DSHW-2013-003246 - 0901a0688037832d

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State of Utah
GARYHERBERT
Govetnor
GREGBELL
Lieutenant Governor
May 14,2013
George Gooch, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham City, UT 84302-0707
RE: Disassembly of Off-Specification Flare Igniter
ATK Launch Systems - Promontory Facility
uTD009081357
Dear Mr. Gooch:
This letter is in response to your correspondence dated April 18,2013 regarding ATK's proposed
operation to disassemble off-specification flare igniter assemblies. As stated in your letter, ATK
provided additional information on the disassembly process and you and members of your staff
met with representatives of the Division to discuss the operation.
It is understood that ATK intends to disassemble the flare igniter assemblies in order to recycle all
of the components of the assembly except for the striker component. The striker contains primer
which initiates the ignition ofthe flare. As you stated, in order to safely disassemble the igniter
assembly, the primer needs to be manually fired.
In your letter, ATK requests a determination from the Division on the regulatory status of the
primer. ATK's position is the primer does not meet any of the characteristics of reactivity, as
defined in 40 CFR 261.23. Part of the basis for this assessment is the primer has been classified
as a DOT Haz,ard Class 1.4S material. EPA has taken the position that DOT Hazard Class 1.4S
materials are not considered an explosive within the meaning of the reactive characteristic.
Based on the information you have provided, our discussion on the disassembly process and the
Division's own research, we concur that the primer does not meet the characteristic of reactivity.
Department of
Environmental Quality
Amanda Smith
Exectttive Dtrector
DIVISION OF SOLID AND
HAZARDOUS WASTE
Scott T. Anderson
Director
195 North 1950 West. Salt Lake Ciry, UT
Mailing Address: P.O. Box 1,14880 . Salt Lake Ciry, UT 841144880
Telephone [phone]. Fa:< (801) 5364222. T.D.D. (801) 5364414
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Solid and Hazardous Waste Control Board
Kevin Murray, Clair
Dennis Riding, Yice 4luir
Eugcne Cole, DrpH
JeffCoombs, MPE LEHS
Mark Franc
Brett Mickelson
Amanda Smitlr
Shane Whitrey
Dwayne Woolley. Scott T. Anderson
Exzctttive Secretary
DSHW-2o13-003246
If you have any questions, please call Jeff Vandel at [phone].
Scott T. Andeison, Director
Division of Solid and Hazardous Waste
STA/JV/Ijm
c: Blair Palmer, ATK Launch Systems
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
David Duster, Region 8 EPA
DSHW-2013-003246