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HomeMy WebLinkAboutDSHW-2021-091336 DSHW-2021-018704 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4284 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 November 1, 2021 Kris Blauer, Manager, Environmental Services ATK Launch Systems - Promontory PO Box 707 Brigham City, UT 84302 RE: ATK Launch Systems - Promontory Class IIIb Landfills Permit Renewal and Statement of Basis SW093 Dear Mr. Blauer: Enclosed is the approved permit, which has been renewed for the ATK Launch Systems - Promontory Class IIIb Landfills. The 30-day public comment period on the draft permit began on August 26, 2021 and ended on September 24, 2021. No comments were received. Periodic inspections of the landfill will be conducted by representatives of the Division of Waste Management and Radiation Control and the Bear River Health Department to assess compliance with permit conditions and applicable Solid Waste Rules. The permit approval and expiration dates are as shown on the permit cover page. A Statement of Basis was prepared for the permit and is enclosed. If you have any questions, please contact Brian Speer at (801) 536-0219. Sincerely, Douglas J. Hansen, Director Division of Waste Management and Radiation Control (Over) DJH/BS/wa Enclosures: ATK Launch Systems Promontory Class IIIb Landfill Permit (DSHW-2021-006587) Statement of Basis (DSHW-2021-018706) Attachment 1 – Design Diagrams (DSHW-2021-006589) Attachment 2 – Site Diagrams and Geologic Maps (DSHW-2021-006591) Attachment 3 – Operations Plan (DSHW-2021-006593) Attachment 4 – Waste Inspection Form (DSHW-2021-006595) c: Jordan Mathis, Health Officer, Bear River Health Department Grant Koford, EHS, Environmental Health Director, Bear River Health Department John Chartier, District Engineer, UDEQ Jason Wells, Director, Env. Services Operations, ATK Launch Systems – Promontory (Email) Page 1 of 12 DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL SOLID WASTE LANDFILL PERMIT ATK Launch Systems - Promontory Class IIIb Landfills Pursuant to Utah Solid and Hazardous Waste Act, Title 19, Chapter 6, Part 1, Utah Code Annotated (Utah Code Ann.) (the Act) and the Utah Solid Waste Permitting and Management Rules, Utah Administrative Code R315-301 through 320 adopted thereunder, a Permit is issued to Northrop Grumman Systems Corporation as owner and ATK LAUNCH SYSTEMS, LLC as operator (Permittees), to own and operate the ATK Launch Systems - Promontory Class IIIb Landfills, which are located as shown below, and as found in the Permit Renewal Application that was determined complete on April 30, 2021: M-136 in SW Quarter of Section 16, Township 11 North, Range 5 West, Salt Lake Base and Meridian, Box Elder County, Utah; M-336 in SE Quarter of Section 8, Township 11 North, Range 5 West, Salt Lake Base and Meridian, Box Elder County, Utah; Rocky Point in NW Quarter of Section 20, Township 11 North, Range 5 West, Salt Lake Base and Meridian, Box Elder County, Utah; The Permittees are subject to the requirements of R315-301 through 320 of the Utah Administrative Code and the requirements set forth herein. All references to R315-301 through 320 of the Utah Administrative Code are to regulations that are in effect on the date that this permit becomes effective. This Permit shall become effective November 1, 2021. Closure Cost Revision Date: November 1, 2026. This Permit shall expire at midnight October 31, 2031. Signed this 1st day of November, 2021. Douglas J. Hansen, Director Utah Division of Waste Management and Radiation Control Page 2 of 12 FACILITY OWNER/OPERATOR INFORMATION LANDFILL NAME: ATK Launch Systems - Promontory Class IIIb Landfills OWNER NAME: Northrop Grumman Systems Corporation OWNER ADDRESS: 2980 Fairview Park Dr Falls Church, VA 22042-4511 OWNER PHONE NO.: (703) 280-2900 OPERATOR NAME: ATK Launch Systems LLC OPERATOR ADDRESS: PO Box 707 Brigham City, UT 84032 OPERATOR PHONE NO.: (801) 251-2166 TYPE OF PERMIT: Class IIIb Landfill PERMIT NUMBER: 0004R3 LOCATION: Landfill sites are located in Township 11 North, Range 5 West, Sections 8, 16, and 20, SLMB; Box Elder County. M-136 – Lat. 41°41'10.37"N, Long. 112°25'41.61"W M-336 – Lat. 41°41'42.97"N, Long. 112°26'26.48"W Rocky Point - Lat. 41°40'21.15"N, Long. 112°26'39.66"W 9160 North Highway 83 Corinne UT PERMIT HISTORY This is the third renewal of the permit. This renewal permit is effective on the date shown on the signature page. Page 3 of 12 The term, “Permit,” as used in this document is defined in R315-301-2(55) of the Utah Administrative Code. Director, as used throughout this permit, refers to the Director of the Division of Waste Management and Radiation Control. The Permit renewal application for ATK Launch Systems - Promontory Class IIIb Landfills (DSHW-2021-005283) was deemed complete on the date shown on the signature page of this Permit. All representations made in the attachments of this permit are enforceable under R315- 301-5(2) of the Utah Administrative Code. Where differences in wording exist between this Permit and the attachments, the wording of this Permit supersedes that of the attachments. This Permit consists of the signature page, Facility Owner/Operator Information section, sections I through V, and all attachments to this Permit. The facility as described in this Permit consists of three Class IIIb disposal cells, identified as M- 136 (propellant ash), M-336 (solid waste generated on-site), and Rocky Point (large industrial component waste). Compliance with this Permit does not constitute a defense to actions brought under any other local, state, or federal laws. This Permit does not exempt the Permittees from obtaining any other local, state, or federal permits or approvals required for the facility operation. The issuance of this Permit does not convey any property rights, in either real or personal property, or any exclusive privileges. Nor does this Permit authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations, including zoning ordinances. The provisions of this Permit are severable. If any provision of this Permit is held invalid for any reason, the remaining provisions shall remain in full force and effect. If the application of any provision of this Permit to any circumstance is held invalid, its application to other circumstances shall not be affected. By this Permit, the Permittees are subject to the following conditions. Page 4 of 12 PERMIT REQUIREMENTS I. GENERAL COMPLIANCE RESPONSIBILITIES I.A. General Operation I.A.1. The Permittees shall operate the landfill in accordance with all applicable requirements of R315-304 of the Utah Administrative Code which are in effect as of the date of this Permit unless otherwise noted in this Permit. Any permit noncompliance or noncompliance with any applicable portions of Utah Code Ann. § 19-6-101 through 125 and applicable portions of R315-301 through 320 of the Utah Administrative Code constitutes a violation of the Permit or applicable statute or rule and is grounds for appropriate enforcement action, permit revocation, modification, termination, or denial of a permit renewal application. I.B. Acceptable Waste I.B.1. This Permit is for disposal of nonhazardous industrial solid waste, as defined in R315- 301-2(35) of the Utah Administrative Code, generated by ATK Launch Systems, LLC and as described in the Permit Application, including regulated asbestos-containing material, and PCBs as specified by R315-315-7(2) of the Utah Administrative Code. I.B.2. The landfill unit designated as M-336 in the Permit Application may accept non- hazardous industrial waste including regulated asbestos waste, office waste, employee cafeteria waste, and carcasses of animals killed on site either by accident or allowed under state and federal permits. I.B.3. The landfill unit designated as M-136 in the Permit Application may accept exclusively non-hazardous propellant burn ash and related non-hazardous debris generated exclusively on site. I.B.4. The landfill unit designated Rocky Point may accept large hardware such as rocket motor nozzles, cases, and other miscellaneous large items. I.C. Prohibited Waste I.C.1. Hazardous waste as defined by R315-261 of the Utah Administrative Code; I.C.2. PCB's as defined by R315-301-2(53) of the Utah Administrative Code, except PCB’s specified by R315-315-7(2)(a) and (c) of the Utah Administrative Code; I.C.3. Household waste; I.C.4. Municipal waste; I.C.5. Special waste except as specified in this Permit; I.C.6. Commercial waste; and Page 5 of 12 I.C.7. Containers larger than household size (five gallons) holding any liquid, non- containerized material containing free liquids, or any waste containing free liquids in containers larger than five gallons. I.C.8. Any prohibited waste received and accepted for disposal at the facility shall constitute a violation of this Permit, of Utah Code Ann. § 19-6-101 through 125 and of R315-301 through 320 of the Utah Administrative Code. I.D. Inspections and Inspection Access I.D.1. The Permittees shall allow the Director or an authorized representative, or representatives from the Bear River Health Department, to enter at reasonable times and: I.D.1.a Inspect the landfill or other premises, practices or operations regulated or required under the terms and conditions of this Permit or R315-301 through 320 of the Utah Administrative Code; I.D.1.b Have access to and copy any records required to be kept under the terms and conditions of this Permit or R315-301 through 320 of the Utah Administrative Code; I.D.1.c Inspect any loads of waste, treatment facilities or processes, pollution management facilities or processes, or control facilities or processes required under this Permit or regulated under R315-301 through 320 of the Utah Administrative Code; and I.D.1.d Create a record of any inspection by photographic, video, electronic, or any other reasonable means. I.E. Noncompliance I.E.1. If monitoring, inspection, or testing indicates that any permit condition or any applicable rule under R315-301 through 320 of the Utah Administrative Code may be or is being violated, the Permittees shall promptly make corrections to the operation or other activities to bring the facility into compliance with all permit conditions or rules. I.E.2. In the event of noncompliance with any permit condition or violation of an applicable rule, the Permittees shall promptly take any action reasonably necessary to correct the noncompliance or violation and mitigate any risk to the human health or the environment. Actions may include eliminating the activity causing the noncompliance or violation and containment of any waste or contamination using barriers or access restrictions, placing warning signs, or permanently closing areas of the facility. I.E.3. The Permittees shall: I.E.3.a Document the noncompliance or violation in the daily operating record, on the day the event occurred or the day it was discovered; I.E.3.b Notify the Director of the Utah Division of Waste Management and Radiation Control by telephone within 24 hours, or the next business day following documentation of the event; and Page 6 of 12 I.E.3.c Give written notice of the noncompliance or violation and measures taken to protect human health and the environment within seven days after Director notification. I.E.4. Within thirty days after the documentation of the event, the Permittees shall submit to the Director a written report describing the nature and extent of the noncompliance or violation and the remedial measures taken or to be taken to protect human health and the environment and to eliminate the noncompliance or violation. Upon receipt and review of the assessment report, the Director may order the Permittees to perform appropriate remedial measures including the development of a site remediation plan for approval by the Director. I.E.5. In an enforcement action, the Permittees may not claim as a defense that it would have been necessary to halt or reduce the permitted activity to maintain compliance with R315-301 through 320 of the Utah Administrative Code and this Permit. I.F. Revocation or Termination I.F.1. This Permit is subject to revocation or termination if the Permittees fail to comply with any condition of the Permit. The Director will notify the Permittees in writing before any proposed revocation action and such action shall be subject to all applicable hearing procedures established under R305-7 of the Utah Administrative Code and the Utah Administrative Procedures Act. I.G. Attachment Incorporation I.G.1. Attachments to the Permit Application are incorporated by reference into this Permit and are enforceable conditions of this Permit, as are documents incorporated by reference into the attachments. Language in this Permit supersedes any conflicting language in the attachments or documents incorporated into the attachments. II. DESIGN AND CONSTRUCTION II.A. Design and Construction II.A.1. The landfill shall be constructed according to the design outlined in Attachment 1 and in the area designated in Attachment 2, including landfill cells, fences, gates, and berms. II.A.2. The Permittees shall notify the Director upon completion of construction of any landfill cells or run-on and run-off diversion systems. No landfill cells or run-on and run-off diversion system may be used until construction is approved by the Director and this permit modified. II.A.3. The Permittees shall notify the Director of the completion of construction of any final cover system and shall provide all necessary documentation and shall apply for approval of the construction from the Director and modification of this permit. II.A.4. If ground water is encountered during excavation of the landfill, the Director shall be notified immediately, and an alternative construction design developed and submitted for approval. Page 7 of 12 II.B. Run-On Control II.B.1. The Permittees shall construct drainage channels and diversions as specified in Attachment 1 and shall maintain them at all times to effectively prevent runoff from the surrounding area from entering the landfill. III. LANDFILL OPERATION III.A. Operations Plan III.A.1. The Permittees shall keep the Operations Plan included in Attachment 3 on-site at the landfill or the location designated in section III.H of this Permit. The Permittees shall operate the landfill in accordance with the operations plan. If necessary, the Permittees may modify the Operations Plan following the procedures of R315-311-2(1) of the Utah Administrative Code and approved by the Director. The Permittees shall note any modification to the Operations Plan in the daily operating record. III.B. Security III.B.1. The Permittees shall operate the Landfill so that unauthorized entry to the facility is restricted. The Permittees shall: III.B.1.a Lock all facility gates and other access routes during the time the landfill is closed. III.B.1.b Have at least one person employed by the Permittees at the landfill during all hours that the landfill is open. III.B.1.c Construct all fencing and any other access controls as shown in Attachment 1 to prevent access by persons or livestock by other routes. III.C. Training III.C.1. The Permittees shall provide training for on-site personnel in landfill operation, including waste load inspection, hazardous waste identification, and personal safety and protection. III.D. Burning of Waste III.D.1. Intentional burning of solid waste is prohibited and is a violation of R315-303-4(2)(b) of the Utah Administrative Code. III.D.2. The Permittees shall ensure that all accidental fires are extinguished as soon as reasonably possible. III.E. Cover III.E.1. The Permittees shall cover the waste as necessary to prevent fires and to control vectors, blowing litter, odor, scavenging, and fugitive dust. The Permittees shall cover wastes that are capable of attracting or providing food for vectors, materials that may become windblown litter or fine materials that may become fugitive dust with a Page 8 of 12 minimum of six inches of earth at the end of the working day in which the wastes are received. The Permittees may use an alternative cover material when the material and operation meet the requirements of R315-303-4(4)(b) through (e) of the Utah Administrative Code. III.E.2. The Permittees shall use a minimum of six inches of earthen cover no less than once each day for Landfill unit M-336 when waste is received there; no less than once each quarter in which wastes are received at Landfill units M-136; and as needed at Rocky Point. This cover shall consist of soil; no alternative may be used. III.E.3. The Permittees shall record in the daily operating record and the operator shall certify, at the end of each day of operation when soil or an alternative cover is placed, the amount and type of cover placed, and the area receiving cover. III.E.4. Cover requirements for dead animals are found in Section III.L of this Permit. III.F. Waste Inspections III.F.1. The Permittees shall visually inspect incoming waste loads to verify that no wastes other than those allowed by this permit are disposed of in the landfill. The Permittees shall conduct a complete waste inspection at a minimum frequency of 1 % of incoming loads, but no less than one inspection per week. The Permittees shall select the loads to be inspected on a random basis. III.F.2. The Permittees shall inspect all loads suspected or known to have one or more containers capable of holding more than five gallons of liquid to ensure that each container is empty. III.F.3. The Permittees shall inspect all loads that the Permittees suspects may contain a waste not allowed for disposal at the landfill. III.F.4. The Permittees shall conduct complete random inspections as follows: III.F.4.a The Permittees shall conduct the random waste inspection at the working face or an area designated by the Permittees. III.F.4.b The Permittees shall direct that loads subjected to complete inspection be unloaded at the designated area; III.F.4.c Loads shall be spread by equipment or by hand tools; III.F.4.d Personnel trained in hazardous waste recognition and recognition of other unacceptable waste shall conduct a visual inspection of the waste; and III.F.4.e The personnel conducting the inspection shall record the results of the inspection on a waste inspection form as found in Attachment 4. The Permittees shall place the form in the daily operating record at the end of the operating day. III.F.4.f The Permittees or the waste transporter shall properly dispose of any waste found that is not acceptable at the facility at an approved disposal site for the waste type and handle the waste according to the rules covering the waste type. Page 9 of 12 III.G. Self Inspections III.G.1. The Permittees shall inspect the facility to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to the release of wastes or contaminated materials to the environment or create a threat to human health or the environment. The Permittees shall complete these general inspections no less than quarterly and shall cover the following areas: Waste placement, compaction, cover; fences and access controls; roads; run-on/run-off controls; final and intermediate cover; litter controls; and records. The Permittees shall place a record of the inspections in the daily operating record on the day of the inspection. The Permittees shall correct the problems identified in the inspections promptly and document the corrective actions in the daily operating record. III.H. Recordkeeping III.H.1. The Permittees shall maintain and keep on file at the ATK Launch Systems Environmental Services Office, a daily operating record and other general records of landfill operation as required by R315-302-2(3) of the Utah Administrative Code. The landfill operator, or other designated personnel, shall date and sign the daily operating record at the end of each operating day. Each record to be kept shall contain the signature of the appropriate operator or personnel and the date signed. The Daily operating record shall consist of the following two types of documents: III.H.1.a Records related to the daily landfill operation or periodic events including: The number of loads of waste and the weights or estimates of weights or volume of waste received each day of operation and recorded at the end of each operating day; Major deviations from the approved plan of operation recorded at the end of the operating day the deviation occurred; Results of monitoring required by this Permit recorded in the daily operating record on the day of the event or the day the information is received; Records of all inspections conducted by the Permittees, results of the inspections, and corrective actions taken shall be recorded in the record on the day of the event. III.H.1.b Records of a general nature including: A copy of this Permit, including all attachments; Results of inspections conducted by representatives of the Director of the Division of Waste Management and Radiation Control, and representatives of the local Health Department, when forwarded to the Permittees; Closure and Post-closure care plans; and Records of employee training. Page 10 of 12 III.I. Reporting III.I.1. The Permittees shall prepare and submit to the Director an Annual Report as required by R315-302-2(4) of the Utah Administrative Code. The Annual Report shall include: the period covered by the report, the annual quantity of waste received, an annual update of the financial assurance mechanism, and all training programs completed. III.J. Roads III.J.1. The Permittees shall improve and maintain all access roads within the landfill boundary that are used for transporting waste to the landfill for disposal shall be improved and maintained as necessary to assure safe and reliable all-weather access to the disposal area. III.K. Litter Control III.K.1. Litter resulting from operations of the landfill shall be minimized. In addition to the litter control plans found in Attachment 3, the Permittees shall implement the following procedures when high wind conditions are present: III.K.1.a Reduce the size of the tipping face; III.K.1.b Reduce the number of vehicles allowed to discharge at the tipping face at one time; III.K.1.c Orient vehicles to reduce wind effects on unloading and waste compaction; III.K.1.d Reconfigure tipping face to reduce wind effect; III.K.1.e Use portable and permanent wind fencing as needed; and III.K.1.f Should high winds present a situation that the windblown litter cannot be controlled, the Permittees shall cease operations of the landfill until the winds diminish. III.L. Disposal of Special Wastes III.L.1. The Permittees may dispose of animal carcasses may in the landfill working face and shall cover them with other solid waste or earth by the end of the operating day in which the carcasses are received. Alternatively, the Permittees may dispose of animal carcasses in a special trench or pit prepared for the acceptance of dead animals. If a special trench is used, the Permittees shall cover animals placed in the trench with six inches of earth by the end of each operating day. III.L.2. The Permittees shall handle and dispose of asbestos waste in accordance with R315- 315-2 of the Utah Administrative Code. III.L.3. Loads of propellant ash for disposal in Landfill unit M-136 shall be transported in such a manner as to prevent leakage or the release of fugitive dust. Page 11 of 12 IV. CLOSURE REQUIREMENTS IV.A. Closure IV.A.1. The final cover of the landfill shall be as shown in Attachment 3. The final cover shall meet, at a minimum, the standard design for closure as specified in R315-305-5(5)(b) of the Utah Administrative Code. IV.B. Title Recording IV.B.1. The Permittees shall meet the requirements of R315-302-2(6) of the Utah Administrative Code by recording a notice with the Box Elder County Recorder as part of the record of title that the property has been used as a landfill. The notice shall include waste disposal locations and types of waste disposed of. The Permittees shall provide the Director the notice as recorded. IV.C. Post-Closure Care IV.C.1. The Permittees shall perform post-closure care at the closed landfill in accordance with the Post-Closure Care Plan contained in the Permit Application. Post-closure care shall continue until all waste disposal sites at the landfill have stabilized and the finding of R315-302-3(7)(c) of the Utah Administrative Code is made. IV.D. Financial Assurance IV.D.1. The Permittees shall keep in effect and active the currently approved financial assurance mechanism or establish another approved mechanism that meets the requirements of R315-309 of the Utah Administrative Code and is approved by the Director to cover the costs of closure and post-closure care at the landfill. The Permittees shall adequately fund and maintain the financial assurance mechanism(s) to provide for the cost of closure at any stage or phase or anytime during the life of the landfill or the permit life, whichever is shorter. IV.E. Financial Assurance Annual Update IV.E.1. The Permittees shall submit an annual revision of closure and post-closure costs for inflation and financial assurance funding as required by R315-309-2(2) of the Utah Administrative Code, to the Director as part of the annual report. IV.F. Closure Cost and Post-Closure Cost Revision IV.F.1. The Permittees shall submit a complete revision of the closure and post-closure cost estimates by the Closure Cost Revision Date listed on the signature page of this Permit and any time the facility is expanded, any time a new cell is constructed, or any time a cell is expanded. Page 12 of 12 V. ADMINISTRATIVE REQUIREMENTS V.A. Permit Modification V.A.1. Modifications to this Permit may be made upon application by the Permittees or by the Director following the procedures specified in R315-311-2 of the Utah Administrative Code. The Permittees shall be given written notice of any permit modification initiated by the Director. V.A.2. Permit Transfer V.A.2.a This Permit may be transferred to a new Permittees or new Permittees by complying with the permit transfer provisions specified in R315-310-11 of the Utah Administrative Code. V.B. Expansion V.B.1. This Permit is for the operation of a Class IIIb Landfill according to the design and Operation Plan described and explained in the Permit Application. Any expansion of the current footprint designated in the description contained in the Permit Application, but within the property boundaries designated in the Permit Application, shall require the submittal of plans and specifications to the Director. The plans and specifications shall be approved by the Director before construction. V.B.2. Any expansion of the landfill facility beyond the property boundaries designated in the description contained in the Permit Application shall require the submittal of a new Permit Application in accordance with the requirements of R315-310 of the Utah Administrative Code. V.B.3. Any addition to the list of acceptable waste in Section I.B shall require the submittal of all necessary information to the Director and the approval of the Director. V.C. Expiration V.C.1. If the Permittees desire to continue operating this landfill after the expiration date of this Permit, the Permittees shall apply for a renewal permit at least six months before the expiration date, as shown on the signature (cover) page of this Permit. If the Permittees submit a permit renewal application and the permit renewal is not complete by the expiration date, this Permit shall continue in force until the renewal is completed or denied. VI. ATTACHMENTS Attachment 1 – Design Diagrams Attachment 2 – Site Diagrams and Geologic Maps Attachment 3 – Operations Plan Attachment 4 – Waste Inspection Form Statement of Basis for the ATK - Promontory 1. INTRODUCTION This Statement of Basis provides the rationale of the Director of the Division of Waste Management and Radiation Control (DWMRC) for issuing the ATK Launch Systems – Promontory Landfills renewal Permit. The Director’s staff conducted this evaluation to ensure compliance with the applicable solid waste rules. Robert Windell wrote this Statement of Basis. 2. FACILITY BACKGROUND a. Facility Location and History Landfill sites are located in Township 11 North, Range 5 West, Sections 8, 16, and 20, SLMB; Box Elder County. M-136 – Lat. 41°41'10.37"N, Long. 112°25'41.61"W M-336 – Lat. 41°41'42.97"N, Long. 112°26'26.48"W Rocky Point - Lat. 41°40'21.15"N, Long. 112°26'39.66"W 9160 North Highway 83 Corinne, UT 84307 b. Regulatory History The Facility first received a permit to operate from the Division on May 24th, 2000, and began accepting waste shortly thereafter. This facility has operated since opening without any regulatory or enforcement actions. The Division maintains records of the 12 most recent inspections of this facility in its database. 3. EVALUATION OF THE PERMIT APPLICATION a. The facility submitted an application for a renewal permit on April 2nd, 2021 (DSHW-2021- 005283), and the Division sent a notification for the receipt of the permit application and a finding of completeness on May 25th, 2021 (DSHW-2021-007062). A draft Permit was prepared and sent to the facility for review and comment on May 5th 2021. After resolving comments from the facility, the draft permit was released for public comment on August 26th 2021. The public comment period ended on September 24th, 2021. No comments were received. After the closure of the public comment period the draft permit was finalized. 4. JUSTIFICATION FOR ISSUING THE PERMIT a. The Director’s staff has evaluated the permit application as required by Section 19-6-108 of the Solid and Hazardous Waste Act and R315-301 through 320 of the Solid and Hazardous Waste Rules. 5. PUBLIC PARTICIPATION a. As required by Utah Administrative Code R315-311-3, the Director provided an initial 30- day public comment period which began August 26th, 2021 and completed on September 24th, 2021. 6. DIRECTOR RESPONSE TO PUBLIC COMMENTS: There were no public comments received by the director in regard to the issuance of this renewal permit. Figure 1 Facility Location Attachment 1 Design Diagrams V o Le . V) yf i g i m p i ; ;; ;; ; O v a k f i g o t IN i g i y g o g i g o qh M t V i l L1 4 1 1 1 1 1 1 1 1 1 1 Wi T Z Ce i n g e g i g i l y X I I ' i f i l 0 0 4 1 1 5 1 ; il h a i l l i g h b ii : 1 1 0 1 1 1 1 M i l ; IG 6 nri i 0 0 n li k N O M M I ;1 1 '11 pi r I .1 9 1 p. e Rb e a Oa a d p, Fff i l l i l l i f f ll l I l H H l l l !B O N I N ? , lo m m 7 7 4 tr o l l i m m l E 7 5 NON NI CAW Or Num. LAM lAt NM 41 42 law MDICIALY 100.20 AVA MCA AIN tIN if NOW TO ANN MOM TELL 21110101,11110 400 NAM OM 00100.— ACM 111II COM If OMAN UMW IAL llr IV 4101. LON 41. 41. 1440. NOID ON II MO Or IN M. 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AILLT 114 H1111401 THAIHHEE C/101100. AT 1/40.1. TE RE-VILOLTANTP 40101101116 10 THE FOLIJNIK SPECIPICATIRTIV =SIM MATURE PASEO MALIK LIVE CEO KM MKT II GOTHIMATHIN • AS e THICK ASPHALT 0011 MKS Or SLOTTED ORM CORRUGATED METAL PVC CUIKERT 12O • 3CC LEA . 11 GA. SLOTTED MAK TP/ 0. TALL ELK r OŒP REPO MSC EARIC UNDISTRITKO OR COMPACTED 0441. VITAIWTHED METAL r. =row. 42 20. r 30 LC • nonstsco ARCAt TY THE RIAVarr MOCK CIIMACL SHALL MOT K REAKCCIATED G28 ^ • INF 11111. S.M. Mt WM/ IMMO GRAPHIC SCALE Wu IT • .o•V ROBERTS 41c SCQEFER mom Al0 00KRACMIC I Loora42/0 CITICAOTAASILT {AK CITY I 6130 LE-otiq b o =CRT SELL 101-011 RIK VT mom KICE NM amen roc, A A 7 5 SD...-KC TITT.K.WE luXtessth *mews ba 00 HAS spa THE NOM ........'4.7..re"", M-136 BURNING AREA nmervismr------ , RUN—OFT AND RUN—ON ow r, DRAINAGE PLAN FIGURE 2.1.1 I ot,-..;12015/04117 - )4-136 BURN GROUNDS =Lc 10 ANKIC 0140 o _.-ox avant pt.. V 0.00/111T .1.1.10 WHAM OHM. 1tTr'00,11101110 of. VITAL omal ROW F r.7( MK 1V ok I MT TT K. 011111101 001.10 11.1.1 anara TAT *VOW P00 CFaJs, TIMC METAL GM M 4010.1.7 1.742.MET IMMOTM NIL C-T M MIMIC E 1,74E21TS NOTE: THIS DRAWING MUST NOT BE CHANGED SIGNIFICANTLY WITHOUT AUTHORIZATION FROM ENVIRONMENTAL SERVICES o A .a""T Aoldnic . ) AUUa us ROCKY POINT LAND FILL, M-BOB LAYOUT CI MAIITI$ }MC ROW 1 =50 GPI.G.556 OPIGOSIOPM Attachment 2 Site Diagrams and Geologic Maps 1.1ter 1 Seri Um, 1.6p 114 6.1•1104. al taw** p.m* GEOLOGWAI. SIAM I. TAR DEPARTADOT OP HAMM. NISSOVIICES 1.e•porwkin 149 THE MR tH MAYES GEOLOGICAL fa RIMY tort ta.m*Pannora 41f .MIC nal sel, Me M-336 Landfil CONTRIIR INTMILL DOM.0 Won lePft[3(10 S FOOT CON/Ds•Is MN. v4 5r, GEOLOGIC MAP OF THE LAMPO JUNCTION QUADRANGLE BOX ELDER COUNTY, UTAH by David M. Miller!, Max D. Crittenden, Jr.2, and Teresa E. Jordan, Grological Sum,. ,Deccaard 1991 Vt. al.N.Vm KM/ OfrAirnalfr W.A. 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Op Oyer ^um. 1.0 w. elanapoomaOM Wesioqxs4 tareaezoporogremedmam eatayagemolbe-*01110e. anijaxgrefaml *odd • I grap tow r anoliolm Mardatofteapa. 31010.0.,..A06SSIGIV.11 Gimo armoUnam Moimagoonl - Law* Vv., lb. magaalamempoentwon0 .F0 loossVerramt aft... taw/soft *ie.. Ma-. —I .010011-OW. G.. Pasmealm.- 0.10,01. 0{00040.00.{ r • Miereaep•IROMentpreallint Calliptulaily**01 I Marx Wawa Otanma RA.* - Pdaymplp Mar mom I 1 -7) VARIES 14'-30' NATIVE SOIL VARIES 15*-100' ===. -.-.-.-.-.-.-.-.- 24" M[N. TRASH --6" TOP SOIL (MIN.) ...... 60" ,.114. GROUND WATER NATIVE CLA) NATIVE VEGETATION SOIL COMPACTED 90% MIN. (1 x1 C-5 CM/SEC) 24" MIN. COVER SOIL COMPACTED 90% MIN. ( 1 x 1 G-5 CM/SEC) -24" MIN. COVER NATIVE VEGETATION -6" TOP SDIL (MIN.) å 1g 1 11 1 • - - • • - • . . • - - • . • - • . • - . • • . • • • • - • • • . - • . • - ..• •-•.......•...• :••••••••.......•.•••••.. •, ........•.•••.. :.....••••-.•-..• ....•.••• ...•••• •••.•••••••••••.•-.•••••... TRASH • • - • ..... • • VARIES 14-30' . • . • • • . . • . • . • e • • • . • • 1 • • • • • • • • .................. • . • ............. • . • . .. • . • . • GROUND WATER NATIVE CLAY VARIES 15' 1 0 0 NATIVE SOIL Depth to groundwater at the M-336, M-136 and Rocky Point disposal units is on average around 300 feet. Soil borings were taken in the M-336 disposal unit in 2018 to a depth between 41.5 and 51.5 feet. Wet soils were only encountered from one of the four borings drilled. Further investigation determined the wet conditions at approximately 50 feet were likely related to a thin lens of perched groundwater than part of the regional water table. Therefore a disposal unit dug to the typical depth of 20 feet, or a maximum depth of 30 feet, ensures waste is at least 10 feet above ground water. Historical Preservation Survey The quitclaim deed between the Thiokol Corporation and U.S. Government requires protection and notification of Native American artifacts. The area was once occupied by the Northwestern Band of the Shoshone Nation. ATK Launch Systems, LLC maintains a close relationship with the Shoshone Nation and the Utah Statewide Archeological Society (USAS) to ensure preservation of known or newly discovered artifacts. Security measures around the Promontory plant help to facilitate preservation of artifacts from illegal scavenging. The facility has worked with the Shoshones and USAS to arrange site tours for limited archeological and historical purposes. The landfill disposal units are not known to be locations rich in artifacts. However, any discovery of artifacts or evidence that artifacts may exist will be communicated to representatives of Shoshone Nation and the USAS. I.f 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 6IPage Attachment 3 - Operations Plan 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. 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 siltlitional inaterial 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 utilin 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. 71Page 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 mariners. 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 8IPage 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 minimi7e 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 collevtion 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 appoximately 12 to 15%. Additional recycling initiatives are planned to support Northrop Grumman Corporation's company-wide sustainability goals. 9age Any other site-specific inforrnation pertaining to the plan of operation required by the Director The landfill units are located within a fenced facility with roving 24 hour anned 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. 1.g Ground Water Monitoring for Class Ina landfills Ground Water Monitoring Plan This application is for renewal of an existing Class Mb landfill. No expansion or transition to the Class Ilia landfill type is requested in the application. II. Facility Technical Information 11.a Maps for All Class III Landfills Topographic rnaps for landfill units Appendix 6 includes site drawings for each disposal unit and associated topographic contours. The M-336 disposal unit is located on the Blue Creek Valley floor and is relatively flat throughout the existing permitted area. The M-136 disposal unit is located at the base of a draw. The slope is moderate from east to west but steepens significantly from the north and south. The Rocky Point disposal unit is located on the western tip of a ridge. The area has moderate relief to the west but has moderately steep terrain on the eastern edge. Most recent U.S. Geological Survey topographic map The most recent topographic map for the Lampo Junction Quadrangle can be found in Appendix 7. The yellow highlighted area shows the approximate boundaries for the Promontory plant. The general location for each disposal unit is outlined and identified. 1.01Page 1I.b Geohydrologioal Assessment for Class Ma Landfills Local and regional geology and hydrology including faults, unstable slopes and subsidence areas on site This application is for renewal of an existing Class IIlb landfill. No expansion or transition to the Class lila landfill type is requested in the application. Evaluation of bedrock and soil types and properties including permeability rates This application is for renewal of an existing Class II% landfill. No expansion or transition to the Class Ina landfill type is requested in the application. Depth to ground water This application is for renewal of an existing Class Mb landfill. No expansion or transition to the Class Ma landfill type is requested in the application. Quantity, location, and construction of any private or public wells on-site or within 2,000 feet of the facility boundary This application is for renewal of an existing Class Mb landfill. No expansion or transition to the Class Ma landfill type is requested in the application. Tabulation of all water rights for ground water and surface water on-site and within 2,000 feet of the facility boimdary This application is for renewal of an existing Class IIIb landfill. No expansion or transition to the Class lila landfill type is requested in the application. Identification and description of all surface waters on-site and within one mile of the facility boundary This application is for renewal of an existing Class IIIb landfill. No expansion or transition to the Class Ma landfill type is requested in the application. For an existing facility, identification of impacts upon the ground water and surface water from leachate discharges This application is for renewal of an existing Class Mb landfill. No expansion or transition to the Class HIa landfill type is requested in the application. 111Page Calculation of site water balance This application is for renewal of an existing Class II1b landfill. No expansion or transition to the Class Ma landfill type is requested in the application. II.c Engineering Report - Plans, Specifications, and Calculations for A11 Class 111 Landfills Unit Design Appendix 8 shows a typical longitudinal cross section of trench type cells for the M-336 and M-136 landfill unit, including clay liner and cover. Side-wall slopes will be cut at a maximum angle of 76 degrees to ensure trench stability during wet conditions. Run-on and run-off control Open cells at the M-336 disposal unit are flanked by trenches to prevent surface waters from running into the cell. The trenches divert water to flat areas adjacent to the cell where dispersion and evaporation can occur. A large trench runs north and south on the west side of M-336 and acts as a surface run-off control. The trench collects surface run- off before it can enter natural drainage channels that flow directly towards Blue Creek. The trench is lined and covered with rip-rap to serve as an evaporation area. The steep wall design of M-336 cells does not allow water to run out of the cell. Water in the cell is mainly from localized rainfall, snow melt, or subsurface seepage during wet conditions. The low infiltration rate of soils in the disposal unit keeps water contained in low areas of the cell until it evaporates as conditions dry. The M-136 disposal unit is constructed in an upland area at the mouth of a draw that runs east to west. Drainage channels are maintained on the north and south sides of the draw. A gravel road is maintained in the center and is elevated to ensure water runs into the ditches. Excavation overburden from M-136 cells is typically piled on the uphill side and side facing the drainage channel to create a berm to further direct run-on water away from the open cell. Rainfall, snow melt, or seepage collected inside the bermed area stays within the cell, while all water outside the berm follows one of the drainage channels. The Rocky Point disposal unit is constructed into the western most point of a gravelly, rocky ridge that runs east to west. Material from the ridge was used to create a large overburden berm on the north and west side of the cell. The large berm prevents water from entering or leaving the cell on those sides. Water cannot leave the east side of the cell since it abuts the ridge. Historical sand and gravel removal from the north and west sides of the ridge have created a primary drainage flow away from the cell. Additionally, the exposed sandy/gravelly surface material provides lower run off potential for rainfall and snowmelt. 12 'Page ILd Engineering Report - Plans, Specifications, and Calculations for Class Ilia Landfills Engineering reports required to meet the location standards This application is for renewal of an existing Class IIIb landfill. No expansion or transition to the Class IIIa landfill type is requested in the application. Anticipated facility life and the basis This application is for renewal of an existing Class IIIb landfill. No expansion or transition to the Class IIIa landfill type is requested in the application. Equipment requirements and availability This application is for renewal of an existing Class II% landfill. No expansion or transition to the Class Ilia landfill type is requested in the application. Identification of borrow sources for daily and final cover and for soil liners This application is for renewal of an existing Class IIIb landfill. No expansion or transition to the Class IIIa landfill type is requested in the application. Run-off treatment and disposal and documentation to show that any treatment system being used has been reviewed by the Division of Water Quality This application is for renewal of an existing Class Mb landfill. No expansion or transition to the Class IIIa landfill type is requested in the application. II.e Closure Requirements for AIl Class III Landfills Closure Plan All landfill cells will be closed using the same process. When a cell is filled, it is capped with a total of 24 inches of native soil and compacted to at least 90% maximum density. The compaction is expected to achieve a hydraulic conductivity rate of approximately 1 x 10' cm/sec. The top layer of the cap will be 6 inches of top soil. The surface will be seeded using a mix of grasses similar to the native vegetation. Closure Schedule 13IPage The M-336 disposal unit has approximately 4.5 acres of available space remaining within the currently permitted area. It is estimated that the disposal unit's capacity will be reached between 2035 to 2044 depending on waste generation rates and management practices. The M-136 disposal unit has approximately 0.1 acres of available space remaining within the currently permitted area. It is estimated that the disposal unit's capacity will be reached between 2024 to 2026 depending on waste generation rates and management practices. ATK Promontory is evaluating potential areas for expansion of the disposal unit. An expansion permit application will be filed with DWMRC once this evaluation is completed. The Rocky Point disposal unit has approximately 8 acres of available space remaining within the currently permitted area. The nature of the type of waste and the unusual cell construction type at Rocky Point presents a challenge for estimating capacity use rates. Manufacturing programs that create large scrap pieces can consume space relatively quickly. However, due to existing available space and the success of current management practices, it is anticipated that Rocky point will have enough capacity to receive waste beyond 25 years. Design of Final Cover The design for final cover is included on drawings M136-G-41 and M336-G-1 in Appendix 6. An expanded view is shown in Appendix 9. Capacity of Site in Volume and Tonnage The M-336 disposal unit has an existing asbestos trench recently opened in the fall of 2020. The trench has approximately 5,000 cubic yards remaining. The existing common trash trench has an estimated 12,000 cubic yards remaining. There is space for at least five new asbestos trenches and three new common trash trenches, or some combination based on waste management needs. The new asbestos trenches would provide about 40,500 cubic yards. New common trash trenches would provide 78,000 cubic yards. Therefore, the total disposal capacity remaining at M-336 is 45,500 cubic yards for asbestos trenches and 90,000 cubic yards for common trash trenches. Part of the estimated capacity is consumed by soil used as cover. Assuming a 1:1 volume ratio of cover to waste, there is about 23,000 cubic yards remaining for waste placed in asbestos trenches. Using a 0.28 ton/cubic yard conversion factor, this equates to just under 6,500 tons of capacity. A 0.5 ton/cubic yard conversion factor for waste in common trash trenches equates to 22,500 tons remaining capacity. The M-136 disposal unit has an existing cell with approximately 1300 cubic yards of space remaining. There is limited space for one new cell beyond the existing open cell. The new cell would provide an additional 800 to 1000 cubic yards. Cover requirements 14IPage for M-136 cells have traditionally required less material than at M-336. Therefore, assuming a 0.5:1 cover to waste ratio. The total waste capacity remaining is approximately 1500 cubic yards. Using a 1.1 tons/cubic yard conversion factor, there is just under 1700 tons remaining capacity. As mentioned earlier, Rocky point is more challenging to estimate capacity due to the type of waste placed in the cell and the way the cell is oriented into the hillside. However, using a standard cell depth of 20 feet and the available area, there is an estimated 210,000 cubic yards of disposal volume available. The general inability to compact the pieces placed in the landfill creates a higher cover to waste ratio. A conservative estimate is 4:1. This leaves an available waste capacity of 42,000 cubic yards. Using a 1.52 tons/cubic yard conversion factor, there is just under 64,000 tons of remaining capacity. Final Inspection by Regulatory Agencies Within 30 days after completion of closure activities, the DWMRC will be contacted to conduct a final inspection. Any required modifications will be completed within 30 days, and a re-inspection requested. Post-closure care will begin once closure is completed to the satisfaction of the DWMRC. Post-Closure Care Requirements for All Class III Landfills Post Closure Care Plan Closed areas of each landfill unit will be inspected quarterly to assess the condition of the cell cap, vegetation growth, and erosion issues. Repairs to the cell cap will be made by adding additional soil as needed. Vegetation maintenance will occur as necessary if seeded or natural vegetation has not become established. Areas showing signs of erosion will be repaired and erosion potential corrected, if possible. Changes to record of title, land use, and zoning restrictions ATK Launch Systems, LLC notified DWMRC of becoming a wholly owned subsidiary of Northrop Grumman Corporation in March 2018. No land use or zoning restrictions have occurred since the current permit was issued. ATK Launch Systems, LLC will promptly notify the Division of any future changes in ownership or land use and zoning restrictions. Maintenance 15 IP age Routine maintenance at each disposal unit will focus on ground cover restoration, run- on/run-off controls, and access road integrity. Ground cover will be reseeded as necessary to ensure top soil stability and minimize fugitive dust generation. Run-on/run- off controls will be checked for bypass and sedimentation that could limit their effectiveness. Access roads will be constructed and maintained in a manner to ensure safe ingress and egress from each disposal unit. In addition, entry points will be constructed to minimize track-out during wet conditions. Inspections will be performed monthly and maintenance needs documented. Repairs will be prioritized and scheduled based on criticality and completed as soon as conditions allow. Heavy equipment used at each disposal unit for waste spread and cover will be maintained through periodic preventative maintenance inspections. The garbage truck will also be maintained through periodic inspections. Inspections are conducted by qualified mechanics in the fleet maintenance department. Contact for Post Closure Care ATK Launch Systems, LLC Environmental Services PO Box 707 M/S 301 Brigham City, UT 84302-0707 (801)251-2166 II.g Financial Assurance Requirements for All Class III Landfills Identification of closure costs including cost calculations Appendix 10 provides a summary of activities needed to close the landfill and calculated costs. Identification of the financial assurance mechanism Closure, post-closure or corrective action is guaranteed by a performance bond with Westminster Fire Insurance Company of Philadelphia, PA. The bond is amended annually by a bond rider to account for increases in closure, post-closure, or corrective action costs due to inflation and/or other factors that may affect cost estimates. 16 1Pa ge Landfill Closure/Post-Closure Cost Estimate M-136, M-336 and Rocky Point Closure item No. Description Means No./Source Units Est. Quan. Unit Price Total Price M-136 Indus 1 di Grade 18" common soil cover - 1 local soil over 600 ft2 area 31-23-23.17-0020 CY 34 $2.48 $84 2 Compact graded soil 31-23-23.23-6000 CY 34 $0.30 $10 Haul topsoil to site (50-mile 3 cycle) 31-23-23.20-1714 CY 12 $20.54 $246 4 Grade 6" topsoil 31-23-23.17-0170 CY 12 $3.83 $46 5 Hydroseed, with mulch & fertilizer 32-92-19.14-5400 MSF 0.6 $111.04 $67 SUBTOTAL $453 ndustrial nail '- • Grade 18" common soil cover - 6 local soil over 34,2000 ft2 area 31-23-23.17-0020 CY 1,900 $2.48 $4,712 7 Compact graded soil 31-23-23.23-6000 CY 1,900 $0.30 $570 Place local soil as topsoil (6" 8 deep) 31-23-23.17-0020 CY 635 $2.48 $1,575 9 Hydroseed, with mulch & fertilizer 32-92-19.14-5400 MSF 34 $111.65 $3,796 SUBTOTAL $10,643 M=808 industrial Landfill Grade 18" common soil cover - 10 local soil over 21,000 ft2 area 31-23-23.17-0020 CY 1,170 $2.48 $2,902 11 Compact graded soil 31-23-23.23-6000 CY 1,170 $0.30 $351 Haul topsoil to site (50-mile 12 cycle) 31-23-23.20-1714 CY 390 $20.54 $8,011 13 Grade 6" topsoil 31-23-23.17-0170 CY 390 $3.83 $1,494 14 Hydroseed, with mulch & fertilizer 32-92-19.14-5400 MSF 21 $111.04 $2,332 SUBTOTAL $15,090 TOTAL DIRECT COST $26,186 Misc. costs as a percent of total direct cost: " Mob/demob 5 % $1,310 Misc supplies/costs 5 % $1,310 Engineering/permitting 10 % $2,620 UDSHW oversight 10 % $2,620 Contingency 10 % $2,620 TOTAL ESTIMATED CLOSURE COST $36,642 Mil 'Page Assumed that local soil was sufficient as topsoil at M-336. Soil at the remaining locations contains sufficient gravel that it was assumed that it would be necessary to import topsoil for final site closure at those locations. M-136, M-336 and Rocky Point Post-Closure item No. Description Means No./Source Units Est. Quan. Unit Price Total Price days 0.5 $2,468.60 $1,234 1 Maintain caps, signs, etc. Crew B-10B 2 Site inspection 01-31-13.20-0120 weeks 0.2 $2,301.40 $460 3 Inspection report 01-31-13.20-0120 weeks 0.1 $2,301.40 $230 4 UDSHW oversight UDSHW estimate hours 6.0 $103.56 $621 ANNUAL SUBTOTAL $2,545 Misc. Costs as a Percent of the Annual Subtotal: Mobilization/dem obilization 5 % $127 Misc. supplies/costs 5 % $127 Contingency 10 % $254 TOTAL ESTIMATED ANNUAL COST $3,055 Assumed maintenance period: 30 years TOTAL ESTIMATED POST-CLOSURE COST: $91,661 Item No. Discussion/Note 1 Site maintenance is anticipated to require a maximum of 2 days effort every 4 years. This effort was accounted for as 0.5 day per year. 2 This estimate is based on quarterly inspections. The individual units are easily accessible and can be inspected in no more than 0.5 hour per location. Allocating a half day per inspection for this site (2 days for the year) is considered sufficient even under unanticipated, abnormal conditions. 3 A full day is allocated to preparation of the annual report, allowing ample time for interaction with the regulatory agency if required. X11/1Page LANDFILL DISPOSAL OPERATIONS (QUARTERLY) M336/M136/ROCKY POINT AREA INSPECTION (QUARTERLY) DATE TIME OPERATOR PRINT SIGN ITEM ACCEPTABLE BUILDING AREA YES NO A. Fences & Access Controls (Gates, Locks, etc.) El 12 B. Roads HOUSEKEEPING A. Waste Placement 12 0 B. Waste Cover 0 C. Litter Control 0 D. Records (Waste is accurately input and up-to-date) 0 RUN-ON/RUN-OFF (STORMWATER/EROSION) A. No water running on or out of landfill 0 B. No significant erosion problems COMMENTS/CORRECTIVE ACTION: FORM FQA-00235 (REV 10-11) Return to Environmental Services Attachment 4 - Waste Inspection Form LANDFILL VISUAL LOAD RECEIVED INSPECTION Inspection Dates from to (Class IIlb Landfill Permit, April 6, 2011 Minimum inspection frequency of I% of loads received, but no less than one complete inspection per day) MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY LOCATION DESCRIPTION PASS INSPECTION (YES/NO) OPERATOR SIGN INSPECTION DATE MONDAY TUESDAY WEDNESDAY THURSDAY FREW LOCATION DESCRIPTION PASS INSPECTION OPERATOR SIGN INSPECTION DATE SATURDAY SUNDAY LOCATION DESCRIPTION PASS INSPECTION OPERATOR SIGN INSPECTION DATE CORRECTIVE ACTION / COMMENTS Waste load inspections shall be conducted as follows: 1 I Ensure that none of the listed prohibited wastes are present. 1 Hazardous Waste as defined by UAC R315-1 and R315-2 2 PCB's as defined by UAC R315-301-2(53), except PCB's specified by UAC R315-315-7(2)(a) and (c) 3 Household Waste 4 Municipal Waste 5 Special waste except as specified in the Permit 6 Commercial Waste 7 Containers greater than household size (5 gallon) holding any liquid, non-containerized material containing free liquids or waste containing free liquids in containers larger than 5 gallons. 2 The operator shall conduct the random waste inspection at the working face or an area designated by the operator. 3 Loads subjected to complete inspection shall be unloaded at the designated area; 4 Loads shall be spread by equipment or by hand tools; 5 A visual inspection of the waste shall be conducted by personnel trained in hazardous waste recognition and recognition of other unacceptable waste; 6 The inspection shall be recorded on a waste inspection form. The form shall be placed in the operation record at the end of each operating day. 7 if the inspection is unsatisfactory for any of the above listed reasons, mark appropriately and list corrective action/comments in the appropriate block. Notify supervision to help rectify the problem. FORM FOP- 0614