DSHW-1995-004352 - 0901a06880157fd1

Michael O. Leavitt
Governor U S Dianne R. Nielson, Ph.D.
Executive Director
Dennis R. Downs
Director
:'^±. btate of Utah
^L.
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF SOLID AND HAZARDOUS WASTE
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
[phone]
[phone] Fax
[phone] T.D.D.
February 16, 1995
Mr. Joe D. Thompson, Director
Waste Management and Environmental Services
Thiokol Corporation
P.O. Box 689
Brigham City, UT 84302-0689
Re: Solid Rocket Motor Disposal Facility
Class 1 Pennit Modification 95-00620
Dear Mr. Thompson:
The Division received a Class 1 modification request on February 9, 1995, regarding the Solid
Rocket Motor Disposal Facility. This modification addressed changes that occurred as the facility
was constructed and incorporated the as-built drawings into the pemiit. Many of the changes in
this submittal were associated with comments that the Division provided to Thiokol on January
24, 1995, following a construction inspection.
The Division hereby grants approval, of Permit Modification 95-00620. Enclosed are copies of
the pages affected by this modification. Please exchange these pages with those currently in the
permit.
If you have any questions regarding this letter, please contact Otis Willoughby at 801-538-6170.
Sincerely,
vvM^-^^^^^ )ennis R. Downs
Executive Secretary
Utah Solid and Hazardous Waste Control Board
DRD\OHW\ow
c: John C. Bailey, M.D., M.S.P.H., Health Officer/Department Director,
Bear River District Health Department
Kathy Barker, DSHW
PniueU on recycled pajier
Thiokol Corporation
RD&D Permit
16 Febmary 1995
MODULE IV - STORAGE AND TREATMENT EV TANKS
rV.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.
I V.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.
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. Hydrolyzed 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 I V.A. 2.
Module IV - 1
Thiokol Corporation
RD&D Permit
16 February 1995
IV.C.2 The Permittee shall use the controls and operating practices to prevent spills and
overflows from each tank system, as specified in Attachment 2. The Permittee
shall test all these controls and operating procedures before hazardous wastes are
placed into the tank systems. These checks, with results, shall be documented in
the operating record.
IV.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.
IV.C.4. The Permittee shall cohiply with the requirements specified in R315-8-10 (40
CFR 264-190 - 264.199 incorporated by reference) when there has been a leak
or spill from a tank or the tank system is unfit for use.
IV.C.5. The Permittee shall comply with the immediate responses specified in the facility
Contingency Plan, when there has been a release from a tank system that
threatens human health or the environment.
IV.C.6. The Permittee shall notify the Executive Secretary as soon as possible, but no
later than 24 hours of detection of a release from a tank system to the
environment.
IV.C.7. The Permittee shall submit, to the Executive Secretary within 15 days of detection
of a release to the environment, a report identifying details of the release, as
specified in R315-8-10 (40 CFR 264-190 - 164.199 incorporated by reference).
IV.C.8. The Permittee shall repair a tank system from which there has been a leak or spill
or close the tank, if it is unfit for use, as specified in R315-8-10 (40 CFR 264-
190 - 264.199 incorporated by reference).
I V.C. 9. Before a repaired tank system is retumed to service, it must be certified by a
quaiified, independent professional engineer, that the repaired equipment is
capable of handling hazardous waste without release for the intended life of the
system. The Permittee shall submit the tank certification report to the Executive
Secretary within seven (7) days of retuming the repaired tank system to service.
IV.C. 10. The Permittee shall provide secondary containment for all tank systems in
accordance with R315-8-10 (40 CFR 264-190 - 264.199 incorporated by
reference).
IV.C. 11. The Permittee shall remove spilled or leaked waste and accumulated precipitation
from the secondary containment when it exceeds 3", within 24 hours, as required
in 40 CFR 264.193 (c)(4).
Module IV - 2
Thiokol Corporation
RD&D Perinit
16 February 1995
IV.D. SPECIAL OPERATING REOUIREMENTS
IV.D.l. Effluent Storage Tank Liquid products from the HTO reactor shall be
pumped into the 600 gallon effluent storage tank where the discharge samples
are taken prior to final disposal. Depending upon the analysis, the liquid
residues shall either be neutralized in the effluent storage tank, disposed to
the Permittee's water treatment plant or recycled back to the HTO reactor.
No other treatment will be allowed in this tank.
IV.D.2. Other regulated tank system treatment activities are specified in Module V.
IV.E. SPECUL REOUIREMENTS FOR IGNITABLE OR REACTIVE WASTES
IV.E.l. Ignitable or reactive waste shall not be placed into a tank system unless the
provisions of R315-8-2.8 and R315-8-10 (40 CFR 264-190 - 264.199
incorporated by reference) are met.
IV.E.2. The Permittee shall document compliance with the ignitable and reactive
waste regulations as required by R315-8-2.8 and place this documentation in
the facility operating record.
IV.F. SPECIAL REOUIREMENTS FOR INCOMPATIBLE WASTES
IV.F.l. The Permittee shall not place acids or oxidizing halides into carbon steel tank
systems.
IV.F.2. The Permittee shall not place organic material or oxidizing acids into any non-
compatible tank system.
IV.F.3. The Permittee shall not place hazardous waste in an unwashed tank system
that previously held incompatible waste or material.
IV.F.4. The permittee shall document compliance with the incompatible waste
regulations of R315-8-2.8 and place this documentation in the facility
operating record.
IV.G. INSPECTION REOUIREMENTS
IV.G.l. The Permittee shall comply with the inspection requirements specified in
R315-8-10 (40 CFR 264-190 - 264.199 incorporated by reference), and the
Tank
Module IV - 3
Thiokol Corporation
RD&D Permit
16 February 1995
MODULE III - STORAGE IN CONTAINERS
IIIA. APPLICABILITY
III.A. 1. The requirements of this permit Module pertain to the operation of
hazardous waste container storage areas at the SRMD facility. Storage
Building T-15 shall only be used to store the un-treated or in-process solid
residues from the solid rocket motors. AJI six structures, support equipment
and the concrete pad are considered part of Building T-15 when holding
hazardous wastes described in this permit. The Permittee shall comply with
R315-8-9 and all conditions of this Module.
III.A.2. Hazardous wastes containing free liquids shall not be stored in Building T-15.
All liquids wastes generated at the SRMD facility shall be stored at Building
E-501, sent to an off-site disposal facility or managed in the water treatment
facility at Building M-705.
III.B. WASTE IDENTIFICATION
III.B.l. The Permittee may store five (5) Class 1.1 propellant solid rocket motors or
any untreated portion of those motors in Building T-15. Each rocket motor
may contain up to 3,660 pounds of Class 1.1 explosive.
III.B.2. All containers storing hazardous wastes at these facilities shall have labels
identifying the waste.
III.B.3. Whenever a waste rocket motor is stored in one of the rooms of Building T-
15, a sign must be posted on the main equipment door that advises the
operators that the enclosed motor is a hazardous waste and is being used for
the SRMD test facilities.
III.B.4. Hazardous wastes shall not be stored in Building T-15 after the expiration
date of this permit.
IILC. COMPATIBILITY OF WASTE WIIH CONTAINERS
The Permittee shall assure that the waste is compatible with containers or the
rocket motor covers as required by R315-8-9.3.
Module III - Page 1
Thiokol Corporation
RD&D Permit
16 February 1995
MODULE V - MISCELLANEOUS UNITS
V.A. APPLICABILITY
V.A.I. The requirements of this Module pertain to all forms of treatment of the
propellant from the solid rocket motors demilitarized at the SRMD facility. The
following process units are covered by this RD&D permit.
V.A.2. Propellant Removal Svstem (PRS) The PRS uses a high pressure (approximately
30,000 psig) cryogenic nitrogen washout technology for the removal and size
reduction of the propellant. The propellant washed from the motors shall be
collected in the Transport/Hydrolysis Container (Washout Chamber).
V.A.3. Hydrolysis Svstem Hydrolysis is a process of decomposition whereby specific
chemical bonds of a compound are split, and waters molecule are added. The
propellant hydrolysis process uses water and a hydrolyzing agent to desensitize
the propellant components. A safe, non-explosive material can then be pumped
to other treatment tanks. Typical hydrolyzing agents that may be used at this
facility incltide sodium hydroxide (NaOH) and amitionium hydroxide (NH4OH).
V.A.4 Hydrolyzed Storage Svstem The hydrolysis propellant solution from the
hydrolysis process will be transported via truck to one of the 600 gallon
Hydrolyzed storage tanks. Hydrolyzed propellant solution will be supplied from
this tank to the HTO processing equipment as needed.
V.A.5. Mix Tank Svstem The hydrolyzed solution will be pumped from the Hydrolyzed
storage tank to the 300 gallon mix tank and diluted with water to make a 1 to
30% by weight solution. Approximately 10 to 500 pounds of propellant will be
mixed in each batch. Ethanol or other additives may be added to the solution at
this step to increase the heating value of the propellant.
V.A.6. Oxidation Reactor Svstem The reactor sytem utilizes High Temperature Oxidation
(HTO) to destroy the organic constituents of the propellant. HTO is a process
whereby the pressure and temperature are increased above the critical point of
water (375°C and 3208 psig) so that desities of the gas and liquid phases become
identical and the distinction between the two phases disappears. Oxygen gas (O2)
is injected into the reactor to facilitate oxidation of the organic components to
form non-hazardous produc;ts. This oxidation process will typically operate at
375°C to 650"C and at pressures of 3,500 psig to 8,000 psig.
Module V - Page 1
Thiokol Corporation
RD&D Permit
16 February 1995
MODULE II - GENERAL FACILITY CONDITIONS
IIA. APPLICABILITY
The residues from five (5) solid rocket motors will be treated in a High
Temperature Oxidation (HTO) reactor at the Permittee's Solid Rocket Motor
Disposal (SRMD) facility. The process will be evaluated as a possible
alternative to the existing Open Burning/Open Detonation treatment methods
for obsolete rocket motors. The requirements of this permit module pertain
to the Solid Rocket Motor Disposal facility and hazardous waste management
units identified within Modules III, IV and V.
ILB. DESIGN AND OPERATION OF FACILITY
II.B.l. The Permittee shall design, construct, maintain and operate the facility and
surrounding areas to minimize the possibility of a fire, explosion, or any
sudden or non-sudden release of hazardous waste or hazardous waste
constituents to air,'soil, groundwater or surface water which could threaten
human health or the environment.
II.B.2. Any additions and construction changes to the facilities that are regulated by
this permit shall be documented by as-built drawings and professional
engineering certifications.
II.B.3. After review of the as-built drawings and field verification of the facilities, the
Executive Secretary will notify the Permittee in writing of any change which
he concludes does not satisfy the operating requirements specified in this
permit. If it is established that such changes are permit violations, the
Executive Secretary may require the Permittee to remove, replace or modify
any construction inconsistent with this permit.
ILC. WASTE ANALYSIS PLAN
II.C.l The Permittee shall follow the procedures of the Waste Analysis Plan
referenced in Attachment 1 of this permit.
II.C.2. The Permittee shall only use test methods described in the Waste Analysis
Plan or those equivalent procedures that satisfy R315-8-2.4. Changes in test
methods
Module II - Page 1