DSHW-2009-014967 - 0901a06880154d38

Michael O. Leavitt
Govtrnor
Dianne R. Nielson, Ph.D.
Ejtecutive Director
Dennis R. Downs
Director
Stare of Utah
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF SOLID AND HAZARDOUS WASTE
Ru
288 North 1460 West
P.O. Box 144880
Salt Lake City, Utah 84114-4880
[phone] Voice
[phone] Fax
[phone] T.D.D.
DSHW TN
1995.20837
January 26, 1995
Mr. Joe D. Thompson, Director
Waste Management and Environmental Services
Thiokol Corporation
P.O. Box 689
Brigham City, UT 84302-0689
Re: Solid Rocket Motor Disposal Facility
UT 009081357
Dear Mr. Thompson:
On January 17, 1995 a site inspection was conducted at the Thiokol Solid Rocket Motor Disposal
(SRMD) facility to ensure that the RD&D Hazardous Waste Permit construction certification
requirements were satisfied. The following people attended the site inspection:
Hal Jaussi - Thiokol
Glenn Mower - Thiokol
Kevin Downey - General Atomics
Raymond Duda - Utah DSHW
Jerry Parkin - Utah DSHW
Otis Willoughby - Utah DSHW
The following items were observed during the construction inspection and discussed during the
post inspection meeting. These deficiencies will need to be corrected before the construction
certification can be considered complete.
1) A copy of red-lined drawings were reviewed prior to the site inspection. Some of
the equipment arrangements have changed, and therefore, the RD&D Pennit
General Arrangement and Flow Sheet drawings will need to be changed and
submitted to the DSHW as a Class 1 permit modification. If the permit
modification is approved, the revised drawings must be identified as "As Built."
All four General Arrangement and the Flow Sheet drawings should become part
of the Permit documents.
Printed on recycled paper
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January 26, 1995
Page 2
2) Thiokol changed the name of the process from Super Critical Water Oxidation
(SCWO) to High Temperature Oxidation (HTO). Both names should appear on
the drawings to minimize confusion with the permit language.
3) The tank certification by R&M Engineering Consultants only verified the seismic
design of the Super Critical Water Oxidation (SCWO) tank skid. This
certification does not satisfy the Permit Condition IV.G.3. for the SCWO reactor.
None of the other tank certifications were available. Permit Condition IV.A.l.
requires tank assessments in accordance with UAC R315-8-10 (40 CFR 264.192(a)
by reference) prior to the completion of the construction certification.
4) The Oxidation Reactor was not installed. The length of this unit apparently has
been decreased from 10 feet 0 inches to 6 feet 0 inches. A Class 1 permit
modification will need to be submitted for this change. An independent
engineering certification will also be needed for this tank after it is installed.
5) Only one Propellant Storage Tank was built and installed. The size of the tank
is different than the permit description. The independent engineering certification
should include an evaluation and a statement about the maximum capacity of this
tank. The existing tank appears to be larger than the permit capacity of 600
gallons. A permit modification must be submitted for this change; the class of
modification will depend on the capacity difference between the permitted tank
and the as-built tank.
6) The dimension and material of construction of the Mix Tank is different than the
permit description. The independent engineering certification should include an
evaluation and a statement about the maximum capacity of this tank. The existmg
tank appears to be larger than the permit capacity of 300 gallons. A permit
modification must also be submitted for this change; the class of modification will
depend on the capacity difference between the permitted tank and the as-built
tank.
7) The dimension and material of construction of the Effluent Storage Tank is
different than the permit description. The independent engineering certification
should include an evaluation and a statement about the maximum capacity of this
tank. The existing tank appears to be larger than the permit capacity of 600
gallons. A permit modification must also be submitted for this change; the class
of modification will depend on the capacity difference between the permitted tank
and the as-built tank.
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January 26, 1995
Page 3
If the capacities of the permitted tanks have been increased by more than 25%, a Class 3 permit
modification request will be required. If the replacement tank meets the same design standard and
the capacity does not change by more than ± 10%, it can be a Class 1 permit modification. Other
capacity changes will be considered a Class 2 modification.
All the construction changes can be included in one Class 1 modification and should be
documented on the "As Buih" drawings. Permit Conditions and Attachments should also be
changed if applicable.
As discussed during the inspection, it may be possible to approve the construction certification
f6r the motor washout facility separately. However, waste placed in the Hydrolysis Tank must
be removed within 96 hours m accordance with Permit Condition IV.A.2.
After these discrepancies are resolved, and all the documentation has been submitted and
ac'cepted, another site inspection will be needed to verify that the construction certification is
complete. Please contact Otis Willoughby at [phone] to schedule the next site visit.
Sincerely,
)ennis R. Downs
Executive Secretary
Utah Solid and Hazardous Waste Control Board
DRD\OHW\ow
c: John C. Bailey, M.D., M.S.P.H., Health Officer/Department Director,
Bear River District Health Department