DSHW-1996-002564 - 0901a0688013fa28

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DEPARTMENT OF ENVIRONMENTAL QUALITY
DfVlSION OF SOLID AND HAZARDOUS WASTE
f iU Eflf V
Michael O. Leavitt Govemor
Diaime R. Nielson, Ph.D. Executive Director
Demiis R. Downs
Director
288 North 1460 West
P.O. Box 144880
Salt Lake Cily, Utah 84114-4880
[phone] Voice
[phone] Fax
[phone] T.D.D.
May 31, 1996
Mr. Gene Curtis
Environmental Services
Thiokol Corporation
P.O. Box 689
Brigham City, UT 84302-0689
RE: Pretreatment of wastewater prior to processing in the M-705 treatment plant
Dear Mr. Curtis:
This letter is sent in response lo your leiter dated May 2, 1996, regarding pretreatinent of various wastewaters prior to
processing in tlie M-70,S treatment plant. If Thiokol's planned pretreatment of wastewater meets the requirements outlined
below, it appears the pretreatment would be covered by the wastewater ireatment exemption [40 CFR 264.1(g)(6)].
• Tlie dnurLS or tanks used to pretreat wastewater must be stalion;u"y devices in order to meet tlie definition of a l;uik
or t;uik sysiem, as defined by 40 CFR 260.10.
• The wastewater treatmenl facility tliat receives effluent from tlie drums or tanks musl be subject lo regulation under
eitiier section 402 or 307(b) of Uie Clean Water Act.
• Tlie dnuns mid tiuiks used for pretreaunent of wa.slewater must receive ;uid treat or store ;ui innueni wastewater
(or wastewater treatmenl sludge) tJiat is a haz;irdous wasle. or generate and accumulate wastewater ireatment
sludge that is a hazardous wasle.
However, be advised that if a tank used for pretreaunenl in conjiuiclion widi die M-705 treatmenl pliuil is also used, on a
routine or occ;ision;il basis, to store or treat a hazardous wastewater prior to shipmenl off-site for U-eaunem. storage, or
disposal, it is not covered by die wastewater tre.ilment exemption.
In addition, any sludge tliat is generated by tlie pretreaunent prtx;ess would have to be managed appropriately. Please address
;uiy questions you have regarding this leiter to Jeff Vandel ofmy sitiff at (801) .S38-6I70.
Jennis R. Downs, Execuiive Secreuiry
Utfili Solid ;uid Haztadous Wasle ConU'ol Board
DRD/JCV/ll
c: John C. Bailey, M.D.. M.S.P.H.. Hltli. Off./Dept. Dir.. Bear River Disu-ict Healtii Dep;irimeiu
L;irry Mize. Seciion Mmiager. DWQ
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file to: Thiokol
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