DSHW-1998-002536 - 0901a0688013efbd

PROPULSION GROUP
P.O. BOX 707
BRIGHAM CITY, UT 84302-0707
801-863-3511
10 March 1998
8700-FY98-ST066
m^
THMOMOL
AEROSPACE & INDUSTRIAl TECHNOLOGIES
\ F"" r •? r "--^
Mr. Dennis R. Downs, Executive Secretary
Utah Department ofEnvironmental Quality
Division of Solid and Hazardous Waste
P. O. Box 144880
Salt Lake City, Utah 84114-4880
MAR t 2 ms
^?-0(IDl
Division of Solid & HazjrJo;;^ '^v.v^e
Utah Departinent of EovironmeMai urait"
Dear Mr. Downs
Subject: Proposed Design Modification to Thiokors UPDES Wastewater Treatment
Facility
References: Application letter to Mr. Kiran Bhayani, Manager ofthe Design Evaluation
Section ofthe Utah Division of Water Quality for Construction of Pipeline from
M-705 to M-392 Tanks, dated 17 February 1998, # 8740-FY98-ST062
Telephone conversation between Dennis Fredrick, Manager ofthe DWQ
Groundwater Section, and John Holladay, Thiokol, on 4 March 1998
Telephone conversation between Lyle Stott from the DWQ Design Evaluation
Section, and John Holladay, Thiokol, on 4 March 1998
On 17 February 1998, Thiokol submitted to Mr. Kiran Bhayani, Manager ofthe Design
Evaluation Section ofthe Utah Division of Water Quality, an application to construct a pipeline
from the M-705 chemical treatment plant to three existing, above-grade, free-standing, self-
supporting tanks (M-392) located approximately 1000 feet northwest ofthe facility. A copy of
this submittal is enclosed. This pipeline and tanks would allow Thiokol to evaporate water from
some high total-dissolved solids M-705 UPDES wastewater facility wastestreams, thereby
reducing pollutants discharged to the waters ofthe State, and providing greater protection of
human health and the environment. As part ofthe review process, the DWQ determined that the
tanks might be subject to DWQ Groundwater Quality Protection regulations, and a construction
permit for the pipeline would not be granted until this issue was resolved.
Groundwater Protection Permit-By Rule
However, the Groundwater Quality Protection regulations provide permit-by-rule provisions
which apply to the M-392 tanks. Administrative Rule R317-6.6.2.A.13 includes a permit-by-rule
provision for "storage tanks installed or operated under regulations adopted by the Utah Solid
Proposed Design Modification to Thiokol's
UPDES Wastewater Treatment Facility
10 March 1998 Page 2
and Hazardous Waste Control Board", and R317-6.6.2.A.15 includes permit-by-rule provision
for "hazardous waste or solid waste management units managed or undergoing corrective action
under R314-1 through R315-14". The tanks were constructed in 1988 as a hazardous waste
storage facility, and complied with rigorous RCRA hazardous waste standards, including double
wall construction and leak detection to insure there is no release to the environment. The tanks
went through formal RCRA closure (ofthe original storage permit) in early 1989, and are
currently identified as RCRA Solid Waste Management Unit (SWMU) #515. Dennis Fredrick,
Manager ofthe DWQ Groundwater Section, accepted the position that the tanks are permitted by
rule, following confirmation of these facts by the DSHW. After consulting with your staff, Mr.
Lyle Stott from the DWQ Design Evaluation Section called John Holladay ofmy staff and
indicated an approval for use ofthe pipeline would be drafted as quickly as time and schedule
permitted.
Although Thiokol is considering the possibilities of using the M-392 tanks for many diverse
UPDES wastestreams with high total dissolved solids (TDS) content, we have immediate need
for the Division ofSolid and Hazardous Waste to evaluate the use of these wastewater facility
resources for evaporation of an M-705 processed waste generated from building M-590.
RCRA Regulatory Evaluation
M-590 generates a wastewater that meets the ignitability characteristic under RCRA but meets
no other listing or characteristic. The ignitability is imparted by some residual volatile organics,
primarily MTBE and ethyl acetate at approximately 500 ppm each, that are not totally consumed
in the process. Currently, the option available to us is to send this wastewater offsite for
incineration. It is. projected that up to 1 million gallons of water will be generated in this process
over a period of six months. Due to the costs and inherent risks ofshipping many truckloads of
this wastewater to the incinerator, a more favorable option for treatment is to remove the
ignitability characteristic in the applicable unit operations (air-strip) ofthe M-705 UPDES
wastewater treatment facility, or by air-sparging in M-705 storage tanks. Evaporation would
then be at the M-705 adjunct M-392 tank evaporation unit.
Samples ofthe wastewater have been treated at the M-705 process and analyzed to determine the
treated levels, these are attached. Due to the manufacturing process being very new, the
analytical data is sketchy to date and we are continuing to monitor the process. (Laboratory data
from the M-590 wastestream reports 470 ppm cyanide, all but 1.35 mg/kg as ferrrocyanide.
Ferrocyanide is a relatively stable compound, and this wastestream does not meet the criteria ofa
D003 reactive waste. It is not amenable to alkaline chlorination, and therefore meets only the
total cyanide category and not the amenable category.)
The regulatory basis for treatment ofthe wastewater at M-705 with subsequent evaporation is
based on the wastewater treatment exemption for NPDES permitted facilities. In 40 CFR
268.40 (the Treatment Standards for Hazardous Waste table) lists the treatment for DOOl,
Proposed Design Moditication to Thiokol's
UPDES Wastewater Treatment Facility
10 March 1998 Page 3
Ignitable Characteristic Wastes, under both the wastewater and nonwastewater categories as
"DEACT and meet 268.48 standards^". The "8" superscript refers to footnotes at the end ofthe
table, where 8 states "These wastes, when rendered nonhazardous and then subsequently
managed in a CWA, or CWA-equivalent systems are not subject to treatment standards"
(meaning the 268.48 Universal Treatment Standards). Therefore, once M-705 has treated the
wastewater and removed the characteristic of ignitability and the wasteswaters continue to be
managed in the NPDES permitted M-392 tanks it is not subject to the Universal Treatment
Standards.
Additionally, it appears from our initial analysis there are other regulatory considerations that
make this treatment a favorable approach. The wastewater as generated meets the 268.3(d)
definition of a non-wastewater i.e. the TOC level is over 1%. Initial samples ofthe post treated
water show levels of underlying hazardous constituents that meet the UTS for nonwastewater
(the total cyanide is below 590 ppm and the volatile organics are also very low). In addition, the
attached data shows that the wastewater once treated, will likely meet the category of a
wastewater i.e. once the volatile organics are removed the TOC levels drop below the 1% level
and the TSS from an initial read is less than 1% as well. The RCRA Hotline was consulted and
they stated that in several references in the Federal Register, EPA states that once a characteristic
waste is treated, and treatability categories change (In this case from nonwastewater to
wastewater) this constitutes a new waste generation point and (if non hazardous) the UTS fallout.
The most recent reference to this is enclosed, 62 FR May 12,1997 page 26007.
M-392 Tank Evaluation
The tanks were constructed in 1988 as a hazardous waste storage facility, and comply with
rigorous RCRA hazardous waste standards, including double wall construction and leak
detection to insure there is no release to the environment. The tanks went through formal RCRA
closure in early 1989, and are currently identified as RCRA Solid Waste Management Unit
(SWMU) #515. The original construction specification detailing design, materials, dimensions,
and leak detection are available upon request. The tanks have an estimated minimum life of 20
years. Prior to use, the tanks went through a rigorous evaluation process. The leak detection
sump for Tank No. 2 at M-392 was pumped and inspected on 11 February 1998. A visual
inspection of Tank No.2 was conducted by Thiokol Environmental Services and judged to be
capable of containing liquids. Water from Thiokol's plant water supply line was diverted into
the tank at an estimated rate of 100-125 g.p.m. Red florescent dye (Rhodamine WT) was
added as the tank was filling. The tank was filled to its operating level which requires a nine
inch freeboard. A sample ofthe dyed tank water and water from the leak detection sump were
collected on 12 February, 16 February and 17 February and were visually compared to each
other. No red dye was detected in the sump water during any ofthe sampling events. The
samples were then viewed under ultraviolet light and compared to tap water. Again, no evidence
ofthe florescent dye was detected. The tank was monitored for a total of 15 days at its operating
capacity.
Proposed Design Modification to Thiokol's
UPDES Wastewater Treatment Facility
10 March 1998 Page 4
On 17 February an independent engineer from EarthFax Engineering inspected the tank and
witnessed the sample collection and analysis. The certification of tank integrity has not been
submitted to Thiokol at this time, but there was no indication from the inspection that the tank
could not be certified.
A qualifled HDPE tank contractor was secured to repair the liners in Tank Nos. 1 and 3. The
contractor conducted both visual inspections and vacuum testing ofthe liners and made all
necessary repairs. The florescent dye water from Tank No. 2 was then transferred into Tank No.
1 where it is being monitored in the same manner as described above. Tank No. 3 will also be
evaluated in this manner.
Please review these plans and contact my office if your review raises questions or concems. My
telephone number is 863-5928 or you can contact John Holladay at 863-6895 or Paul Hancock at
863-3344.
Sincerely
J. D. Thompson, Director
Environmental, Fire & Security
Enclosures: Application letter to Mr. Kiran Bhayani, Manager ofthe Design Evaluation
Section ofthe Utah Division of Water Quality for Construction of Pipeline from
M-705 to M-392 Tanks
62 FR May 12, 1997 page 26007
M-705 post-treated M-590 wastewater laboratory report
Independent Engineer tank evaluation for M-392 tank #2
PROPU)5ION OROUP
P.O. BOX 707
BRIGHAM CITY.UT 84302-0707
801.863-3511
•mOHMU.
^ROSPACE 4 INtXJSTRlAl TECHNaOGES
17 February 1998
8740-FY98-ST062
Mr. Kiran Bhayani, Manager,
Design Evaluation Section
Utah Division of Water Quality
P. O. Box 144870
Salt Lake City, Utah 84114-4870
Dear Mr. Bhayani
Subject: Proposed Design Modification to Thiokol's Wastewater Treatment Facility
References: UPDES Permit No. UT0024805
Telephone conversation between Steve McNeal, DWQ, and John Holladay,
Thiokol, on 9 February 1998
Thiokol's UPDES discharge permit limits total dissolved solids (TDS) in effluent to levels which
will not exceed mean concentrations in Blue Creek, the receiving stream. Thiokol has at times
struggled to meet these limits because ofthe nature of our waste streams, especially those
involved in the recycle or disposal of rocket motor components. Thiokol proposes to modify our
wastewater treatment facility to include two 500,000 and one 200,000 gallon tanks for ambient-
temperature evaporation of high TDS wastewaters. This will reduce pollutants to the waters of
the State, and provide greater protection of human health and the environment. The tanks will
not be used to hold hazardous wastes.
Thiokol will construct a pipeline from the M-705 chemical treatment plant to three existing,
above-grade, free-standing, self-supporting tanks located approximately 1000 feet northwest of
the facility. Drawing M392-G-4 illustrates the proposed pipeline system. The tanks were
constructed in 1988 as a hazardous waste storage facility, and complied with rigorous RCRA
hazardous waste standards, including double wall construction and leak detection to insure there
is no release to the environment. The tanks went through formal RCRA closure in early 1989,
and are currently identified as RCRA Solid Waste Management Unit (SWMU) #515. The
original construction specification detailing design, materials, dimensions, and leak detection are
available upon request. The tanks have an estimated minimiun life of 20 years. Prior to use, the
tanks will be visually inspected and filled to capacity with water and tracer-dye to check the liner
and leak detection integrity. The tanks will be reinspected annually, and leak-tested on a
biannual schedule. The exterior ofthe tanks and the leak detection system will be inspected
weekly. During operation, a minimum nine inches of freeboard space will be maintained within
Proposed Design Modification to Thiokol's
Wastewater Treatment FaciUty
17 February 1998 Page 2
the tanks. Following evaporation, the evaporite residue will be removed from the tanks and
disposed in accordance with applicable USEPA and Utah DEQ laws and regulations.
Please review these plans and contact my office if your review raises questions or concems. My
telephone number is 863-5928 or you can contact John Holladay at 863-6895.
Sincerely
J. D. Thompson, Director
Enviromnental, Fire & Security
Enclosures: Facility modification drawing # M392-G-4
Land Disposal Restrictions Phase n||rreatmen... . ^^ Page 19 of 73
managed in separate loads. In-such instances, the generator will still '^Q'26O0T~
be required to make hazardous waste and LDR determinations for each "*
separate load.
In adopting today's interpretation, EPA emphasizes that this type
of cleaning is a batch operation occurring at widely-spaced intervals
and involving temporary storage units (i.e. units that are removed from
the premises after receiving the rinsate). Thus, the interpretation
does not ever apply where a surface impoundment receives rinsate (see,
e.g.. Chemical Waste Management v. EPA, 976 F. 2d at 20 n. 4 (placement
of any amount of characteristic waste in a surface impoundment makes
the unit a regulated unit even if diluted to non-characteristic levels
afterwards)). The interpretation also does not apply where there are
permanent storage units involved. EPA also notes the evident point that
if commingled rinses still exhibit a hazardous waste characteristic,
the receiving tank is a regulated unit. Persons owning or operating
such tanks.have the same obligations as other generators to determine
whether the waste exhibits a characteristic. See 262.11.
3. Sludge From High TOC (Total Organic Carbon) DOOl Treated in Tank
Based Systems
Many generators introduce" waste into tank-based wastewater
treatment systems where the resulting effluent is discharged to a POTW
or to navigable waters, and the resulting wastewater treatment sludge
is land disposed. At times, the waste that is placed in the tank-based
system exhibits the ignitable characteristic. If the organic content of
the wastewater is sufficiently high, the liquid waste—when first
released—can meet the definition of nonwastewater found in 40 CFR Part
268.2(d).
The fact situation of concern can involve releases of high TOC
ignitable wastes (which have a designated method of treatment), raising
a question of whether that treatment standard for high TOC waste still
applies to sludge generated from the wastewater treatment, even if the
sludge is not itself high TOC ignitable waste.
It is EPA's view that the sludge in this situation should be viewed
as a new treatability group. Put another way, the change of
treatability group principle applies to situations where liquid wastes
which are technically nonwastewaters are inadvertently placed in
wastewater treatment systems in small quantities, for legitimate
wastewater treatment, thereupon becoming wastewaters (as defined in
268.2(f) of the rules), and subsequently generating a sludge. See 58 FR
29871, May 24, 1993 ("In the Third Third final rule, EPA stated that
for characteristic wastes, each Charige of treatability group in a
treatment train marked a new point of generation for determining if a
characteristic waste was prohibited from land disposal'').
Consequently, because the sludge generated from the tank-based
wastewater treatment system is a different treatability group from the
wastewater from which it is generated, it would be considered to be a
newly generated waste that should be evaluated at its point of
generation to determine if it is hazardous, and if so, to then
determine the appropriate LDR standard. (Also, please note that
elsewhere in today's notice the Agency clarifies that the LDR de
minimis exemption applies to small, inadvertent, releases of
characteristic waste into wastewater treatment systems. As a practical
matter, the de minimis" exemption probably makes the.question moot,
because larger releases would not typically occur since they would
likely interfere with wastewater treatment systems operation.)
4. Tank Rinsate -^ •.,-;•,.:,--••
An issue arises when high-TOC ignitable wastes are stored in tanks,
and some residue from these wastes remains in the tanks after the tanks
are emptied and rinsed. The initial high-TOC ignitable waste is
considered a nonwastewater with the treatment standard of CMBST
(combustion) or RORG (recovery of organics). However, it is EPA's view
that the rinsate from an empty tank (see 47 FR 1250, January 11, 1982,
for guidance on empty waste tanks) is a newly generated wastewater and
the high-TOC ignitable waste treatment standards do not attach. The
3/5/98 6:44:12 AM
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Trace Metals in M-590 Waste Water
Date:
LWR-716402
Submitted by:
Analyzed by:
Sample ID
9-Feb93
J. R. Whimpey
L.V. Dearden
K.W. Bates
Aluminum Silver
(ppm) (ppm)
Arsnic Barium Cadmium Chromium Mercury Lead
(ppml (ppm) (ppm) (ppm) (ppb) (ppm)
M-S90 Waste Water 3.167 NotDetected NotDetected NotDetected NotDetected NotDetected NotDetected NotDetected
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Minimum Detection
Umits 0.25 ppm 0.03 ppm O.SQ ppm 0.01 ppm 0.02 ppm 0.05 ppm 1.6 ppb 0.25 ppm
Sample ID Selenium
M-SSO Waste Water NotDetected
Minimum Detection
Limits 0,50 ppm
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PROPULSION GROUP ^^
SCIENCE ANO ENGINEERING
P. O. BOI 707, UUS 245
BrigiMm Chy, UT 84302-0707
8014eM511
LWR-FY98-D947
ITFelMuary, 1998
TO: Jay R. Whimpey
CC: F.E-Bares
FROM: K.E. Nielsen
Chemicai and Physical Analysis
LWR: 716402
WO: , 1A459
SUBJECT: M-sgo Waste Water
p. 5/6
THMOHOK
AEAOSPACE a INDUSTRIAL TECHNOLOGIES
Total cyanide, cyanide reactivity, and anions were measured in the waste watar sampte from M-590.
The total cyanide was determined per SOP #350 in which the sample is distilled and then analyzed for
cyanide using an automated colorimetric method. Cyanide reactivity was determined using the method
from SW-846 :Test Methods for Evaluating Solid Waste, Volume IC, Chapter?, Rev 2, September
1994. The anions were measured by ion chromatography. The results are listed below.
Total cyanide:
Total releasable cyanide:
Nitrate:
Nrtrite:
Chloride:
Orthophosphate:
Sulfate:
470 ppm CN"
1.35 mg HCN/lig waste'
1195 ppm
14810 ppm
755 ppm
2018 ppm
11418 ppm
*The current EPA interim guidance level for total releasable cyanide is 250 mg HCN/kg waste.
The cyanide reactivity was perfomied a second time to optimize generation and recovery of cyanide, but
the recoveiy of spiked sanfiples was only between 10 and 15 percent In spite of this effort. There is no
historical data to evaluate the method performance, however, we feel that within the parameters ofthe
reactive cyanide procedure established by the EPA, the solution does not meet their criteria of a cyanide
reactive waste. Careful handling Is still necessary due to the total cyanide level.
If you have any questions or if there is any other way I can help, please call me at extension 4375.
Kieth E. Nielsen
SCIENCE AND ENGINEERING
THIOKOL ENVIRONMENTAL LABORATORY
TO: JAY WHIMPEY ,
WATER OPERATIONS
FROM: MITCH ROLAND,
SPECTROCHEMICAL ANALYSIS
DATE: 19 JAN., 1998
SUBJECT: M-590 WASTE WATER ANALYSIS, LWR 716402
A WASTE WATER SAMPLE WAS ANALYZED ON THE GC/MS. THE VOLATILES
DETECTED FOR THE SAMPLE ARE LISTED BELOW:
COMPOUND
acetone 25 ppm
4-methyl-2-pentanone 96 ppb
toluene 8.9 ppb
M.M.ROLAND poJ^t^
March 6, 1998 k%. Mj
EarthFax
Mr. Joiin Holladay EarthFax
Thiokol Corporation, Strategic Operations Engineering Inc.
M/S 30IE Engineers/Scientists
PO Box 689 7324 So. Union Park Ave.
Brigham City, Utah 84302-0689 .,^ ^w,/°v°fl.n.7
" ' Midvale, Utah 84047
Telephone [phone]
Subject: Letter Report for Tank Inspection at Area M-392, Tank 2 Fax80i-56i-i86i
Dear Mr. Holladay:
This letter report summarizes inspection activities conducted in behalf of Thiokol
Corporation ("Thiokol") by EarthFax Engineering, Inc. ("EarthFax") during inspection of Tank
2 In area M-392 of facilities operated by Thiokol at Promontory, Utah. Enclosed with this
letter report is a copy of the "Existing Hazardous-Waste Tank Inspection Form" which
Includes specific items observed in the field during Inspection of the tank.
Tank 2 is constructed Of two 80-mll high density polyethylene ("HDPE") flexible membrane
liners, with the outer liner providing secondary containment protection against leaks which
might develop in the inner liner. The walls of the double liner tank are supported using
galvanized steel sheeting and galvanized steel support braces. The floor of the tank is
supported by a concrete pad upon which the tank rests. An absorbent geotextile fabric
material is placed between the two liners and serves as a "wick" to absorb any liquids
which might accumulate between the liners due to precipitation, condensation, or liner
leakage. This wick material Is a non-woven needle-punched polymeric geotextile fabric
which weighs 10 ounces per square yard. The geotextile fabric between the two HDPE
liners is connected to a sump system which serves to collect any condensation,
precipitation, or liner leakage which may accumulate in the geotextile liner. This sump
system is mounted such that the Ild of the sump box is at ground surface elevation. The
sump box is estimated to hold approximately 1 25 gallons of water.
An inspection of this tank was conducted on February 16, 1998. On this date, the tank
contained approximately 4 feet of water to which rhodamine dye had been added on
February 13, 1998. The pink coloration of the water at the time of inspection was
uniform throughout the tank.
During inspection of the tank, no damage due to cracking or corrosion was observed in the
structures which support the HDPE liners, including the cement pad which supports the
HDPE liners, the galvinlzed steel sheeting, and the galvanized steel support braces. Some
moisture was noted on the cement pad around the outside walls of the tank, but this was
due to melting snow.
As the sump box was inspected, a small amount of water (probably less than 0.10 gallons
per minute) was observed issuing from the PVC pipe. A sample of this water was
collected and was visually compared to a similar volume of water collected from the dyed
water in the tank. No pink coloration was observed in the sample of sump water. Rather,
Mr. John Holladay
March 6, 1998
Page 2
this sample was a light brown color which was likely Indicative of dust which has collected
in the sump box or had been deposited on the wick material where it Is exposed to the
atmosphere.
The water samples collected from the sump box and from the tank were then evaluated
using a longwave ultraviolet light (Blak-Ray, Model ML-49, 366 nanometers). The water
sample from the tank, which contained the rhodamine dye, shone Irldescently beneath the
ultraviolet light while the water sample taken from the sump box did not. The purpose of
this evaluation was to determine whether trace amounts of dyed tank water (which might
not be visible to the natural eye) could be present in the sample water collected from the
sump box. Results of this evaluation therefore Indicated that water Issuing from the PVC
pipe in the sump box was not originating from inside the tank. Rather, they corroborate
the theory that the water In the PVC pipe was originating from condensate or precipitation
which had developed between the HDPE liners.
As a control against the possibility that diluted amounts of water tainted with rhodamine
dye might not iridesce beneath an ultraviolet light, the tank sample which had been spiked
with the dye (and had shone irldescently beneath the ultraviolet light) was diluted until the
pink coloration in the sample was not observable to the natural eye (a dilution of about
1:4, v/v). It was then placed beneath the ultraviolet light, whereupon the diluted sample
shone irldescently.
Based on our examination, it Is my opinion that the tank as constructed adequately meets
the requirements of 40 CFR 265.191 for use in storage of hazardous materials.
Furthermore, the foundation soils on which the tank is installed appear to be adequate to
support the tank.
I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my Inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the Information, the Information is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting
false Information, including the possibility of fine and Imprisonment for knowing violations.
Please contact me if you have any questions.
Sincerely,
Richard B. White, P.E.
President
Enclosure
EARTHFAX ENGINEERING, INC.
EXISTING HAZARDOUS-WASTE TANK
INSPECTION PORM Page 1 of ^
1. Client: T^/Dfl&i— r/-\JP.J^£j^AT/riAJ 2. Proj. No.: jJc S?i-C^i^
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4. Tank Identification: ^-.^^ "/aiJ^^Z CvJfeT) 5. Xank Aee: /O/k^/t^
6. Date of Inspection: 7. Inspector: jf/^^/^y ^^/Ai€:
8. Tank Dimensions: /3^'^<Q. i^/C x- /3.0i^. ^/>af )C S/i./•/<$/•
9. Construction Material: DOoBuF ~Li^Fi\ ?CiAl/^/)P£ /hcjL,i^mt^c£l^ L/AJ£P
10. Design Standards Used: naiJSoc.T' Af/1i^ufr9ririJfi.E^ '. /Mf^DUT/^K . //\/G ,
11. Source of Info, in Item 10:
12. Hazardous Characteristics of Waste: UPPP^ L//ir7£^
13. Source of Info, in Item 12: '^/o<e!C^^^2it/^^^L-^
14. Corrosion Protection: /v/l
IS. Results of Tank (and Associated Equipment) Inspection:.
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EARTHFAX ENGINEERING> INC.
EXISTING HAZARDOUS-WASTE TANK -v
INSPECTION FORM Page 2 of ^
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16. General Remarks and Observations:
Signature of Inspector
Signature of Certifying Engineer P.E. Lic. No. State Date