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  • DRAFT

    Hazardous Waste Storage and Treatment Facility Permit

    EPA ID # MND081138604 Facility name: Alliant Techsystems Operations LLC/Proving Ground

    23100 Sugarbush Road NW Saint Francis, Minnesota 55070 Anoka County

    Issuance date: [ ]

    Expiration date: [five years from issuance date] In accordance with the provisions of Minn. Stat. chs. 115 and 116, Minn. R. 7001.0010 to 7001.0730, and Minn. R. 7045.0020 to 7045.1400, a Hazardous Waste Storage and Treatment Facility Permit (Permit) is hereby issued to the Permittee(s) listed on the following page for a facility located at 23100 Sugarbush Road NW in Saint Francis, Minnesota, Anoka County (the Facility). This Permit comprises the Resource Conservation and Recovery Act (RCRA) Permit which has been prepared based upon the information provided by the Co-Permittees most recent Permit Application (Part A and Part B) including revisions received through August 3, 2017. The Permit Application is referenced throughout this Permit and as such, is an integral and enforceable part of this Permit. This Permit shall become effective on the date of issuance by the Minnesota Pollution Control Agency (MPCA) Commissioner or MPCA personnel who have been delegated explicit authority by the Commissioner. The original Permit was issued in February 1987, and reissued in February 1993, April 1998, September 2005, and August 2011. The Co-Permittees must at all times conduct their hazardous waste management activities in accordance with the terms and conditions of this Permit and any other requirements imposed by law or Minnesota Rules. This Permit is effective on the issuance date identified above and supersedes the previous permit that was issued for the Facility. This Permit is effective until five years from date of issuance or until terminated, revoked, or modified by the MPCA, whichever comes first, and it expires at midnight on the expiration date identified above.

    Signature: ( ) This document has been electronically signed. for the Minnesota Pollution Control Agency Ainars Z. Silis Supervisor, Land Permits Unit Land & Air Compliance Section Industrial Division

  • Table of Contents

    Page

    1. List of Permittees ......................................................................................................................................................... 3 2. Facility description ....................................................................................................................................................... 3 3. Description of Regulated/Permitted Units .................................................................................................................. 4 4. Facility layout ............................................................................................................................................................... 7 5. Summary of subject items ........................................................................................................................................... 8 6. Limits and other requirements .................................................................................................................................... 6 7. Submittal/action requirements ................................................................................................................................. 25

  • Permit Issued: [month day, year] EPA ID # MND081138604 Permit Expires: [month day, year] Page 3 of 28

    1. List of Permittees

    Permittee - owner: Orbital ATK Inc 45101 Warp Drive Dulles, Virginia 20166

    Permittee operator: Alliant Techsystems Operations LLC 23100 Sugarbush Road NW Saint Francis, Minnesota 55070

    Orbital ATK Inc is the owner and Alliant Techsystems Operations LLC is the operator; together they are referred to as the Co-Permittees hereafter. The Co-Permittees shall be jointly and severally liable for compliance with the terms and conditions of this Permit. Compliance by one of the Co-Permittees will be considered compliance by the other Co-Permittee to whom the term or condition applies. Other terms and conditions apply to those persons who are included in the term or condition. Should the operator fail to comply with a term or condition of this Permit, the owner shall ensure that compliance is achieved.

    2. Facility description

    The Alliant Techsystems Operations LLC/Proving Ground (Facility) is located at 23100 Sugarbush Road NW in Saint Francis, Minnesota, Anoka County. The Facility is at latitude 45.39607685 N, longitude 93.36534070W, Township 34 North, Range 25 West, and Section 28-33.

    The Co-Permittees began operations at the Facility in 1966 conducting research and development for the assembly and testing of ordnance. The Co-Permittees also conduct demilitarization activities for ordnance/munitions that are identified for disassembly and open burning/open detonation. The Facility is an approximately 4.5 square mile, 3000-plus acre Facility located in St. Francis, Minnesota, a rural community approximately 40 miles northwest of Minneapolis and St. Paul, Minnesota. The Facility lies in the northwest corner of Anoka County.

    Ignitable wastes are generated and stored on site. Waste explosives and munition devices containing explosives are:

    1. Generated on site. 2. Received from off-site Orbital ATK Inc. owned facilities. 3. Received from other ordnance manufacturing facilities and the Department of Defense. 4. Received from governmental agencies (such as law enforcement agencies) on an emergency basis

    for storage and/or treatment.

    The Facility is only permitted to receive waste generated off site that contains the reactive waste code listed as a primary code (D003), or as a secondary code in conjunction with an ignitable/reactive waste classification (D001/D003).

    Hazardous waste storage consist of containerized storage of waste ignitable liquids and sludges, waste ignitable or reactive solids, characteristic and/or listed solid and liquid waste, lab pack waste, scrap x-ray film, universal wastes (such as, lead acid batteries, lithium batteries, and spent fluorescent lamps), open burn treatment residue, bulk explosives, explosive-containing devices, pyrotechnics and pyrotechnic-containing devices, and bulk propellants and propellant-containing devices. Open burn treatment residue, ignitable liquids, lab pack, sludges and other non-reactive wastes are managed at permitted off-site, third-party facilities. Occasionally reactive wastes, including munitions, might be shipped off site for management by third party facilities.

  • Permit Issued: [month day, year] EPA ID # MND081138604 Permit Expires: [month day, year] Page 4 of 28

    Hazardous waste treatment operations consist of open burning and open detonation (OB/OD) of explosives, propellants, and pyrotechnics, and munitions containing these materials. Hazardous waste treatment also includes demilitarization activities of intact or off-spec munitions. Hazardous waste is generated on-site and received from off-site restricted generator groups; hence the Facility is considered an off-site Facility. This Permit authorizes and requires the Co-Permittees to conduct the following hazardous waste management activities: Operating status Operate an outdoor storage container unit. Operate indoor storage container units. Operate miscellaneous treatment units. Operate open burn and detonation units. Perform corrective action at SWMU 7 area.

    3. Description of Regulated/Permitted Units NonExplosive Waste Storage Building (T & S 3). The building is constructed of metal with a concrete floor. The maximum storage capacity is 80 55-gallon drums of solid hazardous wastes and 20 55-gallon drums of liquid hazardous waste. These wastes consist of open burn treatment residues, characteristic and/or listed solid and liquid waste, lab pack waste, polychlorinated biphenyls (PCB) light ballasts, PCB-contaminated equipment, scrap x-ray film, spent photo chemicals and scrap electronic material. Universal wastes, such as fluorescent light bulbs and lead-acid batteries, and recyclable hazardous wastes such as used oil, used oil sludges, and used oil absorbents, are stored in this building. Secondary containment for the liquid waste is provided by use of a 3.5-inch recess in the epoxy coated concrete floor with a compatible polyurethane sealant. Seven hundred sixty-three (763) gallons of secondary containment is provided in accordance with Minn. R. 7045.0526, subp. 6. Hazardous wastes are stored with compatible recyclable hazardous waste as well as products, such as fuel oil and epoxy resin. Solid and liquid hazardous wastes are stored in 55-gallon or smaller drums. The building is surrounded by a seven (7) foot high security fence topped with barbed wire. Ignitable Storage Building (T&S 4). The Ignitable Storage Building is located near the receiving area and is constructed of a metal ceiling and walls with a concrete floor. The building is constructed to be explosion-proof in accordance with the National Fire Protection Association (NFPA). This building stores hazardous waste solvents in 55-gallon or smaller drums. Miscellaneous hazardous waste such as aerosol cans and other lab pack waste are stored in containers and in flammable safety cabinets in the front unheated half of this building. The rear half of the building, which is heated, is used to store products and spill cleanup supplies. The building has a maximum permitted storage capacity of ten (10) 55-gallon drums. Secondary containment for the liquid waste is currently provided by three spill control pallets/containment bins, each of which can hold up to four (4) 55-gallon drums, with each providing approximately 8