DSHW-1998-002020 - 0901a0688013b66f

^' r PROPULSION GROUP
P.O. BOX 707
BRIGHAM CITY, UT 84302-0707
801-863-3511
THMMOH.
AEROSPACE & INDUSIRIAL TECHNOLOGIES
S"^
February 17, 1998
8740-FY98:SL061
^tit, Div, 2 4 io. 'SS
Dennis R. Downs %
Department of Environmental Quality
Division of Solid and Hazardous Waste
P. O. Box 144880
Salt Lake City, Utah 84114-4880
Attn: JeffVandel
Subject: Temporary Authorization, EPA ID # UTD009081357
Dear Mr. Downs:
Thiokol Corporation currently possesses a RCRA Part B Storage Permit. This permit
allows the storage of various types of hazardous waste for up to one year at designated
locations. None ofthese storage locations are designed for the storage of significant
quantities of propellant or rocket motors. We also operate an OBOD facility where we
bum Thiokol as well as non-Thiokol generated reactive waste. The purpose of this letter
is to request Temporary Authorization (as outlined in 40 CFR 270.42(e)) to store rockets
motors at Thiokol's Promontory Facility prior to open buming.
Thiokol has been successful at securing several rocket demilitarization contracts recently.
This work has included propellant ingredient reclamation of 1.3 materials. Thiokol has
developed the technology to recycle the ammonium perchlorate in many 1.3 materials,
but 1.1 propellants continue to require open burning as the safest means ofdisposal.
On December 22, 1997 Gene Curtis met with JeffVandel of your staff to discuss a draft
class 3 permit modification to add certain building to our storage permit to allow storage
of solid propellant/explosives for up to one year prior to processing and open burning.
The purpose of this meeting was to obtain comments from the State prior to submitting a
formal permit modification request. Mr. Vandel said that there would be a 60 + 45 day
comment period for this permit mod, which means we could expect the approval
sometime this summer.
Thiokol has the opportunity to bid on a Sprint motor demil project that would require
tooling design and constmctiori to begin on 2 March. The first motors would not arrive
until 4 May 1998. This program would entail receipt of motors, separation ofthe first
and second stages, and storage prior to open burning. Tooling for this project represents
a significant investment that cannot begin until Thiokol has a cornmitment from the State
that they would be willing to issue a Temporary Authorization to store these motors by 4
A'
Dennis R. Downs
Page Two
February 17, 1998
May 1998. This authorization would prevent disruption of Thiokol's waste management
activities at our bum grounds and would allow us to respond to the increased waste
volume that this program would bring. This authorization would be govemed by the
requirements outlined in the permit modification request.
I anticipate a meeting with Mr. Vandel in the near fiature to discuss any comments the
State may have regarding the draft class 3 permit modification. Once your suggestions
have been incorporated in the permit mod, a formal request will be submitted.
Please let me know at your earliest convenience if the State will be willing to issue
Thiokol a Temporary Storage Authorization, so that work can begin on the tooling design
and fabrication. Thank you for your help in this matter.
Sincerely,
K Thompson, Director
Environmental, Fire & Security