DSHW-2004-002748 - 0901a0688013f15e

ATK
ALUANT TECHSYSTEMS
May 13, 2004
8200-FY05-014
Dennis R. Downs, Director
Division of Solid and Hazardous Waste
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, Utah 84114-4880
Dear Mr. Downs
ATK Thiokol Propulsion
P.O. Box 707
Brigham City, UT 84302-0707
Tel [phone]
Fax [phone]
RECEIVED
MAY 19 200^
UTAH DiVISION OF
SOLID & HAZARDOUS WASTE
RE: Over-Pressure and Fire at M-42 llluminant Mixer (ATK Thiokol
Promontory Site), Written Notification Letter
On May 5, 2004, an over-pressure and subsequent fire occurred at 3:50 am at building M-
42, which is an illuminating device ingredient mix building . We notified Mr. Jeff
Vandel of your staff at 8:05 am of the incident. Mr. Vandel requested that this incident
be classified as a Contingency Plan event. In compliance with R315-8-4.7(j), we have
prepared this written report. The information required in paragraph (j) is provided below:
1. ATK Thiokol Inc., Highway 83 24 miles west of 1-15, Promontory, Utah
[phone]
2 FaciUty address is the same as above, incident occurred at building M-42
3. May 5, 2004, 3:50 am, over-pressure and subsequent fire
4. Less than 1000 pounds of magnesium powder, and less than 200 pounds of a non-
hazardous organic polymer pre-mix.
5. There were no injuries resulting from the over-pressure and fire, because it is an
unattended operation controlled from a remote location.
6. The greatest potential human hazard would be from an overpressure as a result of
the explosion. This building is surrounded by high earthen berms on three sides
to help reduce the hazard to humans or animals as a result of an overpressure.
The open side faces the north, which is Thiokol property, and is frequented by
few people. Further, the mixing operation is initiated from a safe bunker, which
provides worker protection from virtually any potential explosion. The building
is set far enough from the property line to provide safety to off site persons.
Following the initial over-pressure, the 926 pounds of magnesium continued to
bum for several hours. The buming magnesium did create smoke. An evaluation
of the health hazard of buming magnesium conducted by our industrial hygiene
staff indicated there was no exposure risk to our employees or off-site neighbors,
primarily due to the remote location of M-42 and the distant to the nearest
receptor. The area adjacent to the fire was barricaded and non-emergency
personnel were prevented from entering the area. The closest down wind
occupied building was the A4 complex, which lies several hundred yards down
wind.
We also spoke with our closest neighbor to M-42 to see if they had experienced
smoke at their house. They indicated that the smoke had stayed east of their
home, and they were not exposed.
During the initial response, the ATK Thiokol Fire department applied water in an
effort to extinguish a roof fire at M-42. Some of this water filled a non-hazardous
water collection sump, and the balance flowed down a storm channel. A visual
inspection of this water indicated no contamination. We also ph tested this water
which showed a level of 7-8.
We subsequently sampled water inside the building and found ph levels up to 10.
Water was also used after the initial fire to help knock-down the smoke from the
smoldering magnesium fire. This water was kept outside the bermed area to
prevent contact with the building area.
7. Most of the material involved in the fire was fully reacted, forming magnesium
oxide which will be land filled. This material will be closely inspected to remove
any un-reacted magnesium for hazardous waste treatment/disposal. Any residual
premix will be collected and properly disposed. Due to restricted access to the
site during the investigation, we have not yet been able to clean up any remaining
waste. Based on a visual inspection, there appears to be about 2-4ea. 55 gallons
drums of the waste oxide for disposal. There was also sodium nitrate in the
building, which remained in the hopper and was not involved in the fire. This
material will also be properly managed as an oxidizer for re-use or disposal.
We request clarification of Contingency Plan implementation requirements. Our
understanding of the regulations would not have required implementing our Contingency
Plan for a fire at M-42, since it is not a permitted facility. This facility is not listed in our
permit and R315-8-4.7 references manifests, waste, and hazardous waste facilities.
Please provide us your rational for making this determination so that we may better
understand the State's position on this issue. If you have questions or need additional
clarification, please contact Mr. Gene Curtis ofmy staffat [phone].
Sincerely .
' ip^)<^n <^ ^<;,o<^ ^^^
G. E. Gooch, Manager
Environmental Services
Cc: Jeff Vandel