DSHW-1995-004461 - 0901a0688015905f

DEFENSE AND lJ^UNCH VEHICLE DIVISION
P.O. BOX 689
BRIGHAM CITY, UT 84302-0689
801-863-3511
THIOKOL
SPACE'OEFENSE'FASTENING SYSTEMS
11 April 1995
3S50:FY9S:104
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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. O. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs
Reference: Management of Contractor Generated Hazardous Waste
Memo Dated 17 February 1995
In response to your letter concerning the management of
contractor generated hazardous waste, Thiokol has conducted a
records search and has held personnel interviews. The objective
of these activities was to see if there were any records for the
period of 1992 through 1995 to determine if any hazardous waste
was taken off site by a contractor without a completed manifest.
The company position that contractors are responsible for the
disposal of their wastes is stated in the Thiokol Contractor
Safety Handbook, the company Terms and Conditions used by
purchasing agents, and in applicable contracts.
The manifest review showed that the wastes were shipped to
approved disposal facilities with Thiokol listed as the
generator and we did not find any records showing inappropriate
activity.
The personnel interviewed were selected from the three business
units at the Northern Utah location that may be involved with
contractor waste niaterials. Those interviewed were aware of the
corapany policy that contractors are responsible for wastes from
processes or services that they provide. There were not any
documents found where a contractor identified and transported
hazardous waste off plant. The interviews did not identify
specific remembrances of the staff where a contractor took
hazardous waste off plant.
There were many areas reviewed. The information on the most
likely situations of concern are provided. The situation most
likely to generate wastes that may be of concern would be the
painting contractors. The Defense Launch Vehicle organization
uses painting contractors for labor only. The paint is
purchased by Thiokol and wastes from this contract are collected
3550:FY95:104 -2- 11 April 1995
and sent off plant using the on-plant broker. The Space
Division provides facility support to Science and Engineering
and does most all of the paint purchases and paint application
and waste handling and disposal with the on-plant broker. There
is some contract work on the outside of buildings where water-
based paint is used, and it was reported that solvents are not
used with the water-based paints.
A second area is in the use of contract solvents. The two
maintenance departments at this site have contracts with Safety
Kleen, who provide solvents and take the spent solvents off
plant. The spent solvents have been shipped with the
appropriate manifests.
Thiokol requires all contractors to provide an MSDS on all
hazardous materials brought on plant before any work begins.
Thiokol does accept waste from contractors when recognized in
their contract. This practice includes wastes that can go into
the landfill which is mostly building modification and
construction scraps. Each load is reviewed with the
Environmental staff before access is allowed to the locked
landfill area. Hazardous wastes are accepted for Thiokol to
ship off plant in accordance with regulatory requirements.
We feel that the company's current position is appropriate and
does not conflict with the interpretation given in your memo.
We do plan to clarify the wording in the Terms and Conditions to
inform contractors of the hazardous waste options that are
available to them, and that they are not to transport hazardous
waste off plant without specific written direction.
Sincerely
A. K. Lemon, Manager
Facilities, Maintenance, and Waste Management
AKL/bms