DSHW-1998-002120 - 0901a0688013c1ab

PROPULSION GROUP
P.O. BOX 707
BRIGHAM CITY, UT 84302-0707
801-863-35n
THMOKOL
AEROSPACE & INDUSTRIAl TiCHNOlOGIES
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19 March 1998
8740-FY98-ST069 -^Sfg^^
Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board
288 North 1460 West
P.O. Box 144880
Salttake City, Utah 84114-4880
Dear Mr. Downs:
ATTENTION: Jeff Vandel
SUBJECT: Corrective Action for SWMU No. 515
Under an emergency permit issued by USEPA Region VMI, Thiokol Corporation
constructed in the fall.of 1988,.two 500,000 gallon and two 200,000 gallon tanks for
terriporary storage of hazardous waste liquids while construction ofthe M-705
Waste Water Treatment Facility was completed. The tanks are engineered free-
standing tanks consisting of 16 guage galvanized steel panels and structural steel
support frames. The primary and secondary liners are 80-mil HDPE. Stainless
steel tension cables provide support at the base ofthe wall panels. A 110 mil
geotextile protective underlay was placed between the stainless steel tension
system and the secondary membrane liner. The tanks are constructed on
compacted earth with five feet wide concrete support slabs at the periphery. A leak
detection system was incorporated between the flexible membrane liners to
conduct any leakage to a cdilection sump. <
The tanks were granted a RCRA Emergency Permit by USEPA on 3 December
1988 and were closed in 1990. Closure ofthe tanks consisted ofthe following
actions: removing all residue, power washing, an initial rinsing, steam cleaning , a
final rinse, and sampling the final rinse water. The washing process was repeated
for each tank if waste constituents were found in the rinse water.
The Division of Solid and Hazardous Waste recommended in Thiokol's RCRA
Facility Assessment that the tanks undergo an approved RCRA closure after the
ernergency permit expiration. As stated above, the tanks were closed following the
procedure specified in the permit. Thiokol proposed no fiJrther action for the tanks
in its RCRA Facility Investigation Phase I Work Plan based on the completion ofthe
approved closure.
Thiokol has recently requested from the Division of Water Quality approval to
include the tanks as part of its wastewater treatment facility where the tanks would
be used for ambient temperature evaporation of high TDS wastewaters. The tanks
will not be use to hold hazardous wastes.
Thiokol withdraws the proposal of no further action in the RFI, and will initiate
appropriate actions in the RFI to fully characterize the nature and extent of any
release from this unit.
If you have any questions in this matter, please contact me at [phone], or
Frank Walker at [phone].
Sincerely,
J. D. Thompson, Director
Environmental, Fire & Security
cc: Don Ostler, Director, Division of Water Quality