DSHW-2003-008479 - 0901a068801605ee

George E. Gooch, Environmental Services Manager
ATK Thiokol Propulsion – Promontory Facility
P.O. Box 707
Brigham City, UT 84302-0707

RE: State of Utah OB/OD Guidance Document and 24-Hour Restriction for Hazardous Waste Received from Off-Site - EPA I.D. #UTD009081357

Dear Mr. Gooch:

This letter is in response to your correspondence dated November 10, 2003 regarding the requirement that OB/OD facilities treat hazardous waste received from off-site within 24 hours
if the waste is not placed in a permitted storage facility. In your letter, you request that the Division of Solid and Hazardous Waste (the Division) consider the waste placed in burn
trays to be “in process” and allow it to remain in the trays for up to seven days.

The Division does not believe that “storage” of hazardous waste can be interpreted to mean some kind of “other process” that can occur outside of regulatory controls. Either the waste
is being stored or it is undergoing treatment. Thiokol’s management of waste for 24 hours before treatment is still considered storage of hazardous waste; however it occurs without
a permit because the Division recognizes the logistical and practical considerations that are necessary to prepare the waste for treatment and because the length of storage is limited
to 24 hours.

The Division is aware that Thiokol stores reactive hazardous waste generated on site in containers in the burn pans prior to treatment. This is allowable under the rules because, even
though the burn pans are designated and managed as interim status thermal treatment units, Thiokol has declared them to be 90-day storage areas. However, the 90-day storage option
is not available for waste received from off-site sources. Off-site generated reactive hazardous waste must be treated within 24 hours of receipt or placed into permitted storage areas.
To utilize the burns pans for storage of off-site generated hazardous waste beyond the 24-hour limit would require a permit.

Thiokol contends that additional time is needed to ensure optimum burning conditions so as to minimize human exposure to smoke from the open burning operations. While the Division agrees
that optimal burning conditions are preferable, it believes that emergency permits provide the appropriate flexibility and mechanism for extending the time the waste is maintained at
the thermal treatment unit until optimum burning conditions occur. These permits can be issued orally with minimal administrative requirements.

Accordingly, your request cannot be approved. The Division expects Thiokol implement the necessary operational procedures to continue to comply with the 24-hour requirement for off-site
waste and to request an emergency permit when necessary and appropriate.

If you have any questions regarding this letter, please contact Brad Maulding or Jeff Vandel at 538-6170. Thank you for your cooperation.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 12/17/03

Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board

DRD\JV\ts

c: John C. Bailey, M.D., M.S.P.H., Health Officer/Director, Bear River Health Dept.

TN200302476
file to: ATK Thiokol Propulsion - Promontory

December 17, 2003
Page 2

State of Utah

Department of Environmental Quality

Dianne R. Nielson, Ph.D.
Executive Director

DIVISION OF SOLID & HAZARDOUS WASTE
Dennis R. Downs
Director

OLENE S. WALKER
Governor

GAYLE F. McKEACHNIE
Lieutenant Governor

December 17, 2003

288 North 1460 West • PO Box 144880 • Salt Lake City, UT 84114-4880 • phone [phone] • fax [phone]
T.D.D. [phone] • www.deq.utah.gov