DSHW-2004-006447 - 0901a06880160b10

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

RE: Clarification of Contingency Plan Implementation Requirements, ATK Thiokol Propulsion – Promontory Facility, EPA I.D. #UTD009081357

Dear Mr. Gooch:

The Division of Solid and Hazardous Waste (the Division) received your report dated May 13, 2004 regarding the “over-pressure and fire” that occurred at Building M-42 on May 5, 2004.
Mr. Gene Curtis, of your staff, initially notified the Division of the incident by telephone on the morning it occurred. Based on the description of the incident that Mr. Curtis provided,
the Division requested that ATK Thiokol Propulsion (Thiokol) submit a written report to the Executive Secretary in accordance with R315-8-4.7(j). This regulation states that the facility
owner or operator shall record in the operating record the time, date, and nature of any incident that requires implementing the contingency plan. In addition, a written report, as
described in points one through seven of R315-8-4.7(j), shall be submitted to the Executive Secretary. Your correspondence on the incident meets these reporting requirements.

This incident raised a question on the requirements for implementation of the facility’s contingency plan. Is Thiokol required to implement the contingency plan “whenever there is a
fire, explosion, or discharge of hazardous waste or hazardous waste constituents which could threaten the environment or human health” regardless of where on plant it occurs, or only
at RCRA permitted units? It appears that, upon further review of the appropriate regulations, the requirements for implementing the contingency plan are meant to apply only to permitted
units.

If hazardous waste or material which, when spilled, becomes hazardous waste, is released on the property at a location other than a RCRA permitted unit, Thiokol should comply with the
applicable Emergency Control regulations (R315-9).

At Building M-42, it appears that hazardous waste was generated and the potential for a release of hazardous waste or hazardous constituents existed. In addition, a threat to human
health was possible due to the smoke coming off of the burning magnesium powder. For these reasons the Division would encourage Thiokol to consider implementing the contingency plan
in similar situations, or in cases where a permitted unit or SWMU may be affected by an incident that originates elsewhere.

If you have any questions on this subject, please contact Jeff Vandel at 538-9413.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 6/4/04

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

DRD\JV\ts

c: Lloyd Berentzen, Deputy Director, Bear River Health Department

TN200400619
File to: ATK Thiokol Propulsion - Promontory

June 4, 2004
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

June 4, 2004

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