Loading...
HomeMy WebLinkAboutDSHW-2019-014272 - 0901a06880b56eb1 ATTACHMENT 2 INSPECTION SCHEDULES AND PROCEDURE ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 INSPECTION SCHEDULES AND PROCEDURES II.A. Purpose and Scope The inspection schedule used by ATK for the hazardous waste management areas has been designed to meet the requirements of R315-264-15. The inspection schedule promotes the detection of malfunctions, deterioration, discharges, and other situations which may be causing or leading to a release of hazardous waste constituents into the environment or pose a threat to human health. Inspections are conducted by personnel trained to identify potential problem areas and to use the inspection schedule and the inspection log. Nine areas are designated for inspection: the container storage area at E-501, M-705S, M-186, the Thermal Treatment Areas at M-136 (including the burn trays and Burn Station 14) and M-225, T-29B hydrazine dilution, oxidizer leaching at M-705L, the solid propellant/motor storage building M-629, and storage pad S-633. Waste solid propellant and rocket motors are stored at buildings M-629 and storage pad S-633 as well as M-136 burn grounds. Periodically, waste hydrazine is treated (by dilution) at building T-29B. In addition, ATK periodically operates a simple leaching process to remove the oxidizer from 1.3 propellants/explosives and contaminated production materials at Building M-705L. Therefore, inspections of these facilities, in accordance with their inspection schedules, are only required when hazardous waste is being stored or treated at the facility. A facility must be inspected, however, prior to receiving hazardous waste for storage or treatment if inspections were discontinued during the period of inactivity. If any problems are identified with the areas of concern that are listed in the inspection schedules (contained in this attachment), they must be corrected before the facility is put back into use. II.B. Remedial Action or Maintenance Repairs or corrective action for any deterioration or malfunction discovered by an inspection shall be conducted as outlined in Module II, Section F. Repairs to security equipment shall be completed as soon as practicable, but not later than 72 hours after the problem is discovered. As stated in R315-264-15(c), where a hazard is imminent or has already occurred, remedial action shall be taken immediately. II.C. Inspection Records All records of inspections and remedial actions shall be retained in the Operating Record, for a period of at least three years. At a minimum, inspection records shall include the date and time of the inspection, the name of the inspector, a ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 notation of the observations made, and the date and nature of any repairs or maintenance taken. II.D. Inspection Schedules The inspection schedules appear in detail in Tables II-A through II-H. Each inspection schedule is designed so that the items appearing on the schedule are inspected frequently enough to avoid any deterioration of equipment and thus reduce the probability of an environmental or human health incident between inspection times. Each inspection schedule is divided into individual categories and each category contains a specific list of items to be inspected. Inspections are also required within 24 hours after a storm event as outlined in the schedules below. A storm event is defined as precipitation in excess of 1.0 inch in a one-hour period. It shall be documented in the inspection log that the inspection was conducted in response to a storm event. TABLE II-A INSPECTION SCHEDULE FOR DRUM STORAGE AT M-186 MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Fences Weekly Visually inspect all fence lines and look for broken or downed fence lines, loose wires Signs Weekly Readable signs, signs in place Gates Weekly Able to properly close gate, safety flags in place Lock Weekly In working order, able to lock 2. Area Roadway Daily1 Inspect road for spills, soil discoloration Loading/ Daily1 Inspect loading areas for Unloading Areas spills, soil discoloration ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 Periphery Daily1 Inspect grounds for any spills, soil discoloration or stressed vegetation 3. Safety Equipment Eyewash/Shower Monthly Ensure in working order by testing, check water supply Telephone/Radio Monthly Working condition 4. Storage Containment Containers Weekly Number of containers, severe corrosion (i.e., flaking, large rust buildup, rusty bungs), dented drums, hazardous waste labels in place, properly marked, readable, open bungs, no standing liquid on drums, adequate aisle space (2.5 feet) Pads Weekly Chips, cracks, or irregularities in concrete, general condition Sumps/Pads Daily2 Standing liquid on pad or in sumps Drainage Area Weekly Spills, discolored soil Roof Weekly General condition including holes or defects 5. Emergency Equipment Fire Monthly Fire extinguisher full, in working order Extinguisher Absorbent Monthly Adequate supply (minimum 25 lbs) Repack Drums Monthly Two repack drums with seals 55-Gallon drums Monthly Six empty 55-gallon drums with bungs in good condition, no dents, etc. Generator Monthly Routine oil check, fill with gas, test startup Pump Monthly Good working order, hoses intact, test ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 startup and pump 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 Daily except for nonscheduled work days and holidays TABLE II-B INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-136 MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Fences Weekly Visually inspect all fence lines, look for loose wires or broken lines Signs Weekly Readable signs, signs in place Gates Weekly Able to properly close gate Lock Weekly In working order, able to lock 2. Area Roadway Daily1 Spills, discolored soil Loading/ Daily1 Spills, discolored soil Unloading Areas Periphery Daily1 Spills, discolored soil, stressed vegetation 3. Safety Equipment Telephone/Radio Monthly Check operating condition of equipment 4. Burn Ground Area Erosion Weekly3 Survey area and note severe erosion on grounds 5. Storage/Containment Burn tray Prior to placing Tray is intact and liquid tight, accumulation ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 Waste then of liquids Weekly2, 3 Container Weekly2 Closed, labeled, signs of leaks or spills 6. Emergency Equipment Fire Extinguisher Monthly Fire extinguisher full and in working order 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 Inspect upon arrival, then each calendar week 3 And after each storm event. A storm event is defined as more than one inch of precipitation in a one-hour period. TABLE II-C INSPECTION SCHEDULE FOR BURNING GROUNDS AT M-225 MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Fences Weekly Visually inspect all fence lines, look for loose wires or broken lines Signs Weekly Readable signs, signs in place Gates Weekly Able to properly close gate Lock Weekly In working order, able to lock 2. Area Roadway Daily1 Spills, discolored soil Loading/Unloading Daily1 Spills, discolored soil Areas Periphery Daily1 Spills, discolored soil, stressed vegetation ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 3. Safety Equipment Telephone/Radio Monthly Check operating condition of equipment 4. Burn Ground Area Erosion Weekly2 Survey area and note severe erosion on grounds Burn Tray Prior to placing Tray is intact and liquid tight, accumulation waste, then of liquids Weekly2 5. Emergency Equipment Fire Extinguisher Monthly Fire extinguisher full and in working order 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 And after each storm event. A storm event is defined as more than one inch of precipitation in a one-hour period. TABLE II-D INSPECTION SCHEDULE FOR STORAGE AND CONSOLIDATION ROOM AT M-705S MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Signs Weekly Readable signs, signs in place 2. Area Roadway Daily1 Spills, discolored soil Loading/Unloading Daily1 Spills, discolored soil Areas ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 Periphery Daily1 Spills, discolored soil, stressed vegetation 3. Safety Equipment Eyewash/Shower Monthly Ensure in working order by testing, check water supply Telephone/Radio Monthly Check operating condition of equipment 4. Storage containment Containers Weekly Number of containers, severe corrosion (i.e. flaking, large rust buildup, rusty bungs), dented drums, hazardous waste labels in place, properly marked, readable, no open bungs, no standing liquid on the drums Pads, Sumps Weekly Chips, cracks, or irregularities in the concrete, general conditions Portable Secondary Daily2 Cracks, liquid, containment integrity Roof Weekly General condition including holes or defects Sump, pads Daily2 Check for standing liquids in the sump and containment system 5. Emergency Equipment Fire Extinguisher Monthly Fire extinguisher full and in working order Absorbents Monthly Adequate supply (minimum 25 lbs.) Repack Drums Monthly Two repack drums with seals 55-Gallon Drums Monthly Six empty 55-gallon drums with bungs in good condition, no dents, etc. 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 Daily except for weekends and holidays. ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 TABLE II-E INSPECTION SCHEDULE FOR M-629 (Note: As stated in section II.A. of this Attachment, inspections of these storage buildings are not required during periods when hazardous waste is not being stored at the facility) MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Signs Weekly Readable signs, signs in place Bay Doors Weekly Function properly Lock Weekly Function properly 2. Area Roadway Daily1 Inspect road for spills, soil discoloration Loading/Unloading Areas Daily1 Inspect loading areas for spills, soil discoloration Periphery Daily1 Inspect grounds for any spills, soil discoloration or stressed vegetation 3. Communications Equipment Telephone Monthly Working condition; place call to verify operation 4. Storage Containers Motors/bags, etc. Weekly Verify condition of motors/bags, properly marked and labeled, out of place material and check for leakage, or liquid discharge from waste solid rocket motors and propellant . ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 Building Weekly Verify no damage done to exterior of facility Roof Weekly General condition including holes or defects 5. Emergency Equipment Fire Extinguisher Monthly In working order and full 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). TABLE II-F INSPECTION SCHEDULE FOR DRUM STORAGE PAD AT E-501 MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Fences Weekly Visually inspect all fence lines and look for broken or downed fence lines, loose wires Signs Weekly Readable signs, signs in place Gates Weekly Able to properly close gate, safety flags in place Lock Weekly In working order, able to lock 2. Area Roadway Daily1 Inspect road for spills, soil discoloration Loading/ Daily1 Inspect loading areas for Unloading Areas spills, soil discoloration Periphery Daily1 Inspect grounds for any spills, soil discoloration or stressed vegetation ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 3. Safety Equipment Eyewash/Shower Monthly Ensure in working order by testing, check water supply Telephone/Radio Monthly Working condition 4. Storage Containment Containers Weekly Number of containers, severe corrosion (i.e., flaking, large rust buildup, rusty bungs), dented drums, hazardous waste labels in place, properly marked, readable, open bungs, no standing liquid on drums, adequate aisle space (2.5 feet) Pads Weekly Chips, cracks or irregularities in concrete, general condition Sumps/Pads Daily1 Standing liquid on pad or in sumps Drainage Area Weekly2 Spills, discolored soil Roof Weekly General condition including holes or defects 5. Emergency Equipment Fire Monthly Fire extinguisher full, in working order Extinguisher Absorbent Monthly Adequate supply (minimum 25 lbs) Repack Drums Monthly One repack drum with seals 55-Gallon drums Monthly Three empty 55-gallon drums with bungs in good condition, no dents, etc. 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 And after each storm event. A storm event is defined as more than one inch of precipitation in a one-hour period. ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 TABLE II-G INSPECTION SCHEDULE FOR T-29B Hydrazine Dilution Bay (Note: As stated in section II.A. of this Attachment, inspections of building T-29B are not required during periods when hazardous waste is not being treated at the facility) MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Signs Prior to treatment Readable signs, signs in place Door Locked Prior to treatment In working order, locked 2. Area Roadway Daily1 Inspect road for spills, soil discoloration Loading/ Daily1 Inspect loading areas for Unloading Areas spills, soil discoloration Periphery Daily1 Inspect grounds for any spills, soil discoloration or stressed vegetation 3. Safety Equipment Eyewash/Shower Prior to treatment Ensure in working order by testing, check water supply Telephone(cell) Prior to treatment Working condition 4. Storage Containment Containers Prior to treatment Number of containers, severe corrosion (i.e., flaking, large rust buildup, rusty bungs), dented drums, hazardous waste labels in place, properly marked, readable, open bungs, no standing liquid on drums ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 Floor Prior to treatment Chips, cracks, or irregularities in concrete, general condition Roof Prior to treatment General condition including holes or defects 5. Emergency Equipment Fire Prior to treatment Fire extinguisher full, in working order Extinguisher Absorbent Prior to treatment Adequate supply (minimum 25 lbs) 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). TABLE II-H INSPECTION SCHEDULE FOR STORAGE PAD S-633 (Note: As stated in section II.A. of this Attachment, inspections of this storage pad are not required during periods when hazardous waste is not being stored on the pad) MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Fences Weekly Visually inspect all fence lines, look for loose wires or broken lines Signs Weekly Readable signs, signs in place Gate Weekly Able to properly close gate Lock Weekly In working order, able to lock 2. Area Roadway Daily1 Spills, discolored soil ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 Loading/Unloading Daily1 Spills, discolored soil Areas Periphery Daily1 Spills, discolored soil, stressed vegetation Erosion Weekly2 Survey area and note severe erosion on or around storage pad 3. Storage Containers Motors/containers, etc. Weekly3 Verify condition of motors/containers, properly marked and labeled, out of place material and check for leakage, or liquid discharge from waste solid rocket motors and propellant. 1 Daily when in use (i.e. when loading or unloading operations occur at the facility). 2 And after each storm event. A storm event is defined as more than one inch of precipitation in a one-hour period. 3Inspect upon arrival, then each calendar week TABLE II-I INSPECTION SCHEDULE FOR M-705L Oxidizer Leaching Process (Note: As stated in section II.A. of this Attachment, inspections of building M-705L are not required during periods when hazardous waste is not being treated at the facility) MINIMUM EQUIPMENT FREQUENCY AREAS OF CONCERN 1. Security Equipment Signs Weekly1 Readable signs, signs in place Egress paths Weekly1 Egress paths clear during treatment 2. Area Loading/ Weekly1 Inspect loading areas for Unloading Areas spills, soil discoloration ATK Launch Systems Inc. – Promontory September 2019 Attachment 2 – Inspection Schedules and Procedures UTD009081357 3. Safety Equipment Eyewash Weekly1 Ensure in working order by testing, check water supply Telephone (cell) Monthly2 Working condition 4. Equipment Treatment Tank Weekly1 Tank and ancillary equipment is liquid tight, no visible signs of leaking Containment Sump Daily3, 4 Liquid present in sump Containment Weekly1 Containment is intact, free from Chips, cracks, or irregularities in concrete, general condition 5. Emergency Equipment Fire Monthly2 Fire extinguisher full, in working order Extinguisher Spill Kit Monthly2 Spill Response Material Available 1 Weekly when in use (i.e. when treatment is occurring at the facility). 2 Monthly when in use (i.e. when treatment is occurring at the facility). 3 Daily when is use (i.e. when treatment is occurring at the facility). 4 Daily inspection when electronic leak detector is not operable. No inspection required when electronic leak detector is operable.