DSHW-1995-004126 - 0901a06880156462

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15 February 1995
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Dennis R. Downs, Executive Secretary
State of Utah
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
P. 0. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs
Subject: Thiokol Corporation, EPA #UTD00981357, RD&D Permit-
Solid Rocket Motor Disposal Facility, Request for
Class II Modification and Temporary Authorization
Pursuant to 40CFR 270.42(b), Thiokol Corporation is requesting
a Class II modification to our RD&D Permit to allow the
storage of hazardous waste in process for longer than 96 Hours
as stated in our current permit dated June 16, 1994. This
permit condition would add unnecessary exposure and increase
hazardous waste produced. An explanation of why this change
is needed and proposed wording changes are found in attachment
I.
Thiokol Corporation requests Temporary authorization to
proceed with washout operations under new storage requirements
stated in attachment I for the class II permit modification.
This authorization is permitted under 40 CFR 270.42(e) and is
requested to eliminate unnecessary operations with hazardous
materials in this facility during the public comment period
and review process. Justification for this recpaest can be
found in attachment II included with this letter.
If you have any questions or need clarification on any points,
please contact 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.
P.O. Box 689, Bngham City, UT 84302-0689 180V 863-3511
*<
D. R. Downs
15 February 1995
Page 2
"I certify under penalty of law that this document and
all attachments were prepared under my direction or
supervision in accordance with a system design to assure
that qualified personnel properly gather and valuate the
information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons
directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that
there are significant penalties for submitting false
information, including the possibility of fines and
imprisonment for knowing violations."
Sincerely,
^ J. D. Thompson, Director
Safety, Environmental, and Support
JCT/KGC/jct
Attachments: Attachment I, Attachment II
Thiokol Corporation
9 Febraary 1995
ATTACHMENT II
Temporary Authorization
This justification is to meet the requirements under 40CFR 270.42(e)(3)(ii)(E)
Attachment 1 defines the modification to the RD&D permit. This attachment is to meet the
requirements of 40 CFR 270.42(e)(3)(ii)(E) for a Temporary Authorization. The class II
modification is to request a change to the permit condition for the storage of hazardous materials.
This permit condition currently limits storage of hazardous waste at the T-93 facility to 96 hour.
The Temporary Authorization is requested to allow storage ofthis material for the time specified
in Thiokol's class II modification submittal.
One ofthe goals ofthe program is to be able to remove the material from the motor in large
batches which will reduce the handling and set up operations. This process rate may be
achievable by the end ofthe program, but at the start ofthis project will be very time consuming
to assure that everything is working properly. When this operation was being plaimed, the
specialists knew that the startup process would need to proceed slowly. There may have been
some confiision on the time removal goal for the cutting rate and the need to assure proper
cutting ofthe material, and when the 96 hour time limit started. Ifthe 96 hour limit stays in
effect, it will limit the process to small batches of material. The smaller batches means added
employee exposure due to the set up and handling operations with hazardous materials.
The SMRD process starts with the removal of propellant from a rocket motor using high pressure
liquid nitrogen and deposits propellant into the hydrolysis tank. This process requires
numerous shut downs in order to fine tune the equipment and verify removal parameters. Each
shutdovm requires several time consuming adjustments and safety checks before operations
resume. It is very important to start up the process very cautiously to monitor how equipment is
fimctioning and how the material is being removed. This technique has not been attempted in
industry, and even though there has been considerable engineering efforts on this project, the
RD&D work is needed to verify the planned process. This cautious startup will very likely result
in a small amount of material in the hydrolysis container with the 96 hour time limit.
The process is coordinated by a small staff of specialists who will be working one shift only and
are not available to work around the clock to expedite the removal process. Operator fatigue is a
significant hazard when dealing with sensitive reactive materials. Extended operating hours
would add stress and fatigue to the specialists which is not a work environment conducive to a
critical research and development project. Employee exposure will be proportionally increased
based on the number of batches processed. Sound safety practices dictate reducing exposure
Thiokol Corporation
9 Febraary 1995
whenever possible. An outline of our concems are listed below for your review:
1. Without frequent stops to check on the progress ofthe operation, an unsafe
condition may go undetected such as leaking pressure lines, the lance moving into
contact with the propellant, out of place propellant, unobserved fissures in the
propellant surface which could lead to large pieces of propellant in the THC or a
case wall that is mistakenly cut through
2. Equipment malfunctions not detected early, could create a hazardous situation
3. Each time the batch tank is moved for hydrolysis, employees must disconnect
lines and clean propellant contaminated equipment. Each cleanup operation
creates reactive hazardous waste in the form of rags, gloves, coveralls and a
disposable transition cloth which is used between the THC and the wash out
chamber. At the end of each batch the operator would have to undo this
contaminated item and then send it for hazardous waste disposal by open buming.
4. These cleanup procedures expose workers to reactive wastes
In the design ofthis removal procedure, worker safety has been analyzed and ranked as a number
one priority. Thiokol safety policy, as well as industry procedures, require that all unnecessary
exposure to workers be analyzed and minimized whenever possible. The 96 hour requirement
will urmecessarily increase employee exposure to these hazards.
The recommendation from the technical staff is to allow the material to accumulate in the tank
for a longer period of time. The amount of material in the tank will not be greater than that
authorized by the permit. This change will also allow the operators the opportunity to perform
the removal process with fewer moves ofthe transportation tank. Each move of hazardous
materials is a concem and should be eliminated if possible.
This Temporary Authorization is requested to reduce operator exposure and minimize hazardous
waste generated which creates an additional load on the environment.
Thiokol Corporation
9Febraury 1995
ATTACHMENT I
Class II Modification for RD&D PERMIT
This modification is requested to allow more time to process the reactive rocket
motor propellant in a safer and more cautious manner. This modification is
requested under an allowance in 40GFR 270.42(b).
(l)(i) IV.A!2 change 96 hours to read 7 days and 21 days as shown on attached permit page
dated Feb 9, 1995
IV.C. 1 change 96 hours to read 7 days as shown on attached permit page dated Feb 9,
1995
V.C.I change 96 hours to read 7days as shown on attached permit page dated Feb 9,
1995
Add table 03.03B dated Feb 9, 1995 to permit application
Add revised inspection form dated Feb 9,1995 to permit application
(ii) This is a class II modification
(iii) This modification is needed to eliminate unnecessary operations with hazardous
materials and consequent exposure to hazardous materials, (see attachment II for a more
detailed explanation)
(iv) Information required under 270.13 through 270.21, 270.62, and 270.63 was provided in
the original application and associated documents.
(2)(i)-(vi) Public notice will be sent within 7 days ofthis submittal, including all required
information
(3)-(5) The permit modification will be posted for public observation along with a public
meeting and a 60 day comment period
Thiokol Corporation
RD&D Permit
9 Febmary 1995
MODULE IV - STORAGE AND TREATMENT IN TANKS
IV.A. APPLICABILrrV
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.
rV.A.2. Hazardous wastes may be stored in the tanks listed in condition IV.B. for a
maximum period not 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.
IV.B. WASTE IDENTIFICATION AND TANK USAGE
IV.B.l. The Permittee shall only store and ti-eat 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. Hvdrolvzed 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 Febiuary 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.8. 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 conti-ols 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
hazardous Waste Permit Application
Thiokol Corporation
EPA I.D.# UTD009081357
9 February 1995
EQUIPMENT
Security Equipment
Fences
Signs
Gates
Lock
Area
Roadway
Loading/
TABLE 03.03B
INSPECTION SCHEDULE FORT-93/T-94
(To be done only when in use)
MINIMUM
FREQUENCY AREAS QF CONCERN
Areas
Periphery
3. Safety Equipment
First Aid Kit
Weekly Visually inspect all fence lines and look for
broken or downed fence lines, loose wires
Weekly Readable signs, signs in place
Weekly Able to properiy close gate, safety
Weekly In working order, able to lock
Daily Inspect road for spills, soil discoloration
Daily Inspect loading areas for spills, Unloading
soil discoloration
Daily 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)
hazardous Wasta Pennit Application
Thiokol Corporation
EPA I.D.# UTD0090813S7
9 February 1995
TABLE 03.03B (Continued)
INSPECTION SCHEDULE FOR DRUM STORAGE PAD ATT-93/T-94
(To be done only when in use)
EQUIPMENT
Telephone
Storage Containment
Motors
Drainage Area
Building
Roof
Hydrolysis Tank
MINIMUM
FREQUENCY AREAS QF CONCERN
Monthly
Weekly
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:\BLDaiNSP.KGC