DSHW-2006-001982 - 0901a0688013b18c

HAZARDOUS WASTE INSPECTION REPORT
Dates of Inspection:
Facility:
Facility Contact:
Notification:
Applicable Regulations:
Type of Inspection:
Participants:
Time of Arrival:
Time of Departure:
Report Prepared by:
June 26"^ and 27'^ 2006
ATK Thiokol Incorporated - Promontory
P.O. Box 707
Brigham City, UT 84302-0707
George Gooch, Manager
Environmental Services
[phone]
UTD009081357 Generator, TSD
RCRA Permit, UAC R315
CEI
Jeff Vandel (TL), DSHW
Bill Wallner, DSHW
Gene Curtis, Thiokol
George Gooch, Thiokol
Randy Oakeson, Thiokol
26 June 06: 9:45 AM
27 June 06: 9:30 AM
26 June 06: 3:30 PM
27 June 06: 4:00 PM
Jeff Vandel
Facilitv Description
The ATK Thiokol Incorporated - Promontory (Thiokol) facility is located in Box Elder County,
approximately 30 miles northwest of Brigham City, Utah. The 20,000 acre plant site is situated
in Blue Creek Valley, north of the Great Salt Lake, along State Highway 83. Blue Creek Valley
is a remote area that opens to the south onto mudflats and wetlands. The closest inhabitants to
the facility live approximately one mile to the west of the administrafion area on a cattle ranch.
The Bear River Migratory Bird Refuge is located approximately seven miles south of the
Thiokol plant site.
Thiokol Propulsion was bought by Alliant Techsystems (ATK) in 2001, and is now the "sister
facility" to the ATK Thiokol Incorporated - Bacchus Works facility (Bacchus). The Thiokol
plant is divided into four major areas designated as: Defense ahd Launch Vehicle (DLV),
Administrative and Manufacturing Area (or Space), Test Area, and High Performance Propellant
Development Area (or Plant III). There are approximately 675 buildings located on the four
areas that comprise the Thiokol plant. Since operations began in 1956, Thiokol has been
primarily involved in the production and testing of rocket motor propellants. These acfivifies
have included the production ahd testing of motors for the Space Shuttle, the wash-out and
reloading of Minuteman ICBMs, and many other projects for the Department of Defense (DOD).
Currently, Thiokol's primary activities consist of motor producfion for the Space Shuttle,
development work for the next generation of space shuttles including the Crew Launch Vehicle
and Heavy Launch Vehicle, restorafion of Minuteman ICBMs, and the producfion and tesfing of
various types of military flares. Thiokol's role in restoring Minuteman rocket motors consists of
the washout of class 1.3 solid propellant from the first and second stages of the motor, open-
burning the third stage and reloading the first stage with new propellant. The second stage of the
Minuteman rocket is sent to Bacchus for reloading; the third stage is also produced at the
Bacchus facility. Rocket motor nozz;les for all three stages of the Minuteman are produced at the
Thiokol Promontory facility.
Thiokol used to reclaim ammonium perchlorate from the washed-out propellant, but the
reclamation process is currently shut down to make improvements in the process. All ofthe
washed-out propellant is managed as hazardous waste and is sent to the M-136 Bum Grounds for
treatment. The reclamafion facility is supposed to be back on-line by August.
Waste Streams and Management Activities
Thiokol generates, treats, and stores characteristic and listed hazardous wastes as defined by
R315-2 ofthe Rules as a result of its manufacturing and demilitarization activities. Thiokol has
RCRA Part B permits for hazardous waste storage, and post-closure care. In addition, Thiokol
treats reactive (and/or ignitable) hazardous wastes by open buming at two separate sites. Open
buming is currently conducted under interim status at both sites, but Thiokol is in the process of
obtaining a Part B permit for this acfivity.
According to Thiokol's 2005 Biennial Hazardous Waste Report, a total of 5,798,660 pounds of
non-wastewater hazardous waste was generated at the Promontory facility in 2005. This figure
is up frorn a total of 2,478,797 pounds of hazardous waste that was reported in Thiokol's 2003
Biennial Hazardous Waste Report. Approximately 94% of the total amount of hazardous waste
generated at the facility in 2005 was scrap propellant and explosives, and reactive, contaminated
debris! All of this material was treated on-site by open buming.
Thiokol generates a large quantity of hazardous wastewater which is treated at its wastewater
treatment facility at building M-705. Hazardous wastewater is also transported to Thiokol for
treatment from the Bacchus facility. The wastewater is shipped from Bacchus to Promontory by
tanker tmck and is documented by hazardous waste manifest. Once received at the Promontory
wastewater treatment plant, the wastewater is pumped into a holding tank. At this point the
wastewater is regulated by the Clean Water Act. From the holding tank, the wastewater is mixed
with wastewater generated on-site, treated, and then discharged to Blue Creek in accordance with
Thiokol's UPDES permit.
Thiokol began accepting waste propellant for open buming from the Bacchus facility in March
of 1998. Thiokol currently receives hazardous waste from the following off-site facilifies:
Autoliv ASP (Promontory and Brigham City), ATK Space Systems (Clearfield, Magna and
Ogden), ATK Thiokol Inc. (West Valley City and Clearfield), and the Kennedy Space Center
(Cape Canaveral, FL). Hazardous wastes that are not treated at Thiokol are stored at the M-186
storage facility until they are shipped off-site for treatment and/or disposal.
Inspection
Credentials, Purpose and Scope
Thiokol was notified of the CEI on June 7, 2006. An invitation to participate in the inspection
was extended to Randy Wilde of the Bear River Health Department, on June 23, 2006. The
inspection was initiated on the moming of June 26th and concluded on the aftemoon of June
27th, 2006. It was stated at the beginning ofthe inspection that it was being conducted to
evaluate Thiokol's compliance with its RCRA permits and the Hazardous Waste Management
Rules (the Rules). Thescope of the inspecfion, and an approximate schedule, was then discussed
with Thiokol personnel. Prior to the inspecfion, it was decided to focus on the following areas:
• Waste analysis data for hazardous wastes received from off-site for open buming
• Receiving records, treatment documentation and inspection records for the M-136 Bum
Grounds
• Inspecfions of the Liquid Thermal Treatment Area (LTTA) caps
• Closed hazardous waste storage buildings M-107, M-340 and S-616
• Waste analysis records for the paint booths at building M-508
• Waste analysis records for "2440" hazardous wastewater from Bacchus
• Permitted storage areas M-186 and M-705
• M-48 AIRCMM Flare Production building
Details ofthe scope ofthe inspection are listed on the Pre-Inspecfion Checklist, which is
included with this report as Appendix A. In addition to discussing the scope of the inspection.
Gene Curtis was asked some general quesfions that were prepared prior to the inspection, to get
current informafion oh hazai^dous waste issues at the facility. These quesfions and the notes
taken while they were disciussed are included with this report in Appendix B.
M-48 AIRCMM Flare Production Building
Thiokol has a contract with the DQD td supply decoy flares to the military. AIRCMM flares are
produced at building M-48, and due to the war in Iraq, the demand for these flares has steadily
increased. The increase in production ofthese flares has resulted in an increase in the amount of
hazardous waste that is generated.
The bulk ofthe hazardous waste that is generated from AIRCMM flare production is plastic
molds that have a thin layer of Class 1.3, potassium perchlorate-based propellant that remains on
the inside of the mold after the flare propellant is cured. Due to the propellant residue on the
molds, they have been characterized as DOOl and D003 characterisfic hazardous waste. These
molds are currently taken to M-136 and treated by open buming.
Other hazardous waste streams that are generated at building M-48 from the production of flares
include waste propellant that is trimmed off the loaded molds, paper trays that have propellant
residue on them and rags contaminated with propellant and solvent residue. These materials are
collected in satellite accumulafion containers that contain shingle oil to desensifize them. No
problems were observed with their rnanagement. All ofthe containers are frequently emptied
into the 90-day hazardous waste storage containers located outside of the building. The wastes
from the 90-day storage area are taken to the M-136 Bum Grounds daily. The 90-day storage
area appears to be well managed.
A copy of the hazardous waste profile for the flare molds was requested. The profile. No. PR 17,
is included with this report in Appendix C. Thiokol has adopted a method for grouping
individual wastestreams, like the plastic flare molds, into waste profiles that are based on the
Propellant/Explosive/Pyrotechnic (PEP) that makes the material hazardous. Based on our
observafions during the inspecfion, the molds appear to be approximately 75% plasfic and 25%
waste propellant. The plasfic portion of the flare, and other similar non-PEP materials like rags,
are considered trash. The percentage by weight for trash, listed under the chemical composition
secfion of profile PR 17, is "various." When the hazardous waste is taken to the 90-day storage
area, the amount of trash in the wastestream is estimated and then written on the hazardous waste
label. A similar procedure is used for solvents that may or may not be a component of a
particular wastestream that is characterized by the profile. If solvents are a component of the
wastestream, it will be indicated on the hazardous waste label, but the profile for the wastestream
just indicates that the waste may contain solvents at a weight percentage of 0 to 10%. In
addition, the type(s) of solvent that may be present aren't specified on the profile.
Due to the huge number of individual wastestreams, like the flare molds, that are generated at the
Thiokol facility, the desire to group them into profiles is understood. However, the
characterization of the flare mold wastestream by profile PR17, for example, is misleading. If
waste propellant only makes up approximately 25% of the wastestream, then the weight
percentage of potassium perchlorate would be more like 17% instead of the 60 to 80% that is
listed on the profile (see profile PR17, Appendix C). However, when the flare molds are taken to
the M-136 Bum Grounds to be bumed, the amount of trash and PEP that is indicated on the
hazardous waste label is recorded in the bum log with the waste profile number and other
relevant informafion.
This issue appears to be limited to wastestreams generated by Thiokol that are various types of
trash contaminated with PEP that are treated on-site by open buming. The characterization of
these materials and associated waste profiles will be addressed through the permitting process
that is currently under way. In addition, Thiokol is currently working with a competent
authority, recognized by the Department of Transportation, to reduce the quantity of waste
materials generated that are characterized as hazardous due to propellant residue (e.g. the flare
molds). If this objecfive is achieved, the material would be classified as flammable solid waste,
not hazardous waste.
Closed Hazardous Waste Storage Buildings M-107, S-616, M-340
Thiokol closed the hazardous waste storage buildings M-107, S-616, and M-340 in January of
2004. These buildings were used briefly for the storage of waste rocket motors. The Division
verified that the storage buildings were closed in accordance with approved closure plans and
Thiokol's Storage Permit. All three buildings were visited once again during the inspection to
confirm that they were not being used for hazardous waste storage. All of the buildings were
empty at the time of the inspection and there were no indications of improper hazardous waste
storage.
Rocket Motor Storage Building S-617
Rocket motor storage building S-617 was also visited during the inspecfion. This building was a
bunker that was used for the storage of rocket motors - not hazardous waste. However, the roof
of the building collapsed on top of a Castor 120 motor in April, 2005. Once Thiokol determined
that the motor couldn't be saved, the motor was designated as hazardous waste and Thiokol
obtained an emergency permit to treat the motor in-place by open buming. The treatment of the
motor occurred in October, 2005. It: was observed during the inspection that the metal parts of
the motor casing remain at the site.
M-136 Burn Grounds
M-136 Bum Ground Operations
The vast majority of reactive hazardous wastes that are open-bumed at Thiokol are bumed at the
M-136 Bum Grounds. Currently, open buming is conducted several times each week at
M-136. The Bum Grounds are located within Thiokol's secured area, and entry into the Bum
Grounds is further controlled by a gate at the access road. The Bum Grounds are equipped with
video cameras, an alarm system, and a bunker from which bum events are monitored and
controlled.
Open buming is mainly conducted in steel pans or trays that are set on metal I-beams so they
don't sit directly on the dirt and gravel pads. Thiokol continues to bum third stage Minuteman
motors in an earthen, unlined pit (the third stage of the motor has a composite case and is open
bumed). The motors are. unloaded off a flat-bed truck with a crane and placed in the pit. The
casing of the motor is split open and the propellant is ignited with linear charges. The ash and
debris remaining after the motor is bumed are characterized as non-hazardous, and are placed in
the unlined Industrial Waste Trench (IWT), located within the boundary of the Bum Grounds.
Ash and debris removed from the bum trays have been characterized as non-hazardous and are
also disposed of in the IWT. If a complete bum of hazardous waste isn't accomplished, the
waste is re-bumed using "donor" reactive material. Thiokol has obtained a permit from the solid
waste branch for the IWT.
Based on Thiokol's two most recent Biennial Hazardous Waste Reports, the quanfity of
hazardous waste that was treated by open buming at M-136 increased from 2,322,075 pounds in
2003 to 5,798,407 pounds in 2005. This represents an increase of 150%. The majority ofthe
hazardous waste that is treated at M-136 is generated on-site, however wastes are received from
other ATK Thiokol and Autoliv facilities for treatment as discussed above. Generally, two
shipments of hazardous waste are received from the ATK Thiokol - Bacchus facility each
month.
The issue of buming hazardous waste received from off-site within 24 hours was discussed
during the inspecfion. Thiokol has stated that this time limitafion has become a safety concem
because it has forced them on a number of occasions to msh the preparation of the waste for
buming, and not take the fime needed to manage it more carefully. Thiokol is planning to
request a modification to the Storage Permit to allow storage, on a limited basis, in the bum
trays.
M-136 Liquid Thermal Treatment Areas
The caps on the old "LTTAs," that are located within the boundaries of the Bum Grounds, were
inspected to see if they were being maintained. The ruts that were previously observed have
been repaired. Rock has been added to the caps in some areas, and signs that read "Caution -
Environmental Site" have been erected. Thiokol has been inspecting the LTTAs, as required,
using the inspecfion forms that were revised after the last CEI.
M-136 Bum Grounds Operating Record
The operafing record for the M-136 Bum Grounds was evaluated by selecting several shipments
of hazardous waste from the most current Semiannual Manifest Summary and reviewing the
applicable documentation. The documents that were reviewed included: the hazardous waste
manifest, the waste analysis documentation, the bum ground record, and the certificate of
disposal. Inspection records for the Bum Grounds were also reviewed. With the exception of
the waste characterization and profile issue discussed above, no problems with the operating
record were observed.
S-633 90-Day Hazardous Waste Storage Area
The S-633, 90-day hazardous waste storage area is located near the M-136 Bum Grounds, inside
the fence and gate that restricts access to the facility. At the time of the inspection, two third-
stage Minuteman motors were stored in the area along with two "palletainers" that contained
space shuttle propellant. These items are typically grounded by connecting them to metal ground
cables. It was observed during the inspection that one of the Minuteman motors and one of the
"palletainers" were not grounded. The most recent inspection record that was completed prior to
the CEI indicated that the items were properly grounded. This issue was discussed with the
responsible Thiokol personnel, and they corrected the problem. The items were properly labeled
and no other problems were observed.
M-186 Hazardous Waste Storage Area
The M-186 hazardous waste storage area is the primary, permitted storage facility at Thiokol.
Access to the facility is controlled by the gate at the entrance to the M-136 Bum Grounds. An
addifional fence surrounds the storage area, and appropriate signs are posted on the fence at the
entrance and other locafions. The facility is enclosed on three sides and has a roof The floor is
sealed concrete, and is sloped towards collecfion sumps.
The inspection ofthe storage area included an examination of the containers, hazardous waste
labels, the eyewash and shower stations, fire exfinguishers, sumps, and grounds. A copy ofthe
confingency plan is kept at the facility. One of the aisle spaces between two rows of drums was
only approximately two feet wide. This space was adequate to conduct inspecfions and access
the drum labels, but somewhat narrow for moving equipment (e.g. an over-pack dmm) through.
A specific distance for aisle space isn't specified in the storage permit, although the State rule
(R315-8-3.6) is referenced. The state rule requires adequate aisle space for the "unobstmcted
movement of personnel, fire protection equipment, discharge control equipment, and
decontaminafion equipment to any area of facility operafion in an emergency." Upon further
review ofthe aisle space requirement, it was determined that the movement of equipment and
personnel during an emergency response was not obstructed since the drums on both sides of the
narrow aisle space could be accessed by wider spaces on the outside of the rows of drums. In
addition, the current configuration works better for keeping incompatible wastes confined to
designated bays at the storage area. No other issues were identified from the inspecfion of the
storage area.
Waste Analysis Records
Thiokol's waste analysis of on-site and off-site generated hazardous wastes is based on waste
profiles. These profiles are compiled either from analytical results, generator knowledge
informafion, or both. In addition to the waste profiles discussed above, waste analysis records
were requested for paint booth filters from the paint booths at M-508 and wastewater shipped
from the Bacchus facility (referred to as "2440 water") to be treated at Thiokol's wastewater
treatment plant.
M-508 Paint Booth Filters
Thiokol had waste analysis documentation on file for the paint booth filters that are generated at
building M-508. Based on the records that were provided, Thiokol has characterized this
wastestream as hazardous waste. This waste is stored, along with other similar wastes, in a roll-
off box at the M-186 storage area unfil it is shipped off-site for incinerafion. No problems with
the waste analysis records were observed.
Bacchus "2440 Water"
The "2440 Water" that is generated at the Thiokol Bacchus facility is made up of wastewater
collected from many different locafions on the plant. Based on historic analytical results, the
wastewater has been characterized as hazardous waste. Due to the varied nature of this
wastestream, waste analysis records were requested to compare them with previous results and to
see if they are kept current. This wastestream, typically analyzed annually, was last sampled in
January 2005. The 2005 analytical results show a high level of 1,1,1-trichloroethane in addition
to a number of other volafile organic compounds. Volatile organic compounds weren't detected
in the 2004 analytical results. The levels of metals and perchlorate that were detected in 2004
and 2005 were quite similar. Although the levels of consfituents in the wastewater may vary
with fime Thiokol always assumes it is hazardous waste and manages it accordingly.
Compliance Status
R315-2 General Requirements
2-6 Requirements for Recyclable Materials - OK
R315-3 Application and Permit Procedures for Hazardous Waste Treatment, Storage, and
Disposal Facilities
3-1 General Information - OK
3-2 Permit Application - OK
3-3 Permit Conditions - OK
3-4 Changes to Permit - OK
3-5 Expiration and Continuation of Permits - OK
3-6 Special Forms of Permits - OK
3-7 Interim Status - OK
I R315-5 Hazardous Waste Generator Requirements
5-1 Purpose, Scope and Applicability - OK
5-2 The Manifest - OK
5-3 Pre-Transport Requirements
3.34 Accumulation Time - During the inspection, the inspectors observed that ground
cables, used to help prevent accidental ignifion of stored reactive wastes, were not
connected to a waste rocket motor and a "palletainer" containing reactive hazardous
wastes that were stored at the S-633 90-day storage area. Although the Utah Hazardous
Waste Management Rules don't address ground cables specifically, 40 CFR 265.31
(incorporated by reference) states that facilities must be maintained and operated to
minimize the possibility of a fire or explosion. The Division will remind Thiokol of this
requirement and emphasize the importance of keeping ground cables attached to
minimize the possibility of accidental ignifion of these wastes. During the inspection,
Thiokol personnel corrected the problem once they were notified.
5-4 Recordkeeping and Reporting - OK
R315-8 Hazardous Waste Treatment, Storage, and Disposal Facility Requirements
8-1 Purpose, Scope and Applicability
8-2 General Facility Standards
2.1 Applicability - The regulafions in this section apply to Thiokol
2.2 Identiflcation Number - OK
2.3 Required Notices - OK
2.4 General Waste Analysis - OK, issues regarding Thiokol's approach to profiling
certain hazardous wastes that are open-bumed on-site will be addressed through the Part
B Permit process.
2.5 Security - OK
2.6 General Inspection Requirements - OK
2.7 Personnel Training - OK
2.8 General Requirements for Ignitable, Reactive, or Incompatible Wastes - OK
R315-8-;3 Preparedness and Prevention
3.1 Applicability - The regulafions in this section apply to Thiokol
3.2 Design and Operation of Facility - OK
3.3 Required Equipment - OK
3.4 Testing and Maintenance of Equipment - OK
3.5 Access to Communications or Alarm System - OK
3.6 Required Aisle Space - One of the aisle spaces observed during the inspection at the
M-186 Hazardous Waste Storage Area appeared to be too narrow for the unobstructed
movement of fire protecfion equipment, discharge control equipment, or decontamination
equipment. Upon further review of the aisle space requirement, it was determined that
the movement of equipment and personnel during an emergency response was not
obstructed since the drums on both sides of the narrow aisle space could be accessed by
wider spaces on the outside of the rows of drums. In addifion, the current configuration
works better for keeping incompatible wastes confined to designated bays at the storage
area.
3.7 Arrangements with Local Authorities - OK
R315-8-4 Contingency Plan and Emergency Procedures
4.1 Applicability - The regulafions in this section apply to Thiokol
4.2 Purpose and Implementation of Contingency Plan - OK
4.3 Content of Contingency Plan - OK
4.4 Copies of Contingency Plan - OK
4.5 Amendment of Contingency Plan - OK
4.6 Emergency Coordinator - OK
4.7 Emergency Procedures - OK
R315-8-5 Manifest System, Recordkeeping, and Reporting
5.1 Applicability - The regulations in this section apply to Thiokol
5.2 Use of Manifest System - OK
5.3 Operating Record - OK
5.4 Manifest Discrepancies - OK
5.5 Availability, Retention, and Disposition of Records - OK
5.6 Biennial Report - OK
5.7 Unmanifested Waste Report - NA
5.8 Additional Reports - OK
R315-8-7 Closure and Post-Closure - OK
R315-8-8 Financial Requirements - Not reviewed during this inspection
R315-8-9 Use and Management of Containers
9.1 Applicability - The regulafions in this secfion apply to Thiokol
9.2 Condition of Containers - OK
9.3 Compatibility of Waste with Containers - OK
9.4 Management of Containers - OK
9.5 Inspections - OK
9.6 Containment - OK
9.7 Special Requirements for Ignitable or Reactive Waste - OK
9.8 Special Requirements for Incompatible Wastes - OK
9.9 Closure - NA
9.10 Air Emission Standards - OK
R315-8-16 Miscellaneous Units - OK
R315-13-1 Land Disposal Restrictions - OK
Date
10
APPENDIX A
Pre-Inspection Checklist
Facility: ATK Thiokol Inc.
Promontory Facility
EPA ID #: UTD009081357
Address: ATK Thiokol Inc.
Promontory Facility
P.O. Box 707
Brigham City, UT 84302-0707
Type of Inspection: Compliance Evaluation Inspection (CEI)
Date of Inspection: June 26 & 27, 2006
Team Leader: Jeff Vandel
Team Members: Bill Wallner
Pre-Inspection Conference
Date: JW^- '^3 Time: 3-<^/7^
Inspecfion Scope:
Look at waste analysis data for wastes received from off-site for open buming (waste
shipments picked from manifest summary)
Look at receiving records, treatment documentation and inspection records for M-136
Inspect LTTA caps for ruts and check that new checklists are in use
Inspect closed storage buildings (M-107, M-340, and S-616).
Inspect paint booths at building M-508, waste analysis for air filters?
InspectPermittedStorage Areas (M-186, M-705, E-501). ,
Waste profile/analysis for "2440" water from Bacchus facility
M-48 AIRCMM Flare Production Building
Safety Equipment: PPE
Inspection Notification: {indicate the contact and the date and time of contact)
Facility: Gene Curtis, ATK Thiokol - Promontorv, June 7, 2006
• Local Health Department: Randv Wilde, Bear River Health Dep't., June 23, 2006
Team Leader: aUf- VOAAA^A
Supervisor: fJAf^ fAAAAJr\
6
APPENDIX B
ATK Thiokol Propulsion - Promontory
2006 RCRA Compliance Evaluation Inspection
General Information
1. Describe the primary activities that are currently being conducted at the Promontory
facility?
Production (space shuttle motors, other motors or energetics?):
(•itoyM'^i /^L-nAck lA-ti'cK. - /cv c^MY^vno/rf ^ c/c..
:JA/^4 W'W' ' Al^Cf^'^ ^("-^ l^^do^iA^v^ "I
Demilitarizafion:
'X^ft^ <,ia.<^V 1^ 0(^^UA ^oViAcJ <x-{ /^~)36
2. What hazardous wastes does Thiokol currently accept from off-site for treatment
(hazardous wastewater, waste propellant, etc.)?
-^ acc^vs>b/^o4 ^^-l^/s ' cu/^vw-f^) ^'•-^ /? wd/Zaacis
3. What are the main sources of the hazardous waste that is bumed at M-136? (^ /t<jt
<;Ui^^t /^oW iA/«^5-^^
4. What are the main sources of the hazardous waste that is bumed at M-225?
o^i Fl^-lr HT
5. Have any Zone of Engineering Control (ZOEC) samples been collected since July
2004? What were the results?
6. Are any wastes received from off-site disposed of in the on-site, solid waste landfill?
If so, what are they?
APPENDIX C
ATK
ALLIANT TECHSYSTEMS
THIOKOL PROPULSION
m /"^ / /-I
•^Approyedj..!::__: .^1 v^^:; -DateK51!!l£2Q04
1ii'^:
REACTIVE WASTE PROFILE
OPEN BURNING
(Thiokol Generated)
II.
Generator Information
Waste Generation Point:
Main Plant E
Plant 3 |x]
Waste Stream Information
Energetic Waste Type: GAP KP Boron Class 1.3 Propellants - Isocyanate cured
Process Generating Waste: Rocket motor mix/cast processing, laboratory evaluation
-"^t^flS^ens^zation^eqij'il^ftniBi^^ V'\~\ No
rVD'esensjti^mg ifiateria^ -jj.-.'*\ ' !
:• .j^ar.t^. =^7»'*^:.e:si',*a^^.-JMfcCW t SpecialrdisposallinstructiGnsi^^S-
<!*M..
n:f,^--iA:y-
f-il- •^'
UL Waste Characteristics
1. Phvsical State:
[x] Solid {2 Liquid
Color of waste: Various
I I Sawdust absorbed liquids
Hazardous Properties - check all that apply:
I I Water reactive LJ ^i"" reactive
I I Chemically unstable LJ Peroxides
\x\ Impact sensitive [xJ Static sensitive
I I Ability to detonate List conditions:
I I Radioactive Q Pyrophoric
[xl Explosive [x] Friction sensitive
PROFILE NO. PR17
IV.
v.
3. Packaging
iXl Super sack [x] Pink poly [xJ Conductive plastic bag
I I Other, specify:
[x] Sling Bag
RCRA Information
1. Listed wastes: Does the waste contain any EPA listed wastes (F, K, P, or U)?
uil Yes I I No List all codes: Possible solvents
2. Characteristic wastes:
Yes
DOOl X
D002 •
D003 X
No
X
(check all that apply)
Water reactives
Reactive cyanides
Chemically unstable
Explosives
Yes
[x]
No
X
X
X
Indicate Explosive Class: 1.3C (USDOT Classification)
List other characteristic codes:
3. Indicate if the waste contains any of the following:
I—I Asbestos I—I Compounds that will form highly toxic combustion products
4. Are there any underlying constituents? [x] Yes |_J No
Ifyes list: Possible solvents
Chemical Composition
List all materials present. Specified ranges of ingredients other than trash must not be greater than 30%.
Totals must equal or exceed 100%.
Materials
1. Trash (Indicate quantity on "Hazardous Waste Propellant Label")
2. Solvents (If any present - indicate type and code on label)
3. GAP (Glycidal Azide Polymer)
4. Isocyanate Curatives or Processing aids: IPDI, DDI, N-l00, TMXDI, ODI
5. Boron
6. Potassium Perchlorate
Weight % Ranges
Various
0-10
20-50
0.1-5
5-20
60-80
This section must be completed as accurately as possible with common or generic chemical names.
PROHLE NO: PRI7-
VI. Shipping Information (Shipper is responsible for proper DOT container, and packaging.)
All explosive shipments must be classified by USDOT and have either an EX number or an Interim Hazard
Classification prior to transport on a public road. Proper UN packaging, labeling and shipping papers are
required for all shipments on a public highway.
VII. Burn Ground Ash Information
Can the ash from burn ground disposal be anticipated to create any unusual hazards, such as: high water
reactivity, very high/low PH, high toxicity, residual characteristic metals, etc? Indicate any unusual
anticipated hazards below.
Signature of Generator Q^inCCnt GL. OMoncini Date: 11-06-03
Template Rev. l9MaK)3