DSHW-1990-002625 - 0901a06880158fbf

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MHERCULES
DSHWTN
1990-20787
Hercules Aerospace Company
Missiles, Ordnance and Space Group
Bacchus Works
Magna, Utah 84044-0098
[phone]
September 12, 1990
Ut?S" Peo^ c'' Hoaiih
HAND DELIVERED
Dennis Downs
Director
Bureau of Solid and Hazardous Waste
Division of Environmental Health
P.O. Box 16690
288 North 1460 West
Salt Lake City, Utah 84116-0690
Re: Emergency Permit for storage of Waste Explosives
Dear Mr. Downs:
Hercules currently has an emergency permit (UT-04-90) for storage of
waste 1.3 propellant at building 2495. For the reasons described below
Hercules requests that two other storage locations be specified for the
current emergency permit, and that the permit be renewed to allow storage of
this waste for an additional 90 days.
The waste propellant is contained in circular cardboard concrete forms
mounted on pallets. These units are referred to as "slids." Hercules
currently has 120 slids in storage at building 2495. This building will soon
be needed to hold Titan motor segments, which are so large that most of our
motor storage areas cannot accommodate them. Environmental Operations has
been requested to remove the slids from building 2495 by no later than
September 25.
There is no single building on plant that has both the physical space
available and a high enough limit on the amount of explosives that may be
stored to accommodate the slids. Our interim status facility for explosives
storage (ES-1, building 2105) has enough floor space to hold approximately 40
slids. A new building close to the buming grounds that is assigned to
Envirorunental Operations, building 32E, has an explosive weight limit of
10,000 pounds, which corresponds to 22 slids. A third building, SOA, is
normally used for production purposes but can be used for storing waste on a
temporary basis. This building has an explosive weight limit of 50,000
pounds, so it can take no more than 111 slids, space permitting.
/
BW-1000/689 (Rev2'88)
M Emergency Permit for storage of Waste Explosives Page 2
Hercules would like to store up to 50,000 pounds of explosive waste at
building SOA and the remainder at building 32E. Both of these buildings are
located on NIROP and are fairly close to the buming grounds, simplifying the
transportation of the slids from their current location to the new storage
facilities and then to the buming grounds for final treatment. This
arrangement would leave building 2105 available for its normal use, storing
waste explosive ingredients and any backlog of slums that cannot be
immediately treated at the buming grounds.
An additional concern is that Hercules will not be able to dispose of
this backlog of explosive waste before the current emergency permit expires on
October 16. We are confident, however, that all the existing slids can be
bumed during the term of a second 90-day emergency permit. Our buming
ground is in the process of being remodeled and presently has a capacity of
3,500 pounds of explosives per day. When construction is complete in
mid-October, the capacity will be 6,000 pounds per day. We are only buming
2,000 pounds per day, however, because of a limitation from the Bureau of Air
Quality. A new approval order for the burning grounds which will allow us to
burn 4,500 pounds per day (6,000 in special circumstances) has been through
its public comment period and should be issued within the next week or so.
This increased capacity for the buming grounds will ensure that the backlog
of slids can be disposed by the middle of January.
To allow Hercules to operate as described above, your assistance is
required in two ways:
1) Please modify our current emergency permit (UT-04-90) to allow storage
of 1.3 propellant at buildings 50A and 32E. This is needed by
September 21 so that slids can be removed from building 2495 by our
September 25 deadline.
2) Please allow storage of this explosive waste beyond the term of our
current emergency permit by issuing a new permit for buildings 50A and
32E. The new permit is needed on October 17.
Hercules is considering the need to use building 32E for storage of other
explosive wastes on an ongoing basis. If it seems appropriate to obtain
interim status for this facility, that request will be made when we request a
change in our Part A for the newly identified toxicity characteristic wastes.
Thank you for your assistance in this situation. If you need additional
information, please contact Susan Jew at 251-4748.
Sincerely,
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E. Richard Anderson, Hanager
Environmental Planning and
Operations
ERA/SEJew/sjw/7504s