DSHW-1996-002481 - 0901a0688013e7b9

DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF SOLID AND HAZARDOUS WASTE
Michael O. Leavitt
Govcrntir
Dianne R. Nielson. Ph.D.
Executive Director
Dennis R. Downs
Dirccutr
July 10, 1996
288 North 1460 Wesl
P.O. Box 144880
Salt Lake City, Utah 84114.4880
[phone] Voice
(801).1.38-6715 Fax
[phone] T.D.D.
Certified Mail
Return Receipt Requested
Joe D. Thompson, Dir. Waste Manage. & Env. Services
Thiokol Corp.
P.O. Box 689
Brigham City, UT 84302-0689
Re: Risk Assessments and OB/OD Operating Permits
Dear Mr. Thompson:
It has come to the attention of the Division of Solid and Hazardous Waste (the Division) that many
facilities pursuing OB/OD operating permits are unaware of the requirement or have questioned the
need to conduct a risk assessment for an open burning or open detonation operation. Please be
advised that an OB/OD operating permit cannot be issued without a risk assessment that demonstrates
that management of hazardous waste by OB/OD does not pose an unacceptable risk. The risk
assessment requirements are discussed in detail in the Division's OB/OD Guidance. The guidance
discusses the importance of the risk assessment and how it will be used, by the Division, to evaluate
the proposed design and operation of the OB/OD treatment unit.
The Division suggests that facilities which are pursuing an OB/OD operating permit, begin collecting the
necessary data to perform a risk assessment. Facilities may consult the OB/OD Guidance, R315-101
of the Utah Administrative Code and the Risk Assessment Guidance for Superfund (RAGs) documents
for information regarding risk assessments. For those Part B Applications which have already been
submitted without risk assessments, the Division will continue to review and develop comments
regarding their completeness and technical merit. Please be advised that facilities will be billed
quarterly for any review costs incurred by the Division. If you do not want the Division to continue
reviewing your application pending completion of the required risk assessment, please notify the
Division, in writing, as soon as possible.
If you have any questions on this issue or on the status of your permit appiication, please contact Jeff
Vandel at [phone].
Sincen
)ennis R. Downs, Director
Division of Solid and Hazardous Waste
DRD/WMW/II
c John C. Bailey, MD, MSPH, Hlth. Off./Bear River Hlth. Dept.
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