DSHW-1999-005255 - 0901a0688015823b

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v^Thiokol Propulsion
A Division of Cordant Technologies Inc.
P.O. Box 707
Brigham City, Utah 84302-0707 C^Ci . hTOJ^f^
435 863 3511 Tel HAND DELIVERED
OMSiON OF SOL'D & HA2ARDOU!? VV.^.STR
AUG 1 2 1933 ^^ .'f'.-i^v.' ThlOkOl
%,9iiiia»fi»i»2«34i5i6 vL Propulsion
10 August 1999
8740-CY99-ST050
From Cordant Technologies
Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board
Division of Solid and Hazardous Waste
Department of Enviromnentai Quality
288 North 1460 West
P. O. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs
Subject: Post-Closure Permit Class 3 Permit Modification Request for Change of
Sampling Requirements for Groundwater (UTD009081357)
Thiokol requests a modification of the sampling requirements outlined in our groundwater
hazardous waste Post-Closure permit, issued by the Utah DSHW on 1 September 1992. This
request involves changes in (1) the constituents which are required to be sampled, (List 3
described below) and, (2) the number of aliquots required for each point of compliance (POC)
well (from four to one). We understand these changes involve a Class 3 permit modification.
Since September 1992, Thiokol has sampled groundwater for hazardous constituents as
directed in the Utah Hazardous Waste Post-Closure Permit for Post-Closure Monitoring and
Corrective Action ofthe Liquid Thermal Treatment Area. This permit specifies a rotating
schedule of sampling. Semiannually, each POC well is sampled for four aliquots each of
constituents of List 1 ofthe Post-Closure Permit. List 1 consists of volatile organics, anions,
and metals which are known to have been land disposed, or which have been reported in
groundwater. List 2 constituents are sampled once per POC well each year and consist of
contaminants that have not been reported, or reported inconsistantly in Thiokol's groundwater,
but which the DSHW believes have reasonable potential of being present in groundwater. List
3 are all other constituents of 40 CFR 294 Appendix IX, and are sampled once per POC well
every three years.
Thiokol requests that the Utah DSHW suspend the sampling requirement for List 3
constituents. Thiokol sampled for List 3 constituents in 1989, 1990, 1991, 1993, and 1996.
This data, including raw laboratory reports have been submitted to the Utah DSHW in interim
and semiannual reports for those years. In addition, this data has recently been provided
Thiokol Post-Closure Permit Modification Request
10 August 1999 Page 2
electronically to Mr. Jeff Vandel of your staff. No List 3 constituents have been reported in
downgradient groundwater wells. A detection of 0.77 nanograms per liter (PPT) total dioxin
was reported in the upgradient well A-10 in May 1989, and a detection of endosulfan sulfate in
a field blank in May 1990 have been reported in the five years of List 3 sampling. Thiokol
believes both of these reports represent laboratory error. Thiokol believes resources expended
(which are substantial) for List 3 sampling could be more appropriately be used for other
endeavors.
Thiokol also requests a change in required aliquots of each well for List 1 constituents from
four samples to one sample semiannually. Four samples are specified in 40 CFR 264 Subpart
F for detection and compliance monitoring of an operating hazardous waste facility. However,
Thiokol closed the land disposal facility which is responsible for the contamination
approximately ten years ago. Only a Subpart X interim-status open-burning-open-detonation
facility, with very low potential for release to the environment remains on the site. The
contamination exists as dense nonaquous phase liquids trapped in fracmres and pore space
many hundreds of feet below the surface, which slowly dissolves in moving groundwater. The
contamination levels fluctuate, but there has been a general downward trend since disposal
ceased ten years ago. The intent of four samples is to facilitate statistical methods to determine
if there is a release (detection monitoring) or increase (compliance monitoring) from the active
hazardous waste facility. Thiokol does not perform statistical tests for these two purposes
because the first is undisputed, and the second is not controllable. Thiokol therefore believes
resources would be better spent for other endeavors, including sampling other, downgradient
wells.
Notice of a 60 day public comment period and information meeting will be published in local
newspapers on 18 August 1999.
Ifyou have questions, or need additional information, please contact Mr. John Holladay at
[phone], or you may call me at [phone].
Sincerely
. D. Thompson, Director
Environmental, Fire, Security, and Medical Services
NOTICE
On September 1, 1992 the Utah Solid and Hazardous Waste Control Board issued a Utah Post-
Closure Permit to Thiokol Corporation [Permittee] for the post closure and corrective action of
the M-136 Liquid Thermal Treatment Areas and Solid Waste Management Units at their facility
located in Box Elder County, Utah. Thiokol Corporation has submitted a request to modify this
permit to modify groundwater sampling requirements.
A 60 day public conmient period will commence on August 18, 1999, and end on October 17,
1999, at 5:00 p.m. MST. A public information meeting will be held on September 23, 1999 at
2:00 p.m in the auditorium at the Brigham City Library located at 26 East Forest, Brigham City,
Utah.
Information conceming this modification request can be obtained from Thiokol Corp. through
Mr. John Holladay at [phone]. Information about modification requirements, regulatory
requirements, permit modification procedures and permittees compliance history may be
obtained from Mr. Jeff Vandel of the Utah DSHW at [phone]. Copies of the permit
modification request are available for public review during regular business hours during the
comment period at the following offices:
Division of Solid and Hazardous Waste
Martha Hughes Cannon Health Building, 4th Floor
288 North 1460 West
Salt Lake City, Utah
Brigham City Library
26 East Forest
Brigham City, Utah
Bear River District Health Department
655 East 1300 North
Logan, Utah
Comments may be submitted to Mr. Dennis Downs, Director, Division of Solid and Hazardous
Waste, Utah Department ofEnvironmentai Quality, 288 N. 1460 West, P. O. Box 144880, Salt
Lake City, Utah 84114-4880.