DSHW-2018-004891 - 0901a06880832fa6

cf Wast:: Management and Radiation Control
MAY 3 J an8
Dskw-2018-00491 ENV HONMENTAL SERVICE7
May 30", 2018
Mr. Jon Parry,
Utah Department of Environmental Quality
Director-Division of Waste Management and Radiation
P.O. Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Parry,
University of Utah, located in Salt Lake City, Utah 84113, EPA # UTD094674595, a large quantity
generator, is requesting a temporary emergency license for onsite treatment of 15 potentially
unstable, hazardous waste containers of the following material: Picric Acid (1x4oz, 1x500m1, 1x4L,
lx10oz), Parlodion (1x10oz), 2,4,6 Trinitrobenzenesulfonic Acid (1x100g), 2,4 Dinitrophenylhydrazine
(1x10g), Diisopropyl Azodicarboxylate (2x100m1), Tetrahydrofuran (1x500ml, lx100ml), Ethyl Ether
(1x500m1), Sodium Azide (2x500g, lx5g).
The Reactive Materials Division of Clean Harbors Environmental Services has been contacted to treat
the potentially unstable compounds University of Utah. The material in question has been deemed
unstable for transport and disposal and will require treatment prior to shipment.
The process will require two Reactive Materials Field Technicians from Clean Harbors to perform the
following steps:
1. Don personal protective equipment in the event of detonation or deflagration.
2. Enter into the building containing the material carrying a class C explosives magazine Blasters Day
Box. The Blasters Day Box is used to safely carry the potentially explosive material to the remote
opening location and the Portable Remote Unit.
3. The chemicals will then be safely removed from the building and brought to the site of
stabilization and remotely opened with the Portable Remote Opener. The Portable Remote
Opener is a Clean Harbors engineered piece of equipment that has been designed to safely open
potentially explosive chemicals in remote locations where other Clean Harbors standardize
equipment cannot be used. The Portable Unit will be encased with a Kevlar bomb blankets
during the remote opening process.
4. Once the materials have been remotely opened with the Portable Unit they will then be
stabilized, using Clean Harbors Standard Operating Procedure, for future safe transportation and
disposal at a Clean Harbors Incinerator.
The project is estimated to be completed in —1- day and will be performed upon your approval. This
project will be scheduled upon approval. Once approved please send all or any accompanying permit
documentation to:
University of Utah
125 South Fort Douglas Blvd
Salt Lake City, UT 84113
Attn: Mr. Greg Walters
Phone: [phone]
If you have any questions or need additional information, please contact me at [phone]
Sincerely,
6Vf00-,•'"
Jason J. Widdows
Clean Harbors Environmental Services
Reactive Materials Services
WORK PLAN
FOR
CHEMICAL STABILIZATION OF
POTENTIALLY UNSTABLE MATERIAL
AT
THEU
UNIVERSITY
OF UTAH
THE UNIVERSITY OF UTAH
125 SOUTH FORT DOUGLAS BOULEVARD
SALT LAKE CITY, UT 84113
EPA ID # UTD094674595
A LARGE QUANTITY GENERATOR
PREPARED BY:
eanHarba
ENVIRONMENTAL SERVICES*
CLEAN HARBORS ENVIRONMENTAL SERVICES
500 Independence Parkway South
La Porte, TX 77571
By: Jason J. Widdows
Operations Manager, Reactive Material Services
laHarbor WHE UNIVERSITY r UTAH
ENVIRONMENTAL SERVICES.
WORK PLAN
THE UNIVERSITY OF UTAH
TABLE OF CONTENTS
1. INTRODUCTION
2. SCOPE OF WORK/SITE SET-UP
3. CONTAINER HANDLING STRATEGY
4. DISPOSAL OF STABILIZED MATERIALS
5. CONTINGENCY PLAN
6. COMPLIANCE AGREEMENT
7. SITE MAP
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WORK PLAN
THE UNIVERSITY OF UTAH
1.0 INTRODUCTION
Clean Harbors Environmental Services (CHES) has prepared this Work Plan to govern its
operations stabilizing forty five (15) potentially unstable containers at the University of Utah.
The University of Utah has the following material requiring stabilization prior to shipment:
Ethyl Ether 1 Peroxide Former lx500m1
Tetrahydrofuran 2 Peroxide Former 1x500m1,
lx100m1
Diisopropyl
Azodicarboxylate
2 Shock-Sensitive 2x100m1
Parlodion Shock-Sensitive 1 xl0oz
2,4,6
Trinitrobenzenesulfonic
Acid
1 Shock-Sensitive lx100g
2,4 Dinitrophenylhydrazine 1 Shock-Sensitive 1 xl0g
Sodium Azide 3 Shock-Sensitive 2x500g, lx5g
Picric Acid 4 Shock-Sensitive lx4oz, 1x500m1,
1x4L, lx10oz
This material will need to be remotely opened and then stabilized prior to disposal by Clean
Harbors Environmental Services.
The Salt Lake City Fire Department will be made known of the presence of these materials and
will have final approval for all work to be performed.
LOCATION
Mailing Address: Physical Location:
The University of Utah The University of Utah
125 S Ft Douglas Blvd 2205 Red Butte Road
Salt Lake City, UT 84113 Salt Lake City, UT 84113
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11,71-1E UNIVERSITY wwj, of UTAI I
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Contact: Mr. Greg Walters
Phone: [phone]
Email: gregory.waltersAoehs.utah.edu
DATE/TIME OF STABILIZATION: Friday, June 8.
TBD; upon plan approval from the Utah Department of Environmental Quality.
The project is estimated to be completed in 3-5 hours, and will be performed upon your
approval.
2.0 SCOPE OF WORK/SITE SET-UP
Clean Harbors will arrive on site the scheduled project day in order to set up the Exclusion
Zone. Caution tape shall be set up around the Exclusion Zone in order to keep unauthorized
individuals away. No personnel will be allowed in the Exclusion Zone during the operation
except for the two Reactive Materials Technicians, The Exclusion Zone will have a —50ft.
radius in all directions. The following personnel will be on site and their roles are described:
Two Reactive Materials Technicians: Solely responsible for the movement of containers from
the storage area to the outside Exclusion Zone in order to remotely open and stabilize the
materials. These are the only individuals allowed to handle the unstable material.
The University of Utah: Health & Safety personnel to provide site security and traffic control.
Salt Lake City Fire Department will be notified and ready if assistance is needed.
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3.0 CONTAINER HANDLING STRATEGY
PEROXIDE FORMING / POLYMERIZABLE LIQUID HANDLING
A. Peroxide Forming Liquids, Stabilization of lab pack quantities.
Condition of Material/Scenario:
Peroxide formation may be present anywhere in the container, including the side of the
container, the bottom of the container, the threaded cap, or even outside the container. Peroxide
formation in ppm concentrations may not be visually observable and must be identified through
appropriate testing procedures. If any of the following conditions exist the compound may be
explosively unstable and will require stabilization prior to transportation.
A. Material appears to be degraded/contaminated.
B. Material appears to be discolored.
C. Deterioration or distortion of storage container.
D. Gross contamination.
E. Thermal shock. (Sunlight)
F. Oxidation on exterior of container.
G. Age of material exceeds recommended storage time.
Hazard Ana sis:
CHEMICAL Peroxide Hazard SOLVENT USED
Ethyl Ether Peroxide Former FAS / HQ
Tetrahydrofuran Peroxide Former FAS / HQ
Peroxides are less volatile than solvent and tend to concentrate in solution or in the container
threads. Experiments have determined that a percentage of 0.008% (80ppm) or more is enough
to initiate explosive decomposition. Peroxides are sensitive to heat, friction and shock. Some
peroxides may explode without being concentrated. (Example: Isopropyl Ether)
Safe Distances:
If Material is improperly handled there is a potential for a reaction, which include fire and/or
deflagration. Remote opening of lab pack quantities require —50 ft. safe distance.
Basic Equipment Overview:
A. Day box.
B. Portable Remote Opener with Kevlar Safety Circle.
C. Stabilization Kit.
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D. Fire extinguisher (ABC)
E. Eyewash/First-aid kit
F. Stabilization jars.
G. Hydroquinone.
H. Ferrous Ammonium Sulfate.
I. Peroxide test strips
Scope of Work:
Removal of the peroxide forming liquid to the Exclusion Zone. Work signs and danger tape will
delineate this area. All work on peroxidizable compounds will be performed in this area.
ABSOLUTELY NO IJNAUTHORIZED ENTRY into the Exclusion Zone.
A. To move and open peroxidizable material:
1. Secure work area and transportation route.
2. Ground Portable Remote Opener.
3. Check Fire Extinguisher.
4. Remove chemical from storage area.
5. Secure chemical in day box and transport to remote opener in closed day box.
6. Secure wrist-grounding strap to technician prior to removing chemical from day box.
7. Secure chemical in remote opener.
8. Open container in remote opener.
B. Peroxide destruction procedure:
1. Ensure the peroxide test strips have not exceeded their expiration date. Test liquid by
submersing peroxide strip into peroxide forming material.
2. Submerse strip into Deionized water, wait 5 seconds and record results.
3. If no peroxides are detected, add 100m1 of 10% Hydroquinone solution per 1 liter of
peroxide forming liquid to inhibit any future peroxide formation.
4. If any peroxides are present, destroy them by adding 30% Ferrous Ammonium Sulfate
solution per 1 liter of peroxide forming liquid. Be cautious, since reaction may be vigorous
if high peroxide concentrations are present. At first gently, then subsequently vigorously,
stir mixture with a plastic or glass stirring rod. Retest liquid with peroxide test strip. If still
present, repeat stabilization process. When no peroxides are detected, add 100m1 of 10%
Hydroquinone solution per 1 liter of peroxide forming liquid to inhibit any future peroxide
formation.
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SHOCK SENSITIVE MATERIALS HANDLING
A. Shock Sensitive Compounds, stabilization of lab pack quantities.
Condition of Material/Scenario:
El A. Flammable solids, which are shock sensitive when, dry.
These compounds have low to moderate sensitivity.
1. Picric Acid.
2. Dinitrophenol.
3. Trinitrobenzene.
4. Trinitrotoluene.
5. Picrite.
E2 B. Flammable solids, which are shock sensitive when, dry. These compounds have a
moderate to high sensitivity.
1. Cyclonite.
2. PETN.
3. Nitroglycerine.
4. Nitrosoguandine.
5. Tetryl.
E3 C. Contaminated El, E2 materials and DOT forbidden materials. (Highly Shock
Sensitive)
1. Mercury Fulminate.
2. Lead Azide.
3. Lead Trinitroresorcinate.
4. Diazodinitrophenol.
5. Tetrazene.
Hazard Analysis:
CHEMICAL SHOCK SENSITIVE SOLVENT USED
Diisopropyl Azodicarboxylate Shock-Sensitive Acetone
Parlodion Shock-Sensitive Alcohol
2,4,6 Trinitrobenzenesulfonic
Acid
Shock-Sensitive DI Water
2,4 Dinitrophenylhydrazine Shock-Sensitive DI Water / Alcohol
Sodium Azide Shock-Sensitive Physical Evaluation
Picric Acid Shock-Sensitive DI Water / Alcohol
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A. Material may be shock sensitive. Any external energy input may cause high or low order
detonation if any of the following conditions exist.
1. Material appears to be degraded/contaminated.
2. Deterioration or distortion of storage container.
3. Material appears to be discolored.
4. Thermal shock.
5. Mechanical shock.
6. Friction.
Safe Distances:
If material is improperly handled there is a potential for a reaction, which include fire and/or
high/low order detonation. Remote opening of lab pack quantities require —50 ft. safe distance.
Basic Equipment Overview:
A. Day box.
B. Portable Remote Opener with Kevlar Safety Circle
C. Stabilization kit.
D. Fire extinguisher (ABC)/eyewash/First-Aid kit
E. Stabilization jars.
F. Deionized water.
G. Solvents (Alcohol, Acetone)
Scope of Work:
Removal of the El to the Exclusion zone. Work signs and danger tape will delineate this area.
All work on the chemicals will be performed in this area. ABSOLUTELY NO
UNAUTHORIZED ENTRY into the exclusion zone.
A. To move and open shock sensitive material:
1. Secure work area and transportation route.
2. Ground Portable Remote Opener.
3. Check Fire Extinguisher.
4. Remove chemical from storage area.
5. Secure chemical in day box and transport to remote opener in closed day box.
6. Secure wrist-grounding strap to technician prior to removing chemical from day box.
7. Secure chemical in remote opener.
8. Open container in remote opener.
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4.0 DISPOSAL OF STABILIZED MATERIALS
Once the containers have been remotely opened and stabilized they will be set aside for
packaging during the next scheduled lab pack. They will then be transported to a Clean Harbors
a Clean Harbors approved incinerator. (Aragonite)
5.0 CONTINGENCY PLAN
In the event of fire or explosion, the area shall be evacuated and the Salt Lake Fire Department
will be notified. Clean Harbors personnel will not be involved in fire fighting. Incipient fires
can be fought using a portable fire extinguisher. Clean Harbors employees are first aid certified
in the event an individual is injured. Below are emergency numbers that can be called. Clean
Harbors personnel will not be involved in any contingency plan responses under this plan.
EMERGENCY NUMBERS
Salt Lake Fire Department 9-1-1 or 1-801-483-6043
Ambulance Service 9-1-1
University of Utah Hospital 1-801-581-2121
50 N. Medical Drive
Salt Lake City, UT
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6.0 COMPLIANCE AGREEMENT:
All on-site personnel, (i.e., CHE employees and subcontractors), must complete and sign this
section prior to the commencement of site activities for the University of Utah project.
I have read and understand the contents of this High Hazard Work Plan, and have had all
relevant questions answered to my satisfaction. In addition, I agree to comply with the
conditions/provisions outlined therein:
NAME COMPANY/
(Print) SIGNATURE CHE BRANCH DATE
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7.0 SITE LOCATION
Location
All the material in question is currently stored in the University of Utah Regulated Waste
Management Facility (RWMF) Building 590 hazardous waste storage area. The material will be
removed from the storage area and placed in a Class C Magazine Blasters Daybox. The chemicals
will then be carried outside the building to a parking lot area where the stabilizations will take place.
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