DSHW-1998-004408 - 0901a06880158b29

PROPULSION GROUP
P.O. BOX 707
BRIGHAM CITY, UT 84302-0707
801-863-3511
June 23, 1998
8740-FY98:SL086
Mr. Dennis R. Downs, Executive Secretary
State of Utah, Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs
THtOKOL
AEROSPACE & INDUSTRIAL TECHNOLOGIES
4,.
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Subject: Use of the Hydrolysis Unit at T-93
Thiokol has received a request from the U.S. Army to use the hydrolysis process at T-93 to
hydrolyze new propellant. The T-93 RD&D permit, which included the hydrolysis equipment,
has expired and the facility is undergoing closure. The hydrolysis needs to be performed from
July through September 1998 which will likely be prior to final closure approval ofthe T-93
RD&D permit. The hydrolysis unit was used very little in the T-93 RD&D process and has been
cleaned of any waste residue from the tests conducted. Thiokol will conduct confirmatory
sampling from the hydrolysis process as required in the RD&D permit closure plan to assure that
no contamination remains. Once these samples have been collected, Thiokol proposes to use the
hydrolysis unit for the Army project while closure is being finalized for the RD&D permit.
The hydrolyzation process involves approximately 3,000 pounds of propellant that the Army is
manufacturing specifically for this process. The resulting hydrolysate will be sent back to the
Army for use in various testing procedures. Since the process does not involve a waste
propellant, and the resulting product has value and will be used for it's intended purpose, Thiokol
believes that this project is exempt from hazardous waste regulations.
We request concurrence on the use ofthe hydrolysis unit prior to final T-93.PJD&D closure and
the exemption ofthe hydrolysis process from hazardous waste regulations.
We appreciate your division's assistance in this and other issues related to our operational
constraints while maintaining compliance with environmental regulations.
lfyou have questions on this submittal, please phone Paul Hancock at [phone].
Sincerely,
J. D. Thompson, Director
Environmental, Safety and Security