable to remove all contaminated soils or UXO during closure, the treatment units
will be monitored in accordance with the groundwater monitoring plan. This plan will be
updated as necessary in accordance with Section II.P of the Permit.

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5.1 Post-Closure Use of Property
The post-closure use of property following final closure will not be allowed if such use results in
a disturbance of the area. This may endanger personnel entering the area or may result in
disturbance or damage to the facility's monitoring and/or remediation systems (i.e., groundwater
wells) that exist at the TTU. 75 CEG/CEU will maintain the fences and gates while 75
CEG/CEIE will maintain monitoring devices. Table 2 describes the TTU inspection and
maintenance plan. Post closure use of the MSA temporary storage pads will not be restricted if
the area is successfully clean closed.
5.2 Post-Closure Care [UAC R315-270-23(a)(3) and R315-264-603]
The post-closure care period for the TTU will begin after the completion of closure of the waste
management units, including all required corrective measures, and will continue for a period of
time that is dependent on whether the facility can be clean closed. This determination cannot be
made until closure activities are completed.
5.3 Post-Closure Security [UAC R315-264-117(b)]
The TTU is not intended for public access, but is located in an area that may be used for grazing
domestic livestock. In addition, the TTU is within the UTTR-North and immediately west of the
Helicopter Air-to-Ground (HAG) Range. These are used as munitions testing and training
ranges, respectively. Therefore, security requirements will be implemented following closure.
Because of the remoteness of the facility, security can be ensured using the existing three or
four-strand wire fence and the existing locked gates.
5.4 Post-Closure Contact [UAC R315-264-118(b)(3)]
Post-closure contact should be with 75 CEG/CEIE, HAFB, until the post-closure care period is
completed, certified by the permittee, and signed by an independent qualified Utah-licensed
Professional Engineer practicing within the scope of his/her education and training.
5.5 Monitoring Plan [UAC R315-264-118(b)(1)]
Groundwater monitoring will be conducted at the TTU during the post-closure care period (and
during the closure period as well) to determine whether any remaining contamination could
originate from the TTU (e.g., hazardous wastes or hazardous constituents from any contaminated
soils that might remain in place following closure) and impact groundwater quality. Post-closure
monitoring will be the same as that described in the SAP (Attachment 15).
5.6 Maintenance and Inspection Requirements [UAC R315-264-118(b)]
Specific items to be inspected during the post-closure care period, as well as their respective
schedules and corrective action responses, are outlined in Table 2. The TTU will be re-seeded;
however, a final cover of the TTU is not proposed as part of closure activities.
All inspections will be recorded in an inspection log kept by 75 CEG. The inspection log will
include the following:
● the date and time of the inspection,
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● the name of the inspector,
● a notation of observations made regarding:
− condition of security devices (fencing, gates, locks, legibility of signs)
− drainage control (areas indicative of degradation, blockage, settlement, etc.)
− detection/monitoring equipment (damaged well casings, protective posts, eroded well
pads)
− disturbance of surveyed benchmarks
● the date and nature of any repairs or remedial measures taken to correct the problem.
If an inspection reveals deterioration or breakage of equipment and/or structures, remedial action
will be implemented to prevent or mitigate any harm to human health and the environment.
When such a hazard is recognized as being an imminent threat, remedial action will be taken
immediately.
5.7 Amendment of Post-Closure Plan [UAC R315-264-118(d)]
An amended post-closure plan will be submitted for review and approval by the Director if
(1) changes in the operating plans or facility design affect the approved post-closure plan, or
(2) events occur during the active life of the facility, including partial or final closure, that affect
the approved post-closure plan. The Director reserves the right to request modification to the
plan under the conditions described in Utah Admin Code R315-264-118(d)(4).
The post-closure plan will be amended at least 60 days prior to a proposed change in facility
design or operation or no later than 60 days after an unexpected event has occurred that affects
the post-closure plan.
5.8 Survey Plat and Post-Closure Notices [UAC R315-264-116 and 119 and 40 C.F.R. §§
264.116 and 264.119]
75 CEG shall submit to the local zoning authority, or the authority with jurisdiction over local
land use, and to the Director a survey plat that complies with UAC R315-264-116 and 40 C.F.R.
§ 264.116. 75 CEG shall submit such survey plat to the local land use authority, or the authority
with jurisdiction over local land use, and to the Director no later than the submission of the
certification of closure of each hazardous waste disposal unit.

75 CEG shall submit to the local zoning authority, or the authority with jurisdiction over local
land use, and to the Director a record of the type, location, and quantity of hazardous wastes
disposed of within each cell or disposal unit. 75 CEG shall submit such record to the local land
use authority, or the authority with jurisdiction over local land use, and to the Director no later
than 60 days after certification of closure of each hazardous waste disposal unit.

Within 60 days of final certification of closure of the first hazardous waste disposal unit and
within 60 days of final certification of closure of the last hazardous waste disposal unit, 75 CEG
shall record an instrument that is normally examined during title search and that will in
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perpetuity notify any potential purchaser of the information required by UAC R315-264-
119(b)(1)(i)-(iii) and 40 C.F.R. § 264.119(b)(1).

75 CEG shall submit to the Director a certification signed by an authorized official of 75 CEG
signifying the instrument that is normally examined during title search was recorded. Such
certification shall include a copy of the instrument that was recorded.
If the Permittee or any subsequent owner or operator of the land upon which a hazardous waste
disposal unit is located wishes to remove hazardous wastes and hazardous waste residues, the
liner, if any, or contaminated soils, he shall comply with the requirements in UAC R315-264-
119(c) and 40 C.F.R. § 264.119(c).
5.9 Certification of Completion of Post-Closure Care [UAC R315-264-120]
A certification that the post-closure care period for the hazardous waste treatment facility was
performed in accordance with the specifications in the approved post-closure plan will be
submitted by registered mail to the Director no later than 60 days following completion of the
established post-closure care period. The certification will be signed by an authorized official of
75 CEG and an independent qualified Utah-licensed professional engineer practicing within the
scope of his/her education and training. Documentation supporting the Professional Engineer's
certification will be furnished to the Director upon request.
5.10 Financial Requirements for Post-Closure [UAC R315-264-144 and 145]
UTTR-North facilities are owned and operated by the federal government and, as such, are
exempt from the financial requirements of post-closure care under Utah Admin. Code R315-264-
140(c). These include R315-264-144, "Cost Estimate for Post-Closure Care," and R315-264-145,
"Financial Assurance for Post-Closure Care."

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TABLE 1
Estimated Closure Schedule
Task Closure Activity Start Date Completion Date
1 Mobilize to the field First day (D-1) D-3
2 Conduct geophysical survey and remove UXO/scrap D-3 D-13
3 Sample soil and groundwater D-14 D-17
4 Decontaminate and dispose of TTU structures D-17 D-20
5 Demobilize D-21 D-22
6 Review and validate data D-23 D-48
7 Write closure report D-23 D-100
8 Monitor post-closure compliance D-107 To be determined

TABLE 2
Inspection and Maintenance Plan for TTU
Area/Equipment Specific Items Potential Problems Corrective Action Inspection-
Frequency
Security devices Facility fence Broken Repair immediately,
if damaged
Quarterly
Access gate Locking mechanism
jammed
Repair/replace Quarterly
Signs Illegible Replace Quarterly
Detection/
monitoring
equipment
Monitoring wells Unlocked well caps,
damaged casings,
protective posts or
well pads
Secure well caps; if
damage precludes
the use of the well,
seal damaged well,
and install a
replacement well
Quarterly
Benchmarks N/A Damage Replace, if
damaged
Quarterly
Soil Re-seeded
vegetation
Erosion Re-seed; implement
soil retention
measures
Quarterly

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Appendix A
Site 3 Partial Closure Activities: Miscellaneous Munition Burn Pan

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Table of Contents
1.0 EXECUTIVE SUMMARY A-3
2.0 BACKGROUND A-3
2.1 Permit Requirements Describing Operation of the Burn Pan A-5
2.2 Summary of the Burn Pan Closure Process A-6
3.0 HISTORIC BURN PAN USAGE A-7
4.0 HISTORIC SAMPLING DATA A-8
5.0 BURN PAN CLOSURE PLAN REVIEW A-9
6.0 BURN PAN CLOSURE PROCESS A-13
7.0 CLOSURE SAMPLING A-14
7.1 Health and Safety A-15
8.0 SCHEDULE A-17
9.0 REFERENCES A-17

Tables and Figures
Table 1. Historic Treatment Events at the Site 3 Burn Pan
Table 2. Samples and Analytical Methods
Table 3. Containers, Preservatives, and Holding Times
Table 4. UTTR Emergency Contacts

Figure 1. Aerial Image of Site 3 Burn Pan
Figure 2. Burn pan showing weather cover and gantry (February 2017)

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1.0 EXECUTIVE SUMMARY

Note: The burn pan described below was decommissioned and partially closed in
accordance with this plan on May 2, 2018.

The burn pan at the Utah Test and Training Range (UTTR) Thermal Treatment Unit (TTU) was
built in 1992. From 1994 to 1997, it was used to treat 48,033 pounds (5,714 pounds NEW) of
small arms and other explosive wastes. Burn pan usage was discontinued in 1997 because
alternative treatment options for these small explosive wastes were developed, but has continued
to be included as a permitted “inactive” operational site (Site 3) in the UTTR Hazardous Waste
Operating Permit (UTTR Permit) (UT0570090001). The burn pan weather cover is damaged
and in disrepair due to continued detonation activities at the TTU and the purpose of the unit was
questioned during a recent Strategic Arms Reduction Treaty (START) inspection. Because there
is no anticipated future use for the burn pan, the US Air Force is proposing to partially close the
site.
Proposed partial closure activities are governed by the UTTR Permit. Partial Closure will
include removal and recycling of the site gantry, dismantling and recycling of the burn pan
weather cover, and decontamination and recycling of the steel burn pan and lid. Characterization
and restoration of the area surrounding the burn pan will be conducted via ongoing biennial
sampling and final closure activities.

2.0 BACKGROUND
The TTU is located in the eastern part of the UTTR-North, adjacent to the western shore of the
Great Salt Lake in Box Elder County (see UTTR Permit Attachment 1, Figure 1). It is centered
on latitude 41° 07' 45.45'' North, longitude 112° 07' 41.38'' West, as depicted on the Strongs
Knob, Utah, U.S. Geological Survey (USGS) Map. The TTU is operated for the Ogden Air
Logistics Complex (OO-ALC), Hill Air Force Base (AFB), Utah, by the 75 Civil Engineer
Group, 775 Civil Engineering Squadron, Explosive Ordnance Disposal (EOD) Flight, on behalf
of the U.S. Air Force (USAF) and the U.S. Department of Defense (DoD). The UTTR is
assigned U.S. Environmental Protection Agency (USEPA) ID No. UT0570090001.

The TTU occupies a 2-square mile area in a gently southwestward-sloping valley. The TTU
topography and geology, its proximity to Box Elder County Road 02230, the types of operations
conducted, and the quantities of munitions treated were all taken into consideration in
determining the size and shape of the TTU. The TTU is outlined on the aerial photograph shown
in UTTR Permit Attachment 1, Figure 2.

The TTU contains four sites used for treating waste munitions by open burning (OB) or open
detonation (OD) (See UTTR Permit Attachment 1, Figure 2). Sites 1 and 4 are the rocket motor
and bulk propellant OB pads. Site 2 consists of three smaller OB/OD pads for treating rocket
motors as well as other waste munition items and a large pad used for detonation of large missile
motors. Site 3 is the munitions burn pan where cartridge-actuated device (CAD) and propellant-
actuated device (PAD) items, flares, and small arms ammunition are treated by OB.

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Site 3, the miscellaneous munitions burn pan, is located in the eastern portion of the TTU at 41º
07' 55.72'' North latitude, 112º 53' 25.55'' West longitude. It is located approximately 150 ft
southeast of the burn pit it replaced. This pan was constructed in 1992, but not put into operation
until 1994. It is approximately 7 ft wide and 20 ft long and is constructed of steel plate and
concrete. The pan is used to treat by OB, CAD/PAD items, flares, and small arms ammunition.
An aerial view and a photograph of the pan are included in Figures 1 and 2. The engineering
drawings of the pan are included in the UTTR Permit Attachment 1, Figure 4. The pan is
completely surrounded by a concrete containment structure or box and has a movable track-
mounted weather cover intended to keep out precipitation and wildlife when not in use. A large
steel lid for the pan and a site gantry to assist with offloading items to be treated are also present
at the site.

Figure 1. Aerial Image of Site 3 Burn Pan
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Figure 2. Burn pan showing weather cover and gantry (February 2017).

2.1 Permit Requirements Describing Operation of the Burn Pan
The following requirements from Module III of the UTTR Permit discuss how the burn pan was
operated (These requirements will be removed from Module III upon execution of the partial
closure activities described in this Appendix):
III.D.3. Open Burning in the Miscellaneous Munitions Burn Pan (Site 3)

III.D.3.a. The Permittee shall operate and maintain the burn pan in accordance with the design
plans and specifications in Attachment 1.

III.D.3.b. The Permittee shall operate and maintain the munitions burn pan in accordance with
the following conditions:

III.D.3.b.i. Open burning shall be conducted only during daylight hours, sunrise to sunset.

III.D.3.b.ii. The Permittee shall operate and maintain a lid on the burn pan, during years of burn
pan operation, to keep out precipitation, vegetation and wildlife.

III.D.3.b.iii. The Permittee shall manage accumulated precipitation in accordance with the
WAP in Attachment 3.

III.D.3.b.iv. The Permittee shall treat only waste identified in Condition III.B.1 and small arms
ammunition greater than or equal to .50 caliber.
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III.D.3.c. The Permittee shall operate and maintain the burn pan in order to minimize exposure to
air emissions in accordance with the following conditions:

III.D.3.c.i. The area surrounding the burn pan shall be inspected for untreated explosives,
propellant material, or other kick out material after each burn. Non-energetic residue will be
collected, characterized and accumulated for disposal or recycling. Energetic residue that is safe
to handle will be stored at the TTU for up to 90 days and treated at the next OB operation.
Energetic residue that is not safe to handle will be retreated within 24 hours at the TTU.

III.D.3.c.ii. Prior to use of the burn pan, all combustible material, within 50 ft. of the pan, shall
be removed.

III.D.3.d. The integrity of the munitions burn pan and the concrete secondary containment shall
be evaluated by March 1 of each year the pan is in operation. A report of the evaluation, signed
by an independent qualified Utah-licensed professional engineer practicing within the scope of
his/her education and training, shall be submitted to the Director by March 31 of each year. Any
deficiencies identified in the report shall be corrected before the burn pan is used.

III.D.3.e. The Permittee shall use combustible material and fuel oil as an initiator of the burn in
accordance with the following conditions:

III.D.3.e.i. The combustible material shall consist of wooden ammunition crates and/or pallets,
non-explosive contaminated scrap wood and cardboard boxes used to pack and ship the items to
be treated.

III.D.3.e.ii. The fuel shall be less than 50 gallons of No. 2 diesel fuel.

III.E.1.c. The burn pan shall remain closed until the ash is removed.

III.G.2. Soil Monitoring Adjacent to Site 3 Burn Pan

III.G.2.a. The Permittee shall sample the soil adjacent to the burn pan at Site 3 annually, for
every year the pan is in operation, according to an approved sampling and analysis plan (SAP).
2.2 Summary of Partial Burn Pan Closure Activities

To partially close the Site 3 Miscellaneous Munitions Burn Pan, the following steps will be
undertaken:

● Removal and recycling of the site gantry.
● Dismantling and recycling of the burn pan weather cover.
● Removal, decontamination, and recycling of the steel burn pan and lid

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3.0 HISTORIC BURN PAN USAGE
Operational logs of the TTU were reviewed and indicate that the burn pan was used 26 times
from March 1994 through October 1997 to treat a total of 48,033 pounds of waste (5,714 pounds
net explosive weight). Table 1 summarizes the treatment events. Operational logs and manifests
for each treatment event are available in the TTU operating log.

Table 1. Historic Treatment Events at the Site 3 Burn Pan
LOG # Date
Gross
Weight
NEW
1 Notes
2 16-Mar-94 6228 322 Initiators, Linear Charges, Misc. Items
7 17-May-94 517 243 Black Powder, Propellant
9 27-May-94 4791 146 20mm, Misc. Items
15 27-Jun-94 5257 135 Gas pressure gen., Misc. Items
26 9-Aug-94 1088 167 Explosive kits, Flares
4 28-Mar-95 855 22 Det cord, Cartridges, Misc. Items
10 25-Apr-95 932 251 Cartridges, Fuzes
14 3-May-95 268 6 Fuzes, Misc. Items
17 9-May-95 1362 183 Cartridges, Misc. Items
25 13-Jun-95 732 37 Cartridges, Fuzes, Misc. Items
27 20-Jun-95 3864 4 Fuzes
31 18-Jul-95 1234 255 Cartridges, Fuzes
32 24-Jul-95 744 63 Cartridges, Fuzes, Misc. Items
1 6-Mar-96 1085 79 Cartridges, Shape Charges, Fuzes
10 16-Apr-96 573 171 Cartridges, Igniters, Misc. Items
13 30-Apr-96 3187 682 Flares, Cartridges, Misc. Items
20 14-May-96 1066 1066 Flares
30 25-Jun-96 458 9 Cartridges, Fuzes, Misc. Items
36 30-Jun-96 73 9 Fuzes, Rocket Motor
50 4-Sep-96 574 140 Fuzes, Cartridges
68 14-Nov-96 876 61 Igniters, Cartridges, Fuzes
3 20-Feb-97 4081 688 Cartridges, Igniters, Flares
20 21-May-97 1761 90 Cartridges, Charges
33 16-Jul-97 1598 262 Propellant, Cartridges
37 25-Jul-97 4089 394 Flares
66 30-Oct-97 740 229 Cartridges, Fuzes
TOTAL
: 26 Operations 48033 5714
1Net Explosive Weight

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4.0 HISTORIC SAMPLING DATA
Sampling of the burn pan area was conducted in 1989 and 1991 before the current burn pan
structure was installed. This sampling was described in the 1997 RCRA Part B Permit
Application for the TTU (US Air Force, 1997). In 1989, “five samples were collected in a
preliminary study of the munitions burn pit adjacent to what is now Site 3…Four of the five
samples were taken from the top 2 in. of soil in the bottom of the pit. The fifth sample was taken
to represent background conditions approximately 150 to 200 yards east of Site 3.” The results
indicated elevated levels of Total Petroleum Hydrocarbons ranging from 210 to 47,000 mg/kg
(the single background sample level was 20 mg/kg). Detections of some polycyclic aromatic
hydrocarbons including acenaphthene, fluorene, 2-methylnaphthalene, naphthalene,
phenanthrene, and pyrene were also observed as were bis (2-ethylhexyl) phthalate and
dibenzofuran. Metals including arsenic, cadmium, chromium, and lead were also detected, of
which only lead exceeded twice the background sample concentration with an average of 225
mg/kg (lead in the background sample was 16.1 mg/kg).
In 1991, six soil samples were taken in the Site 3 area. Results of the sample analysis indicated
elevated levels of aluminum, cadmium, copper, lead, and zinc and detections of the explosives
HMX, 2,4-DNT, and nitroguanidine. The highest lead concentration of 48,000 mg/kg was found
in the sample from the “west wall of Site 3.” The average “background” concentration of lead
was 29.8 mg/kg during this sampling event.

In 2010, the area containing the burn pan was sampled as part of the annual surface soil sampling
event at the TTU. This sampling is meant to characterize the surface contamination of large
areas within the TTU to show contaminant distribution from open burn and open detonation
events. The sampling is conducted by taking a composites sample comprised of 100 increments
within a 100 x 100 meter grid cell. The samples are homogenized, ground, subsampled, and
analyzed to give a single average value for the cell. Sample results for the grid cell containing
the burn pan area showed an elevated lead concentration along with detections of HMX and 2,4-
DNT. At 44 mg/kg, the lead concentration is the maximum of any grid cell sampled between
2005 and 2015. The average grid cell lead concentration at the TTU over this time period is 10.6
mg/kg.

Overall, the historic sampling data from the burn pan indicate that prior to the construction of the
current burn pan, there were higher levels of metals, primarily lead, and indications of
combustion residues including total petroleum hydrocarbons and some polycyclic aromatic
hydrocarbons associated with the treatment operation. Detection of some explosive residues
(HMX, 2,4-DNT, and nitroguanidine) typical of other areas of the TTU have also been found.
Since the construction of the current burn pan in 1992, only the 2010 sampling event evaluated
the area and found an elevated lead level. It is not known if highly contaminated soils were
removed from the TTU during the 1992 burn pan construction. It is likely that they were
excavated to allow for construction of the concrete containment box and left on site. Because of
potential contamination indicated by past sampling events, extensive disturbance or regrading of
the area surrounding the burn pan containment box will not be conducted during the partial
closure activities described in this appendix.

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5.0 BURN PAN CLOSURE PLAN REVIEW
Closure requirements for the TTU are found in Section II.P and Attachment 8 of the UTTR
Permit. Section II.P.4 requires that “The Permitee shall review the closure plan contained in
Attachment 8 before commencing partial or final closure…If the closure plan requires
modification, the plan shall be modified pursuant to Utah Admin. Code R315-124-5.” Closure
requirements found in Attachment 8 are summarized and reviewed below. Sections titles and
section references are those found in Attachment 8. As a result of this review, modified
language to the closure plan and this appendix to Attachment 8 will be submitted to the Director.

Closure Plans (Section 1.0). This section describes the intent of the closure plan. It does not
address the potential of partial closure in advance of final TTU closure.

Closure Performance Standard (Section 1.1). This section discusses clean closure versus non-
clean closure. Only partial closure involving removal of equipment from Site 3 will be
conducted at this time. Activities that may result in final clean closure or non-clean closure will
be conducted during future closure of the TTU.

Partial Closure and Final Closure Activities (Section 1.2). This section specifically states that
“Partial closure of the TTU is not planned.” This would have to be modified to allow for the
planned partial closure of the Site 3 burn pan area.

Maximum Waste Inventory (Section 1.3). This section discussed the maximum allowable
limits for waste treatment at the TTU. It is not affected by the proposed partial closure activities
at Site 3.

Schedule for Closure (Sections 1.4, 1.4.1, and 1.4.2). This section discusses the schedule and
time allowed for closure. It needs to be modified to allow for partial closure activities.

Closure Procedures (Section 1.5). This section discusses planned closure procedures.
Applicable procedures for the partial Site 3 burn pan closure activities will be utilized.

Geophysical Survey (Section 1.5.1). This section discusses the need for a geophysical survey
to identify areas of the TTU where buried wastes may be present. Since no subsurface work will
be conducted as part of the partial closure activities at the Site 3 area, it will not be completely
closed at this time and will remain part of the active TTU area. Therefore, a geophysical survey
will not be conducted at this time.

Soil and Groundwater Sampling (Section 1.5.2). This section requires that closure activities
involve sampling to establish cleanup requirements in accordance with section II.P of the permit.
Because the burn pan is a man-made structure, the intent of the partial closure activity is to
remove all steel components and leave only the concrete containment box in place. Sampling
will focus on characterization of decontamination fluids prior to disposal. No sampling or
remediation of the area outside of the concrete box will take place at this time.

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Sampling Equipment Decontamination Procedures (Section 1.5.2.1). This section requires
that “Site-specific sampling locations, quantities, sample collection and analytical methods, and
QA/QC issues will be addressed and presented in the final closure plan.” It also requires that
“All field sampling equipment will be pre-cleaned prior to arrival on-site and decontaminated in
accordance with standard procedures. A decontamination area will be established and maintained
on-site for all decontamination activities. The site will be selected by the sampling team based on
the location’s ability to isolate the decontamination area and assist in preventing cross-
contamination of sampling equipment.” These procedures will be followed during partial
closure activities at Site 3.

IDW Management (Section 1.5.2.2). This section requires that “All wastes generated from
field sampling and decontamination activities will be treated as contaminated media until data
are available to determine their actual characteristics. This material will be drummed and stored
at the TTU pending the outcome of sampling analysis.” Labeling and packaging requirements are
also discussed. All investigation derived wastes will be managed in accordance with the
requirements of this section. While this section specifies the use of 55 gallon drums for
collection of IDW, it is not anticipated that this volume of container will be required for the
partial closure activities. Appropriate container sizes will be utilized.

Health and Safety Procedures (Section 1.5.2.3). This section requires that “Personnel
performing sampling will use appropriate Personal Protective Equipment (PPE) deemed
necessary to accomplish sampling tasks. The PPE to be used will be specified in the closure
Health and Safety Plan. Sampling personnel will be properly trained in hazardous waste
sampling procedures and will have appropriate medical monitoring and certification. Sampling
personnel will also be briefed by the EOD RSO on the hazards of sampling in a potential
explosively-contaminated environment.” No soil sampling will be conducted as part of this
partial closure. PPE for those involved in decontamination and IDW sampling is addressed in
the Health and Safety Section below.

Determining Cleanup Goals (Section 1.5.3). This section focuses on background sampling and
determining appropriate screening criteria or risk-based cleanup levels required for clean closure.
Because only the burn pan and associated structures are to be removed, no soil background
sampling is planned.

Inventory Removal (Section 1.5.4.1). This section describes the types of waste that may be
removed from the site during closure activities. During partial closure activities for Site 3, ash
residue left in the burn pan and decontamination fluids will be the primary wastes produced.

Disposal or Decontamination of Equipment and Structures (Section 1.5.4.2). This section of
the permit is most applicable to the partial closure of the burn pan. The applicable portion of the
section is as follows:

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To the extent possible, decontamination and disposal will be
performed on existing man-made structures at the TTU. These include
the burn pan, burn pan cover, and burn pan supporting
structure…Decontamination activities will be done in such a way as to
allow for reuse or recycling of those components suitable for that
purpose (e.g., metal structures that could be certified clean).
All components of the burn pan will be visually inspected, and any
visible waste and debris will be physically removed. The burn pan
concrete pads and support columns will be scraped and brushed of all
loose waste and debris. Upon removal of all loose waste and debris, the
burn pan and its cover will be pressure-washed to remove any remaining
residue. A bermed decontamination pad constructed of 30 mil plastic
and large enough to contain the burn pan and lid will be used to contain
all wash water. The decontamination pad will be positioned adjacent to
the burn pan.
Following decontamination, rinsate samples and concrete chips will
be collected from the burn pan and analyzed for Toxic Characteristic
Leaching Procedure metals and explosive compounds to verify their
cleanliness. If rinsate of concrete chip analysis indicates additional
decontamination is necessary, the decontamination process and
accompanying analysis will be repeated until each component is verified
as clean. Once the treatment structures are certified clean, they will be
either transported to the Oasis R3 yard to be stored until contracted for
disposal/recycling or disposed of at the UTTR-North sanitary landfill.
All waste generated from the decontamination process will be
containerized in drums for characterization and disposal/recycling.

The applicable decontamination procedures described above will be followed during partial
closure of the Site 3 burn pan. The burn pan gantry and weather cover will be recycled without
prior decontamination as they were not exposed to munitions during treatment operations. No
concrete sampling or removal will be performed as part of the partial closure activities. The
only wastes generated will be from decontamination of the burn pan. No reactive wastes
should be present in the burn pan, only residues from prior treatment operations. Non-metal
residues that do not meet the definition of “scrap metal” will be removed prior to recycling.
Visual verification that no non-metal residues are present (i.e., the components are “clean”)
will be accomplished. All metal components will then be sent for recycling in accordance with
the scrap metal exclusions found in R315-261-4(a)(13) and R315-261-6(a)(3)(ii) No disposal
in the UTTR-North sanitary landfill is anticipated. Samples of decontamination water will be
evaluated for proper disposal.

Closure of Containers (Section 1.5.4.3). This section states that “All ash and contaminated
debris identified as treatment residue, solid IDW, and decontamination fluids and rinsates will be
placed in DOT 17E and 17H drums, as previously described. Should sampling analysis
determine these to be contaminated, each container will be closed and transported to a hazardous
waste disposal facility. Remaining containers will be decontaminated and removed from the
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facility.” Any residues, including IDW, generated during partial closure will be properly
managed as described.

Remediation (Section 1.5.4.4). This section states that “In the event contamination is detected
after HAFB and DWMRC agree to pursue clean closure, activities necessary to remediate the
site to predetermined cleanup levels will be conducted. These activities will be documented in
the Corrective Action Plan (CAP) as discussed in Section 1.1.” No remediation efforts are
anticipated during the partial closure activities.

Closure Certification and Required Notices (Section 2.0). This permit section states that:
Within 60 days of the completion of closure for the TTU and the
MSA temporary storage pads, 75 CEG/CEIE will submit in writing (by
certified mail) a closure certification to the Director. The certification
will verify that the hazardous waste treatment facility was closed in
accordance with the specifications outlined in the closure plan, including
the completion of all required corrective action measures. The
certification will be signed by an authorized official of the Hill AFB 75th
Air Base Wing and an independent qualified Utah-licensed professional
engineer practicing within the scope of his/her education and training.
Documentation supporting the professional engineer’s certification will
be furnished to the Director upon request.
No later than the submission of closure certification, 75 CEG/CEIE
will also submit to the Director a survey plat indicating the location and
dimensions of the facility with respect to permanently surveyed
benchmarks. The plat will be prepared and certified by a professional
land surveyor licensed in Utah.

In accordance with this requirement, the Air Force will submit a closure certification for the
partial closure activities at the burn pan area within 60 days of completion. Modified sections of
the UTTR Hazardous Waste Operating Permit will also be submitted with the closure
certification to describe the current state of the burn pan operational area. No survey work will
be conducted during the partial closure activities, so a survey plat will not be submitted.

As a result of the above review, a permit modification will be submitted to the Director in
advance of any partial closure activities to update Attachment 8 to allow for partial closure of
specific TTU areas in advance of final TTU closure.

Closure Cost Estimate (Section 3.0). This section states that “The TTU is a federal
government facility, owned and operated by the Hill AFB 75th Air Base Wing for the AF and the
DoD. As such, it is exempt from the requirements for closure cost estimates.” This statement is
still accurate and applicable to the Site 3 partial closure activities.

Financial Assurance Mechanism for Closure (Section 4.0). This section states that “In
accordance with 40 CFR 264.143, “Financial Assurance for Closure,” federal facilities are
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exempt from the requirements for financial assurance.” This statement is still accurate and
applicable to the Site 3 partial closure activities.
Post-Closure Plan (Section 5.0). This section discusses the need for a post-closure plan that
specifies post–closure monitoring and maintenance activities. Because the partial closure
activities of Site 3 will not result in final closure of any part of the TTU, a post-closure plan is
not applicable at this time. The Site 3 area will continue to be monitored and maintained in
accordance with the active Hazardous Waste Operating Permit, as are other non-treatment areas
within the TTU boundary.
6.0 BURN PAN CLOSURE PROCESS
In accordance with the requirements of the UTTR Hazardous Waste Operating Permit outlined
above, the following procedures will be followed to complete partial closure of the Site 3 burn
pan. The area outside the containment structure will continue to be considered as potentially
contaminated like other areas within the TTU and will be subject to further evaluation and
restoration upon final site closure. Future biennial soil sampling events at the TTU may be used
to further characterize this area.
Details of Phase I closure activities are as follows:
1-Removal and recycling of the site gantry
The gantry located to the south east of the burn pan will be removed with a crane, dismantled or
cut into manageable pieces, and placed in a roll-off container for recycling. No decontamination
or special procedures are necessary prior to recycling as the gantry was not directly exposed to
waste during treatment events.

2-Dismantling and recycling of the burn pan weather cover
The weather cover and supporting rails will be removed by crane, dismantled, and placed in a
roll-off container for recycling. No decontamination or special procedures are necessary prior to
recycling as the weather cover was not directly exposed to waste during treatment events.

3- Removal and decontamination of the steel burn pan and lid prior to recycling
In order to safely enter the containment box without the threat of snake or spider exposure,
vegetation and debris will be removed from above prior to entering. This will be accomplished
using hand implements or power equipment as deemed necessary. Vegetation will be discarded
on-site. Any debris that appears to be from treatment operations (e.g., ash etc.) will be
containerized and managed as potential hazardous waste. Debris that is clearly not treatment
residue will be managed as non-hazardous waste.

The steel burn pan and supporting structure will be disconnected from the concrete containment
box by cutting the mounting bolts with a torch and then removed using a crane. As described in
the UTTR Hazardous Waste Operating Permit, “All components of the burn pan will be visually
inspected, and any visible waste and debris will be physically removed. The burn pan concrete
pads and support columns will be scraped and brushed of all loose waste and debris. Upon
removal of all loose waste and debris, the burn pan and its cover will be pressure-washed to
remove any remaining residue. A bermed decontamination pad constructed of 30 mil plastic and
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large enough to contain the burn pan and lid will be used to contain all wash water. The
decontamination pad will be positioned adjacent to the burn pan.”

Both the burn pan structure and lid will be washed with a pressure-washer to remove any
potential contamination. It is anticipated that less than 15 gallons of water will be needed to
decontaminate each piece of equipment. Rinsate for each wash will be collected in containers
and rinsate samples will be analyzed by the Hill AFB chemistry lab and disposed of properly.
The plastic used on the decontamination pad is not anticipated to be contaminated. It will be
rinsed clean after the final use and disposed as solid waste.

After decontamination, the burn pan, supporting structure and lid will be sent for recycling.
These items may be staged in the R3 (Oasis recycling) lot until transportation to the recycler is
available. It may be necessary to cut these items into smaller pieces to facilitate transportation
which can be accomplished in the R3 lot.

4-Certification and notification
In accordance with permit requirements, the Air Force will submit a certification for the partial
closure of the Site 3 Burn Pan area within 60 days of the burn pan closure. Modified sections of
the UTTR Hazardous Waste Operating Permit will also be submitted with the closure
certification to describe the current state of the burn pan operational area.
7.0 SAMPLING
Sampling of decontamination rinsate will be conducted by Hill AFB hazardous waste program
contractors. The decontamination rinsate will be sampled and analyzed as described in Tables 2
and 3. Applicable Hill AFB standard operating procedures for equipment decontamination, field
decontamination, location and sample identification, and sample handling and shipping will be
followed. These documents are found in the Hill AFB Basewide Quality Assurance Project Plan
(Hill AFB, 2013).

Utah Test and Training Range
Attachment 8-Closure and Post-Closure Plan
Issued DRAFT

A-15

Table 2. Samples and Analytical Methods

Sample Type
Number
of Samples

Analytical
Methods

Purpose/Notes
Decontamination
Rinsate
1

TCLP Metals
(SW-846 1311)
Explosives (SW-
846 8330)
Perchlorate (SW-
6850/6860)

● Characterize rinsate and debris from
burn pan, lid, and containment
structure for proper disposal
● Rinsate will be decanted and
analyzed for explosive residues and
perchlorate but these constituents will
not be used for waste characterization
since they are unregulated and would
have to be present at high enough
concentrations to be reactive to make
the waste hazardous. Remaining solid
debris will be assumed to be
potentially reactive and will be stored
and treated as reactive hazardous
wastes at the TTU.

Table 3. Containers, Preservatives, and Holding Times
Analytical Method Matrix Container* Preservative Holding Time
Explosives, 8330 water 1 L amber with
Teflon lined cap
4° C, dark 7 days from sample
collection to extraction, 40
days from extraction to
analysis
Metals-ICP (Al, As, Ba,
Be, Cd, Cr, Fe, Pb, Ni, Se,
Ag, V, Zn)
6010C/6020A/1311

water
1-liter
polyethylene
with Teflon line
cap
HNO3, 4° C,
dark
180 days from sample
collection to extraction, 28
days from sample collection
to analysis for mercury
Perchlorate, 6850/6860
water
100 ml
polyethylene
with Teflon line
cap
4° C, dark 28 days from sample
collection to analysis
*Container volumes may vary depending on laboratory preference

7.1 Health and Safety
Health and Safety of all personnel involved in the burn pan removal and closure is of primary
importance. An initial safety briefing will be held by the UTTR Unit Environmental Coordinator
prior to commencing work at the site. CE Operations will brief personnel daily as work
assignments are given out. Visitors will be briefed prior to site access. Emergency contact
information, site hazards, and personal protective equipment are discussed below:
Utah Test and Training Range
Attachment 8-Closure and Post-Closure Plan
Issued DRAFT

A-16

Emergency Contacts
In the event of an emergency at the TTU, call Oasis Security:
Call sign “Phoenix”, Phone: [phone]

Table 4. UTTR Emergency Contacts
Contact Phone Number or Radio Call Sign
Hill Range Control Radio call sign: “Hill Range Control”
Phone: [phone]
Oasis Security Radio call sign: “Phoenix”
Phone: [phone]
Hill AFB Emergency
Communications Center (HAFB
ECC)*
Radio call sign: “Hill Fire Dispatch”
Phone: [phone]/3023
UTTR EOD Radio call sign: Depends on current RSO assignment
Phone: [phone]
UEC Radio call sign: “UEC”
Phone: [phone]
*Note: All emergency notifications will be made through the HAFB ECC
Hazards
Primary hazardous that may be encountered during the burn pan closure and a discussion of
mitigating factors are as follows:
Exposure-Work will be conducted during fall/winter months at the UTTR. Personnel will need
to wear appropriate winter clothing and stay hydrated. Work will not be conducted during
inclement weather conditions.
Chemical-Low levels of explosive residues are known to be present in site soils. Wastes
associated with the burn pan may contain excessive levels of heavy metals, primarily lead. Since
site soil will not be significantly disturbed, exposure to soil is not anticipated to pose a
significant risk. Any residual ash material present in the burn pan will be removed during burn
pan decontamination. Appropriate respiratory protection will be used when dealing directly with
dry wastes from the burn pan.
Unexploded Ordnance-The TTU is part of a past and current active military range. Operational
areas are cleared by explosive ordnance disposal (EOD) personnel after each operation and the
entire TTU area is swept on an annual basis. Occurrence of unexploded ordnance may occur.
Should UXO/MEC items be observed, they will be left in place and flagged for further
assessment and disposal by EOD.

Utah Test and Training Range
Attachment 8-Closure and Post-Closure Plan
Issued DRAFT

A-17

Biological Hazards-Potential biological hazards include snakes, spiders, scorpions and larger
animals such as badgers and coyotes. General awareness/avoidance and personal protective
equipment are the primary measures to avoid these hazards. Areas where animals may reside
(e.g., under the burn pan) will be carefully inspected prior to commencing work in the area.
Trip/Fall Hazardous-The potential for physical hazards including trip/fall hazards is significant.
Topography at the site is varied and the burn pan and open concrete containment structure pose a
significant fall risk. All personnel will be briefed on these hazards and only personnel involved
in burn pan removal or sampling activities will be allowed near the open burn pan and
containment structures.
Heavy Equipment-The use of heavy equipment including cranes and loaders at the site will
pose risks for personnel on the ground. All site personnel will remain in view of equipment
operators at all times. Personnel assisting with rigging will be clear of any items being moved
prior to lifting. A spotter on the ground will direct all crane operations to ensure site safety.
Power Equipment and Tools- Power equipment including grinders, drills, power washers, and
other hand tools will be utilized during the burn pan removal and decontamination process. All
manufacturer safety guidelines will be followed and recommended personal protective
equipment (see below) will be employed. Although explosive residues are anticipated at the site,
no explosive hazards are expected due to the low residue concentrations, therefore no additional
explosive safety requirements (e.g., non-sparking or intrinsically safe tools) will be required.
Personal Protective Equipment
All personnel on the site will be required to wear standard Level D PPE, including long pants,
safety-toed boots, hard hats, leather gloves, and eye protection. Personnel performing
decontamination or sampling activities where respirable aerosols or dust may be present will
employ Level C PPE including full-face or half-mask NIOSH approved air purifying respirators
with eye protection and chemical resistant gloves and coveralls. Personnel involved in sampling
or direct management of decontamination residues and rinsate will wear Level C PPE as
described above with eye protection (respirators are not required).
8.0 SCHEDULE
Partial burn pan closure, the burn pan removal and recycling is planned to take place in fall of
2017.
9.0 REFERENCES
US Air Force, 1997. Final Draft, Resource Conservation and Recovery Act Part B Permit
Application for the Open Burning/Open Detonation at the Utah Test and Training Range-North
Thermal Treatment Unit. Radian International, LLC, Oak Ridge, TN. August 1997.
Hill AFB, 2013. Basewide Quality Assurance Project Plan. 26 February, 2013.