DSHW-2024-004631

DSHW-2024-004631 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. 711
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

March 11, 2024

Kris Blauer, Manager, Environmental Services
Northrup Grumman Systems Corporation
PO Box 707
Brigham City, UT 84302-0707

RE: ATK Launch Systems Inc. Promontory Facility Hazardous Waste Storage Permit
Class 1 Permit Modification with Prior Approval
UTD009081357

Dear Mr. Blauer:

On November 21, 2023, the Division of Waste Management and Radiation Control (Division) received
your request for a Class 1 permit modification with prior approval due to a change in ownership
resulting from the purchase of ATK Launch Systems Inc. by Northrop Grumman Corporation
(DSHW-2023-212099). The Division has completed its review of your request and the specific changes
outlined in this request are hereby approved.

The changes have been incorporated and a copy of the revised permit is attached to this letter.
Additionally, an addendum to the signature page of the Permit is enclosed.

If you have any questions, please call Gabrielle Marinick at 385-499-0172.

Sincerely,

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control

(Over)

DJH/GEM/wa

Enclosures: Addendum to Signature Page (DSHW-2024-004613)
Module I – Standard Permit Conditions (DSHW-2014-004375)
Module II – General Facility Conditions (DSHW-2014-004376)
Module III – Storage in Containers (DSHW-2014-004377)
Module IV – Thermal Treatment of Energetic Wastes (DSHW-2014-004378)
Module V – Treatment of Waste Hydrazine (DSHW-2014-004379)
Module VI – Oxidizer Leaching Treatment of Energetic Waste (DSHW-2019-011672)
Attachment 1 – Waste Analysis Plan (DSHW-2014-004364)
Attachment 2 – Inspection Schedules and Procedure (DSHW-2014-004365)
Attachment 3 – Personnel Training (DSHW-2014-004366)
Attachment 4 – Contingency Plan (DSHW-2014-004367)
Attachment 5 – Closure Plan (DSHW-2014-004368)
Attachment 6 – Facility Drawings (DSHW-2014-004369)
Attachment 7 – Security Plan (DSHW-2014-004370)
Attachment 8 – Preparedness and Prevention Plan (DSHW-2014-004371)
Attachment 9 – Container Management Procedures (DSHW-2014-004372)
Attachment 10 – T29B Hydrazine Dilution Procedures (DSHW-2014-004373)
Attachment 11 – M136 and M225 Thermal Treatment Operations (DSHW-2014-004374)
Attachment 11 Figure 11-1 (DSHW-2019-011662)
Attachment 11 Figure 11-2 (DSHW-2019-011664)
Attachment 12 – M-705L Oxidizer Leaching Process (DSHW-2019-011670)
Attachment 12 - M705 Water Based Leach Tank Piping (DSHW-2019-011666)
Attachment 12 – M705 Tank for Water Based Leaching of Reactive Waste Sheets 1-3
(DSHW-2019-011668)

c: Jordan Mathis, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Annette Maxwell, U.S. EPA, Region VIII
Blair Palmer, Environmental Engineer, Northrop Grumman Systems Corporation (Email)
Sally Kaiser, Division of Waste Management and Radiation Control, UDEQ
Kaci McNeill, Division of Waste Management and Radiation Control, UDEQ
Addendum to the Signature Page to the ATK Launch Systems Inc., Promontory Facility
Hazardous Waste Storage Permit

As of March 11, 2024, the Signature Page to the Part B, Hazardous Waste Storage Permit, issued
to the ATK Launch Systems Inc. Promontory Facility on September 26, 2019, is revised to
reflect a change in ownership. This Addendum is created in accordance with a Permit
Modification submitted to the Division of Waste Management and Radiation Control on
November 21, 2024; Division tracking number DSHW-2023-212099.

This Permit is transferred to Northrop Grumman Corporation as the facility owner and Northrop
Grumman Systems Corporation as the facility operator.

The Permit issue date of September 26, 2019, does not change due to the transfer of ownership.
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
1
MODULE I - STANDARD PERMIT CONDITIONS I.A. EFFECT OF PERMIT
I.A.1. The Permittee includes both the facility owner, Northrop Grumman Corporation and the
facility operator, Northrop Grumman Systems Corporation a wholly owned subsidiary
of Northrop Grumman Corporation.

I.A.2. The Permittee is allowed to store hazardous waste in containers, treat reactive and
ignitable hazardous waste in a tank by an oxidizer leaching process, treat hydrazine in
containers by dilution, and treat reactive hazardous waste by open burning or open
detonation at the Northrop Grumman Systems Corporation – Promontory Facility
(NGSC) in accordance with the conditions of this Permit. In addition, the Permittee is
allowed to store waste solid rocket motors at the facility in accordance with the
conditions of this Permit. Any treatment, storage, or disposal of hazardous waste not
authorized in this Permit, is prohibited.

I.A.3. Compliance with this Permit, during its term, constitutes compliance for purposes of
enforcement with applicable sections of Utah Administrative Code (UAC) R315 only
for those management practices specifically authorized by this Permit.

I.A.4. Issuance of this Permit does not convey property rights of any sort or any exclusive
privilege; nor does it authorize any injury to persons or property, any invasion of other
private rights, or any infringement of State or local law or regulations.

I.A.5. This Permit has been developed in accordance with the applicable requirements of
UAC R315-1 through 101 of the Utah Hazardous Waste Management Rules. All
conditions within this Permit shall supersede conflicting statements, requirements, or
procedures found within UAC R315-1 through 101.

I.A.6. The procedures, protocols, inspection schedules, training outlines, contingency plan
responsibilities, and precautions contained in the preparedness and prevention plan as
described in the Attachments to this Permit are enforceable conditions of this Permit.
Permit conditions specified in the modules of this Permit supersede any conflicting
language in the Attachments to this Permit.

I.B. ENFORCEABILITY

I.B.1 Violations documented through the enforcement process pursuant to Utah Code
Annotated (UCA) §19-6-112 may result in penalties assessed in accordance with
R315-102, the Penalty Policy.

Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
2
I.C. OTHER AUTHORITY

I.C.1. The Director of the Division of Waste Management and Radiation Control (Director)
expressly reserves any right of entry provided by law and any authority to order or
perform emergency or other response activities as authorized by law.

I.D. PERMIT ACTIONS

I.D.1. This Permit may be modified, revoked and reissued, or terminated for cause, as
specified in R315-270-41 and R315-270-43. If the Director determines that cause exists
to modify, revoke, and reissue, or terminate this Permit, the action will proceed in
accordance with R315-124-5.

I.D.2. The filing of a request for a permit modification, revocation, reissuance, termination, or
the notification of planned changes or anticipated noncompliance on the part of the
Permittee does not stay the applicability or enforceability of any Permit condition.

I.D.3. The Director may modify this Permit, in accordance with R315-270-41, when the
standards or regulations on which the Permit was based have been changed by statute,
through promulgation of new or amended standards or regulations, or by judicial
decision after the effective date of this Permit.

I.D.4. The Permittee may request Permit modifications in accordance with the procedures of
R315-270-42.

I.D.5. If a conflict exists between conditions in this Permit, the Permittee shall comply with
the most stringent condition, as determined by the Director.

I.D.6. In accordance with the Utah Solid and Hazardous Waste Act, UCA, 19-6-108(13), this
Permit shall be reviewed no later than five years from the date of issuance or renewal
and subsequently modified, if necessary.
I.E. SEVERABILITY
I.E.1. The provisions of this Permit are severable and if any provision, or the application of
any provision of this Permit to any circumstance is held invalid, the application of such
provision to other circumstances and the remainder of this Permit shall not be affected
thereby. Invalidation of any State or federal statutory or regulatory provision which
forms the basis for any condition of this Permit does not affect the validity of any other
state or federal statutory or regulatory basis for said condition.

I.F. DUTY TO COMPLY

I.F.1. The Permittee shall comply with all conditions of this Permit, except to the extent and
for the duration such noncompliance is authorized by an Emergency Permit issued in
accordance with R315-270-61. Any permit noncompliance, other than authorized by an
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
3
Emergency Permit, constitutes a violation of the Utah Solid and Hazardous Waste Act
U.C.A. Sections 19-6-101 through 125, and is grounds for enforcement action; for
Permit termination, revocation and reissuance, or modification; or for denial of a Permit
renewal application.

I.F.2. Compliance with the terms of this Permit does not constitute a defense to any order
issued or any action brought under Sections 3007, 3008, 3013, or 7003 of RCRA
(42 U.S.C. Sections 6927, 6928, 6934 and 6973), Section 106(a), 104, or 107 of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(42 U.S.C. 9606(a), 9604, and 9607, commonly known as CERCLA) as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), or any other State or
federal law providing for protection of human health or the environment from any
imminent and substantial endangerment.

I.G. DUTY TO REAPPLY

I.G.1. If the Permittee wishes, or is required by the Director, to continue an activity regulated
by this Permit after the expiration date of this Permit, the Permittee shall submit a
complete application for a new permit, in accordance with R315-270-30(b) and
R315-270-10(h), at least 180 days before this Permit expires.

I.H. PERMIT EXPIRATION

I.H.1. This Permit shall be effective for ten years from the date of issuance. This Permit and
all conditions herein shall continue in force until the effective date of a new permit, if
the Permittee has submitted a timely (at least 180 days prior to permit expiration or by
an alternate date if requested by the Director) and complete permit application and
through no fault of the Permittee, the Director does not issue a new permit with an
effective date on or before the expiration date of this Permit. A permit continued under
this condition is fully effective and enforceable.

I.I. RESERVED

I.J. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE

I.J.1. It shall not be a defense for the Permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity in order to maintain compliance
with the conditions of this Permit.

I.K. DUTY TO MITIGATE

I.K.1. In the event of noncompliance with the Permit, the Permittee shall take all reasonable
steps to minimize releases of hazardous waste, hazardous waste constituents, and
perchlorate salts to the environment, and shall carry out such measures as are reasonable
to prevent significant adverse impacts on human health or the environment.
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
4
I.L. PROPER OPERATION AND MAINTENANCE
I.L.1. The Permittee shall, at all times, properly operate and maintain all facilities and systems
of treatment and control (and related appurtenances) which are installed or used by the
Permittee to achieve compliance with the conditions of this Permit. Proper operation
and maintenance includes effective performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. This provision requires the operation of
back-up or auxiliary equipment or similar systems only when necessary to achieve
compliance with the conditions of this Permit.

I.M. DUTY TO PROVIDE INFORMATION

I.M.1. The Permittee shall furnish to the Director, within 30 days, any relevant information,
including copies of records required by this Permit, which the Director may request to
determine whether cause exists for modifying, revoking and reissuing, or terminating
this Permit, or to determine compliance with this Permit.

I.N. INSPECTION AND ENTRY

I.N.1. Pursuant to the Utah Solid and Hazardous Waste Act, UCA §19-6-109, the Permittee
shall allow the Director, or an authorized representative, upon the presentation of
credentials and other documents, as may be required by law, to:

I.N.1.a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or
activity is located or conducted, or where records shall be kept as required by the
conditions of this Permit;

I.N.1.b. Have access to and copy, at reasonable times, any records, data and reports required
under the conditions of this Permit;

I.N.1.c. Inspect at reasonable times any facilities, equipment, including monitoring and control
equipment, practices, or operations regulated or required under this Permit;

I.N.1.d. Sample or monitor, at reasonable times, for the purposes of assuring permit compliance
or as otherwise authorized by U.C.A. Section 19-6-109, any substances or parameters at
any location; and

I.N.1.e. Make records of inspections by photographic, electronic, videotape, or any other
reasonable medium. No audio recording devices shall be used without notice to all
individuals in recording range prior to activation of the recording device. Photographic
and video recording shall comply with the safety and security requirements of the
Permittee.

Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
5

I.O. MONITORING AND RECORDS

I.O.1. The Permittee shall retain all data, records, and reports used to comply with the
conditions of this Permit. These include records of all monitoring information required
under this Permit, such as: all calibration and maintenance records; all original strip
chart recordings (or equivalent recordings) for continuous monitoring instrumentation
where applicable; the waste minimization certification required by R315-264-73; and all
data used to support human health and ecological risk assessments for cleanup and
closure activities.

I.O.2. The Permittee shall retain the records and material referenced in Condition I.O.1. at the
Facility for a period of at least three years from the date of the sample, measurement,
report, certification, or recording unless a longer retention period for certain information
is required by other conditions of this Permit. The three-year period may be extended
by the Director at any time by written notification to the Permittee. The retention times
are automatically extended during the course of any unresolved enforcement action
regarding the facility to three years beyond the conclusion of the enforcement action.

I.O.3. The Permittee shall comply with Condition I.O.2. by retaining original documents,
xerographic copies, document replicas, electronic facsimiles, electronic disk, CD-ROM
computer drive files, microfilm, microfiche, photograph, magnetic tape or any other
retrievable medium or similar recordkeeping technique. Any recordkeeping system
shall be capable of reproducing complete, accurate and legible records.

I.O.4. Pursuant to UAC R315-270-30(j)(3), records of monitoring information shall specify at
a minimum:

I.O.4.a. The date(s), exact place, and times of sampling or measurements;

I.O.4.b. The name(s), title(s), and affiliation of individual(s) who performed the sampling or
measurements;

I.O.4.c. The date(s) analyses were performed;

I.O.4.d. The name or initials of the individual(s) who performed the analyses;

I.O.4.e. The analytical techniques or methods used; and

I.O.4.f. The results of such analyses, including the QA/QC data.

I.O.5. This Permit contains and refers to documents and forms on which information and data
is recorded. The documents and forms as attached contain the minimum requirements
necessary to comply with this Permit. The Permittee may reformat documents and
forms or use alternative forms as necessary to carry out administrative duties only if the
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
6
minimum requirements established in the attached documents or forms are maintained.
Changes pertaining to a document or form that changes the required information shall
only be changed in accordance with the provisions of Condition I.D.4.

I.P. REPORTING PLANNED CHANGES

I.P.1. The Permittee shall give written notice to the Director 60 days prior to any planned
physical alterations or additions to any Hazardous Waste Management Unit (HWMU)
or system being permitted or previously permitted in accordance with
R315-270-30(l)(1)and R315-270-42.

I.Q. REPORTING ANTICIPATED NONCOMPLIANCE

I.Q.1. The Permittee shall give written notice to the Director 30 days prior to any planned
changes in the permitted Facility or activity which may result in noncompliance with
requirements of this Permit. Advance notice shall not constitute a defense for any
noncompliance.

I.R. CERTIFICATION OF CONSTRUCTION OR MODIFICATION

I.R.1. The Permittee shall not commence storage, treatment, or disposal of hazardous waste in
a new HWMU or in a modified portion of an existing permitted HWMU, except as
provided in R315-270-42, until:

I.R.1.a. The Permittee has submitted to the Director by certified mail, express mail or hand
delivery:

I.R.1.a.i. A letter signed by the Permittee and an independent, Utah registered professional
engineer, qualified by experience and education in the appropriate engineering field,
certifying that the unit has been constructed or modified in accordance with the design
specified in the approved modification request and this Permit;

I.R.1.a.ii. Certified as-built engineering drawings and specifications, where applicable, with any
deviations from the approved design noted on the drawing and a justification for each
design deviation; and

I.R.1.b. The Director or designated representative has reviewed and inspected the modified or
newly constructed unit and has notified the Permittee in writing that the unit was found
to be in compliance with the conditions of this Permit.

I.R.1.c. After review of the as-built drawings and field verification of the new or modified units,
the Director may notify the Permittee in writing of any change which is not in
accordance with the approved design or the Permit. The Director may require the
Permittee to remove and replace any construction not in accordance with designs and
specifications approved in this Permit.
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
7

I.R.2. If within fifteen calendar days of the date of receipt of the letter required by Permit
Condition I.R.1.a.i., the Permittee has not received notice from the Director, of the
Director’s intent to inspect, or a prior inspection is waived and the Permittee may
commence treatment, storage, or disposal of hazardous waste in the permitted unit(s), if
certified in accordance with Condition I.R.1.a.i.

I.S. TRANSFER OF PERMIT

I.S.1. This Permit may be transferred to a new owner or operator only if it is modified or
revoked and reissued pursuant to UAC R315-270-40. This Permit is not transferable to
any person except after written notice to the Director. The Director may require
modification or revocation and reissuance of the Permit to change the name of the
Permittee and incorporate such other requirements as may be necessary under Utah
Code, Sections 19-6-101 through 125. Prior to transferring ownership or operation of
the Facility during its operating life, the Permittee shall notify the new owner or
operator, in writing, of the applicable requirements of UAC R315-264, R315-270, and
this Permit. Failure by the Permittee to notify the new owner or operator of these
requirements and this Permit in no way relieves the new owner or operator of his
obligation to comply with all applicable requirements of the Rules and this Permit.

I.T. TWENTY-FOUR HOUR REPORTING

I.T.1. In accordance with R315-270-30(l)(6)(i), the Permittee shall orally report to the
Director any noncompliance with this Permit which may endanger human health or the
environment. Any such information shall be reported as soon as possible, but not later
than twenty-four hours from the time the Permittee becomes aware of the
noncompliance.

I.T.2. In accordance with UAC R315-263-30(b), the Permittee shall immediately report to the
Director any spill of any hazardous waste or material which, when spilled becomes a
hazardous waste, if the spilled quantity exceeds 100 kilograms or a lesser amount if
there is a potential for endangerment to human health or the environment, or exceeds
1 kilogram if the material is an acute hazardous waste as identified by R315-261-33(e).

I.T.3. The Permittee shall report to the Director any spill that contains 100 kilograms or more
of perchlorate. This report shall be made as soon as possible, but no later than 24 hours
after the spill occurred. The Permittee shall clean-up all spills that contain perchlorate.
Spills that cannot be cleaned up to meet the most current U.S. EPA Regional Screening
Level (RSL) for Residential Soil shall be reported as a new solid waste management
unit in accordance with Condition I.T.6.h.

Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
8

I.T.4. The non-compliance and spill reports shall include, but not be limited to, the following:

I.T.4.a. Information concerning the release of any hazardous waste which may endanger public
drinking water supplies; and

I.T.4.b. Any information of a release or discharge of hazardous waste, or of a fire, or explosion
at the Facility, which could threaten human health or the environment.

I.T.4.c. A description of the occurrence and its cause;

I.T.4.d. The name, title, and telephone number of the individual reporting;

I.T.4.e. The name, address, and telephone number of the owner or operator;

I.T.4.f. The name, address, and telephone number of the Facility;

I.T.4.g. The date, time, and type of the incident;

I.T.4.h. The location and cause of the incident;

I.T.4.i. The name and quantity of materials involved;

I.T.4.j. The extent of injuries, if any;

I.T.4.k. An assessment of actual or potential hazard to the environment and human health,
where this is applicable;

I.T.4.l. A description of any emergency action taken to minimize threat to human health and the
environment;

I.T.4.m. An estimated quantity and disposition of the recovered material that resulted from the
incident; and

I.T.4.n. Any other information necessary to fully evaluate the situation and to develop an
appropriate course of action.

I.T.5. Within 15 days of the initial spill report, specified in Conditions I.T.1. through I.T.4.,
the Permittee shall submit a written report to the Director.

I.T.6. The written report shall include, but not be limited to the following:

I.T.6.a. The name, title, address, and telephone number of the individual reporting;

I.T.6.b. A description including the date, time, location and nature of the reported incident;
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
9

I.T.6.c. The extent of injuries, if any;

I.T.6.d. The name and quantity of material(s) involved in the spill;

I.T.6.e. An estimated quantity and disposition of the recovered material;

I.T.6.f. An assessment of actual or potential hazards to human health and the environment,
where this is applicable. The report shall also include whether or not the results of the
incident remain a threat to human health and the environment (whether the
noncompliance has been corrected and the release has been adequately cleaned up);

I.T.6.g. If the release or noncompliance has not been adequately corrected or cleaned up, the
anticipated time that the noncompliance or remediation is expected to continue; the
steps taken or planned to reduce, eliminate, and prevent recurrence of the
noncompliance; and/or the steps taken or planned to adequately remediate the release;
and

I.T.6.h. If the spill cannot be cleaned up to meet the most current U.S. EPA RSL for Residential
Soil, the Permittee shall comply with the Notification and Assessment Requirements for
newly identified SWMUs outlined in Section VI.K. of NGSC’s Post-Closure Permit.

I.U. RESERVED

I.V COMPLIANCE SCHEDULES

I.V.1. Reports of compliance or noncompliance with, or any progress reports on, interim and
final requirements contained in any compliance schedule of this Permit shall be
submitted no later than 14 days following each scheduled date.

I.W. MANIFEST DISCREPANCY REPORT

I.W.1. Manifest discrepancies are defined as significant differences between the quantity or
type of hazardous waste designated on the manifest or shipping paper, and the quantity
and type of hazardous waste the permittee actually receives. Significant discrepancies
in quantity are: (1) for batch waste, any variation in piece count, such as a discrepancy
of one drum in a truckload, and (2) for bulk waste, variations greater than 10 percent in
weight. Significant discrepancies in type are obvious differences which can be
discovered by inspection or waste analysis, such as waste solvent substituted for waste
acid, or toxic constituents not reported on the manifest or shipping paper. If a
significant discrepancy is discovered in a manifest, the Permittee shall attempt to
reconcile the discrepancy. If not resolved within 15 days, the Permittee shall submit a
written report, including a copy of the manifest, describing the discrepancy and the
efforts to reconcile the discrepancy, to the Director in accordance with
UAC R315-264-72(c).
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
10

I.X. UNMANIFESTED WASTE REPORT

I.X.1. The Permittee shall submit to the Director an Unmanifested Waste Report within
15 days of receipt of unmanifested waste in accordance with UAC R315-264-76.

I.Y. BIENNIAL REPORT

I.Y.1. The Permittee shall submit to the Director a Biennial Report (EPA Form 8700-13 A/B)
covering Facility activities during odd numbered calendar years. This report shall be
submitted by March 1 of the following even numbered year in accordance with
UAC R315-264-75.

I.Z. OTHER NONCOMPLIANCE

I.Z.1. The Permittee shall submit a written report to the Director of all instances of
noncompliance with this Permit not otherwise required to be reported in accordance
with Condition I.T. This report shall be submitted within seven days of discovering the
noncompliance. The reports shall contain the information listed in Condition I.T. of this
Permit. Reporting shall not constitute a defense for any noncompliance.

I.AA. OTHER INFORMATION

I.AA.1. Whenever the Permittee becomes aware that it failed to submit any relevant facts in a
permit application or modification request, or submitted incorrect information in a
permit application or modification request, or in any report submitted to the Director,
the Permittee shall submit such facts or corrected information within seven working
days of discovery.

I.BB. SIGNATORY REQUIREMENT

I.BB.1. All reports, notifications, submissions or other information required by this Permit,
requested by or submitted to the Director, shall be signed and certified in accordance
with UAC R315-270-11.

I.CC. CONFIDENTIAL INFORMATION

I.CC.1. The Permittee may claim confidential any information required to be submitted by this
Permit in accordance with U.C.A. § 19-1-306, 63G-2-309, and UAC R315-270-12.

I.DD. REPORTS, NOTIFICATIONS, AND SUBMISSIONS

I.DD.1. All reports, notifications, or other submissions which are required by this Permit to be
transmitted to the Director should be sent by certified mail or other means of proof of
delivery to:
Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
11

Director, Division of Waste Management and Radiation Control
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
Phone [phone]

Normal business hours are 8 am to 5 pm, Monday through Friday, except Utah State
holidays. Required oral notifications shall be given only to the Director or an
authorized representative of the Director. Notifications made at other times shall be
made to the 24-hour answering service at [phone]. Notifications made to the
24-hour answering service shall include all applicable information required by this
Permit. The Permittee shall give oral notification to the Director or an authorized
representative of the Director on the first business day following notification to the
24-hour answering service.

I.EE. DOCUMENTS TO BE MAINTAINED AT THE FACILITY SITE

I.EE.1. The Permittee shall maintain at the Facility, for the periods specified, current copies of
the following documents and amendments, revisions and modifications to these
documents:

I.EE.1.a. A copy of the Permit until closure is certified in accordance with Condition II.O.;

I.EE.1.b. Waste Analysis Plans (Attachment 1), and all associated analytical data, as required by
UAC R315-270-14(b)(3) and this Permit until closure is certified in accordance with
Condition II.O.;

I.EE.1.c. Inspection schedules, logs (Attachment 2), and results, as required by this Permit for a
period of at least three years from the date of inspection in accordance with
UAC R315-264-15(d);

I.EE.1.d. Personnel training documents (Attachment 3), and records, as required by
UAC R315-264-16 and this Permit until closure for current employees, or for a period
of at least three years for former employees in accordance with UAC R315-264-16(e);

I.EE.1.e. Contingency Plan (Attachment 4), as required by UAC R315-264-53 and this Permit
until closure is certified in accordance with Condition II.O;

I.EE.1.f. Operating record, as required by UAC R315-264-73, and this Permit until closure is
certified in accordance with Condition II.O;

I.EE.1.g. Closure Plans (Attachment 5), as required by UAC R315-264-112 and this Permit, until
closure is certified in accordance with Condition II.O;

Northrop Grumman Systems Corporation – Promontory March 2024
Module I – Standard Permit Conditions UTD009081357
12
I.EE.1.h. Current cost estimates (Attachment 5) for the closure and post-closure of the HWMUs
covered by this Permit, in accordance with UAC R315-264-142 and Condition II.P. of
this Permit;

I.EE.1.i. Manifest copies, as required by UAC R315-262-40(a), UAC R315-264-71(a)(2)(vi),
and this Permit for at least three years from the date the waste shipment was accepted at
or shipped from the facility to an approved hazardous waste management facility; and

I.EE.1.j. A copy of the Permittee's waste minimization statement as required by
UAC R315-264-73(b)(9) until closure is certified in accordance with Condition II.O.

I.FF. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

I.FF.1. Pursuant to Section 3005(C)(3) of RCRA (Section 212 of HSWA) and
UAC R315-270-32(b)(2), this Permit contains those terms and conditions determined
necessary to protect human health and the environment.
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
1
MODULE II - GENERAL FACILITY CONDITIONS

II.A. APPLICABILITY

II.A.1. The requirements of this Permit module pertain to all Hazardous Waste Management
Units (HWMUs) identified within this Permit.

II.B. DESIGN AND OPERATION OF FACILITY

II.B.1. The Permittee shall design, construct, maintain and operate all of the HWMUs and
surrounding areas to minimize the possibility of a fire, explosion, or any sudden or
non-sudden release of hazardous waste or hazardous waste constituents to the air, soil,
groundwater or surface water which could threaten human health or the environment.
II.B.1.a. Should a fire, explosion or release of hazardous waste constituents occur, the Permittee shall: II.B.1.a.i. comply with Condition II.L. and the Contingency Plan; II.B.1.a.ii. notify the Director in accordance with Condition I.T.; II.B.1.a.iii. take all reasonable steps to minimize the release as required by Condition I.K.1.; II.B.1.a.iv. take reasonable measures to prevent significant adverse impacts on human health and the environment in accordance with Condition I.K.1.; and II.B.1.a.v. submit a written report to the Director in accordance with Condition I.T.5. or I.Z. II.B.1.b. The Director may consider appropriate enforcement action, to include the cessation of any and all hazardous waste management activities, until the Director has determined that the Permittee has adequately addressed the fire, explosion, or release of hazardous waste constituents and implemented appropriate corrective measures. II.B.2. Any request for modifications to the design, construction, maintenance or operation of existing HWMUs or proposals for new HWMUs shall be in accordance with Condition I.D.4. and Utah Administrative Code (UAC) R315-270-42. Modifications of a HWMU shall satisfy applicable requirements specified in this Permit and the Utah Solid and Hazardous Waste Rules. II.B.3. As specified in Condition I.R.c., after review of the as-built drawings and field verification of the new or modified HWMUs, the Director will notify the Permittee in writing of any change which is not in accordance with the approved design or this Permit. The Director may require the Permittee to remove, replace or modify any construction inconsistent with this Permit. II.B.3.a. If within 15 calendar days of the date of the Director’s receipt of the registered professional engineer’s certification required in Conditions I.R.a.i. and II.B.2, the Permittee has not received notice of the Director’s intent to inspect, or a prior inspection is waived, the Permittee may commence treatment, storage, or disposal of hazardous waste in the permitted unit(s).
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
2
II.C. REQUIRED NOTICE

II.C.1. As required by UAC R315-264-12(a)(1), the Permittee shall notify the Director in
writing at least four weeks in advance of the date the Permittee expects to receive
hazardous waste from a foreign source. Notice of subsequent shipments of the same
waste from the same foreign source in the same calendar year is not required.

II.C.2. When the Permittee arranges to receive hazardous waste from an off-site source (except
where the Permittee is also the generator), prior to any waste shipment, the Permittee
shall inform the generator in writing that it has the appropriate permit(s) for, and may
accept, the waste the generator is shipping. The Permittee shall keep a copy of this
written notice as part of the operating record as required by UAC R315-264-12(b).

II.D. WASTE ANALYSIS PLAN II.D.1. The Permittee shall comply with all permit conditions involving waste analysis and the procedures of the Waste Analysis Plan included as Attachment 1. II.D.2. The Permittee shall use the test methods described in the Waste Analysis Plan (Attachment 1) or an equivalent procedure that satisfies Condition II.D.4. Changes in test methods described in the Waste Analysis Plan, as a result of an improvement or refinement by the U.S. EPA or the State of Utah may be implemented without modification of the Permit. II.D.3. The Permittee shall characterize, using analytical techniques if necessary, all waste streams generated on or off-site in accordance with UAC R315-264-13 and Attachment 1. The waste characterization profiles shall be kept in the operating record.
II.D.4. The method used to obtain a representative sample of the waste to be analyzed shall be
the appropriate method from UAC R315-261-1090 or as specified or modified by this
Permit. Laboratory methods shall be those specified in “Test Methods for Evaluating
Solid Waste; Physical/Chemical Methods SW-846 (Third Edition, November 1986)” or
most currently promulgated edition, “Standard Methods for Examination of Water and
Wastewater (17th Edition, 1989)” or most currently promulgated edition; or an
equivalent method as approved by the Director. The analysis of all samples shall be
conducted by laboratories certified by the State of Utah.

II.D.5. When requesting substitute or additional analytical methods, the Permittee shall submit to the Director for written approval a request for substitution of analytical methods which are equivalent to the methods specifically approved for use in this permit. The request shall provide information demonstrating that the proposed methods are equivalent or superior in terms of sensitivity, accuracy, and precision (i.e. reproducibility). II.D.6. The Permittee shall conduct an annual evaluation of each waste stream, as outlined in the waste analysis plan, to verify that the waste characterization is still accurate. These evaluations shall be kept in the operating record until the next annual evaluations are completed. In accordance with the Waste Analysis Plan, the Permittee shall also characterize each new or modified waste stream or each time the process generating the
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
3
waste changes.

II.D.7. Any waste analysis used to evaluate off-site waste for acceptance by the Permittee shall
be conducted using a laboratory that has been certified by the State of Utah. Provisional
certification is not acceptable as certification under this condition.

II.D.8. At a minimum, the Permittee shall:

II.D.8.a. Maintain properly functioning sampling and analytical equipment;

II.D.8.b. Use approved sampling and analytical methods; and

II.D.8.c. Submit an updated list of parameters, analytical methods, and sample preparation
methods on an annual basis. The updated list shall be submitted to the Director on or before January 15th of each calendar year. II.D.9. Whenever the Director determines that the Permittee needs to update the analytical methodologies or the version(s) of SW-846 that are being used by the Permittee’s analytical laboratory, the Director will submit written notification to the Permittee. The Permittee shall obtain documentation that its laboratory is certified by the State of Utah for each analytical method. The Permittee shall have 180 days from the receipt of the Director’s written notification to complete the requested update. If it is not possible to complete the update within the prescribed time, the Permittee shall submit a written request for extension to the Director for approval or use a contract laboratory to perform the analysis. II.D.10. If the Permittee uses a contract laboratory to perform analyses, the laboratory must be certified by the State of Utah to perform the contracted analyses. For parameters for which State of Utah certification is unavailable, the Permittee shall ensure that quality control/quality assurance data provided by the laboratory is sufficient to assess the validity of the data. The Permittee shall inform the laboratory in writing that it must operate under the Waste Analysis Plan conditions set forth in this Permit. II.E SECURITY II.E.1. The Permittee shall comply with the security conditions and procedures contained in Attachment 7 of this Permit. II.F. GENERAL INSPECTION REQUIREMENTS II.F.1. The Permittee shall conduct inspections in accordance with UAC R315-264-15 and shall follow the inspection schedule found in Attachment 2. II.F.2. The Permittee shall remedy any deterioration or malfunction of equipment or structures as required by UAC R315-264-15(c). If the remedy requires more than 72 hours to implement from the time that the problem is detected, the Permittee shall submit to the Director, before the expiration of the 72 hour period, a written report that shall include a proposed time schedule for correcting the problem. II.F.3. Any problem which could endanger human health or the environment shall be corrected as soon as possible after the problem is discovered. The Permittee shall make every
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
4
effort to eliminate the threat to human health or the environment within 24 hours.

II.F.4. If, upon determination by the Director or the Permittee, continued operation of the
waste management unit involved in the inspection could endanger human health or the
environment, the Permittee shall immediately cease operation of the unit until the
problem has been corrected. The Permittee shall be allowed to undertake those
operations which are part of corrective activities.

II.F.5. Records of inspections shall be kept as required by R315-264-15(d).

II.G. RISK THRESHOLDS

II.G.1. The thermal treatment operations at the M-136 and M-225 Thermal Treatment Areas shall be
conducted to minimize the risk to human health and the environment. The risk to human health
was evaluated, in accordance with UAC R315-101 and is based on the risk thresholds identified
in Condition IV.C.11. The operating conditions identified in Module IV for the treatment areas
shall be based on the information provided or referenced in Attachments to this Permit and the
following site specific documents available for review in the Utah Department of
Environmental Quality, Division of Waste Management and Radiation Control files:

II.G.1.a. Sampling Results for Emissions Characterization of Open Burning Waste Propellant Materials,
October 2009;

II.G.1.b. ATK Launch Systems Waste Characterization and Air Dispersion Modeling Protocol for use in
the Human Health and Ecological Risk Assessments, April 2011, Tetra Tech; ADDENDUM
Air Dispersion Modeling Protocol for Open Burning and Open Detonation at ATK Launch
Systems in Promontory, Utah, February 2013, CBI;

II.G.1.c. Air Dispersion Modeling Report for Open Burning and Open Detonation at ATK Launch
Systems in Promontory, Utah, July 2014, CBI;

II.G.1.d. Human Health Risk Assessment Protocol for Evaluation of the Open Burning and Open
Detonation Units, ATK Launch Systems Promontory, Utah, August 2014, Terra Mentis;

II.G.1.e. Open Burn Open Detonation Human Health Risk Assessment, ATK Launch Systems
Promontory, Utah, June 2016, Geosyntec;

II.G.1.f Ecological Risk Assessment Waiver Thermal Treatment Operations UTD009081357,
August 29, 2017, Utah Division of Waste Management and Radiation Control;

II.G.1.g. Thermal Treatment Units M-136 and M-225 Groundwater Monitoring Plan, ATK Launch
Systems Promontory Facility, April 2018, ATK Launch Systems Inc.; and

II.G.1.h. Soil Monitoring Plan, Promontory Hazardous Waste Storage and Subpart X Treatment Permit,
April 2018, Orbital ATK Launch Systems Inc.

II.G.2. Reserved

Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
5
II.G.3. The Permittee shall submit to the Director for review by March 1st of each calendar year, an
annual report on the operation of the Promontory Thermal Treatment areas. This report shall at
a minimum include the following:

II.G.3.a. An accounting of the quantities and types of reactive hazardous waste treated at the M-136 and
M-225 thermal treatment areas, including all donor material and ignition compounds;

II.G.3.b. An accounting of the total quantity of Propellant, Explosives and Pyrotechnics (PEP) and
Contaminated Waste treated at the M-136 and M-225 thermal treatment areas for the annual
reporting period;

II.G.3.c. An accounting of the total quantity and types of reactive metal powders treated at the M-136
and M-225 thermal treatment areas for the annual reporting period;

II.G.3.d. An accounting of the types and quantities of flare molds treated at the M-136 and M-225
thermal treatment areas for the annual reporting period and a summary on the status of waste
minimization projects for treatment of flare molds at the thermal treatment areas;

II.G.3.e. A list and description of any new waste profiles that have been generated for new energetic
materials that have been treated at the Promontory Thermal Treatment Areas;

II.G.3.f. The semiannual annual analytical results for the burn ground ash as required by Section 11.8.2.5
of Attachment 11;

II.G.3.g. An evaluation of the emission factors used in the human health risk assessment, identified in
Condition II.G.1.e., to determine whether these factors are representative of the wastes treated
and identified in the annual report, as directed by II.G.3., or if the emission factors need to be
updated;

II.G.3.h. A review of the human health risk assessment, identified in Condition II.G.1.e., to evaluate
changes to dose-response factors for the three classes of detected COPCs: chromium (total and
hexavalent), 2,3,7,8-TCDD TEQ, and detected potentially carcinogenic PAHs
(benzo(a)anthracene, benzo(k)fluoranthene, chrysene and indeno(1,2,3-cd)pyrene); and

II.G.3.i. A review of the potential human health risk scenarios that were evaluated in the risk assessment
to ensure that these scenarios have not changed.

II.G.4. If the Director determines after reviewing this annual report that any component of the risk
assessment needs to be updated, he will inform the Permittee in writing which components of
the human health risk assessment to update.

II.G.5. If the Permittee is required to update the human health risk assessment for the M-136 or M-225
Thermal Treatment areas, the Permit shall be modified in accordance with Condition I.D. of this
Permit.
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
6
II.H. PERSONNEL TRAINING

II.H.1. The Permittee shall conduct personnel training as specified in Attachment 3 and in
accordance with UAC R315-264-16. New personnel working with or around hazardous
waste shall complete the required personnel training within six months of their hire
date, assignment to the Facility or assignment to a new position at the Facility.
Personnel shall not work unsupervised in these positions until they have completed all
training requirements.

II.H.2. The Permittee shall provide annual training in the use of the Contingency Plan and
hazardous waste management procedures relevant to the positions in which they are
employed for all on-site employees.

II.H.3. The Permittee shall maintain training documents and records as specified in the Training Plan in Attachment 3 and as required by Condition I.O., UAC R315-264-16(d) and UAC R315-264-16(e). These records shall indicate the type and amount of training received. II.H.4. The Permittee shall maintain a current copy of Attachment 3 (Training Plan) at the Facility until the Facility is fully closed and closure is certified in accordance with Condition I.EE.1.d. and UAC R315-264-115. II.H.5. Employees working at the M-136 and M-225 Thermal Treatment Areas shall receive task-specific, on-the-job-training in addition to the training outlined in Attachment 3. This training shall be documented and maintained in the operating record as required in Condition II.H.3. II.I. GENERAL REQUIREMENTS FOR IGNITABLE, REACTIVE, OR INCOMPATIBLE WASTE II.I.l. The Permittee shall comply with the requirements of UAC R315-264-17. II.I.2. In addition to the requirements of UAC R315-264-17, the Permittee shall comply with the Conditions III.G and III.H pertaining to ignitable, reactive, or incompatible waste. II.J. RESERVED II.K. PREPAREDNESS AND PREVENTION II.K.1. The Permittee shall comply with the procedures in the Preparedness and Prevention Plan, Attachment 8. II.K.2. At a minimum, the Permittee shall provide and maintain in good operating condition at the Facility the equipment set forth in Attachment 8, as required by UAC R315-264-32. II.K.3. The Permittee shall test and maintain the equipment specified in Condition II.K.2 as required to ensure its proper operation in time of emergency. II.K.4. The Permittee shall maintain records of the preventative maintenance and repair activities specified in Condition II.K.3. and shall keep schedules, reflecting minimum and planned frequency for the performance of preventative maintenance activities in the
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
7
Operating Record at the Facility in accordance with Condition I.O.

II.K.5. The Permittee shall maintain access to the communications or alarm system as required
by UAC R315-264-34.

II.K.6. At a minimum, the Permittee shall maintain 30 inches of aisle space between containers
or pallets of containers at storage areas M-186 and E-501.

II.K.7. The Permittee shall attempt to make arrangements (Coordination Agreements) with
State and local authorities as required by UAC R315-264-37. Copies of the
Coordination Agreements shall be kept in the Operating Record. The attempts to make
such agreements, any refusals and all final agreements shall be documented in the
Operating Record.
II.L. CONTINGENCY PLAN II.L.l. The Permittee shall comply with Attachment 4, and the emergency procedures described by UAC R315-264-56 whenever there is a fire, explosion, or release of hazardous waste or hazardous constituents which threaten or could threaten human health or the environment. The Permittee shall comply with UAC R315-263-30 and Condition I.T. in reporting releases to the Director. II.L.2. The Permittee shall provide copies of the Contingency Plan to emergency agencies who may be called in an emergency, shall maintain a copy of the Plan at the facility, and shall provide a copy upon request in accordance with UAC R315-264-53. II.L.3. The Permittee shall review Attachment 4 (Contingency Plan), in accordance with UAC R315-264-54, when (a) the Permit is revised, (b) the Contingency Plan fails in an emergency, or (c) changes to the Facility materially increase the potential for fires, explosions or releases of hazardous constituents. The Permittee shall modify Attachment 4 in accordance with Condition I.D. and UAC R315-270-42, if necessary. II.L.4. A trained emergency coordinator shall be available at the Facility or on call at all times in case of an emergency, in accordance with UAC R315-264-55 and identified in Attachment 4. II.M. MANIFEST SYSTEM II.M.1. The Permittee shall comply with the manifest requirements of UAC R315-264-71, R315-264-72 and R315-264-76. The manifest tracking number shall be recorded in the Operating Record with each waste load that arrives or leaves the Permittee's facility. II.M.2. If the waste load is refused and returned to the generator, the Permittee shall document such actions in the Operating Record. II.M.3. The Permittee shall comply with UAC R315-262-217 and UAC R315-264-70 for the movement of each waste load off-site. The Permittee shall record the manifest number in the Operating Record with each waste load that leaves the Permittee’s Facility.
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
8
II.N. RECORDKEEPING AND REPORTING

II.N.1. The Permittee shall maintain an accurate written Operating Record at the facility in
accordance with UAC R315-264-73 and UAC R315-264 1103.

II.N.2. The Permittee shall, by March 1 of each year, submit to the Director a certification
pursuant to UAC R315-264-73(b)(9), signed in accordance with UAC R315-270-11 by
the owner or operator of the facility or an authorized representative, that the Permittee
has a program in place to reduce the volume and toxicity of hazardous waste that he
generates to the degree determined by the Permittee to be economically practicable; and
that the proposed method of treatment, storage, or disposal is the most practicable
method currently available to the Permittee which minimizes the present and future
threat to human health or the environment.
II.N.3. The Permittee shall comply with the biennial report requirements of UAC R315-264-75, by March 1 of each even-numbered reporting year. The report shall include wastes generated, treated or stored at the Permittee's facility during the previous odd-numbered year. II.N.4. The Permittee shall submit additional reports to the Director in accordance UAC R315-264-77. II.N.5. All reports, notifications, applications, or other materials required to be submitted to the Director shall be submitted in accordance with Condition I.DD. II.N.6. The Permittee shall maintain a copy of the certifications required in Conditions II.N. in the operating record and sign each certification in accordance with UAC R315-264-73(b)(9) and UAC R315-270-11(d)(1). II.O. CLOSURE/POST-CLOSURE II.O.l. The Permittee shall comply with UAC R315-264-110 through 120 as applicable and close the facility in accordance with the Closure Plan in Attachment 5 and Condition II.O.3. II.O.2. The Permittee shall notify the Director in writing of its intent to conduct partial or final closure of any portion of the facility in accordance with UAC R315-264-110. The Permittee shall notify the Director at least 60 days prior to the commencement of final or partial Facility closure. II.O.3. The Permittee shall review its closure plans for the HWMUs contained in Attachment 5 and submit updated closure plans for the closure or partial closure of each individual hazardous waste management unit to the Director for approval no less than 60 days prior to the commencement of closure activities. No closure activities shall take place that have not received prior approval from the Director. II.O.4. The Permittee shall amend the Closure Plan in Attachment 5, in accordance with UAC R315-124-5, UAC R315-270-42 and Condition I.D. whenever necessary, or when required to do so by the Director. II.O.5. After receiving the final volume of hazardous waste at the burn grounds or at a
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
9
hazardous waste storage facility, the Permittee shall treat or remove from the site all
hazardous waste and complete closure activities in accordance with the schedule
specified in Attachment 5 or the updated Closure Plan if the schedule was revised.

II.O.6. The Permittee shall decontaminate or dispose of all facility equipment, structures, soil
and rinsate off-site as required by UAC R315-264-114 and Attachment 5. Facility
equipment, structures and soil which have not been decontaminated shall be disposed of
only at a permitted hazardous waste Treatment, Storage or Disposal Facility (TSDF).

II.O.7. The Permittee shall certify that the facility has been closed in accordance with the
specifications in the Closure Plan and Attachment 5, as required by UAC
R315-264-115. The Permittee shall also provide a certification by an independent,
Utah registered professional engineer qualified by experience and education in the
appropriate engineering field that the Facility has been closed in accordance with the approved Closure Plan. II.O.8. For all HWMUs, the Permittee shall describe in narrative form with the closure certification statements all minor deviations from the approved closure plan procedures, submitted in accordance with Condition II.O.3, necessary to accommodate proper closure. The Permittee shall describe the rationale for implementing minor changes as part of this narrative report. Within 60 days after completion of closure of each HWMU, the Permittee shall submit the certification statements required by Condition II.O.7. and narrative reports to the Director. II.O.9. In the event that any of the hazardous waste management units covered by this Permit cannot be clean closed by decontaminating or removing contaminated structures or soil, or releases have occurred which have impacted soil or groundwater, the Permittee shall modify the Closure Plan for that hazardous waste management unit in accordance with Condition I.D. Within 30 days of the date that the Director approves the modification, the Permittee shall close the unit in accordance with the applicable provision of UAC R315-264-110 and UAC R315-101. II.O.10. If a HWMU cannot be clean closed, the Permittee shall submit a survey plat and property description for the HWMU with the submission of the certification of closure for the HWMU, in accordance with UAC R315-264-116 and UAC R315-101. II.P. COST ESTIMATES FOR HWMU CLOSURE II.P.1. The Permittee's closure cost estimate for each HWMU shall be prepared and maintained at the Facility in accordance with Attachment 5 and UAC R315-264-142. II.P.2. By July 30 of each calendar year, the Permittee shall adjust the closure cost estimate for inflation or submit the latest adjusted closure cost estimate for review and approval by the Director. After approval, the Permittee shall maintain the latest adjusted closure cost
estimate in the operating record. The closure cost estimates shall identify the costs, in current dollars, of the steps necessary to perform final closure for each HWMU in accordance with UAC R315-264-143 and UAC R315-264-142. II.P.3. On the five year anniversary date of the submittal of the closure cost estimates required by Condition II.P.2. above, the Permittee shall conduct a detailed evaluation of the
Northrop Grumman Systems Corporation – Promontory March 2024
Module II – General Facility Conditions UTD009081357
10
closure cost estimates for each HWMU and determine whether the annual adjustments
for inflation have been adequate to update the closure cost estimates. The Permittee
shall submit a report on this assessment and if necessary, a modification of the Permit in
accordance with Condition I.D. to the Director 90 days after the report is submitted.

II.P.4. The Permittee shall revise the closure cost estimate within 30 days after the Director has
approved the request to modify the affected closure plan(s).

II.P.5. For each new HWMU placed into operation, an updated closure cost estimate to the
facility must be prepared which includes the new unit, 60 days prior to waste being
placed on or into the new unit.

II.Q. FINANCIAL ASSURANCE FOR FACILITY CLOSURE

II.Q.1 The Permittee shall demonstrate continuous compliance with UAC R315-264-143 by
providing documentation of financial assurance, as required by UAC R315-264-143.
Changes in financial assurance mechanisms shall be approved by the Director before
the change is made effective.

II.Q.2. The Permittee shall revise the financial assurance for facility closure whenever there is
a change in the facility’s closure plan that would change the cost estimate as required by
UAC R315-264-143.
II.R. LIABILITY REQUIREMENTS II.R.1. The Permittee shall demonstrate continuous compliance with the liability requirements of UAC R315-264-147. The Permittee shall have and maintain hazardous waste liability coverage for sudden accidental occurrences in the amount of at least one $1 million U.S. dollars per occurrence with an annual aggregate of at least $2 million U.S. dollars, exclusive of legal defense costs. The Permittee shall submit an approved certificate of hazardous waste liability insurance worded as required by UAC R315-264-147. II.R.2. The Permittee shall demonstrate continuous compliance with the requirements of UAC R315-264-147 to have and maintain liability coverage for non-sudden accidental occurrences arising from operations of the two HWMUs, designated as the M-136 and
M-225 Thermal Treatment Areas. II.R.3. Changes in liability coverage mechanisms shall be approved in writing by the Director 60 before being made effective. II.S. INCAPACITY OF OWNER OR OPERATORS, GUARANTORS, OR FINANCIAL INSTITUTIONS II.S.1. The Permittee shall comply with UAC R315-264-148 including notifying the Director by certified mail within ten days after commencement of a voluntary or involuntary proceeding under Title 11 Bankruptcy, U.S. Code naming the Permittee or owner or operator of the Facility as the debtor.
Northrop Grumman Systems Corporation – Promontory March 2024
Module III – Storage in Containers UTD009081357

1
MODULE III – STORAGE IN CONTAINERS III.A. APPLICABILITY III.A.1. The requirements of this permit Module pertain to the operation of hazardous waste container storage areas at the facility. The Permittee shall comply with UAC R315-264-170 and all conditions of this Module. III.A.2. The designated hazardous waste storage areas are the bays of Buildings M-705S, E-501, M-629, M-186, the burn trays at M-136, Burn Station 14 at M-136, and Storage Pad S-633. Drawings of these storage areas are presented in Attachment 6. III.B. WASTE IDENTIFICATION III.B.1. The Permittee shall, subject to the terms of this Permit, store only the following hazardous wastes, as listed by U.S. EPA hazardous waste code, in containers at storage areas M-186, M-705S and E-501: D001, D002, D003, D004, D005, D006, D007, D008, D009, D010 D011, D016, D018, D019, D021, D022, D023, D024, D026, D027,D028, D029, D030, D035, D036, D038, D039, D040, D042, D043, F001, F002, F003, F004, F005, F006, F007, F008, F009, K044, K045, P003, P012, P022, P028, P029, P030, P042, P044, P047, P048, P056, P064, P067, P076, P077, P078, P087, P092, P093, P095, P098, P102, P104, P105, P106, P112, P116, P119, P205, U001, U002, U003, U004,U006, U008, U009, U011, U012, U019, U025, U028, U029, U031, U037, U041, U044, U048, U053, U056, U057, U069, U070, U072, U075, U077, U078, U079, U080, U085, U088, U092, U093, U095, U098, U101, U102, U103,U105, U106, U108, U112, U113, U115, U117, U118, U120, U121, U122, U123, U131, U133, U134, U138, U140, U147, U148, U149, U151, U154, U156, U159, U160, U161, U162, U165, U168, U169, U170, U171, U185, U186, U188, U189, U190, U196, U201, U209, U210, U211, U218, U219, U220, U221, U223, , U225, U226, U228, U238, U239, U240, U243, U244, U246, U247, U328, U353, U359, U404. III.B.2. The Permittee may store solid reactive or ignitable hazardous wastes, EPA hazardous waste codes D003 and D001, and hazardous waste codes D005, D007, D008, D030, D038, F001, F002, F003, F004, F005 and K044 in storage units S-633, M-629, and M-136 subject to the terms of this Permit. III.B.3. The Permittee may store solid reactive hazardous wastes in accordance with Condition III.B.2. in burn trays at M-136 prior to thermal treatment and subject to the terms of this Permit. Waste stored in burn trays shall be containerized only in covered drums, boxes, plastic bags, woven bags, US Department of Transportation (DOT) approved shipping containers or containerized as described in Attachment 11. Containers shall be labeled and managed as specified in Attachment 9. III.B.4. The Permittee may store waste rocket motors, with hazardous waste codes as identified in Condition III.B.2., that contain solid propellant, one at a time on the ground at
Northrop Grumman Systems Corporation – Promontory March 2024
Module III – Storage in Containers UTD009081357

2
M-136, Burn Station 14, prior to thermal treatment. Storage of waste rocket motors shall be conducted subject to the terms of this Permit and shall be labeled and managed as specified in Attachment 9. III.B.5. The Permittee may store solid reactive hazardous wastes, with hazardous waste codes as identified in Condition III.B.2., on Storage Pad S-633 subject to the terms of this Permit. III.B.6. The Permittee is prohibited from storing hazardous waste that is not identified in Section III.B. of this Module. Any addition of hazardous waste codes to Condition III.B.1. requires modification of the permit in accordance with Condition I.D.3. III.B.7. Except for the storage of waste rocket motors at M-136, Burn Station 14, the Permittee shall only use containers for the storage of reactive wastes that meet the DOD 4145.26-M requirements. III.C. CONDITION OF CONTAINERS III.C.1. If a container holding hazardous waste is not in good condition (e.g., severe rusting, bulging, apparent structural defects) or it has begun to leak, the Permittee shall transfer the hazardous waste from such a container, or the container of hazardous waste itself, to a UN approved container in accordance with Section 8-1-10 of Attachment 8. The transfer shall be completed as soon as possible but not later than 24 hours from the time the problem was first discovered. III.D. COMPATIBILITY OF WASTE WITH CONTAINERS III.D.1. The Permittee shall ensure that the waste is compatible with the containers as required by UAC R315-264-172. The Permittee shall follow the compatibility plan as indicated in Section 9-2.1 and Table 9-2 of Attachment 9. III.E. MANAGEMENT OF CONTAINERS III.E.1. The Permittee shall manage containers in accordance with this module of the Permit, UAC R315-264-173 and the procedures identified in Attachments 9 and 11. A container holding hazardous waste shall always be closed during storage except when the Permittee is adding or removing waste from the container. The Permittee shall not open, handle, or store containers in a manner which may cause the containers to leak. III.E.2. The Permittee shall store liquid hazardous wastes in containers only at storage areas M-186, E-501 and M-705S. Drawings of the container storage areas are shown in Attachment 6. The Permittee may store up to the following volumes of wastes: III.E.2.a. E-501 - 8,800 gallons and no more than 160 55-gallon containers or the equivalent; III.E.2.b. M-186 - 22,000 gallons and no more than 400 55-gallon containers or the equivalent; and III.E.2.c. M-705S - 1,760 gallons and no more than 32 55-gallon containers or the equivalent.
Northrop Grumman Systems Corporation – Promontory March 2024
Module III – Storage in Containers UTD009081357

3
III.E.3. The Permittee shall store solid reactive hazardous waste in containers at storage areas M-629, M-136 and S-633. Drawings of the storage areas are shown in Attachment 6. At capacity, the Permittee may store the following amounts of wastes: III.E.3.a. M-629 - 110,000 lbs. of 1.3 solid reactive waste or 55,000 lbs. of 1.1 solid reactive hazardous waste; III.E.3.b. M-136 – 125,000 lbs. of 1.3 solid reactive waste in Burn Station 14, or the calendar day amounts identified in Conditions IV.C.1.a.. through IV.C.1.f.. for the other Burn Stations at M-136, as described in Condition III.B.3. or III.B.4.; III.E.3.b.i. M-136 - 20,000 lbs. of 1.1 solid reactive hazardous waste, as described in Condition III.B.3. or III.B.4.; and III.E.3.c S-633 – 75,000 lbs. of 1.3 or 20,000 lbs. of 1.1 solid reactive hazardous waste. III.E.4. The Permittee shall maintain an aisle space of 30 inches minimum between containers or pallets of containers at storage areas M-186 and E-501. III.E.5. The Permittee shall store hazardous wastes at M-705S, M-629, S-633 and M-136 so that the labels on the containers or waste rocket motor are visible. III.E.6. The Permittee may stack 55-gallon drums at a maximum of two high at storage areas M-186 and E-501. III.E.7. Hazardous waste containers shall not be stacked at storage areas M-705S, M-629, S-633 and M-136 except as described in Attachment 9-2.3. III.E.8. The Permittee shall unload any transport vehicle hauling containers of hazardous waste for storage within 10 days following arrival at the site. Arrival for purposes of this permit shall be the day the vehicle arrives at the facility. III.E.9. The Permittee shall provide storage for and maintain on-site, an 85 gallon over-pack drum at areas where liquid hazardous waste is stored. III.F. CONTAINMENT SYSTEMS III.F.1. The Permittee shall maintain the containment systems in accordance with the attached plans and specifications contained in Attachment 9 and as specified in UAC R315-264-175. III.F.2. The Permittee shall inspect the container management areas for the presence of free liquids in accordance with Attachment 2. If free liquids are discovered in the sumps or other containment areas, the Permittee shall identify the location in the inspection log. Any liquids discovered shall be removed immediately, but in no case later than 24 hours after the liquid is discovered and managed according to the spill contingency plan specified in Section 9-4.3 of Attachment 9. III.F.3. For purposes of inspections, all containers stored in the liquid hazardous waste storage area shall be considered full to their respective capacities with liquid hazardous waste.
Northrop Grumman Systems Corporation – Promontory March 2024
Module III – Storage in Containers UTD009081357

4
Gondolas/roll-offs that are used only for the storage of solid hazardous waste need not be considered in the calculations for containment. The area for storing solid waste shall be identified.

III.F.4. Some of the containers stored at M-136 contain small amounts of desensitizing fluid
(e.g. diesel, shingle oil, etc.). The containment requirements, as specified in
Attachment 9, apply to the storage of wastes in the burn trays. Inspection of the burn
trays shall be conducted in accordance with Attachment 2.
III.G. SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTE III.G.1. The Permittee shall not locate containers holding ignitable or reactive waste within 15 meters (50 feet) of the facility boundary in accordance with UAC R315-264-176, unless a written approval is obtained from the authority having jurisdiction over the local fire code, as allowed under UAC R315-262-17. III.G.2. If written approval is obtained to allow containers holding ignitable or reactive waste to be located within 50 feet of the facility boundary, in accordance with UAC R315-264-176, the Permittee shall document it in the operating record and notify the Director. III.G.3. The Permittee shall take precautions to prevent accidental ignition or reaction of ignitable or reactive waste and follow the procedures specified in Attachment 8, UAC R315-264-17. III.H. SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTE III.H.1. The Permittee shall not place incompatible wastes, or incompatible wastes and materials, in the same container, in accordance with UAC R315-264-177(a). III.H.2. The Permittee shall not place hazardous waste or materials in an unwashed container that previously held an incompatible waste or material in accordance with UAC R315-264-177(b). III.H.3. A storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby shall be separated from the other materials or protected from them by means of a dike, berm, wall, or other device. III.I. IDENTIFICATION AND LOCATION OF CONTAINERS IN OPERATING RECORD III.I.1. The Permittee shall record in the Operating Record the date and location of each container of hazardous waste accepted in any Permitted container storage area and the date the container is transferred or treated from the storage area for treatment or disposal. III.J. INSPECTION SCHEDULES AND PROCEDURES III.J.1. The Permittee shall inspect the hazardous waste storage and treatment facilities identified in Condition III.B. of this Permit as specified in the Inspection Schedules
Northrop Grumman Systems Corporation – Promontory March 2024
Module III – Storage in Containers UTD009081357

5
contained in Attachment 2. The purpose of these inspections shall be to detect leaking containers, standing liquids, deterioration of containers, and to detect deterioration of, or liquids in, the secondary containment system caused by corrosion and other factors as specified in UAC R315-264-174. III.J.2. If problems are observed during the inspections, the Permittee shall correct the problem in accordance with Module II, Section F. III.K. CLOSURE/POST-CLOSURE III.K.1. The Permittee shall close the permitted hazardous waste storage areas in accordance with UAC R315-264-110, R315-264-178, Condition II.O. and Attachment 5 of this Permit.
Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 1

MODULE IV – THERMAL TREATMENT OF ENERGETIC WASTES

IV.A. APPLICABILITY

IV.A.1. The requirements of this permit module apply to the thermal treatment of energetic or
reactive hazardous waste at the Northrop Grumman Systems Corporation (NGSC) –
Promontory facility, Box Elder County, Utah. The Permittee shall comply with Utah
Administrative Code (UAC) R315-264 and all conditions of this module and Permit.

IV.A.2. The Permit conditions of this module allow thermal treatment at the two Hazardous Waste
Management Units, designated as the M-136 and M-225 Thermal Treatment Areas, as
designed and described in the drawings and specifications in Attachments 6 and 11. The
M-136 Thermal Treatment Area consists of 14 burn stations and 2 open detonation areas.
The M-225 Thermal Treatment Area consists of 4 burn stations and 1 open detonation area.

IV.A.3. Thermal treatment at both of the Promontory Thermal Treatment Areas shall only be
accomplished by properly trained NGSC personnel in accordance with the conditions of
this Permit and its Attachments.

IV.A.4. This Permit has been developed in accordance with the applicable requirements of Title
R315 of the Utah Administrative Code. All conditions in this Permit shall supersede
conflicting statements, requirements, or procedures found in Title R315 of the Utah
Administrative Code or the Attachments to this Permit.

IV.B. PERMITTED AND PROHIBITED WASTE IDENTIFICATION

IV.B.1. The Permittee may treat energetic or reactive hazardous waste by open burning at the
M-136 and M-225 Thermal Treatment Areas; open detonation at M-136, stations 13 and 14
and open detonation at M-225, station 1. These energetic and reactive hazardous wastes
are generated from the following sources:

IV.B.1.a. Class 1.1 and 1.3 propellants and explosives manufactured by or owned by Promontory,
Bacchus, other NGSC facilities , DOD, NASA or other U.S. Government and private
facilities (e.g. cured and uncured propellants, excess propellants and propellant scraps);

IV.B.1.b. Production materials contaminated with class 1.1 and 1.3 propellants and explosives and
reactive residues (e.g., rags, gloves, other personal protective equipment, plastics, rubber
and paper that were contaminated with explosive materials during the manufacturing
process);

IV.B.1.c. Large and small class 1.1 and 1.3 rocket motors and initiating devices;

IV.B.1.d. Class 1.3 Pyrotechnic, Illuminants, Metal Powders;

IV.B.1.e. Production materials contaminated with class 1.3 Pyrotechnic, Illuminants, Metal Powders,
and other reactive residues (e.g., rags, gloves, other personal protective equipment, plastics,
rubber and paper that were contaminated with explosive materials during the manufacturing
process);

IV.B.1.f. Reactive laboratory wastes which may contain solvents;

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 2

IV.B.1.g. Wastewater treatment sludge generated from the processing of explosive ingredients and
propellants defined in UAC R315-261-32 as a K044 listed hazardous waste;

IV.B.1.h. Reactive bag house dust generated from the processing of explosive ingredients and
propellants; and

IV.B.1.i. Waste developmental propellants, explosives and associated contaminated production
materials.

IV.B.2. Only reactive hazardous waste as defined by UAC R315-261 may be treated at the
Promontory Thermal Treatment Areas. Reactive hazardous waste thermally treated at the
Promontory Thermal Treatment Areas may contain the follow EPA waste codes: D001,
D003, D005, D007, D008, D030, D038, F001, F002, F003, F004, F005 and K044.

IV.B.3. The Permittee is prohibited from thermally treating reactive hazardous waste classes and
compositions not included in Conditions IV.B.1. and IV.B.2. including wholly inert items,
improvised explosive devices (e.g. homemade bombs) and chemical wastes.

IV.B.4. The Permittee is prohibited from thermally treating any reactive hazardous waste that does
not have a designated waste profile.

IV.B.5. The Permittee is prohibited from thermally treating decoy flare molds with less than 4%
propellant contamination.

IV.B.6. The addition of hazardous waste codes to Condition IV.B.2. requires modification of the
permit as specified in UAC R315-124-5 and Condition I.D.

IV.B.7 The Permittee shall comply with the waste compatibility requirements of Condition II.I.

IV.C. GENERAL OPERATING CONDITIONS

IV.C.1. Based on the results of the Human Health Risk Assessment (HHRA), identified in
Condition II.G.1.e., the Permittee shall comply with the following treatment limits for the
M-136 Thermal Treatment Area:

IV.C.1.a. The Permittee shall not treat, by open burning (OB), in the M-136 Thermal Treatment Area
more than a total combined amount of 122,000 pounds of reactive hazardous waste in a
calendar day, under treatment scenario M-136-A as outlined in Table 1 of Attachment 11;

IV.C.1.b. The Permittee shall not treat by OB in the M-136 Thermal Treatment Area more than
96,000 pounds total of reactive hazardous waste in a calendar day at any six burn stations
of burn stations 1 through 12, at 16,000 pounds in each station, under treatment scenario
M-136-A as outlined in Table 1 of Attachment 11;

IV.C.1.c. The Permittee shall not treat by OB in the M-136 Thermal Treatment Area more than
10,000 pounds total of reactive hazardous waste in a calendar day at burn station 13 under
treatment scenario M-136-A as outlined in Table 1 of Attachment 11;

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 3

IV.C.1.d. The Permittee shall not treat by OB in the M-136 Thermal Treatment Area more than
16,000 pounds total of reactive hazardous waste in a calendar day, at burn station 14 under
treatment scenario M-136-A as outlined in Table 1 of Attachment 11;

IV.C.1.e. The Permittee shall not treat by OB in the M-136 Thermal Treatment Area more than
125,000 pounds total of reactive hazardous waste in a calendar day at burn station 14 under
treatment scenario M-136-B as outlined in Table 1 of Attachment 11; and

IV.C.1.f. The Permittee shall not treat by open detonation (OD) in the M-136 Thermal Treatment
Area more than 600 pounds total of reactive hazardous waste in a calendar day at each burn
station, 13 and 14 as outlined in Table 1 of Attachment 11.

IV.C.2. In any one calendar day, the Permittee shall not operate more than one treatment scenario,
M-136-A, M-136-B, or M-136-C, in the M-136 Thermal Treatment Area.

IV.C.3. When operating the M-136 Thermal Treatment Area, the Permittee shall maintain the
minimum safe “quantity-distance” spaces as specified in Attachment 11, Section 5.

IV.C.4. The Permittee shall not treat more than 10,000,000 pounds of reactive hazardous waste at
the M-136 Thermal Treatment Area in a calendar year. This 10,000,000 pound limit shall
be established by adding the Net Explosive Weight (NEW) and all donor and initiator
materials. Donor material shall include all pallets, cardboard, packaging material,
absorbents and diesel fuel.

IV.C.5. Based on the results of the HHRA, identified in Condition II.G.1.e., the Permittee shall
comply with the following treatment limits for the M-225 Thermal Treatment Area:

IV.C.5.a. The Permittee shall not treat, by OB, in the M-225 Thermal Treatment Area more than
4,500 pounds of reactive hazardous waste per calendar day under treatment scenario M-
225-A as outlined in Table 1 of Attachment 11;

IV.C.5.b. The Permittee shall not treat by OB in the M-225 Thermal Treatment Area more than 4,500
pounds total of reactive hazardous waste in a calendar day at burn stations 1 through 4, at
1,125 pounds in each station under treatment scenario M-225-A as outlined in Table 1 of
Attachment 11; and

IV.C.5.c. The Permittee shall not treat, by OD, in the M-225 Thermal Treatment Area more than 600
pounds of reactive hazardous waste in a calendar day under treatment scenario M-225-B as
outlined in Table 1 of Attachment 11.

IV.C.6. The Permittee shall not operate more than one treatment scenario, M-225-A, or M-225-B in
a calendar day.

IV.C.7. When operating the M-225 Thermal Treatment Area, the Permittee shall maintain the
minimum safe “quantity-distance” spaces as specified in Attachment 11, Section 5.

IV.C.8. The Permittee shall not treat more than 55,000 pounds, by open burning, and 10,000
pounds, by OD, of reactive hazardous waste at the M-225 Thermal Treatment Area in a
calendar year. This limit shall be established by adding the NEW and all donor and
initiator materials. Donor material shall include all pallets, cardboard, packaging material,
absorbents and diesel fuel.
Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 4

IV.C.9. The Permittee shall maintain the integrity of the Promontory Thermal Treatment Areas to
ensure that they meet the performance standards of UAC R315-264-601 and minimize the
potential impacts to human health and the environment. The Permittee shall adhere to
applicable provisions of Attachments 2 and 11 and the following conditions:

IV.C.9.a. The Permittee shall conduct all OB operations within the secure areas designated as the M-
136 or M-225 Thermal Treatment Areas with controlled access as identified in Attachment
11;

IV.C.9.b. The Permittee shall post warning signs around both of the Thermal Treatment Areas to
keep unauthorized personnel out;

IV.C.9.c. The Permittee shall maintain the egress paths for both of the Thermal Treatment Areas
identified in Attachment 4;

IV.C.9.d. The Permittee shall disable the firing system whenever operators are in the Quantity
Distance restricted area (QD) as defined in Section 11.5 of Attachment 11, for this
treatment unit. The firing system shall only be active or armed when operators are
conducting a pre-burn continuity check, as specified in Attachment 11, Section 8.2.3, or
when the firing system is being maintained and no waste is present in the treatment area, or
after all operators have exited the treatment unit and retreated to the firing control room in
preparation of initiating an ignition as specified in Condition IV.F.2.e;

IV.C.9.e. The Permittee shall assess and monitor meteorological conditions to ensure operators are
not exposed to risks from lightning strikes or other adverse weather conditions that would
preclude the safe operation of the M-136 or M-225 Thermal Treatment Areas. The
Permittee shall record the temperature, wind speed, wind direction, sky conditions and
clearing index prior to each burn in the Facility operating record;

IV.C.9.f. The Permittee shall comply with all requirements for pre-placement of waste, placement of
waste in treatment units, wiring and ignition and the post-burn inspection and clean-up
activities identified in Conditions IV.D, E, F, G, H and I;

IV.C.9.g. The Permittee shall provide operators with access to a functional radio or telephone that
can be used to contact support personnel, including security, safety and fire-fighting units,
whenever the operators are inside the M-136 or M-225 Thermal Treatment Areas;

IV.C.9.h. The Permittee shall maintain the integrity of the two Promontory Thermal Treatment Areas
and support equipment through regular inspections and in accordance with the inspection
plan in Attachment 2. Inspection records shall be maintained at the facility;

IV.C.9.i. The Permittee shall train all operators of the Promontory Thermal Treatment Areas in
accordance with Condition II.H. and Attachement 3 of this Permit;

IV.C.9.j. The Permittee shall not operate either of the Promontory Thermal Treatment Areas without
containment measures (e.g. firebreaks) to ensure the confinement and control of any fire
resulting from the open burn and open detonation operations at the Promontory Thermal
Treatment Areas; and
IV.C.9.k. The Permittee shall not treat propulsive items at the Promontory Thermal Treatment Areas,
unless the item has been rendered non-propulsive or is contained in accordance with
Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 5

Attachment 11.

IV.C.10. The Permittee shall operate the Promontory Thermal Treatment Areas to prevent
unacceptable risk of cancer and non-cancer effects to on-site workers and off-site residents
and to minimize significant effects to the ecosystem surrounding the Promontory Thermal
Treatment Areas. The Permittee shall maintain compliance with the environmental
performance standards listed in UAC R315-264-601.

IV.C.11. The Permittee shall adhere to the following conditions to prevent unacceptable risk of
cancer and non-cancer effects due to exposure to emissions from the open burning
operations:

IV.C.11.a. The excess cumulative carcinogenic risk to on-site workers shall not exceed 1.0x10-4
(one in ten thousand) or a Hazard Index of 1.0 for the potential workers positioned at the
point of on-site maximum exposure, as calculated according to the methodology in the
approved HHRA. The maximum amount treated at the burning grounds shall not exceed
the treatment scenarios outlined in Table 1, Attachment 11; and

IV.C.11.b. The excess cumulative carcinogenic risk to actual or potential off-site receptors shall not
exceed 1.0x10-6 (one in a million). The cumulative non-carcinogenic hazard to actual or
potential off-site receptors shall not exceed a hazard index of 1.0 for any 24-hour period
following initiation of a burn or detonation, as calculated according to the methodology in
the approved HHRA. The maximum amount treated at the burning grounds shall not
exceed the annual maximum quantities outlined in Table 1, Attachment 11.

IV.C.12. Based on the air dispersion and deposition modeling and the HHRA, identified in Section
II.G., the Permittee shall adhere to the following conditions:

IV.C.12.a. The Permittee shall notify the Box Elder County Dispatch prior to each treatment operation
involving reactive material and record the clearing index that shall be obtained from the
National Weather Service in the Operating Record;

IV.C.12.b. The Permittee may OB and OD only between the hours of 9:00 am Mountain Time (MT)
and 6:00 pm MT;

IV.C.12.c. The Permittee shall only OB when the surface wind speed is greater than 3 miles per hour
(mph) and less than 15 mph unless Permit Condition IV.C.13.a. applies; and

IV.C.12.d. The Permittee may conduct burns and open detonations only when the Clearing Index (CI)
is greater than 500 unless Permit condition IV.C.13. applies.

IV.C.13. The Permittee may treat Class 1.1, Class 1.3 and Class 1.3 flare wastes that are
time-sensitive reactive wastes, as defined by I.A.17., by open burning at M-136, Station 13,
when the Clearing Index is less than 500 in accordance with the following scenarios:

IV.C.13.a. Scenario 1: 1,000 pounds or less with a maximum wind speed of 15 mph;

IV.C.13.b. Scenario 2: 1,500 pounds or less with a maximum wind speed of 15 mph and a minimum
wind speed of 3 mph.

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 6

IV.D. WASTE TRACKING

IV.D.1. The Permittee shall track all reactive hazardous waste in accordance with Attachment 11
and maintain this information in the operating record for both of the Promontory Thermal
Treatment Areas.

IV.E. PRE-BURN ACTIVITIES

IV.E.1. Prior to bringing any reactive hazardous waste into either of the Promontory Thermal
Treatment Areas, M-136 or M-225, for thermal treatment, the Permittee shall conduct
pre-burn activities in accordance with the requirements identified in Attachment 11, and the
pre-burn inspection requirements in accordance with the inspection schedule included in
Attachment 2. The Permittee shall also comply with the following conditions:

IV.E.1.a. If the treatment units have not been inspected the same day the unit is loaded, the treatment
unit shall be inspected prior to placing reactive waste in the treatment unit;

IV.E.1.b. Any treatment unit that fails one or more of the inspection criteria shall be removed from
service until the problem is corrected;

IV.E.1.c. No treatment is permitted unless the Permittee verified that either radio or telephone
communication with emergency services is available and will be in effect throughout the
duration of the treatment;

IV.E.1.d. No treatment is permitted if the emergency equipment listed in Attachment 2, Table II-B,
“Inspection Schedule for Thermal Treatment Area at M-136” or Table II-C, “Inspection
Schedule for Thermal Treatment Areas at M-225” is not available for use at each respective
location;

IV.E.1.e. All leaks or spills of diesel fuel shall be cleaned up before the Promontory Thermal
Treatment Areas can be operated; and

IV.E.1.f. The loss of the flashing light will require that the unit be shut down until the problem is
corrected. If the Permittee must use the treatment unit when the flashing light is not
working, the supervisor shall visually inspect the area within the QD of the treatment unit
and ensure that no unauthorized employees are present in the area. If any unauthorized
employees are found within this area, they will be escorted from the area. Treatment
operations can commence once the supervisor verifies in the operating record that the area
is clear.

IV.F. PREPARING WASTE FOR THERMAL TREATMENT BURN

IV.F.1. Prior to placing any reactive hazardous waste in a treatment unit located in Promontory
Thermal Treatment Areas, M-136 or M-225, the Permittee shall comply with all provisions
of Conditions IV.C, D and E of this Permit. The Permittee shall also comply with the
following conditions:

IV.F.1.a. The Permittee shall provide at least two trained operators when a treatment unit is in the
process of being loaded with reactive hazardous wastes as defined in Condition IV.B.1;

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 7

IV.F.1.b. The Permittee shall load the treatment unit in accordance with all internal safety procedures
and requirements and the provisions identified in Attachment 11.8.2.2;

IV.F.1.c. The Permittee shall account for all cardboard, wood and diesel used as donor material to
ensure a complete burn The donor material shall be counted towards the daily treatment
limits, and recorded in the operating record; and

IV.F.1.d. All reusable propellant buckets used as accumulation containers for reactive waste shall be
inspected after use. If there is any contamination in the containers they shall be cleaned or
decontaminated in accordance with the procedures identified in Attachment 11 before being
reused; and

IV.F.1.e. The Permittee shall identify in the operating record the burn station used for each container
of reactive hazardous waste treated.

IV.F.2. Prior to beginning the final preparations for an open burn, the Permittee shall comply with
the following conditions:

IV.F.2.a. The Permittee shall ensure all non-essential personnel leave the treatment area prior to
preparing the reactive waste for ignition, as described in Attachment 11.8.2.3;

IV.F.2.b. All wiring and ignition operations, described in Attachment 11.8.2.3, shall be conducted by
at least two employees;

IV.F.2.c. The Permittee may reactivate the firing system treatment areas only after all operators have
exited the QD for the treatment unit;

IV.F.2.d. As the operators leave the treatment area following operations described in Attachment 11,
Section 8.2.3, they shall close the gate to the treatment area;

IV.F.2.e. After all operators have exited the treatment area and retreated to the firing control room,
the operators may replace the firing system interlock in the firing system control console
and activate the firing system;

IV.F.2.f. After activating the firing system, the operators shall confirm that the flashing red light was
activated to alert all personnel that a treatment event is about to start and that they should
vacate the QD area for the treatment area. If the flashing light is not operational, the
Permittee shall comply with Condition IV.E.1.f. before initiating the thermal treatment;

IV.F.2.g. After the warning identified in Condition IV.F.2.f. has been completed, the Permittee shall
conduct a pre-ignition continuity check of the firing system to ensure that the igniters have
been installed correctly into the hard-wired portion of the firing system. If any firing
circuit fails this test, the Permittee shall perform the following tasks:

IV.F.2.g.i. Remove the interlock for the firing control system, deactivating the firing control system;

IV.F.2.g.ii. At least two operators shall reenter the treatment area, and correct the problem;

IV.F.2.g.iii. If the resistance problem cannot be immediately corrected, the operators may connect a
separate igniter wire to an adjacent stanchion; and

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 8

IV.F.2.g.iv. After the problem with the firing circuit has been corrected the operators shall repeat the
steps described in Conditions IV.F.2.g.

IV.F.2.h. The treatment units shall be fired in accordance with the provision of Attachment 11,
Section 8.2.3 of this Permit;

IV.F.2.i. All thermal treatment events shall be observed with a video camera from the firing control
room or immediately outside the firing control room;

IV.F.2.j. In the event that none of the treatment units ignite, the operators shall wait 30 minutes
before removing the firing system interlock and reentering the treatment area to correct the
problem. After correcting the problem, the operators shall repeat the steps described in
Conditions IV.F.2.c, d, e, f and g, and proceed with activating the firing system;

IV.F.2.k. If at least one treatment unit ignites, then the operators shall wait at least 16 hours before
reentering the treatment area and correcting the problem. After the problem has been
corrected, the operators shall repeat the steps described in Conditions IV.F.2.c, d, e, f and g,
and proceed with activating the firing system;

IV.F.2.l. Prior to ignition, the area supervisor or designee, shall review the placement of the waste on
the treatment units; and

IV.F.2.m. All treatment data shall be maintained in accordance with the requirements of UAC
R315-264-73 and shall be entered into the operating record for the Promontory Facility in
accordance with attachment 11.6.

IV.G. POST-BURN ACTIIVTIES

IV.G.1. Following treatment, the Permittee shall: (a) conduct the post-burn inspection activities
identified in Attachment 2 of this Permit, and (b) conduct clean-up activities identified in
Attachment 11of this Permit.

IV.G.2. The Permittee shall conduct a post-burn inspection, including the tasks specified below,
within 24 hours of completing a treatment event unless one of the exceptions identified in
IV.G.2.i. or IV.G.2.j. applies:

IV.G.2.a. Prior to entering the treatment area, the operators shall deactivate the firing control system
and remove the interlock;

IV.G.2.b. Document in the Operating Record any treatment unit with an open flame, hot spot or
smoldering residue;

IV.G.2.c. Document in the Operating Record any treatment unit with unburned residue;

IV. G.2.d. Document in the Operating Record any treatment unit with unburned reactive hazardous
waste and identify if possible why the waste did not burn;

IV.G.2.e. Inspect for any unburned waste that was ejected from a treatment unit during the last
treatment event. Such waste shall be picked up and placed in a treatment unit;

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 9

IV.G.2.f. Clean the treatment units in accordance with Attachment 11 and record on the inspection
form the date that the treatment units were cleaned, or the reason why the units were not
cleaned within 24 hours after completing the treatment event;

IV.G.2.g. Identify the treatment unit on the inspection form where any unburned waste is being
stored;

IV.G.2.h. Inspect the condition of the safety equipment identified in Attachment 2, Table II-B and
Table II-C;

IV.G.2.i. The Permittee may postpone post-burn activities if lightning strikes or adverse weather
conditions prohibit the safe operation of the treatment areas. Lightning strikes closer than
30 miles restrict attended operations at the Promontory Facility. The Permittee shall
document the reasons for the delay in the facility’s operating record; and

IV.G.2.j. The Permittee may delay the post-burn inspection for burns involving bulk propellant that
occurred on a Thursday if it is the end of the work week or Friday. The post-burn
inspection shall be conducted on the following Monday, unless the meteorological
conditions identified in Condition IV.G.2.i. prohibit re-entry into the treatment area. The
Permittee shall document the reasons for the delay in the facility’s operating record.

IV.G.3. Within 24 hours of completing an open burn that generates a characteristic or listed ash or
residue, the Permittee shall remove all characteristic or listed residues from the treatment
area and manage the waste in accordance with UAC R315-262.

IV.G.4. Except as allowed in Conditions IV.G.2.i. or IV.G.2.j., the Permittee’s area supervisor, or
designee, shall review the Promontory Thermal Treatment Areas log and post-burn
inspection forms within 24 hours of completing each thermal treatment event. The review
shall ensure that all of the recorded information is correct and identify any items that may
require corrective action including any treatment unit that failed to ignite, had an ignition
problem or misfired, had an unplanned detonation, where the burn did not propagate as
expected or any other unexpected event. The Permittee shall document the review and
need for any corrective action in the Operating Record.

IV.G.5. If post-burn requirements are postponed, as allowed in Conditions IV.G.2.j. or IV.G.2.i.,
the Permittee shall document the following information in the operating record:

IV.G.5.a. The reason for the delay in performing the post-burn requirements specified in Condition
IV.G.2.; and

IV.G.5.b. The date when the Permittee cleaned the treatment unit and completed the post-burn
requirements specified in Condition IV.G.2.

IV.G.6. Open burn operations at the Promontory Thermal Treatment Areas may result in the
generation of untreated residue and unburned wastes. The Permittee shall manage these
residues and wastes in accordance with the following provisions:

IV.G.6.a. Small amounts of untreated residue shall be considered newly generated waste and shall be
logged and tracked as such in the explosive waste tracking system. This small amount is
defined as less than 5% of the total volume placed treatment unit. The primary option for
managing this waste is to burn it by 6:00 pm of the following calendar day. If the untreated
Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 10

residue cannot be treated by 6:00 pm of the following calendar day then it shall be managed
in accordance with UAC R315-262;

IV.G.6.b. Unburned waste resulting from a misfire or an interrupted ignition shall be treated by
6:00 pm of the calendar day following the date of the first attempt to treat this waste. For
the purposes of this Permit, an interrupted ignition occurs when anything greater than 5%
of the waste placed on a treatment unit or in a station fails to ignite. This unreacted waste
shall not be considered a newly generated residue. If the Permittee is unable to treat the
unburned waste by 6:00 pm of the following calendar day, the Permittee shall cover the
waste and manage the treatment unit or station in accordance with UAC R315-262. For
operations at M-225, if the cumulative storage time for the unburned waste both while in
storage prior to treatment and while on the treatment unit or in the burn station is greater
than 90 days, the Permittee shall request an emergency storage permit in accordance with
UAC R315-270-61 (this requirement is not applicable to operations at M-136);

IV.G.6.c. For reactive hazardous wastes that have been in storage for greater than 90 days when they
are placed on in a treatment unit or in a burn station and which do not completely burn, the
Permittee shall treat all unburned or unreacted waste by 6:00 pm of the calendar day
following the date of the initial attempt to treat the waste. For operations at M-225, if the
Permittee is unable to treat the unburned or unreacted waste by 6:00 pm of the following
calendar day, the Permittee shall request an emergency storage permit in accordance with
UAC R315-270-61 (this requirement is not applicable to operations at M-136); and

IV.G.6.d. The Permittee shall manage all treatment residues generated from the treatment of listed
and/or characteristic wastes during post-burn activities in accordance with this Permit and
UAC R315-262.

IV.H. STORM WATER MANAGEMENT AND RUN-ON AND RUN-OFF CONTROLS

IV.H.1. The Permittee shall manage all storm water collected from treatment units in accordance
with this Permit, Attachment 11, Section 11 and UAC R315-262.

IV.H.2. The Permittee shall maintain run-on diversion structures in accordance with this Permit and
UAC R315-264-601. The Permittee shall inspect the condition of those structures annually
to ensure that they are in good repair. The annual inspection shall be documented in the
Operating Record for Promontory Thermal Treatment Areas.

IV.H.3. Run-off from precipitation that falls within the operating area of the Promontory Thermal
Treatment Areas shall be managed in accordance with UAC R315-264-601, using berms
and ground slope.

IV.I. TREATMENT RESIDUE AND ASH MANAGEMENT

IV.I.1. All treatment residue and ash generated from the Promontory Thermal Treatment Area
operations shall be managed in accordance with Condition IV.G.6.d. and the procedures
identified in Attachment 11.

IV.I.2. Sampling and analysis of treatment residues and ash generated during operations at the
thermal treatment areas shall be performed in accordance with Attachments 1 and 11 of this
Permit.

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 11

IV.J. INSPECTION SCHEDULES AND PROCEDURES

IV.J.1 The Permittee shall conduct inspections of the Promontory Thermal Treatment areas in
accordance with Attachments 2 and 11 of this Permit.

IV.K. ENIVRONMENTAL MONITORING REQUIREMENTS

IV.K.1. The Permittee has completed an HHRA based on the results of emissions sampling and air
dispersion modeling. The primary documents that were completed in the risk assessment
process, and approved by the Director, are listed in Section II.G. of this Permit.

IV.K.2. The Permittee shall conduct soil monitoring in accordance with the Soil Monitoring Plan
(referenced in Condition II.G.1.h.), in order to further assess the risk to human health from
thermal treatment operations at the Promontory facility.

IV.K.3. The Permittee shall complete the initial sampling event, as directed by the Soil Monitoring
Plan, and submit a written report to the Director for approval on the soil monitoring results
no later than January 31, 2019.

IV.K.4. The Soil Monitoring Report shall contain: (a) the validated analytical data, (b) a soil
sampling location map, (c) a detailed analysis of the data as described in the Soil
Monitoring Plan, including a comparison of the results of the soil monitoring with the
maximum off-site concentrations predicted by the air dispersion model, U.S. EPA Regional
Screening Levels and background soil concentrations, and (d) a recommendation on the
need for additional monitoring.

IV.K.5. The Director may require the Permittee to conduct additional soil monitoring based on the
results of the Soil Monitoring Report.

IV.K.6. The Permittee shall submit a Soil Monitoring Plan addendum in writing to the Director for
approval within 90 days of being notified by the Director in writing that a Soil Monitoring
Plan addendum is required.

IV.K.7. The Permittee shall conduct groundwater monitoring in accordance with Module IV of the
Permittee’s Post-Closure Permit.

IV.K.8. The Permittee shall evaluate the potential impacts to groundwater from thermal treatment
operations at the M-136 Burn Grounds in accordance with the Groundwater Monitoring
Plan as approved by the Director on May 21, 2018.

IV.K.9. Based on the results of the evaluation required by Condition IV.K.8., the Director may
require the Permittee to submit a plan in writing to the Director for approval to mitigate
impacts to groundwater from thermal treatment operations.

IV.K.10. The Permittee shall submit a Groundwater Monitoring Plan addendum in writing to the
Director for approval within 90 days of being notified by the Director in writing that
additional work is required to demonstrate that thermal treatment operations at the
Promontory facility do not impact groundwater.

Northrop Grumman Systems Corporation - Promontory March 2024
Module IV – Thermal Treatment of Energetic Wastes UTD009081357
Page 12

IV.L. ECOLOGICAL RISK

IV.L.1. Based on the justifications presented by the Permittee, on December 19, 2016, in support of
its request to waive the ecological risk assessment for the Promontory Thermal Treatment
area (referenced in Condition II.G.1.f.), the Director approved the waiver request on August
29, 2017.

IV.M HUMAN HEALTH RISK

IV.M.1. The Human Health Risk was evaluated as identified in Condition II.G.1. The Permittee
shall annually evaluate emission factors, dose-response factors and human health risk
scenarios as directed by Conditions II.G.3.g., II.G.3.h. and II.G.3.i.

IV.N. FACILITY MODIFICATION/EXPANSION

IV.N.1. Modification of the design plans and specifications in Attachment 6 or construction of
additional treatment units shall be allowed only in accordance with Condition I.D.4. and
R315-124-5.

IV.O. CLOSURE AND POST CLOSURE

IV.O.1. The Permittee shall close the Promontory Thermal Treatment Areas in accordance with
Condition II.O., Attachment 5 of this Permit, R315-264-110 and R315-264-178.

IV.P. PROMONTORY THERMAL TREATMENT AREAS OPERATING RECORD

IV.P.1. The Permittee shall maintain an Operating Record at the Promontory Facility that describes
the operation of the Thermal Treatment areas. The operating records for the M-136 and
M-225 Thermal Treatment Areas shall, at a minimum, include the following information:

IV.P.1.a. All information required by UAC R315-264-73;

IV.P.1.b. Copies of all inspections required by this module;

IV.P.1.c. All waste tracking information maintained in the electronic Waste Tracking Record
identified in Attachment 11;

IV.P.1.d. A description of the meteorological conditions described in Condition IV.C.9.e. during
each burn;

IV.P.1.e. Copies of all reports identified in Condition II.G.1. and required by Condition II.G.3. and
IV.K and IV.L; and

IV.P.1.f. A running total of the type and quantity of reactive hazardous waste that has been treated at
both of the Promontory Thermal Treatment Areas during the calendar year.
Northrop Grumman Systems Corporation – Promontory March 2024
Module V – Treatment of Waste Hydrazine UTD009081357
MODULE V – TREATMENT OF WASTE HYDRAZINE

V.A. APPLICABILITY

V.A.1. The Permittee may treat hydrazine, U.S. EPA hazardous waste code U133,
by dilution, at Building T-29B, for the sole purpose of safely shipping the
resultant waste to an off-site disposal facility in accordance with this
Module and Attachment 10.

V.A.2. The treatment process shall be conducted in a manner that will ensure
protection of human health and the environment.

V.A.3. Once the hydrazine is determined to be a hazardous waste it will be
managed in accordance with Attachment 10 and 40 CFR 262.34 until it is
shipped to an approved hazardous waste management facility for disposal
or transferred to the M-186 Hazardous Waste Storage Facility.

V.A.4. The Permittee shall comply with the requirements specified in the facility
Contingency Plan (Attachment 4), when there has been a release at
Building T-29B that threatens human health or the environment.
V.A.5. The Permittee shall take precautions to prevent accidental ignition or reaction of the waste hydrazine and follow the procedures specified in Utah Administrative Code (UAC) R315-8-2.8.

V.A.6. The Permittee shall inspect Building T-29B in accordance with the
inspection schedule contained in Attachment 2.

V.B. RECORD KEEPING AND REPORTING

V.B.1. The Permittee shall record in the operating record the following:

V.B.1.a. The date that waste hydrazine is received at T-29B;

V.B.1.b. The quantity of waste hydrazine received;

V.B.1.c. The date the waste hydrazine is treated by the dilution process;

V.B.1.d. The quantity of diluted hydrazine after the dilution process is complete;
and

V.B.1.e. The date the diluted hydrazine is shipped off-site or to the M-186 storage
facility.

Northrop Grumman Systems Corporation – Promontory March 2024
Module V – Treatment of Waste Hydrazine UTD009081357
V.C. CLOSURE

V.C.1. The Permittee shall close Building T-29B in accordance with UAC
R315-8-7, UAC R315-8-9.9, Permit Condition II.O. and the designated
Closure Plan in Attachment 5 of this Permit.
Northrop Grumman Systems Corporation – Promontory March 2024
Module VI – Oxidizer Leaching Treatment of Energetic Wastes UTD009081357

MODULE VI– OXIDIZER LEACHING TREATMENT OF ENERGETIC WASTE

VI.A. APPLICABILITY

VI.A.1. The requirements of this permit module apply to the treatment of reactive
and ignitable hazardous waste, U.S. EPA hazardous waste codes D001 and
D003, by oxidizer leaching at the Northrop Gruman Systems Corporation
(NGSC) – Promontory facility. The Permittee shall comply with Utah
Administrative Code (UAC) R315-264 and all conditions of this Module
and Permit.
VI.A.2. The Permit conditions of this module allow treatment at the Hazardous Waste Management Unit (HWMU), designated as the M-705L oxidizer leaching process, as designed and described in the drawings and specifications in Attachments 6 and 12. The M-705L oxidizer leaching process consists of a 600 gallon leach tank and ancillary equipment and piping. VI.A.3. The treatment of reactive or ignitable items or articles by the oxidizer leaching process at M-705L may be exempt from this Module if the items or articles can be legitimately recycled in accordance with UAC R315-261.
VI.A.4. This Permit has been developed in accordance with the applicable
requirements of Title R315 of the Utah Administrative Code. All
conditions in this Permit shall supersede conflicting statements,
requirements, or procedures found in Title R315 of the Utah
Administrative Code or the Attachments to this Permit.

VI.B. PERMITTED AND PROHIBITED WASTE IDENTIFICATION

VI.B.1. The Permittee may treat reactive and ignitable hazardous waste, U.S. EPA
hazardous waste codes D001 and D003 at Building M705L by oxidizer
leaching. The reactive or ignitable hazardous waste is generated from the
following sources:
VI.B.1.a. Production materials generated at the NGSC Promontory facility that are
contaminated with reactive or ignitable residues (e.g., flare grain-formers,
gloves, other personal protective equipment, plastics, rubber and paper
that were contaminated with reactive materials during the manufacturing
process). VI.B.2. Only reactive or ignitable hazardous waste as defined by UAC R315-261 may be treated in the M-705L oxidizer leaching tank.
VI.B.3. The Permittee is prohibited from treating reactive or ignitable hazardous
waste classes and compositions in the M-705L oxidizer leaching tank that
are not included in Conditions IV.B.1. and IV.B.2.
Northrop Grumman Systems Corporation – Promontory March 2024
Module VI – Oxidizer Leaching Treatment of Energetic Wastes UTD009081357

VI.B.4. The Permittee is prohibited from treating any reactive or ignitable
hazardous waste by oxidizer leaching that does not have a designated
waste profile.

VI.B.5. The addition of hazardous waste codes to Conditions VI.B.1. and
VI.B.1.a. requires a permit modification as specified in R315-124-5 and
Condition I.D.
VI.B.6. The Permittee shall comply with the waste compatibility requirements of Condition II.I. VI.C. GENERAL OPERATING CONDITIONS
VI.C.1. The Permittee shall use appropriate controls and practices to maintain the
integrity of the M-705L tank system and to prevent spills and overflows in
accordance with the standards of UAC R315-264-194.

VI.C.2. In order to minimize the potential impacts to human health and the
environment, the Permittee shall adhere to applicable provisions of
Attachments 2 and 12 and the following Conditions:

VI.C.2.a. Reactive and ignitable hazardous waste shall be managed in accordance
with Attachment 12 and UAC R315-262 until such time it is determined
that it no longer exhibits the reactivity or ignitability characteristic;

VI.C.2.b. The Permittee shall comply with the Waste Analysis Plan and operating
parameters outlined in Attachment 1, Section 3.3.3 and Attachment 12,
Section 12-3 to develop specific Waste Profiles and to determine when the
reactive or ignitable hazardous waste being treated is no longer hazardous;

VI.C.2.c. The Permittee shall comply with the requirements specified in the facility
Contingency Plan (Attachment 4), when there has been a release at
Building M-705L that threatens human health or the environment;

VI.C.2.d. The Permittee shall take precautions to prevent accidental ignition or
reaction of the reactive or ignitable hazardous waste and comply with the
procedures specified in UAC R315-264-17;

VI.C.2.e. Treatment of reactive or ignitable hazardous waste by the oxidizer
leaching process at M-705L shall only be accomplished by properly
trained NGSC personnel in accordance with the NGSC Waste Profile
number, the conditions of this Permit and its Attachments;

VI.C.2.f. The Permittee shall post warning signs outside of the M-705L oxidizer
leaching building to keep unauthorized personnel out;
Northrop Grumman Systems Corporation – Promontory March 2024
Module VI – Oxidizer Leaching Treatment of Energetic Wastes UTD009081357

VI.C.2.g. The Permittee shall maintain the egress paths for the M-705L oxidizer
leaching building as identified in Attachment 4;

VI.C.2.h. The Permittee shall train all operators of the M-705L oxidizer leaching
process in accordance with Condition II.H. and Attachement 3 of this
Permit;

VI.C.2.i. The Permittee shall maintain the integrity of the M-705L tank system and
ancillary equipment through regular inspections and in accordance with
the inspection schedule contained in Attachment 2 of this Permit.
Inspection records shall be maintained at the facility;

VI.C.2.j. The Permittee shall not operate the M-705L oxidizer leaching process without
secondary containment as required by UAC R315-264-193; and

VI.C.2.k. If the electronic leak detection system is not operational, the Permittee shall
conduct visual inspections of the secondary containment structure every day that
the M-705L tank system contains hazardous waste.

VI.C.3. Once the Permittee has determined that the oxidizer leaching treatment process is
complete for a batch of contaminated production materials or class 1.3
propellants or explosives, in accordance with Sections 12-2 and 12-3 of
Attachment 12, the wastewater shall be pumped to the wastewater treatment plant
where it is treated and discharged in accordance with the Permittee’s current
UPDES Permit #UT0024805.

VI.D. RECORD KEEPING AND REPORTING

VI.D.1. The Permittee shall record in the Operating Record the following:

VI.D.1.a. The date a batch of contaminated production materials or class 1.3 propellant or
explosive is placed in the M-705L treatment tank;

VI.D.1.b. The quantity and description of contaminated production materials or class
1.3 propellant or explosive, including the Waste Profile number, placed in
the treatment tank;

VI.D.1.c. The laboratory testing results associated with each Waste Profile number;

VI.D.1.d. The date the treatment process for each batch of contaminated production
materials or class 1.3 propellant or explosive is complete such that all
items in each batch are no longer reactive or ignitable in accordance with
the Waste Profile number;

VI.D.1.e. The date the wastewater is pumped out of the tank to the wastewater
treatment plant; and

Northrop Grumman Systems Corporation – Promontory March 2024
Module VI – Oxidizer Leaching Treatment of Energetic Wastes UTD009081357

VI.D.1.f. The waste determination of the treated production materials and any
residue and the date they are removed from the tank.

VI.E. CLOSURE

VI.E.1. The Permittee shall close the Building M-705L oxidizer leaching
treatment process in accordance with UAC R315-264-110, UAC
R315-264-178, Permit Condition II.O. and the designated Closure Plan in
Attachment 5 of this Permit.

Attachment 1

WASTE ANALYSIS PLAN

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

2
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 Northrop Grumman Systems
Corporation (NGSC). 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 Utah Administrative Code (UAC) R315-261-23. The
term "ignitable waste" consists of propellant/explosive oxidizer containing waste, as
defined in UAC 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
NGSC 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
NGSC-Promontory 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 UAC R315-261-23 and determine
whether the waste exhibits any additional hazardous waste characteristics, and if it is
listed in accordance with UAC R315-261-20 and UAC 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
▪ U.S. 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.
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

3

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 NGSC 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, U.S. 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:

▪ UAC 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
NGSC periodically receives reactive waste from off-site Northrop Grumman Systems
Corporation and non-Northrop Grumman Systems Corporation facilities. This waste is
accepted by NGSC 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
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

4
profiling process. The waste profile for wastes received from off-site contains the same
information as profiles for wastes generated on-site (described above).

Before the waste is accepted, NGSC 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 NGSC, 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 NGSC facility, in accordance with UAC R315-261, NGSC will assess
emission hazards associated with the open burning of these hazardous wastes as required
in UAC 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
NGSC 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 NGSC will decide whether a waste is hazardous as
defined by UAC 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. NGSC 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
NGSC operates a simple leaching process to remove the oxidizer from 1.3
propellants/explosives and contaminated production materials in place of open burning.
NGSC may evaluate some reactive and/or ignitable waste streams for potential oxidizer
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

5
leaching removal. Prior to creating a Waste Profile for each waste stream treated by the
oxidizer leaching process, a WAP for these types of waste streams will be developed by
1) evaluating waste composition, physical state and size, and other 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 [UAC R315-264-13 (b)(2)]

NGSC 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 U.S. 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 [UAC R315-264-13(b)(3), UAC R315-261-1090 and UAC
R315-264-13]
Waste sampled at the NGSC 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

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

6

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
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

7

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 NGSC and
while in transit to the testing laboratory.

3.5 FREQUENCY OF ANALYSIS

3.5.1 Frequency of Analysis for Reactive Waste [UAC R315-264-13(b)(4)]
Reactive waste treated at the NGSC burn grounds come from various Northrop Grumman
Systems Corporation 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, NGSC characterizes all reactive
waste streams using generator knowledge. While these energetic waste streams are not
analyzed prior to being treated, NGSC 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 NGSC 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.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

8

NGSC- 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 Water
Program
Ground Water
Program
Process Gen.
Waste
Scrap
Propellant …
D003
Scrap
Propellant …
D003
Contaminated
Solid Waste
D003
Contaminated
Solid Waste
D003
Fixer/Developer
D011
Fixer/Developer
D011
Solvent/Liner
Waste
None
Solvent/Liner
Waste
None
Alodine Rags
D007, F002,
F003
Alodine Rags
D007, F002,
F003
Solvent/Paint
Waste D001,
F002, F003, F005
Solvent/Paint
Waste D001,
F002, F003, F005
Solvent/Paint
Rags F001,
F002, F003, F005
Solvent/Paint
Rags F001,
F002, F003, F005
Resin Curatives
None
Resin Curatives
None
Non-Haz Used
Oil
Non-Haz Used
Oil
Organic Waste
D001, F002
F003, F005
Organic Waste
D001, F002
F003, F005
Acid Waste
D002
Acid Waste
D002
Lab Packs
Various codes
Lab Packs
Various codes
Contaminated
GW
F001, F002
Contaminated
GW
F001, F002
Note: The EPA codes included above are primary codes only; The above list includes major waste streams only.
Burn Grounds Ash
F005
Burn Grounds Ash
F005
Offspec Oil
None
Offspec Oil
None
Carbon/CarbonCarbon/Carbon
Carbon Parts Manuf.Carbon Parts Manuf.
WW
F001, 2, 3, 5
WW
F001, 2, 3, 5
Offspec Oil
None
OffspecOil
None
Explosive lab
Waste
D003, F005
Explosive lab
Waste
D003, F005

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

9

Reactive Waste Treatment and Disposal Decision Matrix
Figure 3-2

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

10

Chemical Waste Disposal Decision Matrix
Figure 3-3
RCRA Solid Waste
Yes No
Non-Hazardous
Disposal
Is this an Exempt
Solid Waste
Yes
Based on Process
Knowledge / MSDS,
is the waste listed in
Part 261 subpart D?
No
Based on process
knowledge / MSDS,
does the waste exhibit
any characteristics specified
in 261 subpart C?
No
No
Hazardous waste management
and disposal
Yes Yes
Based on
Lab analysis
Unknown
Based on
Lab analysis
Unknown
Is the waste listed
or characteristic
Non-hazardous disposal
No
Yes

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

11
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
Volatile 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 Department of Environmental
Quality, unless otherwise noted. The latest revision to the analytical method will be used
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 1 – Waste Analysis Plan UTD009081357

12
for waste analysis for each parameter. Samples will be collected in accordance with
UAC R315-261-1090.
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)

ATTACHMENT 2

INSPECTION SCHEDULES AND PROCEDURE

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
2

INSPECTION SCHEDULES AND PROCEDURES

II.A. Purpose and Scope
The inspection schedule used by Northrop Gruman Systems Corporation (NGSC)
for the hazardous waste management areas has been designed to meet the
requirements of UAC R315-264-15. The inspection schedule promotes the
detection of malfunctions, deterioration, discharges, and other situations which
may be causing or leading to a release of hazardous waste constituents into the
environment or pose a threat to human health. Inspections are conducted by
personnel trained to identify potential problem areas and to use the inspection
schedule and the inspection log. Nine areas are designated for inspection: the
container storage area at E-501, M-705S, M-186, the Thermal Treatment Areas at
M-136 (including the burn trays and Burn Station 14) and M-225, T-29B
hydrazine dilution, oxidizer leaching at M-705L, the solid propellant/motor
storage building M-629, and storage pad S-633.

Waste solid propellant and rocket motors are stored at buildings M-629 and
storage pad S-633 as well as M-136 burn grounds. Periodically, waste hydrazine
is treated (by dilution) at building T-29B. In addition, NGSC periodically
operates a simple leaching process to remove the oxidizer from 1.3
propellants/explosives and contaminated production materials at Building
M-705L. Therefore, inspections of these facilities, in accordance with their
inspection schedules, are only required when hazardous waste is being stored or
treated at the facility. A facility must be inspected, however, prior to receiving
hazardous waste for storage or treatment if inspections were discontinued during
the period of inactivity. If any problems are identified with the areas of concern
that are listed in the inspection schedules (contained in this attachment), they must
be corrected before the facility is put back into use.

II.B. Remedial Action or Maintenance
Repairs or corrective action for any deterioration or malfunction discovered by an
inspection shall be conducted as outlined in Module II, Section F. Repairs to
security equipment shall be completed as soon as practicable, but not later than
72 hours after the problem is discovered. As stated in UAC R315-264-15(c),
where a hazard is imminent or has already occurred, remedial action shall be
taken immediately.

II.C. Inspection Records
All records of inspections and remedial actions shall be retained in the Operating
Record, for a period of at least three years. At a minimum, inspection records
shall include the date and time of the inspection, the name of the inspector, a
notation of the observations made, and the date and nature of any repairs or
maintenance taken.

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
3

II.D. Inspection Schedules
The inspection schedules appear in detail in Tables II-A through II-H. Each
inspection schedule is designed so that the items appearing on the schedule are
inspected frequently enough to avoid any deterioration of equipment and thus
reduce the probability of an environmental or human health incident between
inspection times. Each inspection schedule is divided into individual categories
and each category contains a specific list of items to be inspected. Inspections are
also required within 24 hours after a storm event as outlined in the schedules
below. A storm event is defined as precipitation in excess of 1.0 inch in a
one-hour period. It shall be documented in the inspection log that the inspection
was conducted in response to a storm event.

TABLE II-A
INSPECTION SCHEDULE FOR DRUM STORAGE AT M-186

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines and look for
broken or downed fence lines, loose wires

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate, safety
flags in place

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Inspect road for spills,
soil discoloration

Loading/ Daily1 Inspect loading areas for
Unloading Areas spills, soil discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
4

3. Safety Equipment

Eyewash/Shower Monthly Ensure in working order by
testing, check water supply

Telephone/Radio Monthly Working condition

4. Storage Containment

Containers Weekly Number of containers, severe
corrosion (i.e., flaking, large rust buildup,
rusty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums,
adequate aisle space (2.5 feet)

Pads Weekly Chips, cracks, or irregularities in concrete,
general condition

Sumps/Pads Daily2 Standing liquid on pad or in sumps

Drainage Area Weekly Spills, discolored soil

Roof Weekly General condition including holes or defects

5. Emergency Equipment

Fire Monthly Fire extinguisher full, in working order
Extinguisher

Absorbent Monthly Adequate supply (minimum 25 lbs.)

Repack Drums Monthly Two repack drums with seals

55-Gallon drums Monthly Six empty 55-gallon drums with bungs
in good condition, no dents, etc.

Generator Monthly Routine oil check, fill with gas, test startup

Pump Monthly Good working order, hoses intact, test
startup and pump

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 Daily except for nonscheduled workdays and holidays.
Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
5

TABLE II-B
INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-136

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines, look for
loose wires or broken lines

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Spills, discolored soil

Loading/ Daily1 Spills, discolored soil
Unloading Areas

Periphery Daily1 Spills, discolored soil, stressed vegetation

3. Safety Equipment

Telephone/Radio Monthly Check operating condition of equipment

4. Burn Ground Area

Erosion Weekly3 Survey area and note severe erosion on
grounds

5. Storage/Containment

Burn tray Prior to placing Tray is intact and liquid tight, accumulation

Waste then of liquids
Weekly2, 3

Container Weekly2 Closed, labeled, signs of leaks or spills
Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
6

6. Emergency Equipment

Fire
Extinguisher Monthly Fire extinguisher full and in working order

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 Inspect upon arrival, then each calendar week.
3 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.

TABLE II-C
INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-225

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines, look for
loose wires or broken lines

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Spills, discolored soil

Loading/Unloading Daily1 Spills, discolored soil

Areas

Periphery Daily1 Spills, discolored soil, stressed
vegetation

3. Safety Equipment

Telephone/Radio Monthly Check operating condition of equipment

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
7

4. Burn Ground Area

Erosion Weekly2 Survey area and note severe erosion on
grounds

Burn Tray Prior to placing Tray is intact and liquid tight, accumulation
waste, then of liquids
Weekly2

5. Emergency Equipment

Fire Extinguisher Monthly Fire extinguisher full and in working order

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.

TABLE II-D
INSPECTION SCHEDULE FOR STORAGE AND CONSOLIDATION
ROOM AT M-705S

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Weekly Readable signs, signs in place

2. Area

Roadway Daily1 Spills, discolored soil

Loading/Unloading Daily1 Spills, discolored soil
Areas

Periphery Daily1 Spills, discolored soil, stressed
vegetation

3. Safety Equipment

Eyewash/Shower Monthly Ensure in working order by testing,
check water supply
Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357
8

Telephone/Radio Monthly Check operating condition of equipment

4. Storage containment

Containers Weekly Number of containers, severe corrosion (i.e.
flaking, large rust buildup, rusty bungs),
dented drums, hazardous waste labels in
place, properly marked, readable, no open
bungs, no standing liquid on the drums

Pads, Sumps Weekly Chips, cracks, or irregularities in the
concrete, general conditions

Portable Secondary Daily2 Cracks, liquid, containment integrity

Roof Weekly General condition including holes or defects

Sump, pads Daily2 Check for standing liquids in the sump and
containment system

5. Emergency Equipment

Fire Extinguisher Monthly Fire extinguisher full and in working order

Absorbents Monthly Adequate supply (minimum 25 lbs.)

Repack Drums Monthly Two repack drums with seals

55-Gallon Drums Monthly Six empty 55-gallon drums with bungs in
good condition, no dents, etc.

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 Daily except for weekends and holidays.

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

TABLE II-E
INSPECTION SCHEDULE FOR M-629

(Note: As stated in section II.A. of this Attachment, inspections of these
storage buildings are not required during periods when hazardous waste is
not being stored at the facility.)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Weekly Readable signs, signs in place

Bay Doors Weekly Function properly

Lock Weekly Function properly

2. Area

Roadway Daily1 Inspect road for spills, soil
discoloration

Loading/Unloading Areas Daily1 Inspect loading areas for spills, soil
discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation
3. Communications Equipment

Telephone Monthly Working condition; place
call to verify operation

4. Storage Containers

Motors/bags, etc. Weekly Verify condition of motors/bags,
properly marked and labeled, out of
place material and check for leakage,
or liquid discharge from waste solid
rocket motors and propellant .

Building Weekly Verify no damage done to exterior of
facility

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

Roof Weekly General condition including holes or
defects

5. Emergency Equipment

Fire Extinguisher Monthly In working order and full

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).

TABLE II-F
INSPECTION SCHEDULE FOR DRUM STORAGE PAD AT E-501

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines and look for
broken or downed fence lines, loose wires

Signs Weekly Readable signs, signs in place

Gates Weekly Able to properly close gate, safety
flags in place

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Inspect road for spills,
soil discoloration

Loading/ Daily1 Inspect loading areas for
Unloading Areas spills, soil discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation

3. Safety Equipment

Eyewash/Shower Monthly Ensure in working order by
testing, check water supply

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

Telephone/Radio Monthly Working condition

4. Storage Containment

Containers Weekly Number of containers, severe
corrosion (i.e., flaking, large rust buildup,
rusty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums,
adequate aisle space (2.5 feet)

Pads Weekly Chips, cracks or irregularities in concrete,
general condition

Sumps/Pads Daily1 Standing liquid on pad or in sumps

Drainage Area Weekly2 Spills, discolored soil

Roof Weekly General condition including holes or defects

5. Emergency Equipment

Fire Monthly Fire extinguisher full, in working order
Extinguisher

Absorbent Monthly Adequate supply (minimum 25 lbs.)

Repack Drums Monthly One repack drum with seals

55-Gallon drums Monthly Three empty 55-gallon drums with bungs
in good condition, no dents, etc.

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

TABLE II-G
INSPECTION SCHEDULE FOR T-29B Hydrazine Dilution Bay

(Note: As stated in section II.A. of this Attachment, inspections of building T-29B are not
required during periods when hazardous waste is not being treated at the facility)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Prior to treatment Readable signs, signs in place

Door Locked Prior to treatment In working order, locked

2. Area

Roadway Daily1 Inspect road for spills,
soil discoloration

Loading/ Daily1 Inspect loading areas for
Unloading Areas spills, soil discoloration

Periphery Daily1 Inspect grounds for any spills, soil
discoloration or stressed vegetation

3. Safety Equipment

Eyewash/Shower Prior to treatment Ensure in working order by
testing, check water supply

Telephone(cell) Prior to treatment Working condition

4. Storage Containment

Containers Prior to treatment Number of containers, severe
corrosion (i.e., flaking, large rust buildup,
rusty bungs), dented drums, hazardous waste
labels in place, properly marked, readable,
open bungs, no standing liquid on drums

Floor Prior to treatment Chips, cracks, or irregularities in concrete,
general condition

Roof Prior to treatment General condition including holes or defects
Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

5. Emergency Equipment

Fire Prior to treatment Fire extinguisher full, in working order
Extinguisher

Absorbent Prior to treatment Adequate supply (minimum 25 lbs.)

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).

TABLE II-H
INSPECTION SCHEDULE FOR STORAGE PAD S-633
(Note: As stated in section II.A. of this Attachment, inspections of this storage
pad are not required during periods when hazardous waste is not being stored
on the pad.)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Fences Weekly Visually inspect all fence lines, look for
loose wires or broken lines

Signs Weekly Readable signs, signs in place

Gate Weekly Able to properly close gate

Lock Weekly In working order, able to lock

2. Area

Roadway Daily1 Spills, discolored soil

Loading/Unloading Daily1 Spills, discolored soil
Areas

Periphery Daily1 Spills, discolored soil, stressed
vegetation

Erosion Weekly2 Survey area and note severe erosion on or
around storage pad

Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

3. Storage Containers

Motors/containers, etc. Weekly3 Verify condition of motors/containers,
properly marked and labeled, out of
place material and check for leakage, or
liquid discharge from waste solid rocket
motors and propellant.

1 Daily when in use (i.e. when loading or unloading operations occur at the facility).
2 And after each storm event. A storm event is defined as more than one inch of precipitation in
a one-hour period.
3Inspect upon arrival, then each calendar week.

TABLE II-I
INSPECTION SCHEDULE FOR M-705L Oxidizer Leaching Process

(Note: As stated in section II.A. of this Attachment, inspections of building M-705L are not
required during periods when hazardous waste is not being treated at the facility.)

MINIMUM
EQUIPMENT FREQUENCY AREAS OF CONCERN

1. Security Equipment

Signs Weekly1 Readable signs, signs in place

Egress paths Weekly1 Egress paths clear during treatment

2. Area

Loading/ Weekly1 Inspect loading areas for
Unloading Areas spills, soil discoloration

3. Safety Equipment

Eyewash Weekly1 Ensure in working order by
testing, check water supply

Telephone (cell) Monthly2 Working condition

4. Equipment
Northrop Grumman Systems Corporation. – Promontory March 2024
Attachment 2 – Inspection Schedules and Procedures UTD009081357

Treatment Tank Weekly1 Tank and ancillary equipment is liquid tight,
no visible signs of leaking

Containment Sump Daily3, 4 Liquid present in sump

Containment Weekly1 Containment is intact, free from Chips,
cracks, or irregularities in concrete, general
condition

5. Emergency Equipment

Fire Monthly2 Fire extinguisher full, in working order
Extinguisher

Spill Kit Monthly2 Spill Response Material Available

1 Weekly when in use (i.e. when treatment is occurring at the facility).
2 Monthly when in use (i.e. when treatment is occurring at the facility).
3 Daily when is use (i.e. when treatment is occurring at the facility).
4 Daily inspection when electronic leak detector is not operable. No inspection required when
electronic leak detector is operable.

ATTACHMENT 3

PERSONNEL TRAINING
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 3 – Personnel Training UTD009081357
2

Annual On-Going Up-Date Training
Outline

I. Introduction to Hazardous Waste
A. Major Laws
B. Government Publications (29, 40, 49 CFR)
C. U.S. EPA, DOT, OSHA Interface

II. Hazardous Waste Determination
A. UAC R315-261

III. Hazardous Waste Accumulation Areas
A. UAC R315-262

IV. Container Management
A. UAC R315-264-170

V. DOT Shipping Criteria
A. 49 CFR 172.101

VI. Reportable Quantities
A. 49 CFR 172.101 Appendix

VII. Implementation of the Contingency Plan

Training is held throughout the year for all TSDF operators that handle or are expected to handle
hazardous waste.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 3 – Personnel Training UTD009081357
3

OUTLINE FOR THE TRAINING OF PERSONNEL WHO
GENERATE, PICKUP/TRANSPORT/DISPOSE OF, AND MANAGE
HAZARDOUS WASTE

INTRODUCTION

This training will teach employees and contractors (if they work with hazardous waste) to
properly handle, pickup/transport/dispose of, and manage hazardous waste. It will enable
employees to safely handle hazardous waste and ensure that facility personnel are able to
respond effectively to emergencies in order to protect human health and the environment. It will
also ensure that the Company is in compliance with all applicable laws and regulations as they
pertain to training.

AUDIENCE

The audience is made up of three major groups. 1) Those individuals who generate hazardous
waste. 2) Personnel who pickup, transport, and dispose of hazardous waste. 3) The technical
people who manage hazardous waste operations at the Company.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 3 – Personnel Training UTD009081357
4

CONTENT OF THE PROGRAM:
(The employee will be able to:) REQUIRED FOR
GROUP(s)

1) Define hazardous waste terms 1,2,3
2) Understand the importance of and follow procedures 1,2,3
3) List characteristics of hazardous waste 1,2,3
4) List various hazardous waste materials 1,2,3
5) List examples of and consequences of improper disposal 1,2,3
6) Comply with Federal and State Laws 1,2,3
7) Comply with Company 1,2,3
8) List the major functions performed in their work area as related
to hazardous waste
1,2,3
9) List their job responsibilities as related to hazardous waste 1,2,3
10) Use resources and references related to hazardous waste 1,2,3
11) Operate various hazardous waste handling equipment 1,2,3
12) Proper use of safety equipment 1,2,3
13) Avoid shortcuts when handling hazardous waste 1,2,3
14) Proper use of monitoring equipment 2,3
15) Identify hazardous waste 1,2,3
16) Segregate incompatible materials 1,2,3
17) Proper use of package materials 1,2,3
18) Label materials 1,2,3
19) Inspection requirements for TSDFs 2,3
20) Requirements for the pickup of hazardous waste 2,3
21) Requirements for the transport of hazardous waste 2,3
22) Dispose of hazardous waste in a timely manner 1,2

23) Respond properly under emergency conditions 1,2,3
24) Procedures to cleanup spills 1,2,3
25) Understand the importance of properly handling and disposing
of hazardous waste to protect employees and the environment
26) Understand the basis for these requirements
1,2,3

1,2,3

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 3 – Personnel Training UTD009081357
5

1. Orientation training. Item numbers 1, 2, 3, 4, and 5 and parts of number 6, 7, 8, and 9
listed above will be covered in orientation training. These items will also be
reinforced on the job.
2. Formal, Structured on-the-job-training. Parts of items 6, 7, 8, and 9 and items 10
through 26 will be covered on the job.
3. Specialty training. This is classroom instruction indirectly related to hazardous waste
operations. Some of these courses are: Asbestos, Propellant Material Handling,
Environmental awareness and Hazardous Waste Disposal and Hazardous Waste for
Dock Coordinators. All training must be recorded.

Employees will not be allowed to handle hazardous waste unsupervised until they have
successfully completed the training program. Training will be completed within six months of
the employee's hire date. There will also be annual refresher training (similar to new hire
training) conducted for all employees affected by the program to assure they are always
adequately trained. This training will consist of, at a minimum, a review of their initial training
in both contingency procedures and the hazardous waste management procedures relevant to the
positions in which they are employed. All training will be evaluated to ensure compliance and
safety. Performance will be measured against specific standards set out at the beginning of the
program.

TRAINING DOCUMENTATION

The following documents and records will be maintained at the facility and made available for
review by the Division of Waste Management and Radiation Control upon request:

1. The job title for each position at the facility related to hazardous waste management,
and the name of the employee filling each job;
2. A written job description for each position listed under number one above. The
description will include the requisite skill, education, or other qualifications and
duties of the employees assigned to each position;
3. A written description of the type and amount of both introductory and continuing
training that will be given to each person filling a position under number one above;
4. Records that document that the required training or job experience has been given to,
and completed by the appropriate personnel.

APPROACH

The training is divided into the following three categories:

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 3 – Personnel Training UTD009081357
6

Records of the training will be kept until closure of the facility or for three years after the
employee leaves the Company.

CONCLUSION

The training program presented in this outline is made up of a number of different components,
all of which work together and supplement each other. All of these components are under the
guidance, supervision, and management of a combination of professional trainers, line
supervision, and hazardous waste management professionals. The trainers are skilled in current
instructional technologies, have appropriate educational backgrounds, and the work experience
to qualify them for this assignment. Much of the training is already being done in one form or
another. Throughout its life, the program will continue to be evaluated and revised. This will
ensure that it is continually improved, current, and in compliance. The program will meet the
needs of the employees, the environment, the law, and the Company.

ATTACHMENT 4

CONTINGENCY PLAN

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
2

HAZARDOUS WASTE MANAGEMENT

Contingency Plan and
Emergency Procedures
For Spills of
Hazardous Materials

July 2019

Northrop Grumman Systems Corporation
Promontory Facility
P.O. Box 707, Brigham City UT 84302-0689
[phone]

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
3

PREFACE

This document, HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND
EMERGENCY PROCEDURES FOR SPILLS OF HAZARDOUS MATERIALS, (herein
referred to as Contingency Plan), provides written instructions on how to take care of spills of
hazardous substances. It is intended to meet the requirements of the Utah Hazardous Waste
Rules and Subpart D of the U.S. EPA Resource Conservation and Recovery Act.

This CONTINGENCY PLAN does not replace, nor is it to be used instead of, the Northrop
Grumman Systems Corporation - Promontory EMERGENCY MANAGEMENT PLAN, or any
other plan which outlines procedures to be followed during general emergencies, disasters, civil
disturbances, riots, bomb threats, etc.

Most spills involving hazardous substances will not require use of the EMERGENCY AND
DISASTER RESPONSE PLAN. Spills that create an emergency situation involving possible
injury to personnel or damage to property will require use of the EMERGENCY
MANAGEMENT PLAN to take care of the emergency. This CONTINGENCY PLAN applies
to containment and cleanup of a hazardous waste spill.

Definitions in the HAZARDOUS WASTE MANAGEMENT CONTINGENCY PLAN AND
EMERGENCY PROCEDURES reflect U.S. EPA and State of Utah environmental language
while those in the EMERGENCY MANAGEMENT PLAN reflect OSHA, UOSH, FEMA, and
Northrop Grumman Systems Corporation language. The user must be careful not to be confused
by differences in language between these documents and must evaluate the applicability of each
document to the particular situation.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
4

TABLE OF CONTENTS

I. INTRODUCTION ......................................................................................................................... 1
A. PURPOSE ............................................................................................................................. 1
B. SCOPE 1
C. NOTIFICATION ................................................................................................................... 1
D. POSTING .............................................................................................................................. 1
E. REVISIONS AND UPDATING ........................................................................................... 1
F. DEFINITIONS ...................................................................................................................... 2
G. PLANT LOCATIONS AND SITE INFORMATION .......................................................... 5
H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS, OR
RELEASES .............................................................................................................. 7

II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION ........................................ 7
A. EVACUATION CRITERIA ................................................................................................. 7
B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL ........................................ 7
C. REPORTING OF EMERGENCY INCIDENTS ................................................................... 8
D. PERSONNEL RESPONSIBILITIES .................................................................................... 8
E. ALARM SYSTEMS ........................................................................................................... 19
F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND
HOSPITALS .......................................................................................................... 15

III. SPILL CONTAINMENT AND CLEANUP ................................................................................ 16
A. CONTROL PROCEDURES ............................................................................................... 16
B. SPILL CONTAINMENT AND CONTROL ...................................................................... 16
C. SPILL CLEANUP ............................................................................................................... 16
D. FOLLOWUP PROCEDURES ............................................................................................ 17
E. INCOMPATIBLE WASTE ................................................................................................ 18
F. CLEANUP MATERIAL AND EQUIPMENT ................................................................... 18
G. DECONTAMINATION EQUIPMENT AND PROCEDURES ......................................... 20
H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT .................................. 20

IV. INSTALLATION RESPONSE TEAM TRAINING ................................................................... 21
A. TRAINING ......................................................................................................................... 21
B. SIMULATION .................................................................................................................... 22

V. TRAINING PLAN ....................................................................................................................... 22
A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN ............................................ 22
B. REVIEW OF LEGAL REQUIREMENTS ......................................................................... 22
C. LOCAL NGSC CORPORATION REQUIREMENTS ....................................................... 22
D. CUSTOMER REQUIREMENTS ....................................................................................... 22
E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM MEMBER . 22
F. EMERGENCY COMMUNICATION SYSTEM ............................................................... 22
G. FIRE PLANS/FIRE DRILL ................................................................................................ 22
H. BOMB SEARCH TECHNIQUES ...................................................................................... 22
I. FIRE BARRICADE/CORDON AREAS ............................................................................ 23
J. EMERGENCY MEDICAL TREATMENT ........................................................................ 23
K. SECURITY OF SITE .......................................................................................................... 23
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
5

L. INVESTIGATION .............................................................................................................. 23
M. PUBLIC RELEASE OF INFORMATION ......................................................................... 23
N. FACT-FINDING METHODS............................................................................................. 23
O. SAFING THE AREA .......................................................................................................... 24
P. CONTROL OF THE CURIOUS ......................................................................................... 24
Q. HANDLING OF REMAINS ............................................................................................... 24
R. NOTIFICATION PROCEDURES ...................................................................................... 24
S. RESCUE EFFORTS ........................................................................................................... 24

TABLES

TABLE I COMPATIBILITY INFORMATION ................................................................................. 25
TABLE II EMERGENCY COORDINATOR CALL LIST ................................................................ 26

FIGURES

FIGURE 1. DECONTAMINATION/SPILL SCENE ......................................................................... 27
FIGURE 2. DECONTAMINATION ................................................................................................... 28

APPENDIX I

NORTH PLANT SITE MAP ................................................................................................... 30
SOUTH PLANT SITE MAP ................................................................................................... 31
TEST AREA SITE MAP ......................................................................................................... 32
PLANT 3 SITE MAP............................................................................................................... 33
M-136 BURNING GROUNDS FACILITY FUNCTION TABLE ......................................... 34
M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE ............................ 34
M-136 SITE MAP AND EVACUATION PLAN…………………………………………....35
M-186 SITE MAP AND EVACUATION PLAN ................................................................... 36
E-501 STORAGE YARD FACILITY FUNCTION TABLE .................................................. 37
E-501 SITE MAP AND EVACUATION PLAN ................................................................... 38
M-225 BURNING GROUNDS FACILITY FUNCTION TABLE ......................................... 39
M-225 SITE MAP AND EVACUATION PLAN ................................................................... 40
T-29B SATELLITE ACCUMULATION AREA FUNCTION TABLE ................................. 41
T-29B SITE MAP AND EVACUATION PLAN .................................................................... 42
M-705 WASTEWATER TREATMENT FACILITY FUNCTION TABLE .......................... 43
M-705S HAZARDOUS WASTE CONSOLIDATION ROOM.............................................. 43
M-705L HAZARDOUS WASTE TREATMENT BY OXIDIZER LEACHING ROOM ...... 43
M-705 SITE MAP AND EVACUATION PLAN ................................................................... 44
M-629 PROPELLANT STORAGE FUNCTION TABLE ...................................................... 45
M-629 SITE MAP AND EVACUATION PLAN ................................................................... 46
S-633 PROPELLANT STORAGE FUNCTION TABLE…………………………….……....47
S-633 SITE MAP AND EVACUATION PLAN…………………………………………..….48

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
6

APPENDIX II

A. BULK FLAMMABLE LIQUID STORAGE AREAS ............................................................ 50
B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE ................................ 51

APPENDIX III

ARRANGEMENTS WITH LOCAL
AUTHORITIES…………………………………………………..52
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
7

I. INTRODUCTION

A. PURPOSE

This plan may be activated by requesting emergency response on phone number
2222 or 911.

The purpose of this Contingency Plan and Emergency Procedures is to set forth
responsibilities, establish organizational structure, and outline the procedures
required to ensure effective warning, response, and control to minimize hazards to
human health or the environment from fires, explosions, or any unplanned sudden or
non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or
surface water.

B. SCOPE

This organizational plan is intended to meet requirements of the Utah Hazardous
Waste Management Rules (UAC R315-264-50 through R315-264-56) and Subpart D
of the Resource Conservation and Recovery Act.

The provisions of this plan will be carried out immediately whenever there is a fire,
explosion, or release of hazardous waste or hazardous waste constituents at one of
the permitted facilities that could threaten human health or the environment. This
plan specifically addresses company actions to be initiated in the event of a spill or
release of hazardous materials.

C. NOTIFICATION

Incidents covered by this contingency plan and which meet applicable State of Utah
and U.S. EPA reporting requirements will be reported to the appropriate agencies by
Environmental Specialists. The Environmental Specialist should confer with the
Manager of Environmental Services prior to notification.

D. POSTING

Copies of the Contingency Plan and all revisions must be:

1. Maintained at the facility and the Fire Department's Spill Response vehicle.

2. Submitted to all local police departments, fire departments, hospitals, and State
and local emergency response teams that may be called upon to provide
emergency services. (Arrangements have been made between Northrop
Grumman Systems Corporation – Promontory and the hospitals located at
Brigham City and Tremonton regarding emergency services that would be
provided as required. Letters of notification are kept in the Operating Record.)
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
8

E. REVISIONS AND UPDATING

This contingency plan will be reviewed and amended whenever:

1. Applicable regulations are revised.

2. The plan fails in an emergency.

3. The facility changes its design, construction, operations, maintenance, or other
circumstances in a way that materially increases the potential for fires,
explosions, or release of hazardous waste or hazardous waste constituents, or
changes the response necessary in an emergency.

F. DEFINITIONS

G.
1. Disaster - An event in which loss of life, serious and/or multiple injuries, major
property or environmental damage, or major disruption of normal operations has
occurred. This includes serious fires or major hazardous material spills,
explosions, injuries to multiple people, and acts of nature such as floods, violent
storms, or earthquakes.

2. Discharge - The accidental or intentional spilling (see Spill), leaking, pumping,
pouring, emitting, emptying, or dumping of hazardous waste on or into the air,
land, or water.

3. Emergency - A situation which, if not quickly controlled, can lead to death,
serious and/or multiple injuries, major loss or damage to property, significant
damage to the environment, or disruption of normal operations.

4. Emergency Command Unit - The group of personnel selected by the
emergency commander to assist in the full scope administration of the
emergency.

5. Emergency Commander - The General Manager or his designee, as head of the
Command Unit, is responsible for the overall direction, coordination, and
function of all units charged with providing countermeasures to cope with
conditions and/or events within the scope of this plan. The Command Unit will
consist of any and all persons selected by the Emergency Commander.

NOTE
The Emergency Commander will be the head of the
Command Unit for all civil disturbances, bomb threats,
national emergencies, and natural disasters.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
9

The Command Unit will operate from a pre-designated Emergency Operations
Center specified by the Emergency Disaster Response Plan or the Emergency
Commander.

6. Emergency Operations Center (E.O.C.) - The location of senior management
where decisions and incident specific policies are made.

7. Environmental Specialist - The Environmental Specialist is the Spill Team
Leader from Environmental Services. He or his designated alternate will assist
the Incident Commander in the evaluation of the impact on the environment
resulting from any emergency, disaster, or hazardous substance discharge.

NOTE
When required, notification of Federal, State, and/or
local environmental agencies shall be through the
Environmental Specialist. Company policy requires
that the event be discussed with the Vice President of
the applicable division and Northrop Grumman Sector
Environmental.

8. Fire Brigade - A group of employees, generally from maintenance, who have
received HAZWOPER training and are called on as needed to assist the
full-time fire department in emergency response.

9. Fire Warden - A designated individual assigned in advance to assist the fire
department in evacuation procedures and give information on the building and
surrounding area.

10. Hazardous Waste - Identified in UAC R315-261 on the basis of specific listed
material and general characteristics. Specific listed wastes are found in these
documents. The U.S. EPA regulations provide detailed technical specifications
of four characteristics:

Ignitable (D001) - An ignitable compressed gas, an oxidizer, a liquid having a
flashpoint < 140 F, or a non-liquid capable of causing fire,
under standard temperature and pressure, through friction,
absorption, moisture, or spontaneous chemical changes.

Corrosive (D002) - A solid waste that (1) is aqueous and has a pH < 2 or > 12.5; or
(2) is a liquid and has a corrosion rate > 0.25 inches/year on
steel.

Reactive (D003) - A solid waste that:

a. Is unstable and readily undergoes violent change without
detonating.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
10

b. Reacts violently with water.

c. Forms potentially explosive mixtures with water.

d. Generates toxic gases, vapors or fumes in a quantity
sufficient to present a danger to human health or the
environment when mixed with water.

e. Is a cyanide or sulfide bearing waste which can generate
toxic gases, vapors, or fumes in a quantity sufficient to
present a danger to human health or the environment when
exposed to pH conditions between 2 and 12.5.

TCLP Toxicity - (as determined by Toxicity Characteristic Leachate Procedures)
- Presence of certain listed toxic materials at levels greater than
those specified in the regulation.

11. Chemical Safety Software EMS-E - a computer based system which contains
a scanned image of the SDS, plus additional safety and disposal information.

12. Hazardous Waste Profile Data (HWPD) Sheet - A Northrop Grumman
Systems Corporation (NGSC) document that lists all U.S. EPA, DOT, and
chemical information needed for marking, labeling, and identifying waste
streams on plant.

13. Hazardous Waste Operations and Emergency Response (HAZWOPER) -
Refers to specific training requirement for handling hazardous materials and for
emergency operations. These requirements are found in 29 CFR 1910.120.

14. Human Resource Coordination - An intermediate between management and
personnel who deals with employee concerns and interests.

15. Incident Commander/Emergency Coordinator - The Incident Commander
will be the on-duty Assistant Fire Chief/Incident Commander.

The Incident Commander will direct the activities of all Field Units from a
designated control point at the scene of the emergency, disaster, or other event.

The Security Manager will be the Incident Commander for countermeasures in
situations caused by hostile persons.

The Fire Prevention Captain will act as Incident Commander until relieved by
an Assistant Fire Chief.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
11

The following items are identified as principles for the Emergency Commander
and Incident Commander to apply to the unique circumstances of the emergency
or disaster:

a. Assist the injured.

b. Stabilize situation and site.

c. Assure evidence is not destroyed, lost, or moved.

d. Record situation through text, photographs, videos, and/or mapping.

e. Notify State and local officials.

f. Secure and admit only qualified essential personnel to the site.

g. Debrief participants.

16. Safety Data Sheet (SDS) - Provides information on safe handling, proper PPE,
and disposal information for each chemical. This document is prepared by the
chemical manufacture. For additional information, contact your local Industrial
Hygiene representative.

17. Non-sudden Release - The accidental discharging (see Discharge), spilling,
leaking, pumping, pouring, emitting, emptying, or dumping of hazardous wastes
or materials which, when spilled become hazardous wastes, into or on any land
or water over an extended period of time. This also includes spills onto asphalt
or concrete pads.

18. Reportable Spill (Discharge) - A hazardous waste spill which must be reported
to the Division of Environmental Response (DERR) and Remediation, National
Response Center and/or other applicable Federal, State or local authorities. The
Utah Hazardous Waste Management Rules list reportable spill quantities as:

a. One kilogram (2.2 lb.) of material in accordance with
UAC R315-263-30(b)(1). A spill of a lesser quantity must be reported if
there is a potential threat to human health or the environment.

b. One-hundred kilograms (220 lb.) of hazardous waste or material which,
when spilled, becomes hazardous waste, in accordance with
UAC R315-263-30(b)(2). A spill of a lesser quantity must be reported if
there is a potential threat to human health or the environment.

c. The Utah Administrative Code R315-264-196 stipulates that a spill of 1 lb.
from a leaking hazardous waste sump is a reportable quantity.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
12

NOTE
For complete descriptions and listings, contact
Environmental Services or refer to UAC R315-263 of
the Utah Hazardous Waste Management Rules.

The following is a partial list of materials used at NGSC and the quantities
which, if spilled, would require State or Federal notification:

U.S. EPA Utah

Material Quantity Quantity
Acetone 5000 lbs. 220 lbs.
Methanol 5000 lbs. 220 lbs.
Methylchloroform 1000 lbs. 220 lbs.
Methylene Chloride 1000 lbs. 220 lbs.
Methyl Ethyl Ketone 5000 lbs. 220 lbs.
Methyl Isobutyl Ketone 5000 lbs. 220 lbs.
Nitroglycerin 10 lbs. 2.2 lbs.
Propellants, reactive
materials (HMX)
oxidizers (AP) 100 lbs. 220 lbs.
Sodium Azide 1000 lbs. 2.2 lbs.
Toluene 1000 lbs. 220 lbs.
Xylene 100 lbs. 220 lbs.

19. Solid Waste - Any discarded material that is a solid, liquid, semi-solid, or
contained gaseous material resulting from industrial, commercial, mining, or
agricultural operations and is not excluded under UAC R315-261-4(a), UAC
R315-260-30, or UAC R315-260-31.

20. Spill - The accidental discharging (see Discharge), spilling, leaking, pumping,
pouring, emitting, emptying, or dumping of hazardous wastes or materials
which, when spilled become hazardous wastes, into or on any land or water.
This also includes spills onto asphalt or concrete pads.

21. Environmental Services - A department with expertise in the areas of
hazardous waste, air and water management, including environmental
regulations in these areas.

G. PLANT LOCATIONS AND SITE INFORMATION

1. The Northrop Grumman Systems Corporation – Promontory plant is located in
Box Elder County approximately 30 miles northwest of Brigham City. The 30-
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
13

square mile plant site is remote from any major population centers and is
reasonably isolated from ranches located at varying distances from the area
boundaries. The plant site is composed of four major areas in which
manufacturing and testing activities take place: South Plant, North Plant,
Test Area, and Plant 3. There are approximately 675 buildings located on the
plant site, (See Appendix I for facility site maps).

NGSC owns and operates these 4 areas. All of these areas are contiguous and
waste disposal is managed by one organization.

From the beginning of operations in 1956 to the present time, plant activities
have encompassed a wide range of programs requiring the production of solid
rocket propellants, rocket motor testing, and industrial support necessary to
achieve each program's objectives. Solid rocket motors manufactured during
this period vary from motors containing 7-9 lb. of propellant to 1,400,000 lb.
Programs have included Space Shuttle SRM, Peacekeeper, Trident, SRAM,
HARM, Standard, Genie, Minuteman, Poseidon and a variety of ground and air
launched flares.

2. The plant site has nine hazardous waste treatment and storage facilities: Burning
Grounds at M-136, and M-225; Drum Storage areas at E-501 and M-186; the
T-29B Hydrazine Dilution Facility; the M-705S Hazardous Waste Consolidation
Room; the M-705L Oxidizer Leaching Treatment Facility; and the solid
propellant waste storage facilities at building M-629 and storage pad S-633.
The site maps and evacuation plans for these facilities are shown in Appendix I.

These nine facilities serve as waste management units for the entire facility.
Reactive wastes treated at the burning grounds include waste propellants, waste
explosives, oxidizers, or solid waste contaminated with propellants, explosives,
or oxidizers. No propellants or explosives are ever stored in the drum storage
areas; hazardous wastes that are flammable, toxic, or corrosive are stored in
these units. The Hydrazine Dilution Facility at T-29B dilutes waste hydrazine
to between 5 to 50 percent by volume for shipment to an off-plant disposal site.
The M-705 Wastewater Treatment Facility treats hazardous and industrial
waters from building sumps. Hazardous wastes are consolidated and lab packed
at the M-705S Hazardous Waste Consolidation Room. The M-705L Oxidizer
Leaching Facility treats 1.3 explosives or propellants by water leaching removal
of the oxidizer from the explosives or propellants.

3. Approved hazardous waste accumulation areas are described in Table I.

4. Fire hydrants are located as follows: 101 hydrants in the Administrative and
Manufacturing area, 95 at North Plant, 47 in the Test Area, and 9 in Plant 3.
Static and dynamic pressure heads have been measured for each hydrant and the
Fire Department maintains this information. The fire protection system at the
plant site meets the NFPA codes for fire protection. NGSC owns and operates
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
14

two pumper fire engines and two brush trucks which are used for emergency
response.

The following water tanks are interconnected:

Location Capacity (gal)

X-1 200,000
X-2 20,000
M-131 50,000
M-132 50,000
M-133 100,000
M-587 (North Plant) 1,000,000
M-696 20,000
T-59 (Test) 1,000,000

The M-203 (Propellant Development Area) water tank with a 100,000 gallon
capacity is not interconnected to the other tanks.

Fire hydrants throughout the plant are color coded according to capacity.

Color Code Flow Capacity (gpm)

Green Fire Hydrant 1,000 or more
Orange Fire Hydrant 500 - 1,000
Red Fire Hydrant 500 or less

5. Information depicting the capacity, location, and practical consequences of a
catastrophic failure of large hazardous material storage areas is found in
Appendix II C, p.67.

6. All buildings with 10 or more regular occupants have an evacuation plan posted
at all major exits of the building. (See Appendix I for the site maps and
evacuation routes of the hazardous waste treatment and storage facilities).

H. PREVENTION OF RECURRENCE OR SPREAD OF FIRES, EXPLOSIONS,
OR RELEASES

1. There are many steps that can be taken to prevent the recurrence and spread of
fires, explosions, or releases at the drum storage areas, burning grounds, and
operating buildings. These include limiting propellant quantities placed in the
burning trays, following safe handling procedures, personnel training,
segregating incompatible and reactive materials in the burning trays and in the
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
15

drum storage areas, practicing good housekeeping procedures, proper labeling,
regular inspections, and separating the burning trays by safe distances. These
procedures are outlined in company operating manuals.

2. Each fire, explosion, or release into the environment is unique. The Incident
Commander must be an experienced individual who will take all possible steps
to prevent a recurrence, to limit the extent of the damage, and to stop the
discharge. These steps may include:

a. Stopping processes and operations.

b. Collecting and containing released wastes.

c. Removing and isolating containers.

d. Preventing additional harm to the environment through knowledge of the
potential hazards associated with storage areas (found in Appendix II, A
and B, pp. 65 and 66, their locations, capacities, and identification.

3. User organizations conduct regular inspections on items such as bulk storage
containers that store hazardous wastes or materials which, if released to the
environment, would become hazardous wastes. Audits are taken on volumes of
stored materials versus consumption to ensure that non-sudden releases are not
occurring. If a non-sudden release of materials is discovered, steps are taken
immediately to minimize the impact on the environment.

II. REPORTING PROCEDURES AND INCIDENT IDENTIFICATION

A. EVACUATION CRITERIA

1. A fire that is a threat to human safety.

2. A spill that is a threat to human safety.

B. IDENTIFICATION OF A HAZARDOUS WASTE IN A SPILL

1. The building personnel working the operation identify the material.

2. The SDSs are referred to for chemical constituents, health hazards and
protective clothing.

3. The Hazardous Waste Profile Data sheet, Chemical Safety Software EMS-E, or
SDS is referred to for proper disposal of the waste.

C. REPORTING OF EMERGENCY INCIDENTS
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
16

1. Spilled material is reported to Security.

2. Security contacts the Environmental Service’s Spill Advisory Team and Safety
for technical support and advice.

3. Environmental Services contacts the State and U.S. EPA to report the incident
(if required).

4. Environmental Services obtains the log from Security to prepare the written
report to the State.

5. Within 15 days, Environmental Services submits the written report to the State
and maintains a permanent copy in the Environmental Services' Central File as
required.

D. PERSONNEL RESPONSIBILITIES

1. EMERGENCY MANAGER

a. At all times, there shall be at least one employee either present on the
facility premises or on call with the responsibility for coordinating all
emergency response measures.

b. The facility emergency coordinator is thoroughly familiar with all aspects
of the facility's contingency plan, all operations and activities at the facility,
the location and characteristics of waste handled, the location of manifests
and all other records within the facility, and the facility layout, or has
immediate access to persons with this information.

c. This person shall have the authority to commit the resources needed to carry
out the contingency plan.

d. Arranges for and directs a spill contingency plan simulation.

2. EMPLOYEES, FIRST LINE SUPERVISORS AND FIRE WARDENS

a. Report all fires or emergencies by activating the fire alarm or calling the
emergency number.

b. Report from a safe telephone location:

Your name and phone number
Type of incident (fire, explosion, injury, spill, etc.)
Location of incident

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
17

c. Stay on the line when possible until released by the emergency operator.

d. Do not attempt to fight fires involving live or possibly toxic hazardous
materials.

e. Do not attempt to contain spills that are beyond capability or training.

3. FIRST LINE SUPERVISORS

a. Ensure personnel evacuate buildings or areas to the assembly point
indicated on the Emergency/Evacuation Plan located in each building.

NOTE
Handicapped personnel must be provided priority and
assistance during evacuation and assembly.

b. Advise the Fire Captain and the Incident Commander of conditions at the
scene.

c. Account for all employees that were in or assigned to the affected building
or area.

d. Report any injured or missing personnel to the Incident Commander.

e. Remain at the assembly point until released by the Incident Commander.

f. Notify appropriate Safety Department and fill out a Mishap Report.

4. INCIDENT COMMANDER

a. Initiate the first response actions.

b. Contact line supervision at the assembly point to determine the details of
the situation:

i. Nature of incident.

ii. Number of personnel injured or not accounted for and the location of
their last known assignment.

iii. Location and type of hazardous materials that may be exposed to fire or
explosion (Quantity Distance Criteria).

c. Applicable Quantity Distance Criteria.

d. Assume control of emergency area.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
18

e. Declare severity of event such as an emergency or disaster as appropriate.

f. Establish emergency scene, coordinate roadblocks, cordon the site, and
control entry/exit from the area.

g. Make an initial assessment of situation.

h. Notify the Security Radio Dispatcher as appropriate, close the switchboard,
if absolutely necessary. The Environmental Specialists must be included if
a building deluge system has been activated and the building sump has
overflowed or another known spill of hazardous material has taken place.

i. Identify safe response routes for follow-on units.

j. Coordinate activities with other emergency units.

k. Commit rescue and first aid crews as necessary.

l. Obtain emergency rescue and ambulance as required.

m. Keep the Emergency Commander informed of the emergency situation.

n. Request outside assistance from the EOC as needed.

p. Check with building’s supervision to identify propellant ingredients and
hazardous constituents in any building or building sump which must be
pumped by Water Operations personnel. Evaluate what hazards, if any,
exist which may hinder safe access to the building.

q. Perform actions in accordance with 29 CFR 1910.120 (HAZWOPER).

5. SECURITY

a. Set up roadblocks as directed by the Incident Commander to preclude
unauthorized entry of personnel and provide clear traffic flow for
emergency vehicles.

b. Coordinate with Incident Commander to ensure orderly evacuation of
personnel.

c. Provide protection for classified information, valuable records, and special
equipment.

d. Ensure protection of Company and Government property from theft or
sabotage.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
19

e. Provide proper disposition, storage, and protection of classified material in
accordance with the Department of Defense Industrial Security Manual.

f. Establish perimeter boundary for emergency scene, set up road blocks,
cordons, etc.

g. Above actions must be consistent with HAZWOPER requirements.

6. SECURITY RADIO DISPATCHER

a. When directed by the Incident Commander, notify appropriate personnel in
accordance with the Emergency and Disaster Response Plan.

b. Monitor and record all emergency radio communications, and establish
required communications between radio units.

c. Upon direction of the Incident Commander, notifies appropriate NGSC
management.

7. TELEPHONE OPERATORS

a. When directed by the Incident Commander, refuse incoming and outgoing
calls unless directed otherwise by the Emergency Commander.

8. INDUSTRIAL HYGIENIST

a. Report to the Incident Commander at the assembly point or Field Command
Post.

b. Advise the Incident Commander on emergencies involving toxic chemical
or radiation hazards.

c. Perform the following activities as necessary:

i. Sample air at the scene, including any sumps which have to be pumped.
(if determined to be necessary by the Industrial Hygienist (IH) on the
scene)

ii. Monitor radioactivity at the scene. (if determined to be necessary by the
IH on the scene)

iii. Advise Emergency Response Team concerning proper decontamination
controls.

iv. Notify Medical Services of personnel exposure to toxic chemicals or
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
20

radioactive materials.

v. Advise the Incident Commander to notify public health authorities.

d. Performs these duties in accordance with HAZWOPER requirements.

9. MAINTENANCE CRAFTS PERSONNEL

a. Respond to all alarms when notified by the Security Police Radio
Dispatcher and report to the Incident Commander at the command post.

b. Control distribution of air, water, steam, and electrical power as directed by
the Incident Commander.

c. Provide equipment, barricading, and shoring as necessary per direction of
Incident Commander.

d. As Fire Brigade, assist when needed.

e. Provide construction type materials and services for containment of
hazardous material spills.

f. Performs these duties per direction of Incident Commander.

10. ENVIRONMENTAL SERVICES PERSONNEL

a. Report to the Incident Commander at the command post, when notified by
Security Police Radio Dispatch.

b. Perform duties as directed by the Incident Commander after material to be
collected has been identified, any hazards associated with the material have
been identified, and safe procedures to handle the material have been
established.

c. Perform these duties in accordance with HAZWOPER requirements.

d. Advise the Incident Commander on potential environmental hazards, safe
handling, and disposal options.

11. MEDICAL SERVICES PERSONNEL

a. Remain at or report to the Dispensary to receive and treat patients.

b. Report to the emergency area when requested by the Incident Commander.

c. Coordinate with surrounding community hospitals and doctors for the
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
21

receipt and treatment of injured.

d. Requisition supplemental medical supplies, equipment, and personnel as
needed. May request helicopter transportation in life or death situations.

e. Conduct and supervise treatment for injured personnel.

f. Review SDS and other relevant information, and transmit same to receiving
hospital.

12 TRANSPORTATION PERSONNEL (IN-PLANT TAXI SERVICE)

a. Coordinate with Incident Commander to ensure adequate transportation of
plant personnel.

13. EMERGENCY COMMANDER

a. Control and coordinate overall activities of the emergency situation. The
Emergency Commander will work from the Emergency Command Center,
and will assist and direct the On-Scene Incident Commander as needed.

b. Evaluate situation and determine need to convene the Emergency Command
Unit.

c. Direct the Telephone Operators to open or close the switchboard according
to the nature of the emergency.

d. Open the Emergency Operations Center as necessary.

e. Identify the disaster potential posed by the emergency.

f. Make the disaster declaration when necessary (disaster responsibilities are
listed in Section III).

14. PHOTOGRAPHER

a. Report to the Incident Commander at the Command Post.

b. Advise the Incident Commander on photo coverage.

c. Photograph the scene as directed.

d. Expedite printing and delivery of the photographs.

e. Interpret the photographs as required.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
22

15. HUMAN RESOURCES COORDINATOR

a. Provide food and assistance with personal needs for emergency team
members and those affected.

b. Notify next of kin of injured persons when advised by Emergency
Commander. (See Section IV, the Emergency and Disaster Response Plan
for procedures).

16. ENVIRONMENTAL SPECIALIST

a. Assess possible environmental hazards resulting from the incident including
assessment of spills caused by the activation of a building deluge system
which in turn caused the building sump to overflow.

b. Initiate reports required by the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA) and Utah Waste Management
and Radiation Control Regulations.

c. Determine (along with the responding local emergency agency) whether the
facility has had a discharge, fire, or explosion which could threaten the
environment outside of the facility. Assure immediate implementation of
emergency procedures.

d. Notify the State and Federal environmental agencies as required.

e. The Environmental Specialist contacts either the government official
designated as the on-scene coordinator or the National Response Center,
[phone], and the DERR at [phone] to relaying the following
information:

i. Name and telephone number of reporter.

ii. Name and address of facility.

iii. Time and type of incident (such as discharge, fire, etc.).

iv. Name and quantity of material(s) involved, to the extent known.

v. The extent of injuries, if any.

vi. The possible hazards to human health or to the environment outside the
facility.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
23

f. Notify the NG Sector Environmental Engineer if the spill is reportable.

David Shead
[phone]

g. Utah Hazardous Waste Management Rules require that the Environmental
Specialist note in the operating record the time, date, and details of any
incident that requires implementing the contingency plan. Within 15 days
after the incident, he must submit a written report on the incident to the
Director of the Division of Waste Management and Radiation Control. The
report must include:

i. Name, address, and telephone number of the owner or operator.

ii. Name, address, and telephone number of the facility.

iii. Date, time, and type of incident (such as fire, explosion, etc.).

iv. Name and quantity of material(s) involved.

v. The extent of injuries, if any.

vi. An assessment of actual or potential hazards to human health or the
environment where this is applicable.

vii. Estimated quantity and disposition of material recovered from the
incident.

h. Notify the community emergency coordinator for the local emergency
planning committee in compliance with requirements outlined in UAC
R315-263-30 and UAC R315-263-33, where applicable.

i. Immediately after an emergency, the Environmental Specialist must provide
direction for treating, storing, or disposing of recovered waste,
contaminated soil or surface water, or any other material that results from a
discharge, fire, or explosion at the facility.

j. The Environmental Specialist and the Incident Commander must ensure
that, in the affected area(s) of the facility:

i. A determination is made who will do the spill remediation work
(Building Personnel, NGSC Spill Remediation Team, or Off-Site
Contractor).

ii. No waste that may be incompatible with the discharged material is
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
24

stored or disposed of until cleanup procedures are completed; and

iii. All emergency equipment listed in the contingency plan is cleaned and
ready for its intended use before normal operations are resumed.

17. CORPORATE PUBLIC AFFAIRS

a. Establish liaison with representatives of public information media.

b. Prepare drafts of general/public information press releases relating to the
emergency.

c. Release information as directed by the Emergency Commander, according
to NGSC Policy.

18. RECORDER

a. Record incoming and outgoing communications at the EOC.
.
b. Record all significant events and actions.

c. Initiate and maintain record information in a timeline log.

d. Assist in the preparation of interim and final reports.

E. ALARM SYSTEMS

1. Alarm systems are available at NGSC for fires or building evacuations if an
emergency or disaster situation exists:

Type People/Materials Sound

Fire and Building People Fire Alarm
Evacuation

Hazardous Waste People Verbal Signal (or fire alarm,
if available)

Storage and
Thermal Treatment Materials Verbal Signal (fire alarm or
air horn, if available)

2. The hazardous waste storage facility at E-501 is located outdoors in open areas,
evacuation of personnel will be in any direction away from the problem. The
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
25

assembly area for E-501 is directly across the street (to the north) from the entrance
gate.

3. The hazardous waste storage facility at M-186 is a large single room building with
five bays each having containment. M-186 is equipped with three man door exits to
the west, and five rollup doors on the east side. The M-186 building is heated. The
assembly point for M-186 is at the M-381 trailer.

4. The hazardous waste storage facility at the M-705 Consolidation Room is a single
room equipped with two exits, a single door on the west and a double door on the
east. Both sets of doors open directly to an open outdoor area where personnel are to
evacuate to an area near the intersection of the main in-plant road and the M-705
access road. The room is equipped with a heat sensor alarm, a fire alarm and a
carbon monoxide alarm on the supplied air system.

5. M-629 is a storage building with multiple exits as outlined in the evacuation plan in
Appendix I.

6. Tables and maps showing the function of the various hazardous waste sites and area
evacuation plans are found in Appendix I, p. 34.

F. LOCAL LAW-ENFORCEMENT AGENCIES, FIRE DEPARTMENTS, AND
HOSPITALS

1. Local law-enforcement agencies, fire departments, and hospitals have been
contacted to assist if needed or respond if requested by NGSC to provide
assistance if necessary in an emergency. The most recent copy of this
Contingency Plan is sent to each agency in order to familiarize them with the
layout, description of hazardous wastes handled, and evacuation plan for the
plant. Copies of the letters sent to each agency are kept in the Operating
Record.

2. All emergency response units from off-plant will be escorted from the
Promontory Facility entrance to the fire/explosion/spill site by an NGSC
authorized agent. This will ensure the units reach the location as quickly and
efficiently as possible.

3. As allowed in UAC R315-262-256(c) a facility possessing 24-hour response
capabilities, such as NGSC, may receive a waiver from needing to make
arrangements with the local emergency response agencies provided that the
waiver is documented in the operating record.

III. SPILL CONTAINMENT AND CLEANUP

A. CONTROL PROCEDURES
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
26

1. Detailed emergency response procedures whenever there is a fire, explosion, or
release (spill) are found in the current Emergency Management Plan.

2. Specific directives for cleaning up spills are given in the Environmental
Management System (EMS). There are over 20,000 chemical entries in the
EMS. Approximately 18,000 of the chemicals in current use exhibit hazardous
properties. The SDS documents are managed in-house to provide a standard
format for easy use. Each entry contains SDS information as well as other
information.

3. The Wastewater Treatment Facility (M-705) is designed to treat wastewater
containing hazardous constituents. The responsible building foreman or
supervisor should report to the M-705 facility personnel any spill or accidental
discharge to a sump suspected of containing chemicals at concentrations above
the levels normally discharged. The report should include the incident location,
name of person reporting, chemical involved, and approximate quantity. The
treatment facility personnel will then be able to determine how best to handle
the wastewater.
4. The propellant storage buildings will be inspected daily or weekly as required
when in use. While the propellants stored in these buildings are solid,
occasionally a small amount of nitro glycerin or similar material can ooze from
the motor and drip to the floor. These drips will be checked for during the
inspections, and cleaned up using rags and acetone within 24 hours of discovery
or as soon as is practicable.

B. SPILL CONTAINMENT AND CONTROL

§265.56(e) of the Resource Conservation and Recovery Act (RCRA) states:

"During an emergency, the Emergency Commander must take all
reasonable measures to ensure that fires, explosions and releases do not
occur, recur, or spread to other hazardous waste at the facility. These
measures must include where applicable, stopping processes and operations,
collecting and containing released waste and removing or isolating
containers."

Confine hazardous material spills to the affected area with dams, Quicksorb, or
other approved means. Hazardous material properties may be determined by
consulting the Hazardous Waste Profile Data Sheet, SDS, or the DOT
Emergency Response Guidebook. No attempt will be made to contain a spill
until the hazardous properties are known. Secondary containment is provided
for most storage tanks. For those tanks without secondary containment, consult
Appendix II for spill containment considerations.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
27

C. SPILL CLEANUP

1. Environmental Operations and Environmental Services will be responsible for
the coordination of spill cleanup activities. Building personnel will clean up
smaller sized spills, incidental to the work process, that are deemed within the
skills and level of training possessed by available building personnel, where the
spill occurred. All other spills will be cleaned up by the Spill Remediation
Team or a company contracted by NGSC.

Proper procedures will be followed for every release of hazardous wastes.
Because of the extensive inventory of hazardous materials managed at NGSC,
each release will require specific safety precautions, cleanup procedures, and/or
disposal methods. See Table II p. for chemical compatibility information.

WARNING
Do not attempt to contain or clean up any spill until
hazards associated with the material are known and
proper safety precautions are taken.

2. Response procedures to be used during container spills or leaks are as outlined:

a. Identify the material

! From the hazardous waste label
! From Environmental Operations and Environmental Services inventory
records
! Through laboratory analysis
! From carrier manifest or placard DOT guide number

b. Protect personnel through the use of personal protective equipment specific
to the identified material (refer to EMS or SDS, available from Industrial
Hygiene.)

c. Stops the spill or leak

d. Contain the material

! Eliminate the source
! Use Quicksorb, or other approved methods

e. Clean up the material

! Re-drum
! Wipe up, use absorbent material, excavate soil

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
28

f. Dispose of the material (refer to EMS and Disposal Instructions for
Reactive Waste Materials, RWDI)

g. Decontaminate the site and clean the equipment

D. FOLLOWUP PROCEDURES

1. When the spill has been properly contained and stopped, appropriate
equipment will be used to remove the spilled material to a disposal site.

2. Spills involving very large quantities of material caused by the failure of a
large storage tank should be dealt with as quickly as possible to minimize
exposure to the environment. The method of pickup generally will be
pumping material into a tank truck, the original tank after repairs, or into
another tank. An alternative may be to use the Environmental Waste
Disposal sump truck to pump liquid hazardous wastes. Contact
Environmental Operations and Environmental Services for use.

3. Proper steps will be taken to repair equipment and facilities and/or remove
the cause of the spill.

4. Operating procedures will be changed, if necessary, to prevent recurrence of
a spill.

5. Safety and Operational Training will be instigated, if required.

6. When possible, all reasonable effort will be made to salvage reusable
material.

E. INCOMPATIBLE WASTE

The Environmental Coordinator and Incident Commander will ensure no waste is
incompatible with any material during the cleanup of a discharge. Table II, p. lists
the information and its available location to the Environmental Coordinator and
Incident Commander to make decisions regarding compatibility. All of these
materials are available for inspection at the plant site.

F. CLEANUP MATERIAL AND EQUIPMENT

The following is a partial list of safety equipment that may be used for cleanup as
indicated per Environmental Management System Software (EMS). All items can
be obtained from Stores or from a call contract.

Item Use

Coveralls Live Operations
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
29

Smocks Manufacturing Area
Tyvek Suit (m) Asbestos & Dust
Tyvek Suit (l) Asbestos & Dust
Tyvek Suit (xl) Asbestos & Dust
Tyvek Sack Suit Asbestos & Chemical Spills
Tyvek Hood Asbestos & Chemical Spills
Polyethylene-
Tyvek Suit Asbestos & Chemical Spills
Saranex Tyvek Suit Chemical Spills
Booties (Yellow) Asbestos & Chemical Spills
Booties (Clear) Asbestos & Chemical Spills
Boots (Rubber) Chemical Spills
Glasses, Safety Spills-Less than 1 quart
Monogoggles Spills-Greater than 1 quart
Ear Plugs Noise-Greater than 90 B(A)
Gloves, Rubber (s) Methyl Ethyl Ketone
Gloves, Rubber (m) Methyl Ethyl Ketone
Gloves, Rubber (l) Methyl Ethyl Ketone
Gloves, Leather General Use
Gloves, Cotton General Use
Gloves Solvent Resistant
Gloves, NBR (s) Methyl Chloroform
Gloves, NBR (m) Methyl Chloroform
Gloves, NBR (l) Methyl Chloroform
Respirator, Half Mask
Air Purifying In O2 Sufficient Areas Only
Respirator,
Full-face Cart In O2 Sufficient Areas Only
Respirator, Fresh Air In O2 Deficient Areas Only
Respirator, No. 8710 Dust, Single-use Only
Filter S (Gray) Dusts, Mists, Fumes, Radon
Daughters, Asbestos
Filter H (Purple) Dusts, Mists, Fumes, Radio-
nuclides, Asbestos
Filter GMA (Black) Organic Vapors
Filter GMC (Yellow) Organic Vapors, Acid Gases
Filter GMD (Green) Ammonia & Methylamine
Filter (Purple/Black) Organic Vapors, Dusts, Mists,
GMA-H Fumes, Radionuclides,
Asbestos
Filter (Purple/
Yellow) GMC-H Organic Vapors, Acid Gases,
Dusts, Fumes, Mists,
Radionuclides, Asbestos
Filter (Black/Olive) Pesticides
GMP
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
30

Acetone Propellant solvent
Rumple cloth wipe
Chemliner bag Contain solvent rags
Velostat bag Conductive bag to contain chemiliner

In addition, the following materials are available if required:

Item Location Ext Description

Lumber M-90 2680/2757 Plywood, Lumbers
Sawdust M-90 2680/2757 Bulk
Pipe M-90 2680/2757 All dimensions
Quicksorb (27-200002) M-3 (Stores) 2757 50 lb. Bag
Absorption Clay Landfill 2837 Bulk
Hydrated Lime(54-426006) M-3 (Stores) 2757 50 lb. Bag
Chemical Spill J. T. Baker
Neutralizer
Acids (General) M-53 2617 3.2 kg
Bases (General) M-53 2617/7436 1.2 kg
Flammable Solvents M-53 2617 (1.1 kg) (18 kg)
Mercury Cleanup Kits M-53 2617 0.9 kg
NG Spill and M-585 8446 5 liter bottle
Detector Kit
Bulldozer (Space/DLV) M-55/M-321 2837/2455 D-8
Front-end Loader M-55/M-321 2837/2455 1½ and 3 yd bucket
Portable Lights and M-6 3431 2 Mercury Lamps
Generator
Sump Tank M-136 2520 3,000 gal
Portable Diaphragm Pumps M-55/M-321 2837/2455
General Trucks M-55/M-321 2837/2455 1½ - 5 Ton
SCBA Respirators Fire Dept 2222 30 Min. Tank
Water Ops. Equip M-705 2222 Sump Trucks, Etc.
Spill Response Truck Fire Dept 2222 Spill Response
and Rescue

G. DECONTAMINATION EQUIPMENT AND PROCEDURES

1. Equipment available for decontamination includes two disposable wading pools,
a wood-framed plastic pool carried on the spill truck for tool and spill team
decontamination, and fire trucks to supply wash down water. Decontamination
procedures outlined on Figures 1 and 2 will be followed to ensure spill
containment and to minimize the area of contamination.

2. The M-186 hazardous waste storage site is located near the burning grounds.
This area is serviced by the M-11 Fire Station which is located 5 minutes away.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
31

The M-705 Hazardous Waste consolidation room and the E-501 drum storage
yard are also serviced by the M-11 Fire Station which is located 7 minutes
away. The M-11 Fire Station is outfitted with quick-response spill control
equipment (See maps, Appendix I). In addition, spill response kits are available
at the M-53 and M-585 Laboratories.

H. EQUIPMENT DECONTAMINATION AND REPLENISHMENT

1. The Incident Commander, or his designee, will ensure all equipment has been
properly decontaminated, cleaned, and replaced before normal operations are
resumed. The following guidelines are to be used for decontamination of
equipment after a discharge has occurred. These steps are also supplemented by
the information found in the sources listed in Paragraph F.

2. As much as possible, measures should be taken to prevent contamination of
equipment. Any delicate instrument which cannot be decontaminated easily
should be protected while it is being used. It should be bagged and the bag
taped and secured around the instrument. Openings can be made in the bag for
sample intake.

a. Sampling Devices

Sampling devices require special cleaning. The instruction and care
manuals provide information on proper decontamination methods for each
instrument used.

b. Tools and Equipment

Equipment and tools designated for spill response should be disposable;
however, some tools and equipment require decontamination.

Decontamination equipment, materials, and supplies are generally selected
based on availability. Soft-bristle scrub brushes or long-handle brushes are
used to remove contaminants. Water in buckets is used for rinsing. Large
galvanized wash tanks or stock tanks can hold wash and rinse solutions;
children's wading pools can also be used. Open top (55-gallon) drums or
similar containers lined with plastic bags can be used to store contaminated
clothing and equipment. Contaminated liquids can be stored temporarily in
metal or plastic cans or drums. Other supplies include paper or cloth towels
for drying protective clothing and equipment.

Personal protective equipment, sampling tools, and other equipment are
usually decontaminated by scrubbing with detergent-water using a
soft-bristle brush followed by rinsing with copious amounts of water.
While this process may not be fully effective in removing some
contaminants, it is a relatively safe option compared with using a chemical
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
32

decontaminating solution. Occasionally, a decontamination chemical is
then needed to change the contaminant into a less harmful substance during
decontamination. The Environmental Coordinator and Incident
Commander, or his designee, may consult the information sources in
Table I, p. 33, to determine the necessity of using a chemical
decontamination solution.

All materials and equipment used for decontamination must comply with
proper disposal. Clothing, tools, buckets, brushes, and all other equipment
that are contaminated must be secured in drums or other containers and
labeled. Clothing not completely decontaminated onsite should be secured
in plastic bags before being removed from the site.

Contaminated wash and rinse solutions should be contained to hold spent
solutions. The spent solutions are transferred to drums which are labeled
and properly disposed of. The Environmental Specialist and Incident
Commander, or his designee, will ensure the disposal of these materials is
done in an appropriate manner.

c. Respirators

Certain parts of contaminated respirators, such as the harness assembly and
leather or cloth components, are difficult to decontaminate. If grossly
contaminated, they may have to be discarded with the other spill cleanup
wastes. Rubber components can be soaked in soap and water and scrubbed
with a brush. Regulators must be maintained according to manufacturer's
recommendations. Persons responsible for decontaminating respirators
should be thoroughly trained in respirator maintenance.

d. Heavy Equipment

Bulldozers, trucks, back-hoes, bulking chambers, and other heavy
equipment are difficult to decontaminate. The method generally used is to
wash them with water under high pressure and/or to scrub accessible parts
with detergent/water solution under pressure, if possible. Shovels, scoops,
and lifts may be sandblasted or steam cleaned. Particular care must be
given to those components in direct contact with contaminants such as tires
and scoops. Wash water generated during the decontamination process
must be contained and disposed of in a proper manner.

IV. INSTALLATION RESPONSE TEAM TRAINING

Building/area personnel responding to spills of hazardous materials incidental to the normal
processes within their building/area will not need training beyond that required by NGSC’s
Hazard Communication Program. Personnel responding to spills, who are not assigned to
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
33

the building/area where the spill occurred, are to be members of the Spill Remediation Team
with the proper OSHA training.

NOTE
Hazard Communication Plus Program is a
combination of the HAZ-COM Program required by
OSHA 29 CFR 1910.1200 and HAZWOPER first
awareness level required by OSHA 29 CFR 1910.120.

A. TRAINING

All personnel involved in cleanup operations will be trained. This training will
include an awareness of the locations of cleanup materials and equipment and the
procedures for the operation of such equipment.

V. TRAINING PLAN

One of the most important objectives of the Contingency Plan is to ensure that the
emergency responders are properly trained. Training should include teaching, exercise and
critique phases. Re-training and review should be completed at least annually. The
following is an outline of training plan elements:

A. SCOPE AND PURPOSE OF THE CONTINGENCY PLAN

B. REVIEW OF LEGAL REQUIREMENTS

1. Authority
2. OSHA requirements
3. State requirements
4. U.S. EPA requirements
5. State Fire Marshall requirements
6. Law enforcement requirements
7. Medical Examiner/Coroner requirements

C. LOCAL NGSC REQUIREMENTS

D. CUSTOMER REQUIREMENTS
Contract review

E. REVIEW AUTHORITY AND FUNCTION OF EACH RESPONSE TEAM
MEMBER

F. EMERGENCY COMMUNICATION SYSTEM

1. Initial notification and follow-up
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
34

2. Verification of information
3. Radio discipline
4. Communication intercept

G. FIRE PLANS/FIRE DRILL

1. Use
2. Exercise
3. Evaluate
4. Evacuation
5. Assembly points

H. BOMB SEARCH TECHNIQUES

1. Outside to Inside
2. Left to right
3. Bottom to Top
4. Evacuation
5. Suspect items (Isolate; don't touch or disturb)

I. FIRE BARRICADE/CORDON AREAS

1. Function
2. Initiate/release

J. EMERGENCY MEDICAL TREATMENT

1. EMT training, equipment
2. First response first aid

K. SECURITY OF SITE

1. Purpose
2. Authority
3. Who authorizes access

L. INVESTIGATION

1. OSHA
2. U.S. EPA
3. Local Law enforcement
4. Medical Examiner/Coroner
5. Customer
6. NGSC

M. PUBLIC RELEASE OF INFORMATION
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
35

1. Who authorizes
2. Importance of controlling
3. Who releases
4. Who reviews
5. Next of kin

N. FACT-FINDING METHODS

1. Initial interview
2. Follow-up interview
3. Recordings
4. Photo Coverage
5. Mapping damage
a. Who?
b. How?
c. Why?
6. Personnel security checks
7. Drug and alcohol tests
8. Weather conditions
9. Product status
10. Operational status
11. Equipment records and history
12. Facility, tooling, modification and history

O. SAFING THE AREA

1. Electric Power
2. Water
3. Steam
4. Toxic chemicals
5. Falling hazards
6. Explosives

P. CONTROL OF THE CURIOUS

1. Outsider
2. Employees
3. Press

Q. HANDLING OF REMAINS

1. Notification
2. Photo
3. Movement (after authorization by Medical Examiner)
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
36

4. Release (after authorization by Medical Examiner)

R. NOTIFICATION PROCEDURES

1. When?
2. Who? 3. How?
4. Verification

S. RESCUE EFFORTS

1. When?
2. When not to
3. How to determine

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
37

TABLE I
COMPATIBILITY INFORMATION

Source of Compatibility Information Location

1. Hazardous Waste Compatibility Chart Available at
Table 9-2 of Attachment 9 Environmental Services offices

2. Safety Data Sheets Located on the internal web Environmental
Management Software (EMS)

3. Work Experience Knowledge of each member of the Response
Team when responding to a discharge

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
38

VI. EMERGENCY COORDINATOR

The Emergency Coordinator is the NGSC Fire Department’s Emergency Manager. The
alternate Emergency Coordinators are the NGSC Fire Department Shift Supervisors. A
primary or alternate Emergency Coordinator is on plant or on call at all times. In this
plan, the Emergency Coordinator may be referred to as the Incident Commander (IC).
The primary and alternate Emergency Coordinators or ICs are identified in the Operating
Record, which is maintained onsite at the Promontory facility. NGSC Promontory
security headquarters/dispatch can be contacted 24/7 at 435-863-8545. NGSC
Promontory security headquarters/dispatch can contact the on plant Emergency
Coordinator or IC.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
39

FIGURE 1. DECONTAMINATION/SPILL SCENE
Difficult Decontamination Situations

Some situations, such as a solvent spilled on tiles or large spills on unprotected ground require the
removal and disposal of the affected material. Other situations, such as contaminated equipment
or fixtures, require steam cleaning and the use of a detergent. Frequently, the rinse from steam
cleaning is best controlled with a wet/dry vacuum. Steam cleaners, detergents, and wet/dry
vacuums can be obtained from local rental companies. The rinse should be tested for the
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
40

contaminant and managed appropriately.

The Spill Scene

While each spill is unique, every spill shares common features best referred to as the
"Spill Scene." This allows a conceptual illustration of the work area which emphasizes the
relationship of the various components.

Complete decontamination of workers, tools, and the spill site must be performed before
the spill response is completed.

It is prudent to establish an area for worker decontamination through which all SPILL
TEAM members must pass prior to leaving the site. In this TEAM DECONTAMINATION
SITE (TDS) protective clothing can be thoroughly washed with detergent and rinsed with
water, if necessary. The soles of ALL WORKERS SHOES MUST BE RINSED before they
leave the area. Outer coveralls (Tyvek, etc.) must be removed in this area. These steps are
necessary to prevent spreading the contamination or introducing toxic substances into
workers homes.

Tools can be rinsed with detergent and water prior to removal from the spill scene.
All rinses from these decontamination procedures must be treated as hazardous
waste. Dry decontamination may be used when appropriate.

It is frequently necessary to test the site for completeness of decontamination prior to
declaring the emergency resolved. Spills which contaminate soil, asphalt, concrete, or
other absorbent materials will require that samples be obtained and analyzed. After all
residual contamination is removed, asphalt and concrete areas must receive a thorough
wash-down with fresh water.

Cold Zone
Secure
Supplies
Decontamination Corridor
Dirty Area Hot Zone
Spill
Warm Zone

Area
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
41

FIGURE 2. DECONTAMINATION

APPENDIX I

FACILITY FUNCTION TABLES, SITE MAPS, & EVACUATION PLANS

NORTH PLANT SITE MAP ............................................................................................... 30

MANUFACTURING AREA SITE MAP ............................................................................. 31

TEST AREA SITE MAP ..................................................................................................... 32

PLANT 3 SITE MAP .......................................................................................................... 33

M-136 BURNING GROUNDS FACILITY FUNCTION TABLE ........................................ 34

M-186 HAZARDOUS WASTE AREA FACILITY FUNCTION TABLE .............................. 34
M-136 SITE MAP AND EVACUATION PLAN .................................................................. 35
M-186 SITE MAP AND EVACUATION PLAN .................................................................. 36

E-501 STORAGE YARD FACILITY FUNCTION TABLE ................................................... 37
E-501 SITE MAP AND EVACUATION PLAN ................................................................... 38

M-225 BURNING GROUNDS FACILITY FUNCTION TABLE ......................................... 39
M-225 SITE MAP AND EVACUATION PLAN .................................................................. 40

T-29B SATELLITE ACCUMULATION AREA FACILITY FUNCTION TABLE .................. 41
T-29B SITE MAP AND EVACUATION PLAN .................................................................. 42

M-705 WASTEWATER TREATMENT FACILITY FUNCTION ......................................... 43
M-705L HAZARDOUS WASTE TREATMENT BY OXIDIZER LEACHING ROOM ......... 43
M-705S HAZARDOUS WASTE CONSOLIDATION ROOM ............................................ 43
M-705 SITE MAP AND EVACUATION PLAN .................................................................. 44

M-629 PROPELLANT STORAGE FUNCTION TABLE .................................................... 45
M-629 SITE MAP AND EVACUATION PLAN .................................................................. 46

S-633 PROPELLANT STORAGE FUNCTION TABLE…………………………………..……47
S-633 SITE MAP AND EVACUATION PLAN ………………………………………………....48

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
42

NORTH PLANT SITE MAP

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
43

MANUFACTURING AREA SITE MAP
(South Plant)

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
44

TEST AREA SITE MAP

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
45

PLANT 3 SITE MAP

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
46

M-136 BURNING GROUNDS

FACILITY FUNCTION: Propellant, explosives, unstable and pyrotechnic waste disposal

Method of
Waste Products Into Area Disposal Spill Cleanup/Handling

Class 1.1 and 1.3 propellant Burning Flashing in waste propellant
wastes, propellant contaminated disposal areas
wastes, and unstable waste.

M-186 HAZARDOUS WASTE AREA

FACILITY FUNCTION: Receive hazardous waste materials and store for shipment

Method of
Waste Products Into Area Disposal Spill Cleanup/Handling

Methyl Chloroform Store for Six UN Drums
Methyl Ethyl Ketone off-plant Quicksorb, 100 lb.
Xylene shipment Two shovels
Toluene One broom
Paint One fire extinguisher
Thinners Emergency shower/eye wash
Oil Store for Two overpack drums
Lab Chemicals off-plant Saranex suit (level B)
Photographic Fixer Solution shipment
Rags & debris

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
47

M-136
AND BURNING PITS
FIRE EXTINGUISHER
LEGEND:
EVACUATE AREA, THEN PROCEED TO ASSEMBLY POINT
200 FEET WEST ON APPROACH ROAD
Date: October 13, 1989
PIT 18
PIT 17
PIT 16
PIT 15
PIT 14
PIT 7
PIT 6
PIT 5
PIT 4
PIT 3PIT 13
PROPELLANT BED
PIT 1 PIT 2
DETONATION PITS
NO. 11 NO. 10 NO. 9 NO. 8
NEWPOND
TANK 1
TANK 2
BURNING PIT 19
M-136
N
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
48

EVACUATE, THEN PROCEED TO ASSEMBLY POINT,
SOUTHWEST AT M-381
Date: March 2, 2000
ROADWAY
OFFICE
TUFSHED
SUPPLY
SHED
SAMPLESHED
FIXER SHED
EYEWASHSHOWER
GATE
GATE
WASTEOIL
STORAGESHED
WASTEOIL
HAZARDOUS WASTE TREATMENT,
STORAGE, DISPOSAL, AND FACILITIES
M-186
FIRE EXTINGUISHER
LEGEND:
N
WASTEOIL
M-186A
M-186B
M-186C
M-186D
M-186E
M-186F
M-186G
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
49

BUILDING E-501 STORAGE YARD

FACILITY FUNCTION: Hazardous Waste Storage Yard

Method of
Waste Products Into Area Disposal Spill Cleanup/Handling

Various Shipment Two fire extinguishers
off-plant Absorbent
for disposal Two repack drums
Electrical pump

Other assorted materials N/A
that may be recycled Telephone/radio
Eyewash/shower
Safety gates
Safety flags
Six UN 55-gal drums
(empty)
Saranex suit (level B)
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
50

FIRE EXTINGUISHER
LEGEND:
EVACUATE AREA, THEN PROCEED TO ASSEMBLY
POINT ON 200 STREET, 200 FEET EAST
Date: October 27, 1999
N
E-501
and
SALVAGE YARD
DRUM
STORAGE
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
51

M-225 BURNING GROUNDS

FACILITY FUNCTION: Disposal of waste products from High Performance Propellant
Development Area and miscellaneous rocket motors, igniters, and
related materials

Method of
Waste Products Into Area Disposal Spill Cleanup/Handling

Composite propellant, uncured Burn Dampened rags (wipes)
from M-209

Composite propellant, cured Burn Pick up, soft brush or wet rags (wipes)
from M-221

NG propellant, uncured from Burn Solvent dampened rags followed by NG
M-208, M-241 detector to verify cleanliness

NG propellant, cured from M-221 Burn Pick up, soft brush and/or wet rags.

HMX from M-208, M-210 Burn with Soft brush and/or water-damp rags.
diesel If possible, wet HMX with water before
handling.

AP from M-210 (fine only) Burn with Sweep with soft brush. Wipe with
propellant composite water-wet rag. Flush with water
into sump.

Binder premix (NG or other Burn or Contain, absorb into sawdust or pulp,
nitrate, etc.) detonate pick up with wipes, wet rags. Apply NG
depending detector to verify cleanliness
on materials
and/or condition

PEP contaminated waste (rags, Burn with Pick up, clean with method used for
containers, etc.) respective respective propellant
propellant or ingredient

Miscellaneous (motor, igniters) Burn or Each case must be dealt with on an
detonate individual basis
depending
on materials
and/or
condition.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
52

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
53

T-29B SATELLITE ACCUMULATION AREA

BUILDING FUNCTION: Hydrazine Storage and Dilution Facility

Waste Product Method of disposal

From Building Disposal Spill Cleanup/Handling

Pure hydrazine Dilute with All areas where normal operations are
Hydrazine-citric water to 5-50% performed have a drainage system which
acid solution solution by culminates in a common sump. Spills
5-50% dilute volume. Waste should be flushed thoroughly with large
hydrazine hydrazine is amounts of water. The wash water is
contaminated shipped for then drummed and shipped for disposal.
waste disposal/Treatment.
Contaminated
waste is also
shipped for
disposal/treatment

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
54

EVACUATE BUILDING, THEN PROCEED TO
T-29B
ASSEMBLY POINT 300 FEET NORTH OF BUILDING HYDRANTN
Date: November 3, 1997
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
55

M-705 WASTEWATER TREATMENT FACILITY

BUILDING FUNCTION: Removal of reactive wastes from sump water

Method of
Waste Products From Area Disposal Spill Cleanup/Handling

Lime Sludge (Heavy Metals) Shipment Two shovels
to off- One broom
plant Plastic gloves
disposal One bin
company Saranex suit (level B)

M-705L IGNITABLE AND REACTIVE HAZARDOUS WASTE TREATMENT BY OXIDIZER LEACHING
ROOM

BUILDING FUNCTION: Removal of oxidizers from ignitable and reactive hazardous waste

Method of
Waste Products From Area Disposal Spill Cleanup/Handling

Solid Waste residue Landfill or Spill Kit (pigs, adsorbent)
off-plant Plastic Gloves
disposal Fire Extinguisher
Oxidizer containing waste Wastewater Emergency eyewash
water at M-705 WWTP
or oxidizer recovery
process

M-705S HAZARDOUS WASTE CONSOLIDATION ROOM

BUILDING FUNCTION: Consolidation and lab packing of hazardous wastes

Method of
Waste Products From Area Disposal Spill Cleanup/Handling

Consolidated hazardous wastes Shipment to Two shovels
Lab packed hazardous wastes M-186 for One broom
eventual Plastic Gloves
off-plant One Fire Extinguisher
disposal Emergency shower/eyewash
Quicksorb, 100 lb.
Two overpack drums
Six UN drums
Saranex suit (level B)

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
56

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
57

M-629 PROPELLANT AND PROPELLANT WASTE STORAGE FACILITY

BUILDING FUNCTION: Storage of reactive hazardous waste propellant/propellant
contaminated materials, motors. Non-waste propellant, (donor propellant) and explosive
initiation articles are also stored within the building.

Solid Hazardous Waste Method of Disposal Spill Cleanup Materials

1.3C Propellant/propellant Thermal Treatment Obtain clean up material as needed
contaminated materials

1.3C Rocket Motors Thermal Treatment Obtain clean up material as needed

1.1C Propellant/propellant Thermal Treatment Obtain clean up material as needed
contaminated materials

1.1C Rocket Motors Thermal Treatment Obtain clean up material as needed

1.3C Flares and Flare Illuminate Thermal Treatment Obtain clean up material as needed
contaminated materials

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
58

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
59

S-633 REACTIVE HAZARDOUS WASTE STORAGE PAD

STORAGE PAD FUNCTION: Storage of reactive hazardous waste propellant/propellant
contaminated materials and motors and non-waste propellant

Method of
Waste and non-waste Products Disposal Spill Cleanup Materials

1.3C Propellant/propellant Thermal Treatment Obtain clean up material as needed
contaminated materials

1.3C Rocket Motors Thermal Treatment Obtain clean up material as needed

1.1C Propellant/propellant Thermal Treatment Obtain clean up material as needed
contaminated materials

1.1C Rocket Motors Thermal Treatment Obtain clean up material as needed

1.3C Donor Burn Propellant Burn Enhancer Obtain clean up material as needed

1.3C Flares and Flare Material Thermal Treatment Obtain clean up material as needed

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
60

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
61

APPENDIX II
BULK STORAGE AREAS INFORMATION

A. BULK FLAMMABLE LIQUID STORAGE AREAS .....................................50

B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE...........51

APPENDIX III

ARRANGEMENTS WITH LOCAL AUTHORITIES………………………………52

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
62

A. BULK FLAMMABLE LIQUID STORAGE AREAS

Type of Capacity Above/Below
Location Flammable Liquid (Gallons) Ground

M-4 Butanol 40 Above
Ethanol 60 Above
Isopropanol 530 Above
Methanol 500 Above
Methyl Ethyl Ketone 400 Above
Paint 500 Above
Paint Thinner 120 Above

M-53 Acetone 60 Above
Ethanol 10 Above
Heptane 10 Above
Methanol 50 Above
Methyl Ethyl Ketone 60 Above

M-55 Gasoline 17,000 Below
M-66 Assorted 80 Above
I-10 Methanol 15 Above
Methyl Ethyl Ketone 50 Above

M-585 Acetone 50 Above
Ethyl Acetate 15 Above
Methanol 10 Above
Toluene 30 Above

M-711 Gasoline 10,000 Below

E-510 Ethanol 100 Above
Isopropanol 1,660 Above
Methanol 35 Above

E-512 Acetone 100 Above
Isopropanol 50 Above
Paint Thinner 50 Above
Polyester Resin 160 Above
Toluene 50 Above
Xylene 160 Above

E-517 Isopropanol 170 Above
Kerosene 50 Above
Methyl Ethyl Ketone 450

T-29B Hydrazine 100 Above

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
63

B. PRACTICAL CONSEQUENCES OF A CATASTROPHIC FAILURE

Building
Number Location Direction of Flow*

I-10 Shed west of building Has self-containment concrete berm

M-4** Building north of M-3 Liquid would run west across asphalt into
drain system

M-8** Two sheds west of Spill would drain down west hill
building

M-43B Shed south of building Self-contained storage building

M-53A Shed south of building Self-contained storage building

M-66 Shed southwest of Spill would run into ditch (trench
building or grading needed to keep surface runoff
from accumulating in containment area)

M-504 Shed south of building Spill would flow into ditch

M-585 Shed east of building Spill would drain into ditch

M-605 Waste dock north of Spill would drain into ditch
building

E-512 Shed west of building Spill would drain into ditch

E-517 Shed north of building Spill would drain into ditch

* All other storage areas have self-containment

** Fire flows and/or spilled material from these buildings will flow into a gated
spill containment structure below M-2. The gates are hand operated.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
64

APPENDIX III

Arrangements with Local Authorities

Due to the remote location of the NGSC Promontory facility and the reactive materials produced, NGSC
has a specialized and well trained full time Fire Department and Security Department onsite. NGSC’s
roads and grounds and Water Operations departments maintains a fleet of trucks, tractors, vacuum trucks
and other equipment that could be used during an emergency response. The facility also has a nursing
staff during normal business hour, and a 24/7 ambulance service operated by NGSC firemen with EMT
certifications. These emergency response capabilities are often used to support the local community.

Since the NGSC Promontory facility has the resources described above, the Quick Reference Guide as
required by UAC R315-262-262 with its associated map showing where hazardous wastes are generated,
accumulated and treated will be maintained in the facility operating record.

Due to these capabilities, the need for outside assistance is greatly reduced. The most likely need for
outside assistance would be that of hospital service. Arrangements have been made with both the
Bear River Valley Hospital and the Brigham City Community Hospital to accept employees that may
have been injured due to an explosion, chemical exposure or other accident. This arrangement included
information on the types of chemicals used at NGSC Promontory as well as explosive hazards and other
mechanical hazards associated with work performed at NGSC.

The most likely scenario that would require assistance from a police agency would be the need to control
traffic on Highway 83. In the event of such an emergency, arrangements for assistance in this area will be
made with the Box Elder County Sheriff’s Department and the Utah Highway Patrol. All on plant traffic
control will be handled by NGSC’s security department.

NGSC has established contracts with different emergency response/remediation contractors for use as
needed. While we do not anticipate the need for emergency service assistance, these companies are on
call to provide service if needed.

All emergency response at the plant will be handled by the NGSC Fire Department, who will act as the
primary emergency authority. If warranted, arrangements will also be made with the Box Elder County
Fire Department and the Tremonton Fire Department. We do not anticipate any need for assistance from
the Division of Environmental Response and Remediation, although notification of emergencies will be
made to this department as required. In addition to those agencies listed above, NGSC will also provide a
copy of the contingency plan to the Box Elder County Emergency Planning Committee for review.

Below is a summary list of those agencies/service providers for which service arrangements will be
sought if needed:
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 4 – Contingency Plan UTD009081357
65

Bear River Valley Hospital
Brigham City Community Hospital
Box Elder County Sheriff’s Department
Utah Highway Patrol
Box Elder County Fire Department
Tremonton Fire Department

The most recent copy of the Contingency Plan will be sent to each of these agencies in order to
familiarize them with the layout, description of hazardous wastes handled, and evacuation plans for the
plant. All notification to these agencies, regarding the Contingency Plan and assistance arrangements will
be kept in the Operating Record.

ATTACHMENT 5

CLOSURE PLAN

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

1

CLOSURE PLAN AND FINANCIAL REQUIREMENTS

This Closure Plan describes the steps that will be taken to close the hazardous waste
management units (HWMUs) at the Northrop Grumman Systems Corporation – Promontory
(NGSC) facility. Closure Cost estimates are maintained in the Operating Record once approved
by the Director. HWMUs included in this document are: M-186; M-705S; M-705L; E-501;
M-136; M-225; T-29B; M-629; and S-633.

The Closure Plan was developed to comply with R315-264-110 through 120 and R315-264-178
of the Utah Administrative Code (UAC). The closure cost estimates were made in accordance
with UAC R315-264-140 through 151

All HWMUs in current operation are being managed in a manner that facilitates clean closure.
Historical sites, such as the LTTAs do require post closure care, and are covered in our Post
Closure Permit.

1.0 Closure Plans [UAC R315-270-14(b)(13), UAC R315-270-23(a)(2), and UAC
R315-264-112(a)(1) & (2)

This Closure Plan identifies the general steps needed to close storage and treatment facilities, as
identified above, at the end of their operating life. Copies of this plan will be maintained at the
Promontory Facility. The closure plans will be followed as written, unless modification to the
original plans have been submitted and approved by the Utah Department of Environmental
Quality (UDEQ), Division of Waste Management and Radiation Control (Division). Upon
update/revision approval, revised pages or complete documents will be sent to all plan
addressees.

1.1 Closure Performance Standards [UAC R315-264-111]

Closure standards specified under RCRA are designed to be protective of human health and the
environment. These goals will be achieved by one of the following closure methods:

▪ Clean closure – this method refers to residential risk based levels. Cleanup to
residential risk based levels, as outlined in UAC R315-101, will be considered clean
closure. Clean closure includes removal of all contaminants, or removal to the risk
based level.
▪ Site Management – closure where waste remains in place and specific post closure care
is required.

For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be “clean
closed”. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(1). All closures will
assess real and reasonably likely impacts to human and ecological exposures.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

2
Preliminary remediation goals can be established prior to implementing any of the closure plans.
Screening levels published by U.S. EPA or site-specific risk based levels based on UAC
R315-101-5.2 may be used.

If contamination from hazardous waste or constituents is discovered at a HWMU above risk
based goals, further investigation will be performed to determine the extent of the contamination.
Based on the results of this investigation, a Corrective Measure Study (CMS) may be prepared
for review and approval by the UDEQ, prior to implementation.

If investigation suggests that clean closure is not a practicable approach, a Site Management Plan
will be prepared. Upon approval, the unit will be closed by implementing appropriate site
management or post closure requirements. If this approach is necessary, the Post Closure Permit
may be modified to provide post closure care for the sites that are not clean closed.

1.2 Partial Closure and Final Closure Activities [UAC R315-264-112(b)(1) through
(b)(7) and UAC R315-264-110 through 120]

This plan is designed to accommodate both partial and final closure. The plan includes separate
steps to close storage, consolidation & disassembly areas, and open burning/open detonation
areas. A detailed plan for closing each HWMU will be submitted in accordance with Permit
Condition III.J.2.

Soil monitoring has been conducted at the M-136 and M-225 burn grounds since 1991.
Semi-annual groundwater monitoring is also conducted, in accordance with NGSC’s
Post-Closure Permit.

1.3 Maximum Waste Inventory and Disposal Method [UAC R315-264-112(b)(3) and
UAC R315-264-110 through 120]

The maximum inventory of hazardous waste onsite at any one time during the life of the
facilities is based on permit limitations for inert facilities, and Quantity/Distance (QD)
limitations for live materials, based on Department of Defense Explosive Safety Standard
4145.26M or a lesser designated amount. If storage capacities change, the Permit will be
modified. These quantity limitations are listed below:

M-186 (inert) ------------------------------ 400 ea. 55 gallon drum equivalent
M-705S (inert) ---------------------------- 32 ea. 55 gallon drum equivalent
E-501 (inert) ------------------------------ 160 ea. 55 gallon drum equivalent
M-136 (live) ------------------------------ 125,000 lbs. 1.3 / 20,000 lbs. 1.1
M-225 (live) ------------------------------ 55,000 lbs. 1.3 / 1,500 lbs. 1.1
T-29B (inert) ----------------------------- 1 ea. 55 gallon drum (pure) equivalent
M-629 (live) ----------------------------- 110,000 lbs. 1.3 / 55,000 lbs. 1.1
S-633 (live) ------------------------------- 75,000 lbs. 1.3/20,000 lbs. 1.1
M-705L(inert)----------------------------- 6,000 lbs. 1.3

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

3
NGSC treats reactive hazardous wastes on-site at the M-136 and M-225 open burning grounds.
NGSC also treats ignitable and reactive hazardous wastes on-site at the M-705L oxidizer
leaching process. Wastewater is collected and treated on site and discharged through one of two
UPDES permitted treatment facilities. All other hazardous wastes are transported to fully
permitted disposal or recycling facilities.

1.4 Schedule for Closure [UAC R315-264-112(b)(6) and UAC R315-264-110 through
120]

Section 1.4.1 of this plan provides an estimated closure schedule for all activities associated with
implementation of this Closure Plan. If sample results indicate the need for additional
investigation or a CMS, the schedule will be modified to accommodate the changes. Final
closure will be certified by an independent professional engineer licensed in the State of Utah.

1.4.1 Time Allowance for Closure [UAC R315-264-113(a) and (b) and UAC R315-264-110
through 120]

Final closure is expected to be initiated within 30 days following shipment of the final volume of
hazardous waste. If more time is required, a request will be submitted to the Director of the
Division of Waste Management and Radiation Control (Director). All hazardous wastes will be
removed or treated within 90 days of (1) plan approval, or (2) after receiving the final volume of
hazardous waste, whichever is later. Final closure activities will be completed within 180 days
of (1) plan approval, or (2) after receiving the final volume of hazardous waste, whichever is
later.

1.4.2 Extensions for Closure time [UAC R315-264-113(a) and (b) and UAC R315-264-110
through 120]

If closure activities cannot be completed within the time designated in this Closure Plan, a permit
modification and request for additional time will be submitted to the Division. The request will
state the reason for needed additional time and the status of the closure underway. It will also
address any added measures that must be followed to minimize any threats to human health or
the environment during the extension period.

1.5 Closure Procedures [UAC R315-264-112 and UAC R315-264-114 and UAC
R315-264-110 through 120]

All permitted treatment and storage facilities have been designed and managed to minimize
possible contamination. This includes chemical resistant concrete coatings, blind containment
sumps, regular inspections, regular maintenance, and prompt cleanup of any spilled materials.
These practices should greatly reduce the need for significant remediation efforts upon closure.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

4
1.5.1 Soil and Groundwater Sampling

Groundwater sampling is not covered under this plan. A groundwater monitoring program is
required by NGSC’s Post-Closure Permit and is currently in place. Soil sampling should not be
required for any of the permitted facilities, except for the two burn ground areas (M-136 and
M-225) and S-633. However, if the Director determines that soil sampling is necessary at any of
the permitted facilities, NGSC shall submit a soil sampling plan as requested. The soil sampling
plan shall conform to the QAPP contained in Attachment 3 of the Post-Closure Permit.

Detailed sampling plans will be submitted in accordance with Permit Condition II.O.2. Samples
will first be collected at locations most likely to have been affected by waste management
practices – as approved by Division personnel. Twenty soil samples will be collected at M-136,
eight soil samples will be collected at M-225 and eight soil samples will be collected at S-633.
These samples will be sent to a State of Utah certified laboratory for analysis as required by
Module II.D. Sample collection, preservation and handling methods will follow those outlined
in the Waste Analysis Plan of this permit, and will be in compliance with all applicable SW-846
methods. All samples will be processed and analyzed by a Utah Certified Laboratory in
accordance with Module II.D and UAC R444-14-3(2). Laboratory methods shall be those
specified in “Test Methods for Evaluating Solid Waste; Physical/Chemical Methods SW-846
(Third Edition, November 1986)” or most currently promulgated edition, “Standard Methods for
Examination of Water and Wastewater (17th Edition, 1989)” or most currently promulgated
edition; or an equivalent method as approved by the Director.

Analytical and Extraction Methods
Parameter Analytical procedure Extraction Procedure
Volatiles SW-846; 8260 SW-846; 5030 (W), 5035(S)
Semi-Volatiles SW-846; 8270 SW-846; 3510 (W), 3550(S)
RCRA Metals SW-846; 6010 SW-846; 3005 (W),7471 (S)
Mercury SW-846; 7470/7471 SW-846;7470 (W), 7471 (S)
Explosives SW-846;8330 Modified SW-846; 8330 Modified
Perchlorate EPA 314.0 EPA 314.0

1.5.1.1 Sampling Equipment Decontamination Procedures

All field sampling equipment will arrive on site pre-cleaned, and will be decontaminated
following standard protocol and the waste analysis plan in this permit. A mobile
decontamination station will be used to clean all sampling equipment that could come in contact
with soil samples.

1.5.1.2 Sampling Waste Management

All waste generated from field sampling and decontamination operations will be managed in
accordance with the current UAC R315 rules. Water used in the decontamination process will be
containerized and disposed of in accordance with permit requirements. Soils will be stored in
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

5
DOT approved containers pending lab results. Any soil determined to be hazardous waste will
be managed appropriately.

All non-aqueous hazardous waste generated by the sampling operation will be transported to a
fully permitted TSDF for disposal. Any waste determined not to be hazardous under U.S. EPA
regulations will be sent via third party to a non-hazardous landfill for disposal.

A field log will be maintained to track and identify all samples. This log will include sample
numbers, dates, times, sample depth, samplers name, weather conditions, test methods and
constituents for which to analyze.

1.5.1.3 Health and Safety Procedures

Soil and water sampling will be performed by trained and qualified personnel. A determination
of appropriate personal protective equipment (PPE) to be used for this effort will be determined
at the time of closure. PPE selection will be based on potential hazards as determined at the time
of closure, and in consultation with Industrial Hygiene professionals.

Soil sampling should only be required at the burn grounds, because of well-maintained
secondary containment and waste management practices during the entire life of all other
permitted facilities. Protective clothing appropriate for the task will be used during removal of
waste and during decontamination of containment areas for the permitted storage and treatment
units.

1.5.2 Determining Cleanup Goals

For the purposes of estimating closure costs, it is assumed that all of the HWMUs will be clean
closed. Clean closure can be achieved by cleaning the units to background conditions or by
meeting the clean closure equivalency as defined in UAC R315-101-6(c)(1). All closures will
assess real and reasonably anticipated potential impacts to human and ecological exposures. It is
anticipated that the HWMUs will be clean closed and will not require post-closure care.

1.5.3 Site Cleanup

1.5.3.1 Inventory Removal [UAC R315-264-112(b)(3) and UAC R315-264-110 through
120]

The maximum inventory of hazardous waste on hand at any given permitted facility is based on
the maximum allowed under this permit, or a quantity - distance limit for explosives, imposed by
the Department of Defense and NGSC. These limitations are specified in Section 1.3 of this
Closure Plan.

Transportation and disposal costs of all hazardous waste during closure of a facility will be based
on hiring a third party. The transportation contractor will be licensed and insured, and the
disposal facility will be a permitted facility. Reactive hazardous wastes may be open burned on
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

6
site. Cost calculations for treatment, disposal and equipment decontamination will be based on
maintaining an NGSC staff sufficient to complete these efforts.

1.5.3.2 Disposal or Decontamination of Equipment and Structures [UAC R315-264-
112(b)(4), UAC R315-264-112(e), and UAC R315-264-114 and UAC R315-264-110
through 120]

Decontamination of equipment and structures at the Promontory facilities will follow one of two
plans. These plans cover the open burning units, and all other facilities.

The open burning facilities use burn trays, pipes, concrete vaults or rocket cases to contain the
waste to be treated. Most of the material burned is hazardous by characteristic only. Any waste
that may be contaminated with, or contains solvents or hazardous heavy metals is designated as a
derived waste, and the ash collected for offsite disposal. Therefore, except for the derived trays,
all ash in trays, vaults, cases, and on the ground around these units will be collected and disposed
on-site. The burn trays will then be high pressure water washed and the rinsate collected for
disposal. After the final rinse, a composite sample from the trays will be collected and analyzed
at a Utah certified lab as required by Module II.D requirements to verify proper tray
decontamination. Each sample will include rinsate from 5 trays. Samples will be extracted and
analyzed as described in 1.5.1.

All facilities except for M-136, M-225, M-629 and S-633 are designed with secondary
containment. The secondary containment includes a concrete pad with curbing and blind sump
to simplify cleaning. The containment pads and sumps are coated with a chemical resistant
epoxy to prevent liquid migration through the concrete. Secondary containments are inspected
daily, when in use, and maintained as needed. After removal of all containerized waste, the
liquid chemical containment pads of facilities E-501, M-186, M-705L, M-705S, and T-29B will
be high pressure water washed, and the rinsate will be collected for disposal. After the final
wash, rinse water samples will be collected from each sump and characterized for disposal.
Samples will be sent to a State of Utah certified laboratory for analysis following the
requirements found in Module II.D.

1.5.3.3 Closure Containers [UAC R315-264-178]

Non-reactive hazardous waste requiring off-site disposal will be placed in UN or a bulk
U.S. DOT authorized containers for offsite shipment to permitted disposal facilities. Empty
containers will be managed as described in Attachment 9.

2.0 Closure Certification [UAC R315-264-115 and UAC R315-264-110 through 120]

Within 60 days of completion of closure of each facility, NGSC will submit a certification to the
Division in accordance with Module I.DD. of this Permit, that the hazardous waste management
facility was closed in compliance with this Closure Plan. This certification will be signed by
NGSC and an independent registered professional engineer licensed in the State of Utah.
Documentation supporting the engineer's registration will be provided upon request.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 5 – Closure Plan UTD009081357

7
3.0 Closure Cost Estimate [UAC R315-264-142]

Closure cost estimates are maintained in the operating record once approved by the Director.
Closure cost estimates are based on using a third party except for the thermal treatment and
disposal of reactive waste which will be conducted on site.

4.0 Financial Assurance Mechanism for Closure [UAC R315-264-143 and UAC R315-
309]

NGSC will maintain current financial assurance meeting the requirements outlined in the above
referenced Federal and State regulations. NGSC will provide documentation to Division
supporting compliance with financial mechanism requirements.

5.0 Post Closure Plan

If it is determined that a HWMU can’t be clean closed, contaminants may be left in place, and a
post closure or site management plan will be developed. Any proposal for post closure care or
site management will be developed in accordance with UAC R315-264-110 through 120 and
UAC R315-264-140 through 151, and will be submitted to the Director for approval. If this
approach is necessary, the Post Closure Plan may be modified to provide post closure care for
the sites that are not clean closed.

ATTACHMENT 6

FACILITY DRAWINGS

ATTACHMENT 7

SECURITY PLAN

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 7 - Security UTD009081357
2

07 HAZARDOUS WASTE MANAGEMENT

07.01.1 SECURITY PROCEDURES

07.01.1 Purpose and Scope

The work performed at the Northrop Grumman Systems Corporation
(NGSC) Promontory facility primarily involves Department of Defense
and NASA contracts; therefore, comprehensive security agreement
measures have been instituted. The facility has both a twenty-four hour
surveillance system and an artificial barrier around the facilities to
minimize the possibility of unknown entry of livestock or personnel.

07.01.2 Surveillance System

Security is maintained by a trained security force which controls entry and
exit from the facility and provides patrol, escort, and other activities
within the plant. The main plant entrances are manned by a minimum of
one security officer during normal working hours. All other gates are
locked and only used when authorized by Security. All employees
entering the facility must show identification badges at the gate and wear
them in plain sight throughout the day. All visitors and vendors are
required to wear special identification badges.

07.01.3 Artificial Barrier

There are artificial or natural barriers around the entire plant. The primary
barrier consists of a chain link and barbed wire fence with controlled
access at the main entrances to the plant. The chain link fence runs along
the highway from Building A until it runs into the gully formed by Blue
Creek just west of M-46. A natural barrier is provided by the Blue Creek
gully which is approximately 15 feet deep with near vertical sides. This
barrier extends for approximately 8,000 feet to a five-foot, four-strand
barbed wire fence. This fence extends to the north, changes to chain link,
and runs around the north end of the Plant. The chain link fences are
seven feet high and topped with barbed wire. This fence is continued by a
five-foot, four-strand barbed wire fence, which completes the primary
barrier by encircling North Plant, Test, and South Plant. Plant III is
encircled by a five-foot, four-strand barbed wire fence and also has
controlled access at the main entrance. Each hazardous waste
management area also has an artificial barrier.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 7 - Security UTD009081357
3

E-501: The Container Storage Area is surrounded by a seven-foot chain link
fence and has controlled access. The gate is locked when no one is
present.

M-136: A five-foot, four-strand barbed wire fence surrounds the Burning
Grounds area. It has a gate, which is locked when no one is present.

S-633: The storage area is located inside the secured M-136 perimeter fence.
S-633 is also surrounded by a five foot four strand barbed wire fence
in addition to the M-136 fence.

M-186: A five-foot, four-strand barbed wire fence surrounds the Container
Storage Area. It has a gate, which is locked when no one is present.

M-225: The Burning Grounds are surrounded by an eight-foot, chain link
fence. It has a gate, which is locked when no one is present. A
five-foot, four-strand barbed wire fence surrounds the runoff
dispersion area.

M-705L: The hazardous waste management area is inside a building with
lockable doors to provide access control. In addition, the facility uses
the plant’s artificial barrier.

M-705S: The hazardous waste management area is inside a building with
lockable doors to provide access control. In addition, the facility uses
the plant’s artificial barrier.

M-629: The solid reactive waste storage area is inside the building and
remains locked except when occupied by personnel for placement of
material into storage or removal from storage.

T29B: Building T29B remains locked at all times and is controlled by
authorized Test Service personnel.

07.01.4 Signs

All hazardous waste management areas (i.e., E-501, M-136, S-633,
M-186, M-225, M-705L, M-705S, M-629 and T29B) have warning signs
placed at the access approaches. All signs are legible from a distance of at
least 25 feet. All signs have a legend which reads “Danger - Unauthorized
Personnel Keep Out.”

ATTACHMENT 8

PREPAREDNESS AND PREVENTION PLAN

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

1

8-1 PROCEDURES, STRUCTURES, AND EQUIPMENT

8-1-1 Purpose and Scope

Precautions have been taken to minimize the accidental or sudden release
of hazardous waste or waste constituents into the environment. The
precautions comply with the requirements of Utah Administrative Code
(UAC) R315-264-31.

8-1-2 Loading and Unloading Operations

Several precautions have been taken to minimize hazards during the
loading and unloading of hazardous waste. These precautions are divided
into four classes of Waste Management: Open Burning, Oxidizer
Leaching, Drum Storage and Propellant/Explosives Storage.

Open Burning of hazardous waste explosives and propellants requires
special precautions. Precautions taken during loading and unloading
operations are described in Attachment 11. Safe loading and unloading of
explosive waste helps to minimize waste release into the environment and
reduce the possibility of unplanned ignition of waste material.

Waste energetic material received from off-site for storage prior to open
burning, will be handled under the same precautions as all other wastes
accepted for disposal at the burn grounds. Loading/off-loading areas will
be inspected each day waste is received, and at a minimum of once per
week.

Oxidizer leaching of ignitable and reactive hazardous waste is conducted
in Building M-705L, which is a small Building adjacent to the M-705
wastewater treatment facility. Several provisions are in place and
described in Attachment 12 to prevent releases to the environment during
this process. This process is completed inside a closed building with
containment.

Several precautions are also taken at the Drum Storage areas. Spill control
equipment is located at each area and can be used in loading and
unloading operations. All drums are on pallets and are loaded and
unloaded by a forklift. The design of the Drum Storage facilities allows
adequate aisle space for movement of drums with a forklift to minimize
the actual handling of the drums. Permit conditions II.K.6. and III.E.4.
state that, at a minimum, the Permittee shall maintain 30 inches of aisle
space between containers or pallets of containers at storage areas M-186
and E-501. All forklift truck operators must have a license to operate the
forklift truck. The operator receives this license by attending a training
program which includes an actual driving test that must be passed. The
hazardous waste operators must also participate in the Hazardous Waste
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

2

Training Program discussed in Attachment 3.

Waste propellant, explosives and rocket motors are carefully off loaded
from trucks using forklifts, building cranes or a trailer mounted knuckle
boom. Small containers, less than 50 lbs., may be off loaded by hand. All
operators of the equipment listed above, undergo extensive training in the
proper use of the equipment they operate. This training includes
classroom as well as hands on training. All Northrup Grumman Systems
Corporation (NGSC) propellant moving, grounding and bonding
procedures will apply.

Many precautions are taken during the transfer of waste hydrazine during
the dilution process that is used to prepare this waste for off-plant
disposal. These precautions include medical certification, operator
knowledge of chemical properties, special safety equipment, and specific
operating instructions.

8-1-3 Prevention of Run-on and Run-off

Run-on and run-off are controlled at the drum storage facilities M-186 and
E-501 by a concrete berm around the facility. The M-705S storage and
consolidation room is totally enclosed preventing run-on from entering the
facility and eliminating any possibility for run-off. The M-705L oxidizer
leaching process is totally enclosed preventing run-on from entering the
facility and eliminating any possibility for run-off. Details of these
structures and how they control run-off are found in Attachment 6 of this
Permit.

Run-on and run-off at the Burning Grounds, M-225, M-136, and storage
pad S-633 are controlled by diversion, collection ditches, and trenches. A
diversion ditch directs run-on around the Burning Grounds. The run-off at
M-136 is collected in a ditch and dispersed in a dispersion area. The
run-off at M-225 is dispersed in an area directly in front of the burning
area. Both areas will be included in the zone of Engineering Control.
Waste material at the S-633 storage pad is stored in closed or covered
containers/articles. Drawings showing the control systems for M-136 and
M-225 are included in Attachment 6.

Run-on and run-off at building M-629 is controlled since the facility is a
fully enclosed building which is elevated above the surrounding grade to
prevent rain intrusion. Drawings of this building are found in Attachment
6 of this permit.

8-1-4 Prevention of Water Supply Contamination

The drum storage areas, M-186, E-501, M-705L and M-705S each have a
containment system which is designed to prevent releases of contaminants
to the environment. Each system is constructed to be leak-proof and
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

3

divert run-on. These containment systems are shown in the facility
drawings contained in Attachment 6.

The propellant/motor storage areas store only solid materials, and do not
require secondary containment. The nature of this solid waste greatly
reduces the potential for contaminating water supplies.

The materials in the trays at the burning grounds are normally destroyed
on a biweekly basis, except those materials too sensitive to store which are
burned the same day. The burn trays are inspected weekly and prior to
loading to look for cracks or holes. Minimizing free liquids and
controlling run-on and run-off prevents water supply contamination. It is
not anticipated that groundwater or surface water will become
contaminated from the storage operations.

8-1-5 Mitigating Effects of Equipment Failures and Power Outages

A power outage or equipment failure will have little effect on the
hazardous waste storage and treatment areas. Any equipment failures,
such as truck breakdowns, pump repairs, etc.; can be managed by on-plant
maintenance. Power outages can occur, but all critical operations have
backup generators so hazardous waste can be controlled. NGSC maintains
an electrical lineman crew that has the necessary equipment and
experience to repair on plant power outages. In the event of a very large
power outage or repair, Rocky Mountain Power will be contacted and
necessary measures taken to restore power.

8-1-6 Prevention of Undue Exposure to Personnel

Exposure to personnel handling hazardous waste is minimized by
containing and safely packaging waste and supplying personnel with
proper protection and safety equipment. Section III F of the Contingency
Plan (Attachment 4) lists the equipment available to all plant personnel.
Specific procedures and requirements for personnel protection during the
handling of hazardous waste are specified in area standard operating
procedures.

8-1-7 Emergency Equipment

This equipment is inspected on a monthly basis. The emergency
equipment is intended to help respond to small emergencies such as leaks

or spills. It is not intended to respond to major incidents, fires, nor
explosions. It is limited to equipment that is manually operated and is
easily portable. Monthly inspections assure there are adequate supplies of
material on hand and mechanical items are operable so that immediate
response to small emergencies can be safely handled.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

4

NGSC maintains a spill response trailer which is used to respond to spills
that are medium to large. The trailer contains safety and spill response
equipment. This trailer is maintained by the fire department and is
inspected weekly or after use to ensure that an adequate supply of material
is on hand.

8-1-8 General Areas

The general area of each hazardous waste storage site is inspected on a
daily basis when in use. These inspections consist of observing the area
for possible spills or mismanagement of hazardous waste. These areas
require daily inspections when in use to minimize potential for
mismanagement of hazardous wastes during loading, unloading, or
handling.

8-1-9 Safety Equipment

Safety equipment is inspected monthly. Monthly inspections include
testing equipment to make sure it is in working order and ensuring that all
equipment is complete and in place. These inspections help to maintain a
safe work environment and minimize human health incidents.

8-1-10 Storage and Containment System

The storage and containment system shall be inspected as directed in
Attachment 2. In some cases, inspections are required, as stated in the
attachment, after each storm event. A storm event is defined as more than
one inch of precipitation in a one-hour period. This is not only a
regulatory requirement, but these inspections help to operate the container
storage area in a safe manner and minimize environmental incidents.
Inclement weather and mismanagement are the primary sources of
deterioration of the containment system and containers.

Standing liquids in the containment system and/or sumps must be
managed according to Section 9-4.3 of Attachment 9 – Container
Management Procedures. Inspections are conducted in order to effectively
manage standing liquid. These inspections minimize environmental
impacts from the actual storage of hazardous wastes in the storage areas.

If a leaking or deteriorating drum is identified during the inspection, the
contents or the entire container must be immediately transferred into a
new container. The new container must be numbered and labeled with
exactly the same number and label as the old container. The date and time
of any transfer action must be noted in the inspection log. The transfer of
the leaking or deteriorating drum can be handled in two ways: the
contents of the container can be transferred by pump to a new drum, or the
drum can be placed in an 85-gallon over-pack drum with the space
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

5

between the two drums filled with an absorbent to control any possible
leaks.

8-1-11 Burning Ground Area

Burning of explosives and reactive wastes occurs normally on a biweekly
basis, but can occur more often if conditions necessitate the increased
frequency. Inspections of the area, equipment, and burn trays, are
conducted weekly or as specified in Attachment 2. Items inspected under
this category are subject to general wear or weathering.

In addition, containers stored in burn trays at M-136 are inspected to
ensure that they are in good condition, closed and labeled. Burn trays are
inspected for cracks and gaps and accumulation of leaked liquids or
precipitation. Inspections conducted as described above, provide the time
necessary to correct maintenance and erosion or wear problems. They also
minimize the environmental impact at the Burning Grounds.

8-1-12 General Facility

Equipment and PPE required to properly manage hazardous waste and for
spill clean-up are kept at the permitted facilities and regularly inspected.
New materials are purchased as needed to assure an adequate supply.

8-1-13 Fire Department Equipment

The Fire department inspects their equipment on a routine basis and after
each use. This equipment is especially important to aid in minimizing the
effects from fires, explosions, and spills. The inspections are performed
and records are kept by the Fire Department personnel.

8-1-14 Heavy Equipment

Most of the heavy equipment is used on a regular basis for construction
services and for the management of solid wastes. It is also available for
use in emergencies. This equipment is handled at the heavy equipment
garage and is inspected on an hour-usage basis rate of 100-150 hours

depending on the equipment type and working conditions. A detailed
checklist is covered by Maintenance that is checked thoroughly by trained
personnel. All inspection records on heavy equipment are kept on file at
Maintenance Control and are available for inspection.

8-1-15 Inspection Log

All inspections are recorded. These forms are put into one of three
inspection logs. Each log contains the most recent three years of records
and is available for review. Environmental Services keeps the inspection
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

6

logs of the results of all inspections on the security equipment, emergency
equipment, general area, safety equipment, storage and containment
system, burning grounds, and general facility categories. The Fire
department keeps a log of the Fire department categories and Maintenance
Control keeps a log for the heavy equipment category.

8-2 CONTINGENCY PLAN

8-2-1 Purpose and Scope

NGSC has developed and supplied a contingency plan as required by
UAC R315-270-14(b)(7) and UAC R315-264-50. This plan has been
devised as a separate document so that it can be used independently of this
permit.

A copy of the contingency plan is in Attachment 4. The plan has been
designed to minimize hazards to human health and the environment from
fires, explosives, or any unplanned or sudden release of hazardous wastes.

8-3 PREPAREDNESS AND PREVENTION

8-3-1 Purpose and Scope

The hazardous waste treatment and storage facilities have been designed,
constructed, maintained, and operated to minimize the possibility of
unplanned fires, explosions, or discharges of hazardous wastes. In the
event of an emergency, the responsibilities of responders, organizational
structure, and procedures required to ensure effective warning, response,
and control to minimize hazards to human health or the environment are
addressed in detail in the Contingency Plan (Attachment 4).

8-3-2 Required Equipment

All hazardous waste facilities are equipped to respond effectively to an
emergency situation. Should an emergency situation arise, such as a

discharge of hazardous waste, a fire, or an explosion, employees who are
in hazardous waste management areas should be able to respond according
to the procedures outlined in the Contingency Plan.

All hazardous waste facilities are equipped with internal and external
communication systems. Internal communications are provided by voice
signals and commands specified in the Contingency Plan in Section E. All
hazardous waste facilities are in open-space areas and there are no loud,
industrial noises that could muffle voice commands or signals. These
voice commands provide immediate onsite emergency instructions to
employees in the hazardous waste management areas. An external
communication system using telephones is provided for employees at each
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

7

area. These telephones can be used to contact Internal Emergency
Response or initiate the Contingency Plan. Storage buildings not
equipped with alarms or hard wired phones, will utilize cellular phones to
contact NGSC’s emergency responders if needed.

To prevent personnel from fighting fires in the waste rocket
motor/propellant storage buildings and adjacent waste docks, fire
extinguishers are not provided. All other hazardous waste storage areas
are equipped with fire extinguishers.

The buildings that have separate electrical rooms, have extinguishers that
are to be used in the electrical rooms only. Spill clean-up material will be
provided in each of these buildings as outlined in section III.F of the
Contingency Plan. The location of the fire extinguisher is shown on the
evacuation plan in Appendix 1 of the Contingency Plan. Along with these
portable extinguishers, NGSC maintains a fire department to respond to
fires or explosions. Descriptions of fire equipment, available water, and
the Fire department are described in Section I G of the Contingency Plan.

Building M-629 is equipped with a fire sprinkler system, which is checked
at least annually. NGSC’s full time, fully equipped and trained Fire
Department are immediately available for any emergency response action.

8-3-3 Testing and Maintenance of Equipment

All emergency and safety equipment is inspected on a routine basis to
ensure it is in working order and in good repair. These inspections are
documented and are available for inspection.

8-3-4 Access to Communications or Alarm Systems

All employees who manage hazardous waste have immediate access to
both internal and external communication systems. All employees have
access to telephones or cellular phones and are trained on how to summon

external emergency assistance if required.

8-3-5 Required Aisle Space

Aisle space has been designed into each drum storage pad. This type of
drum storage allows easy access to thoroughly inspect the area around
each drum and allows adequate room to transfer hazardous waste into a
new drum if a drum is found to be leaking or in poor condition. There is
enough aisle space and clearance around each storage pad to allow free
movement of fire protection equipment, spill control equipment, and any
needed decontamination equipment. Detailed drawings of the drum
storage areas are found in Attachment 6 of this Permit. An aisle space of
30 inches minimum between containers or pallets of containers will be
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

8

maintained at storage areas M-186 and E-501. Hazardous waste stored in
containers at M-705S, M-629, S-633 and M-136 will be stored so that they
may be readily inspected and hazardous waste labels are visible.

8-4 PRECAUTIONS TO PREVENT IGNITION AND REACTION

8-4-1 Purpose and Scope

Precautions to prevent accidental ignition or reaction are essential to the
safety of all personnel. The precautions taken ensure compliance with
UAC R315-264-17. The precautions are a part of everyday manufacturing
and production activities at NGSC.

8-4-2 Precautions for Open Burning of Explosives and Propellants

Many precautions are taken to prevent accidental ignition or reaction of
hazardous waste materials at the Burning Grounds at M-136 and M-225.
Because of the extremely sensitive nature of these wastes, special
precautions are taken for each source of ignition.

Safety procedures for handling energetic and sensitive materials are found
in NGSC’s Hazardous Operations Standard Manual (HOPS) and the
internal handling procedures or protocols.

8-4-3 Precautions for Drum Storage of Hazardous Waste

The drum storage buildings have been designed to hold flammable liquids.

The front and all sides of E-501 are open to ensure that proper ventilation
is maintained in each storage area. Doors are opened as needed at M-186
and M-705S to provide adequate ventilation. Unauthorized personnel are
kept out of the storage areas. The areas are inspected on a weekly or daily
basis and all leaking or damaged containers are replaced as addressed
above and in Attachment 9.

In the event of a spill of hazardous waste or material which, when spilled,
becomes hazardous waste, the person responsible for the material at the
time of the spill shall immediately take appropriate action to minimize the
threat to human health and the environment and comply with UAC
R315-263-30 and implement the Contingency Plan if necessary.

8-4-4 Precautions for Propellant/Motor Storage

All propellants/motors will be safely handled in accordance with HOPS.
These procedures include, but are not limited to, proper grounding and
bonding protocol. All permitted hazardous waste storage and treatment
facilities are located more than 50 feet from any property line to help
minimize the fire potential of adjoining property. General site maps which
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

9

show these buildings, as well as the property lines, are found in
Attachment 6.

8-4-5 Precautions for Oxidizer Leaching Treatment

All explosives/propellants will be safely handled in accordance with
HOPS during the oxidizer leaching process. Safety provisions, such as
shielding of the heat exchanger within the process tank, to prevent
accidental ignition and reaction of these wastes are described in
Attachment 12. All permitted hazardous waste storage and treatment
facilities are located more than 50 feet from any property line to help
minimize the fire potential of adjoining property. General site maps which
show these buildings, as well as the property lines, are found in
Attachment 6.
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

10

TABLE 8A

Precautions Against Accidental Ignition and Reaction of Hazardous Waste
Explosives and Propellants

IGNITION SOURCE PRECAUTIONS
Smoking Burning grounds are designated as areas
where smoking is a fire hazard and as such
must meet the requirements of company
procedures. Requirements for smoking are
strictly enforced by the Safety department.

Open Flames

The use of a flame, heat, or spark-emitting
device in any area requires a permit.
Requirements for uses and restrictions of
these permits are found in company
procedures. These permits are issued prior to
starting work.

Static Electricity

Static electricity can be an ignition source. To
avoid static charges, all explosive or
propellant waste is packed in a container with
either a conductive or static dissipative liner.
During storage and prior to and/or during
transportation of wastes to the burning
grounds, all conductive waste containers are
grounded to prevent static spark. Upon
placement in the metal burn tray, grounding is
no longer required. Rocket motors for
disposal will not be packaged in these liners,
but will be grounded to the case prior to being
placed into position for open burning.

Incompatible Materials

Incompatible materials are not placed in the
same containers and incompatible wastes are
segregated at each waste pickup dock.

Friction and Sparks

Vehicles hauling waste propellant must have
spark arresters in the exhaust line.
Non-sparking rakes are used in preparing the
trenches for burning or re-burning. A porous,
non-sparking truck bed is also used.

Electrical Equipment

No electrical work is allowed in areas where
explosives or propellant are present.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 8 – Preparedness and Prevention UTD009081357

11

TABLE 8B

Precautions Against Accidental Ignition and Reaction of Hazardous Waste
in Drum Storage

IGNITION SOURCE PRECAUTIONS
Smoking The drum storage areas are designed as
areas where smoking is a fire hazard and as
such must meet the requirements of
company procedures. Requirements for
smoking are strictly enforced.

Open Flames

The use of a flame, heat, or spark-emitting
device in any area of the plant requires a
permit. Requirements for uses and
restrictions of these permits are found in
company procedures. These permits are
issued prior to starting work.

ATTACHMENT 9

CONTAINER MANAGEMENT PROCEDURES

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

2

CONTENTS

9 USE AND MANAGEMENT OF CONTAINERS ...............................................3
9-1 PURPOSE AND SCOPE .............................................................................3
9-1.1 Facility Description ....................................................................3
9-2 MANAGEMENT OF CONTAINERS ........................................................4
9-2-1 Types of Containers for Storage ................................................4
9-2-2 Waste Compatibility ..................................................................5
9-2-3 Storage of Containers .................................................................6
9-2-4 Inspections .................................................................................8
9-2-5 Operating Record………………………………………… .......8
9-3 LAB PACKS AND WASTE CONSOLIDATION......................................8
9-3-1 Lab Pack Preparation .................................................................8
9-3-2 Lab Pack Labeling .....................................................................9
9-3-3 Containment Sealer ....................................................................9
9-3-4 Lab Pack Compatibility .............................................................9
9-4 CONTAINMENT ........................................................................................9
9-4-1 Capacity of Containment ...........................................................9
9-4-2 Containment Sealer ..................................................................10
9-4-3 Removal of Free Liquids From
Containment Area ....................................................................10
9-5 RUN-ON AND RUN-OFF CONTROL ....................................................11
9-6 REQUIREMENTS FOR IGNITABLE AND REACTIVE
WASTES ..................................................................................................12

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

3

9 USE AND MANAGEMENT OF CONTAINERS

9-1 PURPOSE AND SCOPE

Northrop Grumman Systems Corporation – Promontory (NGSC) currently
manages the drum storage areas at M-186, E-501, M-705S, the solid
propellant storage building M-629, storage pad S-633 and solid propellant
storage in burn trays and at Burn Station 14 at M-136 in accordance with
Utah Administrative Code R315-264-170. These waste storage areas are
owned and operated by NGSC. All containers are being temporarily
stored waiting thermal treatment on-site or shipment off-site for recycling,
treatment and/or disposal.

The drum storage site at M-186 is designed to hold 400, 55-gallon drums
of various types of waste intended for treatment or disposal. The drum
storage site at E-501 is designed to hold 160, 55-gallon drums of various
types of waste intended for treatment or disposal. The M-705S storage
and consolidation room is designed to store a maximum of 32, 55-gallon
drums, both rooms include palletainers of various types of waste intended
for consolidation or lab packing. For solid propellant storage capacities,
see Module III section E.

9-1.1 Facility Description

The M-186 storage building is permitted for the storage of the hazardous
wastes identified in Permit Condition III.B.1. The storage pad is divided
into five storage bays to keep incompatible materials separated. The pad
is a coated concrete floor with secondary containment. The M-186 storage
facility is shown in Figure E-1 of Attachment 6.

The E-501 storage pad is permitted for the storage of the hazardous wastes
identified in Permit Condition III.B.1. The pad is a coated concrete floor
with secondary containment. The E-501 storage facility is shown in
Figure B-1 of Attachment 6.

The M-705S Storage and Consolidation Room is a single room with a
coated concrete floor and secondary containment. It is permitted for the
storage of the hazardous wastes identified in Permit Condition III.B.1.
The room is equipped with plastic containers to keep incompatible
materials separated. Poly-spill pallets are used to provide separate
containment for each consolidation drum and lab pack drum as needed.
The M-705S storage facility is shown in Figure C-1 of Attachment 6.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

4

M-629 is designed for storage of solid propellant/explosives. This
building is sited for the maximum quantity of propellant/explosives based
on Quantity/Distance, DOD siting criteria found in the contractor safety
manual, 4145.26m. Each building is set up to permit proper grounding
and cross bonding as appropriate. The M-629 storage facility is shown in
Figure 6-D of Attachment 6.

Storage Pad S-633 is designed for storage of solid propellant/explosives.
It is secured by a perimeter fence, a vehicle access gate that can be locked,
and has the appropriate warning signs for a storage area. It has a road base
surface, and has lighting protection. Precipitation run-on or run-off is
prevented by a combination of diversion ditches, collection ditches and
trenches. The S-633 storage pad is shown in Figure J-1 of Attachment 6.

The storage of solid propellant wastes at M-136 includes waste stored in
containers placed in burn trays and waste rocket motors that contain solid
propellant placed on the ground at Burn Station 14. The storage of waste
materials at M-136 is permitted in order to facilitate more efficient and
safer waste handling practices, and to accommodate delays in waste
treatment due to weather or other uncontrollable delays. Storage of this
waste will be in compliance with this permit and UAC R315-264-170.

9-2 MANAGEMENT OF CONTAINERS

9-2.1 Types of Containers for Storage

The containers to be used for storage, lab packing, or consolidation at
M-186, E-501, and M-705S will meet the UN or U.S. DOT criteria or will
be a sturdy liquid tight alternative container. No more than 400 drums
will be stored at M-186; 160 drums at E-501; and 32 drums at M-705S.
Substitute containers will reduce the number of drums that can be stored
based on the volume of the container chosen.

The containers that will be used for storing solid, reactive wastes at M-629
and S-633 include rocket motor cases, covered drums, boxes, plastic bags,
woven bags, slids, and U.S. Department of Transportation (DOT)
approved shipping containers. The standard containers used at the Facility
are described in Attachment 11, Section 11.4.

All solid reactive waste stored at M-136 will be stored in containers as
described in Attachment 11.4. Storage of these containers is permitted in
liquid tight burn trays or on the ground at Burn Station 14 for intact rocket
motors. All containers will be kept closed during storage.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

5

Lab pack and consolidation drums used for different compatibility groups
will be separated using a portable secondary containment system (PSCS)
such as a Poly-spill pallet. The PSCS will have the capacity to hold a
minimum of 55 gallons. Most PSCSs are unsatisfactory for storing most
organic waste; therefore, flammable/combustible waste lab packs or
consolidation drums will be placed on a pallet and stored on the floor
using the room’s containment system. Lab pack and containment drums
with non-hazardous waste will be stored on the floor. Non-hazardous
waste found to be incompatible with solvents would be placed on a PSCS
for which it was found to be compatible. All full consolidation or lab pack
drums will be transferred from M-705S to a permitted storage facility to
stay within M-705S’s storage capacity.

TABLE 9-2
HAZARDOUS WASTE COMPATIBILITY FOR STORAGE AT
M-186, E-501, M-705S, M-629, and S-633

General Compatibility Groups DOT Hazard Class in Group

1. Flammable/combustible liquids a. Flammable Liquids
and non-flammable solvents b. Combustible Liquids

2. Corrosives (acids) a. Corrosive Liquids (acids only)

3. Corrosives (bases) a. Corrosive Liquids (bases only)

4. Reactive Chemicals a. Organic Peroxides
b. Oxidizes

5. Toxic Chemicals a. Toxic
b. Infectious

6. Explosives a. 1.1
b. 1.3

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

6

9-2.3 Storage of Containers

M-186, E-501 and M-705S

Before any waste container is accepted at M-705S, E-501, and M-186, it
shall be inspected to determine whether the waste matches the identity of
the waste specified on the accompanying manifest or shipping paper. In
addition, the containers shall be inspected to ensure that they are in good
condition, are closed, and labeled in accordance with R315-262-17(a)(5)

If the drum is found to be unacceptable, it must be immediately repacked
and relabeled or the waste transferred to a new drum. Each drum or
container must be entered into the operator’s log (see Section 9-2.5) when
the drum or the container is accepted into the drum storage area. A
forklift and/or pallet jack is used to move the pallet into the storage area.

Drums or containers in the holding bays at M-186 and at E-501 will be
sampled according to Attachment 1 of this permit. The wastes are
accumulated until enough containers exist to complete a load. The
containers are then loaded into a truck and shipped to the disposal facility
for proper treatment and/or disposal.

All drums stored at the M-705S, E-501, and M-186 storage areas will be
stored with either both plugs closed or with the top of the drum sealed. No
waste containers will be open unless waste is being added or removed.
Adding or removing waste will only occur at these storage facilities if a
container is damaged, leaking, for sampling, for waste consolidation,
and/or for lab packing. A container may be filled if spilled material is
found in a sump during the transfer of waste containers. A container being
filled or replaced will be located in the containment area. This will
provide containment if any spillage results from an incident during
transferring procedures. Precautions to be taken during the transfer of the
waste include: insuring all transfer equipment (i.e., hoses, pumps,
funnels) is located inside the containment area; ensuring a proper drum is
used when transferring waste material.
An aisle space of 30 inches minimum between containers or pallets of containers will be maintained at storage areas M-186 and E-501. Hazardous waste stored in containers at M-705S, M-629, S-633 and M-136 will be stored so that they may be readily inspected and hazardous waste labels are visible. 55-gallon drums may be stacked at a maximum of two high at storage areas M-186 and E-501 only. Containers stored at M-629 and S-633 that can be safely stacked, such as flare or munition boxes, may be stacked to a maximum height of six feet.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

7

All storage containers shall have hazardous waste labels attached that meet
the requirements of UAC R315-262-17(a)(5). All personnel required to
complete RCRA labeling shall receive training as appropriate.

M-629 and S-633

All waste propellant/explosives stored at M-629 and S-633 must be
entered into the operating record. Building and storage pad inspections
must begin upon first receipt of material and end when all hazardous waste
has been removed from the building or storage pad. All containers must
be kept closed except when adding or removing waste. Adequate aisle
space must be provided to permit proper container inspection. Total
quantity limitations are as outlined in module III section E.

All containers shall have hazardous waste labels attached that meet the
requirements of R315-262-17(a)(5).

M-136 Burn Trays and Burn Station 14

All solid reactive wastes received from off-site shall be inspected prior to
placement into burn trays or Burn Station 14 at M-136 to determine
whether the waste matches the identity of the waste specified on the
accompanying manifest or shipping paper. In addition, the containers
shall be inspected to ensure that they are in good condition, are closed, and
labeled in accordance with UAC R315-262-17(a)(5).

If a container holding hazardous waste is not in good condition, e.g.,
apparent structural defects, or if it has begun to leak, NGSC personnel
shall take steps as appropriate to prevent a release from the container to
the environment.

Prior to placement of hazardous wastes into burn trays, the tray shall be
inspected as outlined in Attachment 2. Once the container or waste rocket
motor is received it is placed in a burn tray or Burn Station 14, the date of
the placement shall be added to the hazardous waste label.

Containers stored in burn trays at M-136 shall remain closed during
storage, except when it is necessary to add or remove waste. A container
holding hazardous waste shall not be handled or stored in a manner which
may rupture the container or cause it to leak. Containers shall be stored
such that the hazardous waste labels may be readily inspected.

9-2.4 Inspections

All container storage areas are inspected on at least a weekly basis.
Details of inspection requirements for the storage areas are outlined in

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

8

Attachment 2. If a container is found with severe corrosion, structural
defects, rusty bungs, or leaking, the contents or the entire container must
be immediately transferred into a new container. The new container must
be numbered and labeled with exactly the same number and label as the
old container. The date and time of any transfer action must be noted in
the inspection log.

9-2.5 Operating Record

All waste brought into the M-186, E-501, M-705S, M-629, S-633 and
M-136 storage areas are entered into a hazardous waste log compliant with
R315-264-73. This log is kept for all wastes.

If a waste material is consolidated, the consolidation drum is recorded in
the hazardous waste log in such a way as to allow the consolidated
material to continue to be tracked. Waste materials to be lab packed are
placed in a lab pack drum and recorded in a hazardous waste log in such a
way as to allow the material and the drum to also be tracked.

The operating record is kept for all hazardous wastes. These records are
used to track wastes as they come in from on and off-plant generators and
satellite generator facilities.

9-3 LAB PACKS AND WASTE CONSOLIDATION

9-3.1 Lab Pack Preparation

NGSC disposes of several hazardous wastes in lab packs. Completed lab
packs are stored in the drum storage bays. Before a lab pack is accepted at
the drum storage bay, it must be prepared, labeled, and documented in
accordance with UAC R315-262-17(a)(5).

Materials in small containers may be stored at the lab packing and
consolidation room at M-705S or at M-186 for lab packing or waste
consolidation. The materials are separated into compatibility groups based
on DOT hazard classification. The materials are generally in small
containers ranging from one or two ounces to 5-gallon cans. The small
containers are then stored in palletainers or on a shelf until ready to lab
pack or consolidate. Incompatible materials are not allowed to be stored
in the same palletainer, or containment bay.

9-3.2 Lab Pack Labeling

Each waste container must be labeled with a complete hazardous waste
label.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

9

9-3.3 Containment Sealer

The concrete containment area where consolidation and lab packing occur
at M-186 and M-705S, is sealed with a high build polyamide epoxy
coating system or equivalent. The Safety Data Sheet and compatibility
chart for this material can be found on the manufacturer’s web site.

9-3.4 Lab Pack Compatibility

Under no circumstances will a lab pack contain wastes that are
incompatible. Compatibility of wastes will be determined by using the
SDS or other reference sources. If a waste is not found in the reference
material, then the material will be assumed incompatible with all wastes
and lab packed separately unless research by Environmental Waste
Disposal’s technical staff documents compatibility. Lab packing will be
done in accordance with U.S. DOT regulations and the requirements of the
disposal company.

9-4 CONTAINMENT

9-4.1 Capacity of Containment

All the container storage areas and consolidation/lab packing areas at
M-186, E-501, and M-705S are designed to hold a minimum of ten
percent of the volume of waste stored in the area or the volume of the
largest container, whichever is greater. Table 9-5A summarizes the
calculations.

TABLE 9-5A

Containment Capacity of Drum Storage Areas Storage Container Number of Drums
to be Stored
Needed
Containment
Containment
Available M-186 Storage Bay 80 Drums 440 Gal 980 Gal E-501 Storage Pad 160 Drums 880 Gal 895 Gal M-705S Room 16 Drums* 88 Gal 830 Gal M-705S Poly-spill pallet 4 Drums 55 Gal 85 Gal * Includes Palletainers

Storage building M-629 and storage pad S-633 are not permitted to store
liquids. Each container will be inspected to assure no liquids are present
upon arrival at the storage facility. Storage building M-629 is fully
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

10

enclosed to prevent contact of waste with rainwater, and does not require
secondary containment. Roof leaks must be repaired as soon as is
practicable. Storage pad S-633 is located within the M-136 Thermal
Treatment Area. Any rainwater falling on the pad is collected in the
M-136 storm water run-on/run-off control system.

9-4.2 Containment Sealer

The containment area at the M-186 and M-705S storage facilities are
coated with an epoxy resin to resist liquid penetration. No leakage or
spillage is anticipated during waste storage; however, in the event spills or
leaks do occur, the epoxy will prevent the material from penetrating the
concrete.

The containment system at E-501 is coated with an epoxy sealer that is a
high-build chemical resistant coating. The chemical compatibility and
properties of this epoxy are available from the manufacturer.

9-4.3 Removal of Free Liquids From Containment Area

Removal of free liquids at M-186, E-501, and M-705S must be done with
a pump or vacuum truck. When free liquids are found in the sump, a
portable drum pump, either electric or hand operated, is used to transfer
the liquid to a UN 55 gallon drum. A vacuum truck can also be used to
pump out collection of rain water and snow melt. Water pumped with the
vacuum truck will be taken to a UPDES permitted wastewater treatment
facility (M-705) for processing. All free liquids taken from the sumps will
be managed as hazardous wastes until waste analysis or inspection dictates
otherwise.

Precautions will be taken to avoid spills. All spills are cleaned
immediately, unless the size demands spill response. After the liquids are
transferred into drums, a sample will be taken from each drum according
to the sampling procedure in the Waste Analysis Plan, contained in
Attachment 1. The drums will be managed as hazardous waste until a
determination has been made classifying the contents. If the analysis
indicates the liquid is a hazardous waste as defined by Utah
Administrative Code R315-261, then the drums will continue to be
managed as a hazardous waste. If the liquid is a wastewater, the liquid
will be taken to M-705 Wastewater Treatment Facility.

Occasionally, small amounts of liquid such as nitroglycerine can drip from
rocket motors onto the concrete floor. These drips are typically less than
1-inch in diameter and may drip as much as once per week. Any sign of
out-of-place waste will be checked during the regular inspections outlined
in Attachment 2. Clean up of dripped materials will be completed as soon
as is practicable using rags and acetone or other appropriate cleaners.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

11

M-136 Burn Trays

Although the burn trays at M-136 are permitted for the storage of solid
reactive wastes in containers, some of these containers contain small
amounts of desensitizing fluid (e.g. diesel, shingle oil, etc.). Therefore,
the containment requirements of UAC R315-264-175, as discussed below,
apply to the storage of wastes in the burn trays.

The burn trays shall be free of cracks or gaps and be sufficiently
impervious to contain leaks, spills, and accumulated precipitation until the
collected material is detected and removed.

Spilled or leaked waste and accumulated precipitation shall be removed
from the burn trays in as timely a manner as is necessary to prevent
overflow of the tray. Inspection requirements for burn trays and the
accumulation of liquids are outlined in Attachment 2.

If the collected material is a hazardous waste under UAC R315-261, it
shall be managed as a hazardous waste in accordance with all applicable
requirements of the State of Utah Hazardous Waste Management Rules. If
the collected material is discharged through a point source to waters of the
United States, it is subject to the requirements of section 402 of the Clean
Water Act, as amended.

9-5 RUN-ON AND RUN-OFF CONTROL

Run-on and run-off water is prevented from entering the M-186 and E-501
drum storage pads. Three sides of each pad contain a curb that is six
inches in height and a sloped grade in the front that is three inches above
the ground surface. Each pad has sufficient height to prevent run-on from
entering the drum storage containment system. Detailed drawings of these
facilities are contained in Attachment 6.

The storage facility at M-705S is totally enclosed to prevent any run-on
water from entering the building.

Calculations have been performed for the M-186 storage pad and these
indicate that no run-on or run-off should enter the storage building and
affect the capacity of the containment area. The calculations were based

on a 24-hour, 25-year storm event and were submitted with the Part B
Permit Application.

The terrain around the burn grounds and storage pad S-633 has been
graded and drainage ditches surround the area in order to minimize
run-on/run-off. The topography and drainage ditches at M-136, M-225,
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 9 – Container Management UTD009081357

12

and S-633 are shown in Attachment 11 Figures 11-1 and 11-2, and
Attachment 6 Figure J-1.

In addition, all waste will be in water tight burn trays to prevent run-on
and run-off. Waste Rocket motors will be covered to eliminate contact
with rain water.

9-6 REQUIREMENTS FOR IGNITABLE AND REACTIVE WASTES

All container storage areas are located more than 50 feet from facility
property lines. The aerial photograph contained in Attachment 6
(Figure 6A) shows the property boundaries and facility location.

ATTACHMENT 10

T-29B HYDRAZINE DILUTION PROCEDURES

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 10 – Hydrazine Treatment UTD009081357
2

10 HYDRAZINE DILUTION PROCESS . . . . . . . . . . . 3
10-1 PURPOSE AND SCOPE . . . . . . . . . 3
10-2 PROCESS DESCRIPTION . . . . . . . . . 3
10-3 ENVIRONMENTAL PERFORMANCE STANDARDS 4
10-3-1 Prevention of Releases to Ground Water or
Subsurface Environment . . . . . . . . . 4
10-3-2 Prevention of Releases to Surface Water,
Wetlands, or Soil Surface . . . . . . . . . 4
10-3-3 Prevention of Releases to Air . . . . . . . . . 4
10-4 MONITORING, ANALYSIS, INSPECTION,
RESPONSE, REPORTING, AND CORRECTIVE
ACTION . . . . . . . . . . . . . . . . . . . 5

10-5 RECORD KEEPING AND REPORTING . . . . . . . . 5

10-6 CLOSURE . . . . . . . . . . . . . . . . . . . . . . . . . .5

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 10 – Hydrazine Treatment UTD009081357
3

10 HYDRAZINE DILUTION PROCESS

10-1 PURPOSE AND SCOPE

Northrop Grumman Systems Corporation - Promontory (NGSC) operates
a small treatment process to dilute waste hydrazine at Building T-29B.
This process dilutes hydrazine waste with water so that waste hydrazine
solutions do not exceed hydrazine concentrations above 50 percent. The
dilution process is necessary because of the extreme flammability and
reactivity of hydrazine and the lack of a disposal facility for concentrated
hydrazine. The diluted waste hydrazine is shipped off plant to an
incinerator for destruction.

10-2 PROCESS DESCRIPTION

The dilution of waste hydrazine with water is a simple process. NGSC
does not generate large amounts of waste hydrazine, but because
hydrazine is extremely flammable and reactive, special care must be used
in its disposal. Hydrazine is used during a motor firing static test process.
At the completion of the test, residual hydrazine is removed from the test
system and is collected in a small, nitrogen purged, cart mounted tank, and
transferred to Building T-29B. Typically hydrazine is filtered and stored
in the tank until it is used during the next static test. In the event the
hydrazine can’t be used or is no longer needed it is transferred to a drum
where it is mixed with water and sent off-site for disposal as a hazardous
waste. Lab samples from quality assurance testing of the hydrazine
product are also dumped directly into the water/hydrazine diluted drum for
disposal. The waste collection container can be managed as either a
90-day waste or under satellite accumulation rules depending on the waste
volume.

Here is a description of the hydrazine mixing process. This tank is
equipped with a scrubber vent system which is utilized during initial
transfer into the tank. A volume of water equal to the volume of
hydrazine is placed into a 55-gallon drum at T-29B. A tube is run from
the tank into the bottom of the 55-gallon drum. The hydrazine is then
dispensed into the drum through the tube using nitrogen pressure. This
process is repeated until the collection container is full. This transfer is
performed with personnel in Level A personal protective equipment
(PPE). After the transfer is complete, the air in the room is tested to
assure safety before the Level A PPE is removed.

The system is designed and operated to prevent any releases and to safely
transfer the material. After the material transfer has been completed, the
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 10 – Hydrazine Treatment UTD009081357
4
material is shipped off plant for disposal or sent to the M-186 Hazardous
Waste Storage Facility.

10-3 ENVIRONMENTAL PERFORMANCE STANDARDS

The T-29 Hydrazine dilution process has been located, designed, operated,
maintained and will be closed in a manner that will ensure protection of
human health and the environment. This section addresses the prevention
of releases due to migration of hazardous constituents into the ground
water or subsurface environment, surface waters, wetlands, surface soils,
and in the air.

10-3-1 Prevention of Releases to Ground Water or Subsurface Environment

Several parameters have been considered in determining the prevention of
a release to groundwater or subsurface environments. It is important to
note that there will only be a limited amount of pure hydrazine, generally
no more than 55 gallons, to dilute at any one time and that this process is
all done within a containment system. The containment system is shown
in the facility drawing contained in Attachment 6 (Figure H-1). Because
of the secondary containment, there should be minimal potential for
deposition or migration of waste constituents into the subsurface or
groundwater.

10-3-2 Prevention of Releases to Surface Water, Wetlands, or Soil Surface

The dilution area has secondary containment to ensure collection of any
spill. A 7,500-gallon, emergency-use-only sump has been designed to
contain any spill. The sump is only used if a spill occurs; it is not used on
a routine basis. The sump is designed to collect any large spill and has
more than sufficient capacity to hold any spill during the dilution process.

The use of this containment, along with careful procedures and the low
volume of waste, reduces the potential for any adverse effect on human
health or the environment.

10-3-3 Prevention of Releases to Air

The transfer of hydrazine is conducted with strict safeguards and
procedures to prevent the migration of waste constituents in the air. This
process transfers the hydrazine using nitrogen. Escaping gases are
minimized by discharging through a tube under water in the collection
drum. These procedures minimize the quantity of any hydrazine
migration through the air and minimize the potential for any adverse
effects to human health or the environment.
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 10 – Hydrazine Treatment UTD009081357
5
10-4 MONITORING, ANALYSIS, INSPECTION, RESPONSE,
REPORTING, AND CORRECTIVE ACTION

Because hydrazine requires special handling precautions and safety
procedures, NGSC personnel follow internal procedures when performing
the dilution process. NGSC will conduct the dilution process in a manner
that will ensure protection of human health and the environment.

NGSC will comply with the requirements specified in the facility
Contingency Plan (Attachment 4), when there has been a release at
Building T-29B that threatens human health or the environment.

NGSC will comply with the ignitable and reactive waste regulations as
required by Utah Administrative Code (UAC) R315-264-17.

NGSC will inspect Building T-29B in accordance with the inspection
schedule contained in Attachment 2.

10-5 RECORD KEEPING AND REPORTING

NGSC will record in the operating record the following:

1. The date that waste hydrazine is received at T-29B;

2. The quantity of waste hydrazine received;

3. The date the waste hydrazine is treated by the dilution process;

4. The quantity of diluted hydrazine after the dilution process is
complete; and

5. The date the diluted hydrazine is shipped off-site or to the M-186
storage facility.

10-6 CLOSURE

NGSC will close Building T-29B in accordance with UAC R315-264-110
through 120, UAC R315-264-178, Permit Condition II.O. and the
designated Closure Plan in Attachment 5 of this Permit.

ATTACHMENT 11

M-136 and M-225 Thermal Treatment Operations
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

2

11.0 PROCESS INFORMATION
All reactive waste management operations at the facility are conducted and are under
the management of Northrup Grumman Systems Corporation (NGSC). The reactive
waste management process is described in the following text.

11.1 Facility Description
The NGSC Promontory facility is located in a remote area of west Box Elder County,
Utah, approximately 30 miles northwest of Brigham City, and approximately 11 miles
north of the Great Salt Lake. The facility was purchased by Thiokol in 1956, with the
exception of a 1,500-acre tract that was sold to the U.S. Air Force in 1958 and then
repurchased in 1995. The facility has been held in its entirety since purchase.

Northrop Grumman Systems Corporation conducts thermal treatment of reactive
hazardous wastes at two treatment units: (1) the main facility, M-136, located centrally
to the two main manufacturing sites; and (2) M-225 located in a remote development
location called Plant III.

M-136 is the primary treatment area for conducting open burning at the NGSC
Promontory facility. Open detonation is also conducted at M-136 which is a secured
fenced facility within the main facility fence.

The M-225 treatment area receives small amounts of the reactive hazardous waste
materials from the Plant III propellant development area. The M-225 treatment unit is
surrounded with an 8-foot high chain link fence. The waste materials are treated via
open burning or open detonation.

The M-136 and M-225 treatment areas are fenced and are located within a controlled and
fenced facility that is patrolled and maintained by a security department. The treatment
areas have warning signs posted around the perimeter. The vegetation is controlled within
the treatment areas through application of herbicide and putting in place loads of gravel
and road base. Surrounding both treatment areas are a large system of fire breaks that are
constructed using large equipment to till and cultivate a large strip of land removing any
vegetation. The system of fire breaks are designed to contain a fire within its
boundaries.

Contained within the boundaries of the M-136 treatment area are twelve former surface
impoundments called Liquid Thermal Treatment Areas (LTTAs). These impoundments
were used for the disposal of hazardous waste and wastewater and then capped and closed.
The units are currently under post closure care and managed through a Post Closure Permit
which includes requirements for groundwater monitoring and corrective action. The
Post-Closure groundwater monitoring program includes all wells around the M-136 and
M-225 treatment areas as part of the groundwater monitoring system. These wells are
routinely monitored thorough the permit requirements which includes the Sampling and
Analysis and Quality Assurance Plans.

The NGSC Promontory facility is located in the Blue Spring Valley which is bounded
on the east by the Blue Spring Hills and on the west by Engineer Mountain and the
Promontory Mountain ranges. Within the Blue Spring Valley, the terrain is
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

3

characterized by topography that slopes down from the mountain crest at an elevation
of approximately 6,050 feet above mean sea level (AMSL) toward the center of the
Blue Creek Valley at an elevation of 4,250 feet AMSL. As a result, the surrounding
environment extending out to 6.2 miles (10 kilometers) from both treatment units can
be characterized as complex terrain.

GEOLOGY
The NGSC Promontory facility is located in the Southern Blue Creek Valley, northwest
of the Salt Lake Valley, which is the eastern most structural valley of the Basin and
Range physiographic province, which includes parts of Utah, Idaho, Nevada, Arizona,
and New Mexico. The Basin and Range province consists of a number of north-south
aligned mountain ranges and valleys bounded by high-angle normal faults. The Blue
Creek Valley, in which NGSC Promontory facility is located, is bounded on the east and
west by the Blue Springs Hills and the Engineer and Promontory Mountain ranges,
respectively. Movement along the faults has displaced the mountains upward relative to
the adjacent valley. Likewise, the mountains immediately west of NGSC Promontory
facility are bounded on their eastern margin by one or more faults which are partly buried
by recent deposits.

Bedrock, composed of Middle Paleozoic shale, sandstone, and limestone, is exposed in
the ranges adjacent to the site. The bedrock is highly fractured with some folding.

During the Mississippian and Permian Periods, marine sediments consisting of sand, clay,
and calcareous detritus were deposited in shallow marine environments. In the late
Cretaceous Period, compressional forces from the west resulted in folding and thrust
faulting in conjunction with uplift of the region into mountain ranges. Extensive jointing
and fracturing of the bedrock were caused by this folding and faulting episode. Tensional
stresses in the early to middle Tertiary Period resulted in north south trending normal
faults that formed a series of high linear mountain ranges with intervening basins which
received sediment from adjacent highlands. This activity was associated with volcanism
and ancient lake deposition.

In the late Tertiary Period, a series of geologic units tentatively identified as the Salt Lake
Group were formed from deposition of sediments in large lakes which developed within
the valleys. These lake deposits are composed primarily of silts and clays with minor
amounts of sand and gravel and are characterized by low to moderate permeabilities;
extensive deposits of volcanic ash are also present in the Salt Lake Group. The alluvial
fan deposits were overlapped by more recent lake sediments of Pleistocene Lake
Bonneville, the predecessor to the present Great Salt Lake. Lake Bonneville covered
much of western Utah and parts of Idaho and Nevada between about 23,000 and 12,000
years ago. Deposits associated with the lake consist of lakebed and alluvial materials
reworked by lake bottom and shoreline processes. Lake Bonneville sediments thicken
southward.

The most recent sedimentary deposits consist of stream alluvium and mud and debris
flows. The stream alluvium consists primarily of silty and clayey sand and gravel. The
mud and debris flow deposits are characterized by a broad gradation of sediments from
clay-size fines to boulders as large as 3 feet in diameter.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

4

HYDROGEOLOGY
Groundwater in Blue Creek Valley occurs under unconfined and confined conditions.
These two conditions exist in fractured and faulted bedrock, lake clays and gravels,
unconsolidated alluvium, gravel, and sandy deposits. Precipitation, surface water
infiltration, and plant discharges that infiltrate into sediments may migrate slowly,
vertically, and horizontally to form perched water tables above the 50- 150-foot depth of
the regional water zone. The perched ground water may eventually migrate to the deeper
regional system. The regional system ranges from 50-600 feet in depth depending on the
topographical location. Blue Creek may recharge shallow aquifers in the center of the
Blue Creek Valley. The direction of movement within the faulted and fractured bedrock
will be controlled by the connection of faults and fractures. Regionally, the groundwater
flow trend is from north to south. Depth to groundwater at the M-136 treatment units is
an average 300 feet. Depth to groundwater at the M-225 treatment unit is 600 feet.

The groundwater quality in Blue Creek Valley is generally poor due to naturally
occurring chlorides and total dissolved solids. Levels of dissolved solids range from 400
to over 12,000 mg/l. The quality of groundwater depends upon the sediments, which it
has contacted. Quality is quite good in local, up gradient areas of water recharge, but
degrades rapidly as it moves from mountain to the valley axis. High levels of total
dissolved solids in lowland areas are probably due to slow migration through Tertiary
sediments. Down gradient from the NGSC sites, quality deteriorates rapidly as it enters
the mudflats of the Great Salt Lake.

CLIMATE
NGSC has a 10-meter meteorological tower and instruments to measure and record air
temperature, barometric pressure, relative humidity, solar radiation, precipitation, vertical
and horizontal wind speed, and direction.

The NGSC plant site is classified as semiarid, with an average annual total precipitation
of 14.88 inches at the NGSC meteorology station. During the winter months, the average
total snowfall amounts to 24 inches. Precipitation typically occurs on 95 days out of the
year (includes trace precipitation). During the year, it would be expected that 35 percent
of the days would be clear, 30 percent of the days would be partly cloudy, 34 percent
would be cloudy, and fog would be expected to occur about 1 percent of the time.
According to interpreted weather data for the NGSC facility, the 25-year storm with
24-hour duration would result in 2.4 inches of precipitation.

Evaporation rates are high throughout the year, with the Great Salt Lake averaging 66 in.
a year. The average area evapotranspiration rate is 46.6 inches. The consistently low
precipitation and high evaporation allow little if any percolation into subsurface soils.

The average annual temperature in the NGSC Promontory area is in the 45 to 50 degree
range, with generally hot, dry summers. Relative humidity averages between 20 and 30
percent during summer afternoons. Nights are usually cool, but daytime maximums
occasionally exceed 100 degrees F. On clear nights, cold air usually drains from the
slopes of the adjacent ranges and accumulates on the valley floor, while the foothills and
bench areas, such as at NGSC, remain relatively warm. The average daily temperature
ranges from about 11 to 32 degrees F in January and from about 54 to 91 degrees F in
July.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

5

On an annual basis, the winds for the valley tend to prevail from the north during the
earlier morning hours and south to southeast, averaging about 10 mph, during the
afternoon.

Blue Creek is the only perennial stream in the valley drainage basin and is the closest
water body to the M-136 treatment unit. Blue Creek originates some 15 miles north of
the Promontory facility from a warm saline spring, which flows along the western
boundary of the facility.

The Promontory area is characterized as a very sparsely populated rural region, with
primarily dry farms and ranching activities. Low growing perennial grasses and shrubs
characterize the vegetation in the area. The ecological habitat found at the NGSC
Promontory facility includes many head of mule deer and large populations of various
birds, rabbit, and predator species.

11.2 WASTE CHARACTERIZATION
Wastes will be characterized to identify hazardous properties to ensure they are
properly managed. The Waste Analysis Plan (see Attachment 1) will be used to
characterize and classify reactive wastes.

11.3 REACTIVE WASTE DESCRIPTION
The primary products produced at the facility include solid rocket motors, military and
aviation flares, and high explosive/high energy compounds. Solid rocket motors are
typically cast with composite propellants. Composite propellants are classified as a
DOT 1.3 material, and typically contain a non-explosive liquid binder mixed with
aluminum powder and ammonium perchlorate. Flares are generally classified as a
DOT 1.3 material, and typically contain an inert binder, a metal powder, and an
oxidizer. High explosive compounds are generally classified as DOT 1.1 material and
are generally nitramine compounds developed for specific military requirements.
Reactive wastes are produced from the manufacturing process include, but are not
limited to the following: cured and uncured propellants; rocket motors; small initiating
devices; explosives articles, propellant scrap; and explosive ingredients such as HMX,
RDX, CL-20, explosive contaminated metal powders such as aluminum and
magnesium and oxidizers such as ammonium perchlorate and potassium perchlorate.
The facility also contains both quality assurance and research and development
laboratories. The quality assurance laboratories generate wastes similar to
manufacturing wastes. The Research and Development laboratories generate a small
quantity, but a wide variety of both explosive compounds and precursors to explosive
compounds.

Reactive wastes are characteristic hazardous wastes for reactivity (D003). Nearly all of
the reactive wastes are reactive due to the presence of propellants and explosives.
Some reactive wastes, such as those from laboratory operations, may contain solvents
which would also be a listed waste defined by UAC R315-261-1. Wastewater
treatment sludge generated from the processing of explosives is a K044 listed
hazardous waste. Reactive wastes also include materials such as rags, gloves, other
personal protective equipment, plastics, rubber and paper contaminated with explosive
materials during the manufacturing process.
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

6

Reactive wastes may also be received from off-site sources. With one exception,
off-site wastes are rocket motors, propellants or explosives with similar formulations
and ingredients to those generated on site.

11.4 REACTIVE WASTE GENERATION AND COLLECTION
NGSC uses a variety of containers to store reactive wastes at the Promontory facility.
The standard containers used at the facility are described in this section. However, due
to the nature of our business, new types of containers may be required in the future, and
can’t be described in this application. To ensure that all containers are safe to use,
containers will be selected using the DOD Contractor’s Safety Manual for Ammunition
and Explosives (DOD 4145.26-M). All containers for reactive waste that are currently
used, or will be used in the future, will meet the DOD 4145.26-M requirements.

Operating buildings generating reactive wastes use a variety of collection containers as
described below:

• Conductive Containers – Electrically conductive containers are typically bags
made of opaque, volume-conductive carbon-impregnated polyolefin or
polypropylene. They can be grounded to prevent the build-up of static electricity.
The bags are available in a variety of sizes from small containers to larger than one
cubic yard. They are typically used to line other containers, but can be used
without an outside container. Typical conductive containers include Velostat®
bags, Velostat® sheet material, and conductive sling bag and Super Sack®
containers.

• Static Dissipative Containers –Static dissipative containers are typically bags
made of a polyethylene material. The material prevents the build-up of static
electricity by continually dissipating the charge. These bags are typically used to
line other containers, but may be used without an outside container. Typical static
dissipative containers include pink poly bags, pink poly sheet material and static
dissipative Cromhmiq™ sack containers.

• Fiberboard drums – Wastes may be collected directly into commercially available
30-gallon fiberboard drums. These drums have a removable lid that can be sealed in
place with a locking chime after the drum is filled. Fiberboard drums selected for
this application are approved by DOT for highway transportation of hazardous
materials and can be used to ship these wastes off-site for treatment and disposal.

• Sumps- Explosive contaminated wastewater is collected in sumps at the point of
generation. When appropriate, propellant “chips” and other suspended solids are
filtered out before the wastewater reaches the tank, and when the wastewater is pumped
out of the tanks. The wastewater is pumped into tanker trucks where it is treated at
M-705 and discharged under a UPDES permit. Filters containing “chips and other
suspended solids” are accumulated, treated, and disposed of in accordance with the
applicable hazardous waste management rules.

• Other Containers – Large blocks of cured propellant are containerized by wrapping
the waste in plastic and placing it on wood pallets. Ammunition cans are used to hold
initiating and ordnance items. Waste rocket motors are generally large enough to be
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

7

their own container. Plastic buckets are used to hold conductive and static dissipative
bags. The buckets are reused and become contaminated with reactive material. The
buckets are cleaned by removing the contaminated material using a rag. The
contaminated rag is then collected for disposal and managed as directed in UAC
R315-262. If a bucket cannot be cleaned, it is managed as a hazardous waste and
treated by open burning. Laboratory waste may come in a variety of sizes and types of
containers such as plastic, metal or glass. DOT containers for Class 1.1 and 1.3
reactive materials may also be used. A plastic cover secured to a tray may be used as a
container for unburned residue or containers of off-site waste stored in a tray prior to
thermal treatment.

Operating personnel accumulate reactive waste in these containers as it is generated.
When a reactive waste container is full or at the end of an operating shift, it is closed
or sealed as applicable for the container. A hazardous waste label is filled out and
attached to the container. Operators at the buildings that generated the waste enter
pertinent information into the electronic waste tracking system described in Section
11.5.

Most operating buildings that generate reactive waste have an explosive waste
collection area located approximately 50 feet from the operating building. Except as
described below, waste containers are placed in the collection area to facilitate removal
of waste propellant, explosive and reactive wastes from the operating buildings. The
collection sheds are constructed of wood or corrugated metal and are secured to a
concrete floor.

When managing reactive wastes, NGSC building operators use the temporary
collection sheds as 90-day or satellite accumulation stations. Reactive wastes are
placed in the collection area either as they are generated or at the end of each operating
shift. Waste containers that are not full at the end of a shift are sealed, a hazardous
waste label is attached to the container and they are moved to the temporary collection
area.

Containerized explosive wastes are picked up from the collection location using a
vehicle approved for the transport of explosive wastes. Extreme care is used when
handling all explosive wastes. Wastes are transported directly to either M-629, S-633
for storage, or to the M-136 or M-225 burning ground.

Propellant and explosive operating buildings at the facility, including explosive waste
90-day storage and satellite accumulation areas, are designed and constructed in
accordance with strict federal standards. These standards identify the criteria that must
be used to construct buildings where reactive material will be used and/or stored.
These standards also require that explosive buildings to be separated by sufficient
distance, or a quantity-distance relationship, to prevent an explosive event in one
building from propagating to another building. Quantity-distance rules also control the
location of propellant and explosive operating buildings with regard to public property
(highways, parks, etc,) and private property. All buildings used for temporary storage
of waste explosives, including the temporary storage sheds, are correctly sited with
respect to the applicable quantity-distance rules.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

8

11.5 QUANTITY DISTANCE DETERMINATION
The facility uses the Department of Defense (DOD) guidance to calculate quantity
distance relationships. The evaluation was conducted according to NAVSEA OP5,
Volume 1, Revision 4, Paragraph 11-3.2. The method used to determine safe quantity
distance relationships for both Class 1.1 and 1.3 propellants is provided below.

The quantity distance relationship for Class 1.3 propellant is determined by the following
formula: D = 5W1/3. Where W is the weight of Class 1.3 propellant and D is the safe
distance. The formula applies to Class 1.3 propellant and Class 1.3 propellant ingredients.
The safe distance is defined as the interline protection for mass fire for Class 1.3
propellant.

The quantity distance relationship for Class 1.1 propellant is determined by the
following formula: D = 18W1/3. Where W is the weight of a Class 1.1 explosive and D
is the safe distance. The formula applies to Class 1.1 propellant and Class 1.1 propellant
ingredients. The safe distance is defined as the unbarricaded interline protection for Class
1.1 propellant.

11.6 WASTE TRACKING
NGSC maintains an electronic waste tracking record to collect and manage information
about reactive wastes generated at the facility. This tracking system uses a
combination of paper records and an electronic database.

Wastes being accumulated in containers at operating areas within the facility are
labeled and managed in accordance with UAC R315-262 for either a satellite
accumulation or less than 90-day hazardous waste storage area. The electronic tracking
system maintains the following information to monitor cradle to grave waste handling
practices:

• ID# - container identification number
• Date – accumulation date
• Building # - identifies where the waste was generated;
• RWDI# - identifies the reactive waste disposal instruction
• Profile # - identifies the profile
• Quantity of PEP – quantity of propellant, explosive or pyrotechnic material ;
• Quantity of Contaminated waste - explosive and total weight of the container;
• Material Description – description of the material
• Propellant name – describes the propellant by type, program other identifier
• Log Date – date logged into the system

The electronic tracking system maintains information on all containers of reactive
waste in 90- day storage at M-136 and M-225. It also tracks the total weight of waste
placed on each burn tray, and the total weight of waste burned on any given day.

In the event reactive waste is shipped off-site for treatment, the system maintains the
following information: the manifest number, transporters, manifest ship date, and
manifest return date.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

9

In the event the electronic tracking system is not operable, the information will be
tracked using paper copies until the electronic system is operable. In the event this
occurs, NGSC will transfer all information to the electronic system within three
business days of the system becoming operational again.

11.7 REACTIVE WASTE STORAGE
NGSC may store hazardous wastes prior to disposal. Solid reactive wastes are stored
in designated facilities as described in this section, and are segregated according to
compatibility requirements.

• M-629 – This building can be used to store any of the explosive wastes listed in
Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be
provided to permit proper container inspection. All containers will be labeled and
managed in accordance with UAC R315-262. This building is equipped with a fire
sprinkler system, which is checked annually. Employees are not permitted to fight
fires inside an explosive storage building. This building is totally enclosed, so there
are no precipitation run-on or run-off concerns.

• M-136 - Trays at M-136 can be used to store waste containers prior to treatment
subject to the terms of the Permit. In addition, waste rocket motors may be stored on
the ground at Burn Station 14 prior to treatment subject to the terms of this Permit.
All containers of waste must be closed, labeled and managed in accordance with UAC
R315-262.

• S-633 - This storage pad can be used to store any of the explosive wastes listed in
Section 11.3. All containers of waste in storage will be closed except when waste is
being added to or removed from the container. Adequate aisle space must be provided
to permit proper container inspection. S-633 is approximately 100’ x 100’ in size. It
is secured by a perimeter fence, a vehicle access gate that can be locked, and has the
appropriate warning signs for a storage area. It has a road base surface, and has
lighting protection. All waste containers will be labeled, and managed in accordance
with UAC R315-262. This area does not have water immediately available, and relies
on the Fire Department for any emergency action. Employees are not permitted to
fight fires inside a reactive waste storage area. Precipitation run-on or run-off is
prevented by a combination of diversion ditches, collection ditches and trenches.

11.8 TREATMENT OF REACTIVE WASTE
The facility utilizes thermal treatment methods to safely dispose reactive hazardous
wastes. Thermal treatment methods include both open burning and open detonation.
Reactive hazard wastes may also be shipped off-site and treated at other permitted
treatment storage and disposal facilities.

11.8.1 OFF-SITE TREATMENT OF REACTIVE WASTE
All hazardous reactive wastes treated off-site will comply with all applicable local,
State and Federal regulations.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

10

11.8.2 ON-SITE TREATMENT
The M-136 and M-225 facilities are thermal treatment units designed to treat reactive
hazardous wastes using open burning or open detonation. Treatment by open burning
at M-136 is limited to a maximum of 125,000, 122,000, or 1,200 pounds per day
depending on the treatment scenario. Thermal treatment scenarios are limited to those
shown in Table 1 below. Treatment by open detonation will be conducted at burn
stations 13 and 14 only, and is limited to 600 pounds per burn station. Figure 11-2
shows the security fence, control bunker, and vehicle access points for M-136.

Treatment by open burning at M-225 is limited to a maximum of 4,500 pounds per day.
Each burn station 1-4 may burn all or a portion of the 4,500 pound limit. Treatment by
open detonation is limited to the 600 pounds per day in the M-225 open detonation
area. Figure 11-2 shows the security fence and vehicle access points for M-225.

The process flow for open burning at both treatment areas is identified below:

1. Pre-planned Activities
2. Placement of Waste in Treatment Units, Wiring and Ignition
3. Post-burn Inspection and Cleanup

The following precautions are used to ensure operator safety while working at the
M-136 and M-225 burn grounds:

1. Emergency egress routes are always maintained while employees are working in
the treatment areas.
2. The firing systems are disabled using an interlock to prevent accidental ignition.
3. Weather conditions are monitored to assure operators are not exposed to risks from
lightning strikes.

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

11

TABLE 1 - NGSC Promontory OB/OD Treatment Limit Scenarios
Appendix A, June 2016 HHRA Report

Treatment
Scenario
Treatment
Scenario
Description
Annual
Emissions
Rates –
Chronic
Exposure
Max. lbs./year
Annual
Emissions
Rates –
Chronic
Exposure
Max.
lbs./day
One-Hour
Emission
Rate – Acute
Exposure
Max.
lbs./event
(or hour or
day)
Annual
Max ÷ One-
Hour
Emission
Rate
lbs./event
(or hour)
M-136 A1
OB in 6
Stations –
1,4,7,8,10 and
11
6,720,000
(1,120,000X6)
18,408
(3,068X6)
96,000
(16,000X6) 70
M-136 A2 OB in Station
13 840,000 2,301 10,000 84
M-136 A3 OB in Station
14 840,000 2,301 16,000 52.5
M-136 B
OB of large
rocket motors
in Station 14
1,500,000 4,110 125,000 12
M-136 C13 OD in Station
13 50,000 137 600 83.333
M-136 C14 OD in Station
14 50,000 137 600 83.333
M-225 A OB in Stations
1 through 4 55,000 151 4500 12.222
M-225 B OD in Station 1 10,000 27 600 16.666

The Permittee shall not operate more than one treatment scenario at M-136 or M-225 in a
calendar day. One treatment scenario can occur at M-136 and M-225 on the same
calendar day.

11.8.2.1 PRE- PLACEMENT ACTIVITIES
OBOD operations at the facility are a continuous process. Wastes are transported from
the generation areas and brought into the treatment areas on a daily basis. Wastes are
off-loaded and placed in trays and managed under 90-day rules at M-225 and as a
permitted storage area at M-136 until treatment occurs. When treatment is completed,
the trays are cleaned, inspected and the loading process begins again. Pre-placement
inspections occur during the post-burn inspection and clean-up phase of the treatment
process.

Prior to placing reactive waste for treatment at the OBOD facilities, operators visually
verify the following tasks were completed during post-burn inspection and cleanup
activity:

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

12

1. Any untreated waste and/or unburned residue has been identified, collected and is
being properly managed;
2. Storm water accumulated in the trays has been removed.
3. Trays which do not meet the inspection criteria have been removed from service.

11.8.2.2 PLACEMENT OF WASTE IN TREATMENT UNITS
Reactive hazardous waste is transported to the OBOD facilities using a vehicle which
meets explosive safety requirements. Reactive hazardous waste may be offloaded by
hand or mechanical means including a knuckle boom, forklift, crane, or other
appropriate equipment. Reactive hazardous waste is not collected, transported, or
unloaded during a lighting warning, which is defined as lightning within 30 miles of
the facility. If collection, transportation, or unloading operation has started, the
operation is brought to a safe halt.

Treatment units used to treat and contain waste are listed below but are not limited to,
the following:

• Burn Trays – Metal trays constructed in several different sizes including, 4’X10’,
5’X16’, 8’X8’, and 8’X20’. Typical construction is out of steel plate A36 grade
steel ranging thicknesses of ¼”, 3/8”, ½”, ¾”, and 1 inch.

• Clamshell Disposal Trays – Used for the disposal of items that have the potential
to be propulsive. Typical construction is a square welded box 1-inch thick, A36
steel plate with a vented lid that enables treatment of potentially propulsive items,
while safely containing the propulsive energy.

• Restraining Trays – typically constructed of 1-inch thick A36 steel plate welded
into a square box that is filled with sand. There are several different designs for
restraining trays which include: (1) steel tubes sitting on end in the sand are used to
hold potentially propulsive items which are secured to the tube allowing the
exhaust to vent out of the open end of the steel tubes, and (2) used without steel
tubes where propulsive items are secured at the base for items where the exhaust
will vent from the side of the item.

• Small Motor Disposal Vaults – Constructed from a concrete 10x10 foot sump
filled with sand. Small rocket motors such are placed into the sand with the aft end
exposed perpendicular to the ground. Motors are treated with the propulsive force
directed into the concrete sump and the sand.

The vehicle containing hazardous waste is to be parked near the receiving tray with any
side rails lowered to facilitate offloading of the waste. Containers are transferred
directly from the truck and carefully placed into the burn tray. Items to be open
detonated are offloaded from the vehicle by hand, knuckle boom, or by forklift and
then placed on the ground for treatment

Items that have the potential to be propulsive are off-loaded into the clamshell,
sandbox, or small motor disposal vault by hand, knuckle boom, or by forklift. After
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

13

offloading, items are restrained using engineered restraints allowing for safe treatment.
Potentially propulsive items (e.g. rocket motors) may also be off-loaded into station 14
using the knuckle boom, forklift, or crane. The case may be placed on the ground,
sand/dirt mounds, chocks, or other support media for treatment.

PEP waste which generates ash or residue which is listed or characteristic is segregated
from PEP waste which generates non-regulated ash. Ash and residue are managed as
described in 11.8.2.5.

11.8.2.3 WIRING AND IGNITION
After waste has been placed on a tray, the next step is to complete a resistance check on
the ignition system. As a safety precaution, a physical interlock (e.g. key) is used to
prevent the firing panel from being accidently engaged during the resistance check.
The key remains in under the control of the operators during the resistance check and
all subsequent operations until the operators return to the control bunker to complete
treatment. Each firing stanchion must have 10 ohms or less. A firing stanchion that
has a resistance of 10 ohms or greater must be tagged out until repairs are made.

Once the resistance check is completed igniter installation is performed. The igniter is
attached to the firing system by connecting the lead wire from the initiating device to
the firing stanchion. Igniter installation operations are performed by a minimum of two
operators. The types of igniters commonly used are listed below:

1. Burn Grounds Igniter –Propellant with a hot wire
2. Bag Igniters – Propellant, explosive, pyrotechnic with electric match or other
electric initiation device
3. Blasting Caps – Small amount of primary explosive
4. Electric Matches – Wire attached to small explosive device
5. Fuse – A tube, cord, or the like, filled or saturated with combustible matter
6. EBW – Exploding Bridge Wire, a wire that contacts explosives fired by a high
voltage electricity source
7. TBI – Through Bulkhead Initiator, shock initiation of an energetic material
provided through an integral barrier

Linear shaped charge may also be used to facilitate thermal treatment of potentially
propulsive wastes and items contaminated with reactive hazardous wastes.

Reactive hazardous wastes may be desensitized by adding one of the liquids listed
below. The addition of these liquids modifies the reactive nature of the waste making it
safer to store, handle and transport. It also slows the burning rate of the material during
treatment.

1. Oils
2. Water
3. Alcohol
4. Triacetin
5. Physical Media (e.g. Conductive and static dissipative packaging)

When necessary, additional burn enhancers may be used to promote a more complete
burn. Additives include, but are not limited to, the following:

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

14

1. Diesel Fuel
2. Alcohol
3. Wood (e.g. Pallets)
4. Propellant

The burning ground operators verify the treatment area has been evacuated of all
personnel before proceeding with ignition. The burning ground operators retreat to the
control bunker and close the door. The lockout key is inserted into the control system
which allows power to the firing panel. Circuit continuity is checked at the firing panel
which verifies that igniters were properly installed. A flashing red light is activated
once the firing system is operational to alert personnel inside the area that a treatment
operation is about to begin. The appropriate stanchion is chosen and the igniter fired
by pressing the ignition buttons. Two operators are required for this operation.

In the event of a misfire, operators must wait a minimum period before reentering the
treatment area to correct the problem. If a misfire occurs on the first tray, being burned
the process stops, and personnel are required to stay in the bunker for at least 30
minutes. After 30 minutes, the igniter which failed is uninstalled. This process
requires two employees and is done by: (1) the two employees performing the task
remove the physical interlock and keep it in their possession, (2) the igniter wires are
removed from the stanchion where the misfire occurred then twisted together to short
the circuit. The igniter is not physically removed from its position. A new igniter is
installed, and the operators return to the control bunker and repeat the process.

If a misfire occurs and it is not the first tray in the burn sequence, the operators return
after 16 hours and repeat the process described above.

The Box Elder County Dispatch is notified prior to each treatment. This notification
can be made by telephone, fax or email, and may be made immediately prior to ignition
or an undefined number of hours prior to igniting the waste. Notification must be made
the same day as the waste is treated.

11.8.2.4 POST-BURN INSPECTION AND CLEANUP
Following a treatment event, the area where the burn or detonation occurred cannot be
re-entered for at least 16 hours after completion of the event without specific approval
from NGSC management. A preliminary inspection is performed before the cleanup
begins. This inspection includes checking for hot spots and checking for unburned
reactive hazardous waste. Hot spots include visual indications of hot material (flame,
smoke, high temperature). If these conditions exist, post-burn clean is postponed until
the hot spots are gone.
All residues remaining on the burn trays are visually inspected to determine if there is
any unburned reactive material. Unburned reactive material will be reburned.
Depending on the nature of the material that did not burn, donor material or burn
enhancers such as diesel or wood may be used to ensure the material will completely
burn. Unburned waste ejected from the tray will be collected and placed on a burn tray,
and treated in the same manner.
Small amounts of untreated residue will be considered as newly generated waste and
will be tracked as such in the tracking system. A small amount is defined as less than
or equal to 5% of the total volume placed on the tray or treatment area. The primary
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

15

option for managing this waste is to burn it by 6 pm the following calendar day. If
untreated residue cannot be treated by 6 pm the following calendar day then it will be
managed in accordance with UAC R315-262.
Unburned waste that results from a misfire or an interrupted ignition can remain on a
burn tray. An interrupted ignition occurs when anything greater than 5% of the waste
on the tray fails to ignite. In this situation, the waste is considered unreacted waste
instead of newly generated residue. NGSC will attempt to reburn the waste by 6 pm of
the following calendar day. If unforeseen circumstances prevent the burn from
occurring by 6 pm of the following day, the waste will be covered and the burn tray
will be labeled and managed as a 90-day storage area in accordance with the
requirements of UAC R315-262. The cumulative storage time for the waste both in
storage prior to burning and on the burn tray may not exceed 90-days. If it is necessary
to storage this waste for greater than 90-days, an emergency permit would be
requested.
Typically, the post-burn and cleanup activities described in this section will be
conducted the next calendar day following treatment. The clean process begins after
the preliminary inspection is completed. Cleaning is accomplished using a variety of
tools and equipment such as rakes, shovels, a forklift and a tractor. Ash is classified for
disposal as described in 11.8.2.5. The majority of the waste treated is classified as U.S.
EPA waste number D003 reactive only. The ash resulting from treating D003 reactive
waste is collected, and transported to the on-site landfill where it is disposed.
Ash classified as hazardous is collected and managed in accordance with the
requirements of UAC R315-262. Ash resulting from the treatment of K044 is collected
and disposed in the on-site landfill. After the tray is cleaned, it is inspected for holes,
weld cracks, and 6 inches of wall height. If a tray fails the inspection criteria, it is
removed from service. These inspections are maintained onsite in the operating record.
In the event a tray is not going to be used for an extended period, it is stored in a
manner to prevent stormwater accumulation (e.g. stored upside down or with a lid). If
accumulated liquid is present in a burn tray it is removed and delivered for treatment at
a UPDES permitted facility.
11.8.2.5 Ash Classification
A waste assessment is conducted prior to receiving waste for treatment. The waste
assessment is made using generator knowledge of the production process, the raw
materials used to produce the material, and the chemical composition of the materials.
If the assessment identifies that, at the point of generation, the waste meets any of the
following three criteria, all ash from the initial treatment is collected, and the ash is
sampled and analyzed using the protocol described in Attachment 1.

1. It could potentially contain UAC R315-261-31 listed constituents.
2. It could potentially contain toxicity characteristic constituents above the UAC
R315-261-24 regulatory level.
3. It could potentially contain underlying hazardous constituents above the UAC
R315-268-48 treatment standards.

Based on the analytical results, the ash is managed using the logic in Attachment 1
Figure 3-2. All ash classified as hazardous based on the above criteria is managed in
accordance with the requirements of UAC R315-262.
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

16

As stated above, the majority of the waste treated at the burn grounds is classified as
U.S. EPA waste number D003 reactive only. The ash resulting from treating D003
reactive waste is collected, and transported to the on-site landfill where it is disposed.
To ensure that significant concentrations of perchlorate are not disposed of in the
on-site, solid waste landfill, a representative sample of burn ground ash resulting from
the typical treatment of D003 reactive waste shall be analyzed for perchlorate on a
semiannual basis.
The analytical results of the burn ground ash shall be included with the Promontory
Thermal Treatment Areas Annual Report as required by Condition II.G.3.f.

11.9 RECEIVING HAZARDOUS WASTE FROM OFF-SITE
NGSC periodically receives reactive hazardous waste from off-site sources. All
hazardous waste received from an off-site source will be managed at one of the
permitted storage units. All off-site generated hazardous waste will be reviewed and
approved prior to being accepted using the following criteria:

• U.S. EPA hazardous waste number(s);
• Physical description;
• Chemical description;
• Source of the waste;
• Sampling frequency;
• Parameter for analysis;
• Handling code;
• Tracking system number;
• DOT shipping description; and
• Safe handling instructions

Upon receipt, all off-site generated hazardous waste will be visually inspected to ensure
that it meets the acceptance criteria, the manifest is correct, and the containers are
labeled, closed, in good condition and compatible with the waste. All deficiencies will
be resolved with the generator before the waste is received. After the waste has been
accepted, it will be managed using the tracking systems described in Sections 11.6.

11.10 ENVIRONMENTAL PERFORMANCE STANDARDS
UAC R315-264-600 contains requirements for treatment, storage and disposal facilities
to meet environmental performance standards to ensure operations are conducted in a
manner that ensures protection of human health and the environment. The follow areas
of concern have been or are in the process of being addressed to ensure compliance
with the performance standard requirements.

Prevention of Releases Due to Migration of Waste Constituents in the
Groundwater or the Subsurface Environment - This standard requires actions to
prevent releases that may have adverse effects on human health or the environment due
to migration of waste constituents in the ground water or subsurface environment.
Topics that must be considered are:

Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

17

• The volume and physical and chemical characteristics of the waste in the unit,
including its potential for migration through soil, liners, or other containing
structures;
• The hydrologic and geologic characteristics of the unit and the surrounding area;
• The existing quality of groundwater, including other sources of contamination and
their cumulative impact on the groundwater;
• The quantity and direction of groundwater flow;
• The proximity to and withdrawal rates of current and potential groundwater users;
• The patterns of land use in the region;
• The potential for deposition or migration of waste constituents into subsurface
physical structures, and into the root zone of food-chain crops and other vegetation;
• The potential for health risks caused by human exposure to waste constituents; and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents.
Prevention of Releases Due to Migration of Waste Constituents in Surface Water,
Wetlands or on the Soil Surface - This standard requires actions to prevent releases
that may have adverse effects on human health or the environment due to migration of
waste constituents in surface water, or wetlands or on the soil surface. Topics that must
be considered are:
• The volume and physical and chemical characteristics of the waste in the unit;
• The effectiveness and reliability of containing, confining, and collecting systems
and structures in preventing migration;
• The hydrologic characteristics of the unit and the surrounding area, including the
topography of the land around the unit;
• The patterns of precipitation in the region;
• The quantity, quality, and direction of groundwater flow;
• The proximity of the unit to surface waters;
• The current and potential uses of nearby surface waters and any water quality
standards established for those surface waters;
• The existing quality of surface waters and surface soils, including other sources
of contamination and their cumulative impact on surface waters and surface
soils;
• The patterns of land use in the region;
• The potential for health risks caused by human exposure to waste constituents;
and
• The potential for damage to domestic animals, wildlife, crops, vegetation, and
physical structures caused by exposure to waste constituents.
Prevention of Releases Due to Migration of Waste Constituents in the Air - this
standard requires actions to prevent releases that may have adverse effects on human
health or the environment due to migration of waste constituents in the air. Topics that
must be considered are:
• The volume and physical and chemical characteristics of the waste in the
unit, including its potential for the emission and dispersal of gases, aerosols
and particulates;
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

18

• The effectiveness and reliability of systems and structures to reduce or
prevent emissions of hazardous constituents to the air;
• The operating characteristics of the unit;
• The atmospheric, meteorologic, and topographic characteristics of the unit
and the surrounding area;
• The existing quality of the air, including other sources of contamination and
their cumulative impact on the air;
• The potential for health risks caused by human exposure to waste
constituents; and
• The potential for damage to domestic animals, wildlife, crops, vegetation,
and physical structures caused by exposure to waste constituents.

11.10.1 Compliance With Environmental Performance Standard Requirements
All of these factors have been and will continue to be evaluated until closure of the
facility to ensure waste treatment methods are conservative and will not adversely affect
human health or the environment. Control measures include, but are not limited to the
following:
Human Health Risk Assessment - A Human Health Risk Assessment (HHRA) has been
conducted to evaluate the risk to the public from open burning and open detonation
operations at the facility. Tasks associated with the HHRA included developing an air
dispersion model, evaluating sources, source parameters, and waste materials, and
characterizing emissions. The HHRA addresses the following environmental
performance related concerns:
▪ The volume and physical and chemical characteristics of the waste in the unit,
including its potential for the emission and dispersal of gases, aerosols and
particulates;
▪ The effectiveness and reliability of systems and structures to reduce or prevent
emissions of hazardous constituents to the air;
▪ The operating characteristics of the unit;
▪ The atmospheric, meterologic, and topographic characteristics of the unit and the
surrounding area; and
▪ The potential for health risks caused by human exposure to waste constituents.
The methods used in the HHRA are based on United States Environmental Protection
Agency (U.S. EPA) risk assessment guidance documents, and to the extent possible, the
dispersion modeling methodology within the Human Health Risk Assessment Protocol
(HHRAP) for Hazardous Waste Combustion Facilities (U.S. EPA, September 2005). The
completed HHRA Protocol and Report has been reviewed and approved by the Division
of Waste Management and Radiation Control (Division). Limits on OBOD operations
have been based on this assessment.

Ecological Risk assessment – The need to conduct an Ecological Risk Assessment
(ERA) has been evaluated and a waiver was granted by the Division. The ERA waiver
was justified because, the ecological receptors will not be affected by the treatment
operations, Volatile Organic Compounds (VOCs) do not accumulate in the ecological
system, modeled soil concentrations for metals, semi-volatile organic compounds
(SVOCs) and other contaminants are below background levels, below measurable
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

19

existing laboratory methods and several orders of magnitude below available
environmental screening levels. Impacts of the thermal treatment unit operations will be
evaluated using the Soil Monitoring Plan (SMP).
Soil Monitoring Plan – An SMP has been developed to verify the air dispersion and
deposition models that were developed for the HHRA. The SMP will be used to evaluate
the existing quality of surface soils, and to determine what impact continued operations at
the thermal treatment areas has on surface soil. Risks to human health and the
environment will be evaluated using the data collected during implementation of the
SMP.
Groundwater Monitoring Plan – a Groundwater Monitoring Program (GMP) has been
in place at the facility since 1986 to monitor contaminants that were released from past
disposal practices. The sampling methods, constituents of concern, sampling frequency,
sampling results and analytical methods are closely reviewed and monitored by the
Division.
The GMP addresses the following concerns:
• The hydrologic and geologic characteristics of the unit and the surrounding area;
• The existing quality of groundwater, including other sources of contamination and
their cumulative impact on the groundwater;
• The quantity and direction of groundwater flow; and
• The proximity to and withdrawal rates of current and potential groundwater users.

A GMP has been developed to evaluate the impact of thermal treatment operations on
groundwater down gradient of the M-136 and M-225 Thermal Treatment Areas. The
plan identifies additional statistical studies, any additional groundwater modeling needed
and groundwater monitoring frequency and reporting.
Annual Review of Limits – Permit Condition II.G.3.g. requires NGSC to review the
emission factors established by the HHRA to determine whether the factors are still
representative of the wastes treated. In addition, Permit Condition II.G.3.h. requires
NGSC to review the HHRA to evaluate changes to dose-response factors for the three
classes of detected COPCs: chromium (total and hexavalent), 2,3,7,8-TCDD TE, and
detected potentially carcinogenic PAHs (benzo(a)anthracene, benzo(k)fluoranthene,
chrysene and indeno(1,2,3-cd)pyrene)., A review of the potential human health risk
scenarios evaluated in the HHRA is also required to assure that the scenarios have not
changed. These reviews are conducted annually and are included with the Promontory
Thermal Treatment Areas Annual Report that is submitted to the Director of the Division
of Waste Management and Radiation Control by March 1st of each calendar year. The
annual Report requirements are listed under Condition II.G.3
Stormwater Management – Stormwater run-on and run-off is controlled by a
combination of soil grading and drainage ditches. The terrain around M-136 and M-225
has been graded and drainage ditches surround the areas in order to minimize stormwater
run-on and run-off. The topography is shown in Attachment 6, Figures F-1 and I-1.
Stormwater collection and drainage is shown in Attachment 11 Figure 11-1 and Figure
11-2. The combination of controlling run-on and run-off, containing waste in water-tight
Northrop Grumman Systems Corporation - Promontory March 2024
Attachment 11 M-136 & M-225 Thermal Treatment Operations UTD 009081357

20

burn trays, lack of precipitation, high evaporation rate and depth to groundwater prevents
waste constituents from being released to the groundwater and or subsurface
environment. Ongoing soil and groundwater monitoring are used to verify these controls
are effective in preventing adverse effects to human health and the environment.
Actions to Prevent Releases to the Environment – All spills of hazardous materials are
promptly cleaned up. Internal procedures require that chemicals be properly
containerized, labeled, stored, used and disposed. The workplace is routinely audited to
ensure compliance with procedures. When spills do occur, the released material is
promptly cleaned up and the reporting requirements of UAC R315 and Condition I.T.3.
are followed.
Open Burning is Conducted in Steel Containers – Open burning is conducted in
containers which minimizes the potential for waste constituents to migrate to the
groundwater, surface water or related environments. The Operating Permit requires
routine inspections to ensure the containers are properly maintained. Containers
requiring repair are removed from service until repairs are completed.
Ash Management – Ash and residue from OBOD operations are promptly collected and
disposed. Ash is managed and classified as described in sections 8.2.4, and 8.2.5 of this
attachment.
Storage and Inspections – All PEP and residues from OBOD treatment are stored in
accordance with Section 4 of this attachment and R315-262 Hazardous Waste Generator
Requirements. Storage and treatment areas are inspected as required by Attachment 2
and are operated in accordance with Attachment 9 of this permit.
Regulatory Oversight - The facility is subject to strict regulatory oversight by the
Division of Waste Management and Radiation Control. All aspects of hazardous waste
management described in this Attachment are subject to their review. When necessary,
deficiencies are identified and corrective action is taken by the permittee.

Propulsion Systems
Brigham City, Utah 84302
NORTHROP GRUMMAN
SYSTEMS CORPORATIONNORTHROP
GRUMMAN
Propulsion Systems
Brigham City, Utah 84302
NORTHROP GRUMMANSYSTEMS CORPORATIONNORTHROP
GRUMMAN

ATTACHMENT 12

M-705L OXIDIZER LEACHING PROCESS

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 12 – Oxidizer Leaching Process UTD009081357

2

12 OXIDIZER LEACHING PROCESS ...................................................................3

12-1 PURPOSE AND SCOPE .....................................................................3

12-2 PROCESS DESCRIPTION ................................................................3

12-3 WASTE ANALYSIS AND OPERATING PARAMETERS............4

12-4 ENVIRONMENTAL PERFORMANCE STANDARDS .................4
12-4-1 Prevention of Releases to Groundwater or
Subsurface Environment ...............................................................4
12-4-2 Prevention of Releases to Surface Water,
Wetlands, or Soil Surface ..............................................................4
12-4-3 Prevention of Releases to Air ........................................................4

12-5 MONITORING, ANALYSIS, INSPECTION,
RESPONSE, REPORTING, AND CORRECTIVE
ACTION................................................................................................5

12-6 RECORD KEEPING AND REPORTING ........................................5

12-7 CLOSURE ............................................................................................5

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 12 – Oxidizer Leaching Process UTD009081357

3

12 OXIDIZER LEACHING PROCESS

12-1 PURPOSE AND SCOPE

Northrop Grumman Systems Corporation - Promontory (NGSC) operates a
small treatment process in which it can remove the oxidizer from class 1.3
explosive sufficient enough to render the explosive nonreactive. This
process is conducted in Building M-705L. This process leaches the oxidizer
from class 1.3 explosives with heated water, and agitation if needed,
rendering the explosive nonreactive. The effluent wastewater is then treated
through various processes in the advanced wastewater treatment facility
prior to being discharged. The remaining solid residue is then prepared for
disposal as a solid waste.

The oxidizer leaching process allows some reactive hazardous waste to be
treated by wastewater technology in place of treatment by open burning.

12-2 PROCESS DESCRIPTION

The oxidizer leaching process is a simple process. NGSC only treats
specific waste streams that can fit this treatment methodology. As
previously described, the process leaches the water soluble oxidizer from
1.3 class explosives using water and agitation if necessary to render the
explosive nonreactive.

The following is a description of the oxidizer leaching process. The process
uses a 600 gallon leach tank that was fabricated from 3/16” stainless steel.
The tank is equipped with high and low level transmitters and is heated by
low pressure steam. The tank has been designed with steel grating between
the reactive waste items and the heat exchanger to prevent direct contact
with the explosive material and the hot surface of the heat exchanger. The
heated steam control is interlocked with the water level, to prevent steam
heat from being applied when the low level water alarm is active.

The system also utilizes air sparging to assist in the leaching process if
needed. Water is supplied to the unit and is protected with backflow
prevention. The building has been adequately ventilated for this process.
Water sampling is performed periodically to monitor the oxidizer levels
during the leaching process. Once the oxidizer levels stop increasing in the
water, this indicates that no further leaching is taking place and the process
is complete. The inert waste is then removed from the baskets and prepared
for disposal as a solid waste. The oxidizer containing wastewater is then
treated by one or multiple biological, chemical, or physical treatment
processes at the wastewater treatment facility.

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 12 – Oxidizer Leaching Process UTD009081357

4
12-3 WASTE ANALYSIS AND OPERATING PARAMETERS

Prior to treatment of a new composite propellant waste or propellant
contaminated waste article, a Waste Profile is developed to determine the
operating parameters such as, temperature, air agitation and time necessary
to complete the oxidizer removal.

The Waste Profile is developed in a “bench top” laboratory type process and
then followed by laboratory testing to determine the amount of oxidizer
remaining and a determination of when the material is no longer a reactive
waste. The Waste Profile number and laboratory testing results are
maintained in the facility permit operating record.

The system is designed and operated to prevent any releases to the
environment and to safely render the reactive material to a nonreactive state.

12-4 ENVIRONMENTAL PERFORMANCE STANDARDS

The M-705L leaching process has been located, designed, operated, and
maintained in a manner that will ensure protection of human health and the
environment. This section addresses the prevention of releases due to the
migration of hazardous constituents into the groundwater or subsurface
environment, surface waters, wetlands, surface soils, and in the air.

12-4-1 Prevention of Releases to Groundwater or Subsurface Environment

Several parameters have been considered in determining the prevention of a
release to groundwater or to subsurface environments. It is important to
note that this process is completed inside a closed building with
containment. The containment system, consisting of concrete floor space
with curbing and a concrete sump within the floor space area, is shown in
the facility drawing contained in Attachment 6 (Figure K-1). Because of
this secondary containment, there should be negligible potential for
deposition or migration of waste constituents into the subsurface or
groundwater.

12-4-2 Prevention of Releases to Surface Water, Wetlands, or Soil Surface

The oxidizer leaching area has secondary containment to ensure collection
of any spill or release. The oxidizer leach tank has a maximum volume of
approximately 600 gallons. The containment system has a volume of
approximately 800 gallons. Within the containment system is a blind sump
with a volume of approximately 100 gallons. The sump is only used if a
spill occurs; it is not used on a routine basis. The sump is located beneath
the leach tank to contain a small spill. The overall floor space containment
Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 12 – Oxidizer Leaching Process UTD009081357

5
is designed to collect any large spill and has more than sufficient capacity to
hold any spill during the oxidizer leaching process.

The use of this containment along with the high level transmitter and the
low volume of waste and wastewater reduces the potential for any releases
to surface water, wetlands, or surrounding soils.

Wastewater resulting from this treatment process will be treated by one or
multiple biological, chemical, or physical treatment processes at the
wastewater treatment facility prior to being discharge to the environment.

12-4-3 Prevention of Releases to Air

The oxidizer leaching process is completed within a closed building that
contains a closed tank with a lid. The only constituent released to the air is a
very small amount of hydrogen. An on-site Safety evaluation has been
completed to verify that no hazard is created from the small amount of
hydrogen released within the building. Since there is very small amount of
constituents released to the air, the potential for any adverse effects to
human health or the environment are negligible.

12-5 MONITORING, ANALYSIS, INSPECTION, RESPONSE,
REPORTING, AND CORRECTIVE ACTION

Handling explosive waste requires special handling precautions and safety
procedures, NGSC personnel follow internal procedures for performing the
leaching process. NGSC will conduct the leaching process in a manner that
will ensure protection of human health and the environment.

NGSC will comply with the requirements specified in the facility
Contingency Plan (Attachment 4), when there has been a release at
Building M-705L that threatens human health or the environment.

NGSC will comply with the ignitable and reactive waste regulations as
required by Utah Administrative Code (UAC) R315-264-17.

NGSC will inspect Building M-705L in accordance with the inspection
schedule contained in Attachment 2.

12-6 RECORD KEEPING AND REPORTING

The Permittee shall record in the Operating Record the following:

12-6.1 The date a batch of contaminated production materials is placed in the
M-705L treatment tank;

Northrop Grumman Systems Corporation – Promontory March 2024
Attachment 12 – Oxidizer Leaching Process UTD009081357

6
12-6.2 The quantity and description of contaminated productions materials or
propellants/explosives, including the Waste Profile #, placed in the treatment
tank;

12-6.3 The laboratory testing results associated with each Waste Profile #;

12-6.4 The date the treatment process for each batch of contaminated production
materials or propellants/explosives is complete;

12-6.5 The date the wastewater is pumped out of the tank to the wastewater
treatment plant; and

12-6.6 The waste determination of the treated production materials and the date
they are removed from the tank.

12-7 CLOSURE

NGSC will close Building M-705L in accordance with UAC R315-264-110
through UAC R315-264-120, UAC R315-264-178, Permit Condition II.O.
and Attachment 5 of this Permit.

NORTHROP GRUMMAN
FLIGHT SYSTEMS DIVISION, PROMONTORY, UT
INNOVATION SYSTEMS SECTOR
2017265-M-101 REV:
SHEET: OF
CLIENT:
PROPELLANT REMOVAL BATH
PROJECT NAME:
0
WASH TANK
PLAN AND ELEVATIONS
PROJECT SITE:
AREA:
DRAWING NUMBER:
ORBITAL ATK CORININE, UT
----
PROJECT NUMBER:
2017265
P&ID TAG NUMBER:
NONE
PRECISION SYSTEMS ENGINEERING
9805 South 500 West Sandy, Utah 84070 USA
www.pseutah.com [phone] 11
REV.
ISSUED FOR CONSTRUCTION0
DES. CHK.ENG. CHK.REV. DESCRIPTION:
--------
ENG. APPR.
----
PLAN
1"=1'-0"
ELEVATI0N
1"=1'-0"
10'-812" (OAL)
8"
3'
-
0
"
3'
-
6
"

(
O
A
L
)
3'
-
3
13
16
"
(
L
I
D

-

T
Y
P
.
)
2'-7" (LID)2'-7" (LID)2'-7" (LID)2'-7" (LID)
C
M-102
18" (GAP)
2116"
-
A
-
B
VIEW A
1"=1'-0"-
VIEW B
1"=1'-0"-
1316
"
5"
312"
1'-6"
4"5"
⅊316" (TYP. - SHELL)
L3x3x316" (TYP. 6X)
NOZZLE SCHEDULE
MARK SIZE CLASS SERVICE
1 3"R.F. 150#LEVEL
2 34"FNPT 3000#TEMP.
3 112"SCH. 40S PIPE (T.O.E.)DRAIN
4 112"FNPT 3000#WATER SUPPLY
5 112"FNPT 3000#AIR SPARGER SUPPLY
6 3"R.F. 150#STEAM SUPPLY (HEATER)
7 3"R.F. 150#CONDENSATE RETURN
D
M-102
LID SHOWN IN
OPEN POSITION
(REF)
2
4
3
5
NOTES:
1.U.N.O. ALL FAB'D STEEL MATERIAL TO BE 316L S.S.
2.ALL WELDS AT SEAMS AND NOZZLES TO BE CONTINUOUS WATER TIGHT.
3.FLANGE HOLES TO STRADDLE CENTERLINES.
L3x3x316" (TYP.)
G
TYP. (4) CORNERS
1
M-102 (LID 4X)
4
M-103
(INTERIOR PIPE)
(INTERIOR PIPE NOT SHOWN)
(INTERIOR PIPE NOT SHOWN)
1'-6"
18" (GAP)18" (GAP)
612"
1'
-
2
"
1112"
6
1
1112"
412"734"
7
M-102
J (LATCH 4X)
M-102
H
7516"2'-718"2'-718"2'-718"
OUTSIDE SHELL
T/ L3
BTM/ PLATE
ISSUED FOR CONSTRUCTION
NORTHROP GRUMMAN
FLIGHT SYSTEMS DIVISION, PROMONTORY, UT
INNOVATION SYSTEMS SECTOR
11
REV.
ISSUED FOR CONSTRUCTION0
DES. CHK.ENG. CHK.REV. DESCRIPTION:
--------
ENG. APPR.
----
SECTION
M-1011"=1'-0"
C
10'-212" (SHELL OUTSIDE)
3'
-
0
"

(
S
H
E
L
L

O
U
T
S
I
D
E
)
234" (TYP.)
SLOPE
V-BOTTOM
SECTION
M-1013"=1'-0"
D
5"
312"
212"
1"
212"
3/16
TYP.
Ø58" HOLE THRU
(TYP.)
14"
3/16
TYP. - LEG TO SHELL
2-6
8"
212"
3/16
TYP.@ NOZZLES U.N.O.
SL
O
P
E
V-
B
O
T
T
O
M
SL
O
P
E
V-
B
O
T
T
O
M
3/16
CORNER TO CORNER - TYP.
114"
⅊316" (V-BOTTOM)
SLOPED TO DRAIN
1'-51316"1'-513 16"
176.78°
⅊316"
3
-
DETAIL 3
1"=1'-0"-
(V-BOTTOM PROFILE)
LID (4) REQ'D
DETAIL
M-1011"=1'-0"
1
3'
-
3
13
16
"
2'-7"
-
F
SECTION F
3"=1'-0"-
G
-
1"

(
T
Y
P
.
7"
11116" TYP. (3) SIDES
4X Ø516" HOLES THRU
(FOR LATCH)
16GA. SHEET (PERF T304 ROUND)
(4) SIDES
MIDDLE PIECE
WELDED TO TOP & BTM PIECES
16GA. SHEET (SOLID)
BOTTOM PIECE
TYP. (4) CORNERS
5
-(HANDLE)
SECTION G
1"=1'-0"-
DETAIL 5
1"=1'-0"-
HANDLE (4) REQ'D FOR LIDS
HANDLE (8) REQ'D FOR EXP. METAL PANELS
4"

(
T
Y
P
.
)
6"
Ø14" RB(INTERIOR PIPE NOT SHOWN FOR CLARITY)
NOTES:
1.U.N.O. ALL FAB'D STEEL MATERIAL TO BE 316L S.S.
2.ALL WELDS AT SEAMS AND NOZZLES TO BE CONTINUOUS WATER TIGHT.
3.U.N.O. ALL PIPE TO BE SCH. 40S.
(V-BTM PLATE)
3/16
V-BTM TO SHELL2-6
4'-1012" (TYP.)4'-1012" (TYP.)
⅊14" (TYP.)
L3x3x316" (TYP.)
2'-11916"
L114"x114"x316" (ALL AROUND)
(PANEL SHELF)
L114"x114"x316"
(TYP. ALL
AROUND INTERIOR
SHELL WALL)
18" (GAP - TYP.)
DETAIL 6
1"=1'-0"-
REMOVABLE EXP. METAL
PANEL (4) REQ'D
6
-
(REMOVABLE PANEL)
2'-63 8"
2'
-
1
1
3
8"
6
-(REMOVABLE PANEL)
3316
"1'-012"
10
3
4"
5
-(HANDLE 2X)
EXPANDED METAL
McNICHOLS (OR EQUAL)
STYLE: 12 #16
TYPE: 316 SS FLATTENED
OPENING LWO: 1"
TYP. (4) CORNERS
EXP. METAL TO L1
L1x1x18"
(TYP.)
93
4"
(1
"
)
3/16
L1 TO SHELL - TYP.2-61/8
2-6
HINGE - PIANO TYPE)
McMASTER-CARR
P/N: 1582A268
(OR EQUAL)
WELDED TO L3 & LID.
CENTER ON LID.
(TYP. 4X)
COPE L3 LEG
TO FIT L3 RIM ANGLE FOR
WELDED CONNECTION
3/16
316
"
3/16
3/16 2-6
SECTION
M-1013"=1'-0"
H
NOZZLE PROJ. INSIDE
TO BE 14" MIN. FOR WELD
6
-(REMOVABLE PANEL)
234"
512"
2116"
℄ HINGE
914"1716"
916
"
114"
16GA. SHEET (SOLID)
TOP PIECE
SECTION
M-1013"=1'-0"
J
13 4"
1116
"13
16
"
2X Ø516" HOLES THRU
L3x3x316"
234"
1"
3/16
COPE L3
LATCH (4X)
DESTACO MODEL 344-SS
(OR EQUAL)
4X SOC HD CAPSCREWS
1/4-20UNC x 58" W/
LOCK WASHER &
HEX NUT (SS)
2X SOC HD CAPSCREWS
1/4-20UNC x 78" W/
LOCK WASHER &
HEX NUT (SS)
212"
6"
NOZZLE PROJ. INSIDE
TO BE 14" MIN. FOR WELD
T/ L3
T/ SHELL PL
(3")
3"
LID FLUSH
W/ L3
ISSUED FOR CONSTRUCTION
SECTION K
1"=1'-0"-
-
K
(2'-7")
2'-35 8"
(3'-31316")
11116"2'-1018"4"
1"

(
T
Y
P
.
)
7"
2017265-M-102 REV:
SHEET: OF
CLIENT:
PROPELLANT REMOVAL BATH
PROJECT NAME:
0
WASH TANK
PLAN AND ELEVATIONS
PROJECT SITE:
AREA:
DRAWING NUMBER:
ORBITAL ATK CORININE, UT
----
PROJECT NUMBER:
2017265
P&ID TAG NUMBER:
NONE
PRECISION SYSTEMS ENGINEERING
9805 South 500 West Sandy, Utah 84070 USA
www.pseutah.com [phone]
NORTHROP GRUMMAN
FLIGHT SYSTEMS DIVISION, PROMONTORY, UT
INNOVATION SYSTEMS SECTOR
11
REV.
ISSUED FOR CONSTRUCTION0
DES. CHK.ENG. CHK.REV. DESCRIPTION:
--------
ENG. APPR.
----
8'-4"
1'-03 4"
8916
"
PIPE ELEVATION
DETAIL
M-1011"=1'-0"
4
PIPE PLAN
1" PIPE
NOZZLE 5
NOTES:
1.U.N.O. ALL FAB'D STEEL MATERIAL TO BE 316L S.S.
2.ALL WELDS AT SEAMS AND NOZZLES TO BE CONTINUOUS WATER TIGHT.
3.AIR SPARGER PIPE TO BE SCH. 40S WITH THREADED FITTINGS.
4.HEATER PIPE (STEAM) TO BE 3" SCH. 10S WITH BUTT-WELD FITTINGS.
45°
45°
SPARGER PIPE HOLE PATTERN @ BTM OF PIPE
SEE SPARGER PIPE HOLE PATTERN DETAIL
312" (TYP. SPA.)
Ø18" HOLES IN 1" PIPE
ALONG BTM SIDE
(STAGGERED AS SHOWN)
PIPE SUPPORT
L3x2x14"x0'-3" LG. (LLV)
TRIM VERT. TO MATCH V-BTM
ATTACH PIPE W/ S.S. U-BOLT & NUTS
(4) PLC'S
3/16
TYP.
NOTE 3
NOTE 3
112"x1" RED. COUPLING (2X)
8916
"
112" UNION
1" CAP (2X)
1" PIPE
TANK SHELL
(REF)
TANK V-BTM
(REF)
NOTE 4
NOTE 4
1'
-
8
7
8"
2'
-
4
3
4"
(1
1
12")
(1
1
12")
1'
-
8
7
8"2'
-
4
3
4"
3" PIPE (TYP.)
412"
10" (TYP.)6'-8" (TYP.)
5'-114" (TYP.)
53 8"9'-33 4"
3/16
TYP.
PIPE SUPPORT
L3x2x14"x0'-6" LG. (LLV)
(2) PLC'S
538"
(T
Y
P
.
)
TANK SHELL
(REF)
73
4"
612"
112" PIPE
1'-114"
SLOPE
ISSUED FOR CONSTRUCTION
412"
2017265-M-103 REV:
SHEET: OF
CLIENT:
PROPELLANT REMOVAL BATH
PROJECT NAME:
0
WASH TANK
PLAN AND ELEVATIONS
PROJECT SITE:
AREA:
DRAWING NUMBER:
ORBITAL ATK CORININE, UT
----
PROJECT NUMBER:
2017265
P&ID TAG NUMBER:
NONE
PRECISION SYSTEMS ENGINEERING
9805 South 500 West Sandy, Utah 84070 USA
www.pseutah.com [phone]
NORTHROP GRUMMAN
FLIGHT SYSTEMS DIVISION, PROMONTORY, UT
INNOVATION SYSTEMS SECTOR