DSHW-1998-004333 - 0901a068801584d7

-^ y PROPULSION GROUP
P.O. BOX 707
BRIGHAM CITY, UT 84302-0707
801-863-35H
July 20,1998
8700-FY98T-009
RECEIVI
JUL 2 7 1998
THtOKOL
AEROSPACE & INDUSTRIAL TECHNOIOGIES
4cV k^
Division of Solid & HazarSi^DS^Aiste
Utah Department of Environmental Quaiity
Dennis R. Downs, Director
Division of Solid and Hazardous Waste
Department of Environmental Quality
P. O. Box 144880
Salt Lake City, UT 84114-4880
Subject: Addendum to the Part B Class III Permit Modification and
Temporary Authorization #MOD98.00729 (EPA ID # UTD009081357)
Dear Mr. Downs,
On December 22, 1997 I submitted a Class III permit modification request for our Part B
Hazardous Waste Permit. Due to some misunderstanding between the State and Thiokol,
we did not pay the $1,000 permit change fee and did not receive our State Tracking
Number. Enclosed with the hard copy ofthis letter is your check for the appropriate
permit fee. Please provide Thiokol with the Official State Tracking Number. Thiokol
will notify the facility mailing list and publish a public notice ofthis permit modification
request within 7 days of today's date. This notice will include announcement of a 60 day
comment period, time and place of a public meeting, name and phone number of facility
contact, DSHW contact and information on viewing documents.
This permit modification includes the addition of rocket motor storage facilities, EPA
codes, inspection frequency changes and changes in our sampling and analysis plan. A
revised hard copy along with an electronic copy ofthe permit change was submitted,
along with each requested change underlined to help simplify the modification process.
Thiokol requested and obtained a Temporary Authorization to utilize the motor storage
buildings prior to final approval, to permit work on a demilitarization project. This
authorization was granted on March 13, 1998 and expires on September 14, 1998.
While preparing to begin this demilitarization project, we discovered that the State of
Utah considers the entire rocket motor to be a hazardous waste, including the motor case.
Due to this interpretation, which was different than Thiokol's, we need a treatment permit
to allow separating the motor stages and removal of certain rocket equipment. This
equipment includes such items as initiators, gas generators, igniter, hydraulic oil
reservoirs, Freon cylinders and other items. Removed reactive equipment will be placed
in labeled conductive containers and taken to our OBOD facility for treatment. Non-
reactive hazardous waste will be properly packaged and sent to a permitted offsite TSDF
for disposal. All non-hazardous items will be managed appropriately either on or off site.
Although our immediate need is to obtain approval to treat Sprint Motors, our intent is to
secure a treatment permit that will allow us to treat a variety of motors that may come to
Thiokol in the future for demilitarization.
Waste motors shipped to Thiokol will be received at either M-345 or M-3 receiving.
Paper work will be inspected for completeness and accuracy. The motor will then be
transported to one ofthe storage buildings included in this permit modification. M-340,
M-107, M-47 and S-616 will be used for storage only, while M-603 will be used for both
storage and disassembly of rocket motors. All building will store both waste and non-
waste motors and bagged propellant. All hazardous waste motors, propellant and
chemicals will be managed in fiill compliance with 40 CFR 264. Non-waste motors and
propellants~stored"in these btiildings will be managed in compliance with OSHA, DOD
and Thiokol requirements.
Each waste motor will arrive at Thiokol accompanied by a Uniform Hazardous Waste
manifest and Land Ban Notification, if not already on file. Prior to arrival onsite, each
motor model will have an open buming profile completed. This profile will include
general properties ofthe propellant, applicable EPA codes, any special safety and
handling procedures, USDOT shipping information, and a list ofthe chemical
constituents in the propellant. In light of a complete knowledge ofthe propellant
composition, and to avoid unnecessary risk to workers, the propellant will not be sampled
and analyzed.
Each ofthe storage buildings covered under this permit are within Thiokol's secured
Promontory facility. Security guards patrol the area 24 hours per day, and the buildings
are locked to control access. Signs have also been installed on each building that identify
them as hazardous waste storage sites and include the building number. These signs can
be opened when waste is stored, and closed when all waste has been removed. These
storage facilities will be inspected weekly, plus daily when a motor is moved into or out
of a building. Items to be inspected are outlined in the December 22nd submittal. Each
employee responsible for inspecting a storage building has been trained on how to
conduct the inspection^ and-where to send the completed inspection form. Personnel
working in or inspecting a storage building will have access to Thiokol's emergency
responders via a cell phone, landline or two-way radio. All inspection forms will be
stored in central filing, and will be available for review by the State DEQ.
The purpose for this addendum is to add this type of treatment to our class III
modification request, and to request that this treatment be covered under our Temporary
Authorization. A Temporary Authorization to treat (disassemble) these motors is needed
in order to enable us to respond to sudden changes in the type and quantity of waste
managed under our facility permit. This treatment is also needed to render the motors
safer and more manageable for thermal treatment at the Bum Grounds. Through
preparing these motors properly for thermal treatment, the bum characteristics can more
accurately be predicted which means a safer bum for Thiokol persoimel and the
environment. Thiokol's ultimate goal is to protect workers. Completing this work in a
safe manner, will prevent a dismption of ongoing waste management activities.
Thiokol has plans to bring in technicians experienced in this disassemble process from
New Mexico to help train local workers. We have informed them not to come until we
have received approval to perform this treatment. We are already behind on this project,
and are trying to complete the work before winter sets in.
Your help in resolving this treatment issue as quickly as possible will be greatly
appreciated. Please contact Mr. Gene Curtis ofmy staff, at [phone] ifyou have
any quesfions or need clarification.
" I certify tmder penalty of law that this document and all attachments were prepared
Under my direction or supervision in accordance with a system design to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry ofthe person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, tme, accurate and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and
imprisonment of knowing violations"
Sincerely,
L D. Thompson, Director
Environmental, Fire, Security & Medical Services