DSHW-2025-001159

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ADoc-110678

Application Document
Name
ADoc-110678 Owner Brian Speer
Application A-155944 Internal Comments
Document Name 1) Facility Map or Maps 2) Facility Legal
Description 3) Plan of Operation 4)
Waste Description 5) Ground Water
Report 6) Closure Design 7) Cost
Estimates 8) Financial Assurance 9) or
Additional documents as necessary
External Comments
Status Submitted Link to gdrive file File not present
Application
Recordtype
Solid_Waste Document Type
Gdrive file id
Application Report
Account Northrop Grumman Systems
Corporation

Created By Paul Hendrickson, 12/9/2024, 2:08 PM Last Modified By Paul Hendrickson, 1/7/2025, 10:54 AM
Files
8200-FY25-02 Landfill Permit Mod letter
Last Modified 1/7/2025, 10:29 AM
Created By Paul Hendrickson
m336g Landfill Facility Map
Last Modified 12/9/2024, 2:10 PM
Created By Paul Hendrickson
Plan of Operations for NGSC Promontory Class III
Landfills_Revised
Last Modified 12/10/2024, 1:06 PM
Created By Paul Hendrickson
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2/27/25, 3:26 PM ADoc-110678 ~ Salesforce - Unlimited Edition
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NORTH ROP1
GRUMMAN I
Northrop Grumman Systems Corporation
9160 North Highway 83
Promontory,UT 84307
northropgrumman.com
Jam 6,2025
8200-FY25-02
Doug Hansen
Utah Department of Environmental Quality
Division of Waste Management and Radiation Control
P.O.Box 144880
Salt Lake City Utah,84114-4880
Re:Request for minor modification of NGSC Promontory Class TUb Landfill Permit to
clarify the acceptance of bio-solids from onsite wastewater treatment plants
Dear Mr.Hansen:
Northrop Grumman Systems Corporation is submitting this request to modify the
NGSC Promontory Class ITIb Landfill permit to clarify the acceptance of bio solids
from onsite wastewater treatment plants into the landfill by listing it in permit condition
I.B.This is in line with the existing NGSC UPDES biosolids permit.Currently the
DEQ water quality permit (UPDES Biosolids Permit UTL-024805)states under the
treatment method Biosolids are dewatered and transferred to a collocated landfill at
the facility.Included in this application is a facility map of M336 landfill where
biosolids are received and a revised plan of operation.
If you have any questions,please contact Paul Hendrickson at [phone].
Sincerely,
Blair Palmer,
Manager,Environmental Services
Northrop Grumman Systems Corporation
cc:A.Milne
Plan of Operations for All Class III Landfills

Description of on-site waste handling procedures and an example of the form
that will be used to record the weights or volumes of waste received

All waste handling operations will be performed by trained heavy equipment operators,
with knowledge and experience in waste identification. Operators are responsible for waste
pickup, off-loading at a disposal unit, landfill cover, and inspections.

ATK Promontory will use its own front load garbage truck to collect waste from nearly 100
dumpsters located throughout the facility. Garbage runs typically occur twice per week
depending on the manufacturing rate. Waste collected by the garbage truck is taken to the
M-336 main disposal unit. Once there, the waste is dumped at the working face where it
will ultimately be pushed into the cell and covered. Compaction is provided by running
over the waste with the on-site bulldozer. Cover material is staged on the edges of the
trench and pushed into the cell. Waste is covered daily with soil to minimize blowing,
vectors, fires, odors and scavenging. The cover material is spread over the waste to
achieve a 6” depth.

M-336 asbestos trenches are narrow trenches with steep sidewalls. Cover is staged on the
edge of the trench. Asbestos containing materials and other dust generating wastes are
containerized and placed in the bottom of the trench. Cover material is placed as necessary
to prevent container degradation by weather and dispersal from wind. On-site wastewater
treatment plants produce biosolids that are dewatered and may be disposed of in the M-336
main cell or the asbestos trench to minimize contact with disease vectors.

Ash and remnants from thermal treatment operations at M-136 are collected in “burn trays”
and transported to the industrial waste trench. Burn residues are deposited at the edge of a
steep working face and pushed over the sides of the cell. Material settles to the bottom of
the cell and is covered as additional material is added. Soil is added as needed to maintain
proper cover for materials that may become displaced by wind. However, the steep trench
side-walls and working face provide substantial protection from wind transport.

Large components are off loaded on the south working face of the Rocky Point landfill for
placement into the cell. Most components are large and must be specifically placed to
utilize cell space. Cover is periodically applied to the cell once the volume has been
strategically filled. Care is take to ensure material disposed of in the Rocky Point landfill
does not present a wind-blown hazard.

The volume of solid waste delivered to each disposal unit is directly recorded into the
facility’s Environmental Management System (EMS). Tonnage is estimated using
conversion factors from UDWMRC, USEPA, and on-site factors developed from specific
knowledge of the material.

Appendix 3 includes an example of an EMS load record and compiled waste report.

Schedule for conducting inspections and monitoring, and examples of the forms that will
be used to record the results of the inspections and monitoring

Inspections are currently conducted once per quarter at the three disposal units. Inspections
are recorded on form FQA-0235 (see Appendix 4). Inspection records are maintained in
Environmental Service's central files for three years.

Form FOP-0614 is used to record visual load inspections. A current example of FOP-0614
is shown in Appendix 5. A minimum of one visual load inspection is recorded per
operating day.

Contingency plans in the event of a fire or explosion

A fully staffed and equipped fire department is maintained at the facility 24/7. The fire
department includes a hazardous materials response team with associated equipment.
Landfill operations are part of the facility’s overall contingency plan for hazardous waste
treatment, storage and disposal (TSD). The contingency plan part of the Promontory
facility’s Emergency and Disaster Response Plan is maintained by the Plant Security and
Fire Protection department. A copy of the contingency plan is on file with DWMRC as an
appendix to ATK Launch Systems, LLC hazardous waste storage and operations Part B
permit application.

Plan to control fugitive dust generated from roads, construction, general
operations, and covering the waste

Primary landfill roads will be sprayed with a dust suppressant as needed to control dust
generated from haul operations and equipment movements. A water truck equipped with a
water cannon and forward, rear and side spray nozzles will be used to maintain sufficient
moisture in areas that receive heavy operations traffic and have the potential to generate
fugitive dust.

Plan for litter control and collection

Operators perform perimeter fence line inspections monthly to recover any wind-blown
debris that escaped a landfill cell during dumping or compaction/cover operations. Debris
is recovered, bagged and placed into the disposal cell to be covered.

Procedures for excluding the receipt of prohibited hazardous or PCB
containing wastes

The Promontory facility is only accessible to badged employees, limited badged
contractors, and a few escorted visitors. In addition, the landfill entrances are locked when
operators are not present to control unauthorized access and dumping from manufacturing
operations inside the plant.

Control is achieved in two manners. The first is preventative control at the source. The
second is developing corrective actions upon knowledge that a prohibited material was
bound for the landfill or discovered during a load inspection.

Preventative control is partially achieved by Environmental Coordinators that are assigned
to specific manufacturing processes throughout the plant. These coordinators are
extensively trained in solid and hazardous waste regulations, and have a good knowledge
of what can, and cannot go into the on-site landfills. Environmental Coordinators serve as
a knowledge base for other personnel in the work area to ensure wastes are directed to the
appropriate disposal pathway.

Environmental Services and Environmental Operations personnel make periodic random
inspections of plant dumpsters to look for prohibited waste that has been disposed of
incorrectly. This provides a secondary layer of protection to prevent unauthorized waste
from being transported to the landfill units.

Waste identification and load inspection training is a critical component to exclude
prohibited wastes from being placed into the landfill units. Haulers of waste to the landfill
must have a general understanding of waste identification to help identify potential
prohibited waste before it arrives. Haulers are trained to question wastes that have an odor,
appear to be in corroded containers, have containers that may hold liquids, have e-waste
components, etc. Landfill operators are trained on how to properly conduct a load
inspection and identify prohibited wastes that may have slipped past preventative controls.
If a prohibited waste is identified during a load inspection, the waste is segregated and
directed to the proper disposal pathway. An investigation is then started to understand how
the waste was able to get through the other controls. The investigation determines if waste
generators/handlers need additional training or if landfill processes need to be updated.

Procedures for controlling disease vectors

The on-site cafeterias, medical clinic, and wastewater treatment operations are sources of
organic waste that goes to the ATK Promontory landfill. This waste is placed in the M-
336 main cell or asbestos trench where daily cover is applied to minimize contact with
disease vectors and to control their populations.

A plan for alternative waste handling

The Promontory facility maintains a backup plan for waste operations in the event any
equipment used for waste handling is unexpectantly out of service. If the garbage truck is
out of service, waste collection will be performed by a contractor. The contractor may haul
the waste to the M-336 landfill, or off-site for disposal. If landfill equipment is out of
service, similar equipment from other on-site operations may be borrowed on loan, if
available. If not available, equipment may be rented from local vendors until the normal
equipment can be returned to service.

A general training plan for site operations

All landfill operators and plant personnel that dispose of waste in the landfill receive an
annual training that covers basic landfill operation, waste load inspections, waste
identification, and landfill safety procedures. Basic landfill operation training emphasizes
which landfill unit can receive certain types of waste. Waste load inspection training
provides guidance on what materials will and will not be accepted in the landfill cells.
General waste identification training is intended to make operators and landfill users aware
of wastes that may be hazardous or otherwise prohibited. Training on landfill safety
procedures is designed to promote operator and user awareness of landfill risks and
minimize accident potential.

Any recycling programs planned at the facility

The Promontory facility actively recycles paper, cardboard, scrap metal, wood, and plastic.
The facility currently maintains a solid waste diversion rate of approximately 12 to 15%.
Additional recycling initiatives are planned to support Northrop Grumman Corporation’s
company-wide sustainability goals.

Any other site-specific information pertaining to the plan of operation
required by the Director

The landfill units are located within a fenced facility with roving 24 hour armed guards.
Only authorized personnel are allowed within the facility. In addition to this security, the
landfills are fenced with locked gates when operators are not present.

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