DSHW-2009-018114 - 0901a0688015829d

TO:
MEMORANDUM
Thiokol Corporation File
UTD 009081357
FROM: Jeff Vandel
Envtronmental Scientist
THROUGH: Brad Maulding \^CtA
Hazardous Waste Facilities Manager
DATE: December 27, 1999
SUBJECT: Results of Public Comment Period, and Minutes of Public Hearing for Thiokol's
Proposed Class 111 Post-Closure Permit Modification
A Public Hearing was conducted by the Division of Solid and Hazardous Waste (the Division) on
December 1, 1999 at the Brigham City Public Library to receive comments on Thiokol's
proposed Class III Post-Closure Permit Modification. No members ofthe public attended the
hearing, and therefore, no comments were received.
Thiokol requested to modify the pennit in order to reduce the number ofgroundwater samples
collected from each weU, and to eliminate the requirement to analyze for specific constituents
(List 3 ofthe Post-Closure Permit). Thiokol has maintained a groundwater monitoring system
since 1986 to track the location and concentration of hazardous constituents that have been
released to the water-table aquifer.
The second public coinment period for the Permit Modification began on October 29, 1999 and
ended on December 15, 1999. No comments were received from the public.
Approval of the Permit Modification wiU allow Thiokol to collect Just one sample semiannually
from the compliance monitoring wells instead of four. In addition, Thiokol will no longer be
required to sample for the List 3 constituents once every three years, however, it will still be
required to sample for the List 1 constituents semiannually, and the List 2 constituents annually.
The Hearing Statement that was prepared for the Hearing is attached to this memorandum.
STATEMENT OF HEARING OFFICER
FOR PUBLIC HEARING
Thiokol Corporation
Public Hearing to Accept Comments on a
Request to Modify the Post-Closure Permit
December 1, 1999
Brigham City Library
2:00 P.M.
Hearing Officer: Jeff Vandel
Ladies and Gentlemen, I call this hearing to order. My name is Jeff Vandel. I represent the Utah
Solid and Hazardous Waste Control Board and have been appointed by the Executive Secretary
ofthe Board as the hearing officer. This is a hearing to receive public comment on Thiokol's
request to modify its Post-Closure Permit, and is being held under the authority of Title 19,
Chapter 6, Section 104 ofthe Utah Code Annotated, 1953 as amended.
In September of 1992, the Utah Solid and Hazardous Waste Control Board issued Thiokol a
Post-Closure Permit for the hazardous waste treatment and disposal units that were operated at
the facUity. Prior to 1988, waste treatment and disposal practices at the facility resulted in the
release of a nuinber of hazardous constituents to the water table aquifer. The Post-Closure Permit
outlined the conditions for closure ofthe units, and groundwater monitoring requirements.
Thiokol has requested to modify the Post-Closure Pemnit in accordance with Resource,
Conservation and Recovery Act (RCRA) regulations. The requested Permit modification pertains
to two groundwater monitoring requirements.
First, the Permit requires that four groundwater sainples be coUected froin each compliance well
on a semiannual basis. The requirement for collecting four samples from each well per sampling
event was put into the Permit in 1992 in order to perform a particular statistical analysis on the
analytical results. Thiokol has requested to reduce the number of samples collected semiannually
from each well from four to one.
Thiokol has collected groundwater samples from approximately 60 different weUs since 1986.
Twelve ofthese weUs are identified in the Perinit as "compliance wells." Four samples have been
collected from each one ofthe compliance wells on a semiannual basis since 1992. Statistical
analyses that have been conducted on the analytical data associated with these wells has clearly
shown that there has been a release of specific hazardous constituents to the groundwater.
Thiokol does not dispute this finding. The statistical procedure that requires four samples per
sampling event is no longer necessary to demonstrate that certain constituents have been released
to the groundwater, and is not currently being conducted. In addition, the EPA no longer
recommends this particular statistical procedure.
The Division of Solid and Hazardous Waste (the Division) and Thiokol both believe that
resources would be better utilized to sample other wells further down-gradient rather than
continuing to collect four samples semiannually from the compliance wells.
The second requested modification pertains to a requirement to sample each compliance well for a
Hst of specific constituents once every three years. When the permit was written, it was unclear
what all ofthe constituents were that had been released from the hazardous waste treatment and
disposal units. Constituents that were restricted from land disposal, but were not handled at
Thiokol or previously detected in groundwater samples, were put on "List Three" of the Permit.
The Permit requires that Thiokol coUect one sample from the compUance weUs every three years
to be analyzed for the List Three constituents. Thiokol coUected samples for this analysis during
the foUowing years: 1989, 1990, 1991, 1993, and 1996. Based on the analytical results ofthe
groundwater samples coUected during these years, it does not appear that any ofthe List Three
constituents have been released to the groundwater.
If the Permit Modification is approved, Thiokol wiU no longer be required to sample for these
constituents every three years, however, it is stUl required to sample for the "List 1" constituents
semiannuaUy, and the "List 2" constituents annuaUy.
The public notice for this hearing and the associated pubUc comment period was pubUshed in the
October 29, 1999 edition of The Herald Journal, The Ogden Standard Examiner, Salt Lake
Tribune, and the Deseret News. AdditionaUy, notice of this hearing was maUed to members of the
pubUc who in the past have indicated a desire to be notified of such activities and was broadcast
on KSL radio. The pubUc comment period for this Permit Modification request began on October
29, 1999 and wUl conclude on December 15, 1999. A pubUc information meeting was held on
September 23, 1999 at the Brigham City PubUc Library to explain the proposed Permit
Modification and to answer questions. Copies of the Draft Permit Modification have been and are
avaUable for examination and pubUc review at: the office ofthe Division of SoUd and Hazardous
Waste, 288 North 1460 West, Salt Lake City, Utah; the Brigham City Library, 26 East Forest
Street, Brigham City, Utah; and the Bear River District Health Department, 655 East 1300 North,
Logan, Utah.
Opportunity wiU be provided to any person desiring to participate in this hearing. Written
coinments concerning the Permit Modification request wUl be received, and accepted for the
record, no later than 5:00 P.M., December 15, 1999. Oral comments wUl be accepted at this
hearing, time permitting.
These proceedings are bemg recorded and a transcript of these proceedings wUl be avaUable for
pubUc inspection at the Division of SoUd and Hazardous Waste, 4th Roor ofthe Martha Hughes
Cannon Health BuUding.
This is an administrative hearing and as such there wUl be no cross exammation of any
participants. Those who have questions or comments to make should state their names and direct
their questions or coinments to me. I ask that you confine your remarks to the Perinit
ModUncation request, and related issues, and Umit your remarks to 10 minutes or less. Comments
that are not pertinent may be ruled out of order.
It is the poUcy of the Department of Environmental QuaUty that this hearing remain in session for
at least one hour. If, during that hour, there comes a time when there is no one desiring to make a
comment or ask a question, the hearing wUl be recessed. At the end of the hour or when there is
an indication that someone would Uke to make a comment or ask a question, the hearing wUl be
reconvened and the record reopened. This hearing wUl then be concluded after aU those who
desire to make a comment have done so.
Written comments may be submitted in person to the Division of SoUd and Hazardous Waste,
Fourth Floor ofthe Cannon HeaUh BuUding or they may be maUed to Dennis R. Downs,
Executive Secretary, Utah SoUd and Hazardous Waste Control Board, P.O. Box 144880, Salt
LakeCity, Utah 84114-4880.
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Thiokol Corporation
Public Hearing on Thiokol's
Request to Modify Its Post-Closure Permit
Brigham City Library
December 1,1999
2:00 PM
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