DSHW-2006-002619 - 0901a0688013d940

ATK
ALUANT TECHSYSTEMS
RECEIVED
UIAH UIVIiilUlM Ol-
SOLID & HAZARDOUS WASTE
ATK Thiokol Inc.
P.O. Box 707
Brigham City, UT 84302-0707
Tel [phone]
Fax [phone]
August 29, 2006
8200-FY07-040
Dennis R. Downs
Division of Solid and Hazardous Waste
Department of Environmental Quality
P. O. Box 144880
Salt Lake City, UT 84114-4880
RE: ATK-Thiokol, Promontory EPA ID # UTD009081357
Response to Your Letter Dated August 17, 2006, Regarding More Detailed
Information for Temporary Authorization Request,
Dear Mr. Downs,
ATK Thiokol-Promontory (ATK) appreciates your timely assistance in addressing our
Temporary Authorization request. ATK has prepared this letter to address those items for which
you requested additional information.
R315-8-9.2,9.3 & 9.4 - All packaged waste received from off-site at the M-136 bum grounds
will be containerized in one of the following USDOT approved or UN packages:
• Cardboard box lined with plastic
• Slid (Sona tube secured to a pallet and covered with plastic) with plywood shipping
cover removed prior to placement into the bum tray
• Fiber drum with or without plastic liner
• < 119 gallon plastic box lined with a sling bag and banded to a pallet. Sling bag will be
removed from the plastic box prior to placement into the bum tray.
All ofthe above containers will be inspected for holes, cracks, gaps and general package integrity
prior to placement into the bum tray. The containers will also be checked to verify proper
closure, in preparation for storage. Containers found to be leaking or in poor condition, will be
transferred to a good container to prevent leakage into the environment.
All containers used for storage of energetic waste will be compatible with their contents. These
containers will be closed at all times, except when adding or removing waste, and will be
handled with care to avoid leakage.
R315-8-2.6 & 9.5 - A weekly inspection form is attached to this submittal for your review. All
items on this form will be inspected on the day waste is received, then once each calendar week.
In addition to this inspection schedule, loading, unloading and roadway areas will also be
inspected for signs of spillage each day waste is received. The weekly inspections will also look
at labeling, closed containers and tray conditions. Trays in poor condition, which could lead to a
release to the environment, will not be used. Any problems detected during these inspections
will be noted in the comment section, and corrective actions noted on a subsequent inspection
form. All tray numbers used for storage of off-site reactive waste is also noted on the inspection
form.
A copy of the inspection form for the brush truck with associated emergency equipment needed
to contain brush fires is also included for your review. This form is maintained by the ATK Fire
Department, while the weekly inspection records are stored in central files.
R315-8-9.6 - All reactive waste received from off-site is in solid form. However, some of this
waste may include various RCRA non-hazardous oils or water used to desensitize the energetic
waste. Therefore, all steel trays holding liquid waste are closely inspected to make sure they are
in good condition, and capable of containing free liquid. Upon inspection, any significant
rainwater accumulation in the tray is removed before placement of the waste. The containment
capacity ofeach tray greatiy exceeds the volume ofthe desensitizing liquid and provides enough
capacity for a substantial rainfall event. Significant rainwater will be removed from the tray
prior to use, and taken to our UPDES permitted facility for proper treatment and subsequent
discharge. The open top design ofthe bum trays simplify the removal of liquid, without the need
of sloped trays.
The bum trays are constructed of 3/8" to 1" thick steel with minimum 12" high sidewalls. Each
liquid tight tray is elevated on a beam or forklift channel, which helps prevent run-on.
The waste covered under this Temporary Authorization does not contain any ofthe EPA codes
specified in R315-8-9.6 (d)(1).
R315-8-9.7 & 9.8 - Ail reactive waste shall be stored at least 50' from the facility property line.
Precautions shall be taken to prevent accidental ignition by following ATK standard operating
procedures (SOP's). These procedures help to protect energetic waste from exposure to sources
of ignition include, but are not limited to: smoking, open flames, sparks, frictional heat, static,
etc. SOP's also require that incompatible waste be placed into separate secure trays for storage
and treatment.
All containers, in which the waste is placed, will be clearly marked with the words "Hazardous
Waste" and the date when storage at M-136 began. This labeling and dating practice will be
followed for all waste received from off-site and not bumed within 24 hours.
Thanks for your help in addressing this issue. If you have any questions or need additional
clarification, please contact Gene Curtis ofmy staffat [phone].
Sijicerely, .^ /J^^^
David P. Gosen, P.E.
Director, Environmental Services
C: Jeff Vandel, DSHW
THIOKOL FIRE PREVENTION
EQUIPMENT INSPECTION RECORD
,:jDAiLY.VisuAL CHECKS
Coolant Leaks
Oil Leaks
Pump Fuel Level
Water Tank Leaks
Water Tank Level
Tires
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Horn and Siren
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TYPE OF EQUIPMENT
Brush Truck
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WEEKLY CHECKS
Engine Oil Level (Sunday)
Road Test (Sunday)
Pump Oil Level (Thursday Swing)
Pump Run Engine 15 min. (Thursd ay Swi ng)
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MoNTEiiA CHECKS
Radiator Level (First Sunday Of The Month)
Tire Pressure Checked & Filled (First Sunday Of The Month)
DA^ INITIALS RE\L\RKS
Front PSI | 1 BACK PSI 1 SUGGESTED TIRE PSI 80 1
MAINTENANCE & SERVICE
DATE OUT TIME OUT DATE IN TIME IN TOTAL HOURS
DOWN
DESCRIPTION OF PROBLEM
OTHER EQUIPMENT ASSIGNED WITH BRUSH TRUCK
WEEKLY CHECKS
Station Back up Generator Oil Level (Thursday Swing)
Station Back up Generator Run Engine 15 min. (Thursday Swing)
Station Back up Generator Fuel Level (Thursday Swing)
Station Back up Generator Battery Water Level (Thursday Swing)
WEEK
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REMARKS
EQUIPMENT INVENTORY
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Set Master Keys (3 Keys)
Can Of Matches
Pair Binoculars
Set Jumper Cables
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Shovels
Pick Head Ax
Polaskis Ax
McCloed Rake
Reserve Fuel Can (5 gallons)
Drip Can
Ice Chest (Check Ice and Drinks)
5 Gallons AAA Foam
MriW^iHHi^SS^BBI'
Chock Block
Bladder Packs
Emergency Shelters
Canteens
Radio Chest Carrying Case
Drum wrench
Goggles
Wildland Packs
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Forestry Nozzle
Combination Nozzle
Spanner Wrench
Pin Lug Wrench
Water Jug
Torch Kit
Set Bolt Cutters
100'Roll Forestry Hose
Hydrant Wrenches
1" Nozzle
Tow Strap
Lifepak 500 Defibrillator
First Aid Kit
Roll Caution Tape
Foam Pack
Headlamps
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WEEKLY OFF-SITE WASTE STORAGE INSPECTION FORM
M-136 BURN GROUNDS
Trav numbers used for storage
Transportation Corridor
Roadway (spillage) '•^
Loading/unloading areas ''"^
Storage Containers
Containers closed '
Container properly labeled '
Signs of leaks or spills
Bum tray (holes, water,
deterioration) '
Waste stream is consistent
with manifest & profile
Satisfactory
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Unsatisfactory - ^
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Comments/Corrective Actions
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Signature: Date: Time:
Inspect upon arrival, then each calendar week
Requires comments/corrective action
Daily inspection when in use
Inspection form to be kepi at facility for 3 years