DSHW-1995-002488 - 0901a0688013ac71

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8 February 1995 /r-i "^/dvicl^
V000:FY95:083
Dennis R. Downs, Executive Secretary
State of Utah
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs:
SUBJECT: Thiokol Corporation, EPA #UTD009081357, RD&D Permit
Solid Rocket Motor Disposal Facility, Request For a
Class II Modification and Temporary Authorization
A condition was discovered in our permit dated 16 June 1994,
which will require a Class II modification to correct. Sections
IV.C.l, IV.A.2, and V.C.I state that wastes may be stored in the
tanks for 96 hours only. The nature of these RD&D procedures are
not compatible with this permit condition. Most of the
processes can be completed within 7 days. However, the
propellant removal process could take up to 3 weeks to complete.
As you are aware, with any construction/research and development
project, delays in completion are not uncommon. Delays in this
project and permit problems have hindered processinq and proper
treatment of these waste rocket motors. Typical with any
hazardous waste, the sooner the waste can be neutralized,
treated or otherwise rendered non-hazardous, the safer it is for
those individuals responsible for proper storaqe and manaqement
of the hazardous material.
Thiokol Corporation requests a Class II modification and a 180
day Temporary Authorization to proceed with processinq rocket
motors under compliance with all current permit conditions
except for the storaqe limitation of 96 hours. Storaqe
limitations for this authorization would be those delineated in
our Class II modification submitted with this request.
These chanqes are listed below by paqe number and are dated 9
February 1995:
Module IV-1
IV.A. 2 - 96 hours removed, 7 days and 21 days added
IV.C.l - 96 hours removed, 7 days added
P.O. Box 689, Brigham City. UT 84302-0689 [phone]
D. R. Downs
8 February 1995
Paqe 2
Module V-Paqe 2
V.C.I - 96 hours removed, 7 days added
Section 3 (application)
Table 03.03B - New two paqe table added
T-93/T94 Inspection Form - Form modified to include
all items found on Table 03.03B
I have enclosed a check for $1,000 as required for processing
this pennit modification.
If you have any questions or need clarification on any points,
please call Gene Curtis at 863-4479. We look forward to a
timely response on this issue and appreciate the help and
professional attitude your staff has demonstrated in the past.
"I certify under penalty of law that this document and
all attachments were prepared under my direction or
supervision in accordance with a system desiqned to
assure that qualified personnel properly gather and
evaluate the information submitted. Based on my
inquiry of the person or persons who manaqe the
system, or those persons directly responsible for
qatherinq the information, the information submitted
is, to the best of my knowledqe and belief, true,
accurate, and complete. I am aware that there are
significant penalties for submitting false
information, including the possibility of fine and
imprisonment for knowing violations."
sincerely.
Mft^^^^^^^t^-^
J. D. Thompson, Director
Safety, Environmental, and Support
JDT/KGC/jcp
Attachment: a/s
Thiolcol Corporation
RD&D Permit
9 February 1995
MODULE IV - STORAGE AND TREATMENT IN TANKS
IV.A. APPLICABILITY
IV. A. 1. The requirements of this Module pertain to the storage and treatment of hazardous
waste in the tank systems identified in condition IV.B. The Permittee shall
comply with R315-8-10 (40 CFR 264-190 - 264.199 incorporated by reference)
and all other conditions of this permit for tank systems.
IV.A.2. Hazardous wastes may be stored in the tanks listed in condition IV.B. for a
maximum period hot to exceed 7 days with the following exceptions: propellant
chips may be stored in the hydrolysis tank during removal operations for up to
21 days; once hydrolysis begins, an additional 7 days of storage is permitted.
rV.B. WASTE IDENTIFICATION AND TANK USAGE
IV.B.l. The Permittee shall only store and treat the residues from five (5) Class 1.1
propellant solid rocket motors in the tanks identified in this Module. Only the
following tanks may be used to store and treat those wastes:
IV.B.2. Hydrolysis Tank less than 2,000 gallon capacity, 7'-0" diameter x 7'-6" high,
stainless steel.
IV.B.3. Hydrolvzed Propellant Storage Tank 600 gallon capacity, 1 each, 5'-2 1/2" ID
X 5'-0" high fiberglass reinforced polyethylene-lined modified to limit capacity
to 600 gal.
IV.B.4. Mix Tank 300 gallon capacity, 4'-8" ID x 5'-0" high fiberglass reinforced
modified to limit capacity to 300 gal.
IV.B.5. Oxidation Reactor less than 5 gallon capacity, 3.2" ID, 5.6" OD x 6'-0" long,
lined titanium.
IV.B.6. Effluent Storage Tank 600 gallon capacity, 4'-8" ID x 5'-0" high fiberglass
reinforced polyethylene-lined.
IV.C. GENERAL OPERATING REOUIREMENTS
IV.C.l All sludges and liquids shall be removed from the treatment tanks and ancillary
systems at the end of each operating batch. Batch operations shall not exceed 7
days except as noted in IV.A.2.
Module IV - 1
Thiolcol Corporation
RD&D Permit
9 February 1995
V.A.7. Pressure Letdown System The pressure letdown system is responsible for
reducing the pressure of the cooled reactor effluent stream from its operating
pressure to near ambient pressure.
V.A.S. Effluent Storage System The effluent storage system separates the solid, liquid,
and gaseous products generated during the HTO process. All phases initially enter
a single effluent storage tank. Gases generated during HTO are vented to the
atmosphere. Solids are either collected in a filter bag situated at the top of the
tank or are allowed to collect in the tank with the liquid fraction.
V.B. ALLOWABLE WASTE FEED
V.B.I. The Permittee may only feed the Class 1.1. propellant residues and those
combinations of chemical additives that are necessary to safely treat the hazardous
waste constituents of the solid rocket motors. Inert materials may be tested in the
systems to verify the process controls and operating procedures.
V.B.2. Only the residues generated by propellant removal system from the five (5) solid
rocket motors manifested as hazardous wastes for this project shall be treated in
this equipment.
V.B.3. The amount of Class 1.1 propellant treated in the oxidation reactor shall not
exceed 500 pounds per batch.
V.C. OPERATING REOUIREMENTS
V.C.I. All sludges and liquids shall be removed from the treatment units and ancillary
systems at the end of each operating batch. Batch operations shall not exceed 7
days except as noted in IV.A.2.
V.C.2, The Permittee shall use the controls and operating practices to prevent spills and
overflows from each process unit, as specified in Attachment 1. The Permittee
shall test all these controls and operating procedures before hazardous wastes are
placed into the tank systems.
V.C.3. In the event of an equipment or power failure, the Permittee shall not add wastes
or chemicals and shall cease operating the affected tank system.
V.C.4. The Permittee shall comply with the requirements specified in R315-8-6.12 when
there has been a leak or spill in a treatment unit or the system is unfit for use.
Module V - Page 2
bazardous Waste Pennit Application
Thiokol Corporation
EPA I.D.#UTD009081357
9 February 1995
TABLE 03.03B
INSPECTION SCHEDULE FOR 1-93/7-94
(To be done only when in use)
MINIMUM
EQUIPMENT
Security Equipment
Fences
Signs
Gates
Lock
Area
FREQUENCY
Weekly
Weekly
Weekly
Weekly In v
Roadway Daily
Visually inspect all fence lines and look for
broken or downed fence lines, loose wires
Readable signs, signs in place
Able to properly close gate, safety
In working order, able to lock
Inspect road for spills, soil discoloration
Loading/
Areas
Periphery
3. Safety Equipment
First Aid Kit
Daiiy Inspect loading areas for spills, Unloading
soil discoloration
Daiiy Inspect grounds for any spills, soil discoloration or
Stressed vegetation
Monthly Kit complete and in place (all Thiokol employees
have access to the Dispensary on plant)
bazardous Waste Permit Application
Thiokol Corporation
EPA I.D.# UTD0090813S7
9 February 1995
TABLE 03.03B (Continued)
INSPECTION SCHEDULE FOR DRUM STORAGE PAD AT T-93n"-94
(To be done only when in use)
EQUIPMENT
Telephone
MINIMUM
FREQUENCY AREAS OF CONCERN
Monthly
Storage Containment
Motors Weekly
Drainage Area
Building
Roof
Hydrolysis Tank
Weekly/
Storms
Weekly
Weekly
Daily
Emergency Equipment
Fire
Extinguisher
Monthly
Working condition; place call to verify
operation
Verify condition of motors, properly marked
and labeled, out of place material
Spills, discolored soil
Verify no damage done to exterior of facility
General condition including holes or defects
Signs of corrosion or release of waste, proper
design operation
In working order and full
Building Inspection
Building T-93 / T-94
Bldg.-General
Steam Valves
and Piping
Plumbing
Electrical
Spills/Leaks
Grounding
Locks on Doors
Telephone
Signs
Motors
Foundation
Settling
Cracking
Roof
Walls-Interior
Paint
Doors & Partitions
Gates & Lock
Works Properly
if Sat. 1 Remarks
Walls-Exterior
Doors and Seals
Floors
Concrete
Coverings
Bldg. Periphery
Erosion
Drainage Area
Vegetation Control
Fences
Roadway
Loading/Unloading
Spill Equipment
Contingency Plan
Fire Extinguisher
Protective Clothing
Fire Aid Kit
Tanks
Spills/Leaks
Hydrolysis Tank
Spills/Leaks
Problems / Corrective Actions
Note: Sat. = Satisfactory
Signature: Date: Time:
REV 9 February 1995 FILE: B:\BLDGINSP.KGC