DSHW-1990-002792 - 0901a06880187fea

DEPARTMENT OF HEALTH
DIVISION OF ENVIRONMENTAL HEALTH
Norman H. Bangerter
Siizannp Dandoy. M.D.. M.P.H.
E.\"i ulivp I )irt'i riir
Bureau oi Sond & Hazardous Waste
?88 North 1460 West. PO Box 16690
Kenneth L. Alkema Sail LaKe Cly. Utah 84116-0690
liirn.'.nr 1801 I 538-6170 flSHV* '
1990-20784
September 21, 1990
E. Richard Anderson
Enviromnental Planning and Operations Manager
Hercules Aerospace Company
Missiles, Ordinance and Space Group
Bacchus Works
Magna, UT 84044-0098
Dear Mr, Anderson:
A technical review and comparison of the September 1987 Part B (with December 1988
replacement pages)/November 1988 Subpart X applications has been completed. A list of
questions and comments concerning these applications has been compiled, and is enclosed.
After your staff has reviewed the Notice of Deficiency (NOD), please contact Rachel Shilton
to schedule a meeting to discuss the NOD.
A general comment in the NOD is to combine the two (2) applications. One permit will
govern the operations at Hercules. It will be most efficient for our staff to review a single
application rather than two (2) separate applications. Please plan to have the combined
application for the next submittal.
If you have any questions, please contact Rachel Shilton at 538-6170.
Sincerely,
William J. Sinclair
Permits Section Manager
Bureau of Solid and Hazardous Waste
c: Harry L. Gibbons, M.D., M.P.H., Salt Lake City/County Health Dept.
Tom Aalto, EPA Region VIII
DRD/BS/rs
hercules\nod2\teluiical.rvw
09/21/90, 7:54am
Hercules Permit Application
Review
November 1988 Submittal
General Comments
Combine the September 1987 (including December 1988 updates) with the November 1988
application. This is different than what was previously decided, but since Utah will be
administering the entire program and permit, it will be much easier to maintain one permit
for all of the RCRA units, than two (2) separate permits. In reviewing both applications,
I believe that if Hercules adds the noted paragraphs to the November 1988 application, it
should reflect a totally encompassing application. This review was done based upon the
combining of the two (2) applications.
For all new construction of hazardous waste management units, Hercules needs to submit
to the Bureau the design, the design specifications, and design drawings.
The area that is within Hercules' Boundary on Plate 2.1-1, but not within the Lease
Boundary and encloses Plant 1, Plant 3, and NIROP ~ who owns it? What are Hercules'
arrangements for the use of it?
All units that will be used to manage hazardous waste should be described, even if those
units will not be regulated under a final permit. Even though Hercules does not intend to
use the waste water tanks for longer than ninety (90) day storage, please describe them as
ninety (90) day regulated tanks. This information is required before the application can be
deemed complete. These should be included on the possible SWMU list.
Specific Additions
The following items should be added to the Subpart X (November 1988) application when
a combined application is compiled.
22.1.3 (Plant 1 Explosive Hazardous Waste Container Storage Facility (ES-1))
Add Figure 2.2.10a. (Facility design (HS-1) flammable storage shed (flammable
storage shed profile))
Add Figure 2.2.10b. (Facility design (HS-1) flammable storage shed)
Hercules NOD - page 1
4.4.3 (Description of Containers)
Add the fifth (5th) paragraph from this section to the Subpart X application. The
paragraph begins: "The main structure and flammable storage portions of HS-1 are
also used to store wastes in containers smaller than 55-gallons„„" This paragraph
ends with: "Those materials that have been repackaged are clearly labeled with the
name,"
Add Table 4.3-la (Small Containers Stored at HS-1)
4.4.1.1 (Containers with Free Liquids Stored at HS-1)
Add Figure 4.4-1. (Maximum drum storage configuration, HS-1 main and covered
concrete structures)
Add Figure 4.4-2. (Contairmient support grill)
Add Figure 4.4-3. (Contairmient catch pan)
4.4.1.2 (Containers without Free Liquids, to the Subpart X application)
Add Figure 4.4-4. (Storage configuration, HS-1 flammable storage shed)
Add Figure 4.4-5. (Maximum drum storage configuration, HS-1, solids pad)
4.42.1 (Hazardous Waste container Storage Facility HS-3; Containers with Free Liquids
Stored at HS-3)
Add Figure 4.4-6. (Maximum drum storage configuration HS-3)
4.4.3.2. (Containers without Free liquids Stored at ES-1)
Add Figure 4.4-7. (Maximum drum storage configuration, ES-1)
4.4.x (Container Management Plan)
Hercules should develop and include a container management plan. This plan
should describe how a container is moved, stored, recorded, tested, etc. within the
facility. It does not need to be a lengthy document, but should accurately describe
how the containers are managed. This document will be included in the final permit.
Hercules NOD - page 2
5.3.1 (Equipment Requirements)
Add Table 5.3-6 (Continued-4) (last page of Table 5.3-6)
5.3.1.4 (Water for Fire Control)
Use this information instead of the November 1988 information in the Subpart X
apphcation.
5.4.3. (Water Supplies)
Use this information instead of the November 1988 information in the Subpart X
application.
5.4.5 (Personal Protective Equipment)
Use this information instead of the November 1988 information in the Subpart X
application.
5.5.1 (General Precautions)
Use this information instead of the November 1988 information in the Subpart X
application.
5.5.2 (General Precautions for Handling Ignitable or Reactive Waste and Mixing of
Incompatible Waste)
Use this information instead of the November 1988 information in the Subpart X
application.
5.5.3 (Management of Ignitable, Reactive, or Incompatible Wastes in Containers)
Use this information instead of the November 1988 information in the Subpart X
application,
6.4.6 (Storage and Treatment of Released Material)
Use this information instead of the November 1988 information in the Subpart X
application.
6.5 (Emergency Equipment)
Use Tables 6.5-1 (Emergency Response Equipment Located at HS-1)
Hercules NOD - page 3
6.5-2 (Emergency Response Personal Protective Equipment Located
at HS-1)
6.5-3 (Emergency Response Equipment Located at HS-3)
6.7 (Evacuation Plan)
Use this infomiation instead of the November 1988 information in the Subpart X applicatioa
6.8 (Required Reports)
Use this information instead of the November 1988 information in the Subpart X
application.
Figure 6,7-1 (HS-1 (8562) - Evacuation Plan) Use this figure instead of the figure in
the Subpart X application.
Figure 6,7-2 (HS-3 (8561)-Evacuation Plan) Use this figure instead of the figure in
the Subpart X application.
Figure 6,7-3 (Burning Ground Evacuation Plan) Use this figure instead of the figure
in the Subpart X application.
Figure 6,7-4 (ES-1 (2105)-Evacuation Plan) Use this figure instead of the figure in
the Subpart X application.
7.1 (Outline of Training Program)
Add Table 7,1-1 (Environmental Plarming and Operations Department Personnel)
to the Subpart X application.
7.1.2 (Training, Content, Frequency, and Technique)
Add Table 7,1-4 (Continued-4) (Description of Course work) (page four (4) of Table
7,1-4)
Add Table 7,1-5 (Training Program Course Requirements) (page one (1))
7.1.3 (Training Director)
Use this information in the Subpart X application. However, this paragraph should
be changed to only describe the requirements of the position, not the qualifications
of a particular person. This should be a generic description, as should all of the
position descriptions.
Hercules NOD - page 4
8.3 (Closure Cost Estimate)
Add the information from the text of 8.3 (Closure Cost Estimate) to the Subpart X
application.
8.4 (Financial Assurance Mechanism for Closure)
Use this information in the Subpart X application.
Hercules NOD - page 5
Specific Comments
2.1.1 (Plant 1)
Is the last paragraph of Plant 1 description still correct? It states: "The Plant 1
Static Firing Range occupies a two acre site in the south area of the plant and
includes four (4) firing bays. These bays provide horizontal and vertical firing
capability." Is there a static firing area in Plant 1? What is this range used for?
2.2.1.2 (Plant 1 Hazardous Waste Container Storage Facility (HS-1))
The second to last paragraph of this section references "clear sealed." The
specifications for the "clear seal" used need to be provided for review.
Documentation should be provided that shows that the sealant is resistant to the
waste streams.
2.2.1.3 (Plant 1 Explosive Hazardous Waste Container Storage Facility (ES-1))
As built drawings are required for all regulated units. Hercules should provide as
builts for HS-1, ES-1, HS-3, and the NIROP Burning Ground.
2.2 (Description of Hazardous Waste Facilities)
These descriptions will be used in the actual permit. Are they correct? Specifically:
Section 2.2.1.1 (Plant 3, Hazardous Waste Container Storage Facility (HS-3)), Figure
2,2-1 (Facility Design (HS-3) - Site Plan), Figure 2,2-2 (Facility Design (HS-3) - Plan
View), Figure 2,2-3 (Facility Design (HS-3) - Section A), Figure 2,2-4 (Facility
Design (HS-3) - Section B), Figure 2,2-5 (Facility Design (HS-3) - Spill Containment
Basin Detail Section C), Photo 2,2-1 (Plant 3 Hazardous Waste Container Storage
Facility (HS-3), Looking Southwest), Section 2,2.1.2 (Plant 1 Hazardous Waste
Container Storage Facility (HS-1)), Figure 2.2-6 (Facility Design (HS-1) - Site Plan),
Figure 2.2-7 (Facility Design (HS-1) - Plan View), Figure 2.2-8 (Facility Design (HS-
1) - Covered Concrete Pad Detail), Figure 2.2-9 (Facility Design (HS-1) - Covered
Concrete Pad Sections), Figure 2.2-10 (Facility Design (HS-1) - Primary Building
Concrete Pad Sections), Photo 2.2-2 (Plant 1 HWCSF), Photo 2.2-3 (Plant 1
Hazardous Waste Container Storage Facility), Section 2.2.1.3 (Plant 1 Explosive
Hazardous Waste Container Storage Facility (ES-1)), Photo 2.2-5 (Plant 1 Explosive
Waste Container Storage Facility (ES-1), Looking North), Photo 2.2-6 (Plant 1
Explosive Waste Container Storage Facility (ES-1), Looking Northeast), Section 2.2.2
(NIROP Open Burning Grounds and Facilities), Figure 2.2-11 (Burning Ground with
Steel Pans Site Plan), Figure 2.2-12 (NIROP Pan Design), and Photo 2.2-4 (NIROP
Burning Grounds, Looking West).
Hercules NOD - page 6
2.2.2 (NIROP Open Buming Grounds and Facilities)
The protection shelter and buming cage are not addressed in the burning ground
inspection section.
The burning grounds are not addressed in the potential of wind dispersal and means
to control wind dispersal.
State the time frame for analyzing burning ground ash and potential run-off
investigation.
If a bum at the NIROP grounds is in progress, how will an emergency evacuation
affect the burn? Are there any provisions for aborting a burn, or extinguishing a
bum in progress?
2.3.1 (Topographic Map Information) (Paragraph five (5))
Are there any mn-on control measures for NIROP? The only mn-on control
mentioned is that it will not flood, due to the holding pond located adjacent to the
site. Surface flow during heavy storms could cause mn-on (or more accurately, mn-
through) the burn grounds toward the holding pond. Is there a berming system to
prevent this occurrence?
Has any study been done on the effect of heavy flooding to the depth of
groundwater. The groundwater is already shallow in some areas close to NIROP.
This possibility should be investigated.
2.3.4.2 (Vehicle Usage)
Table 2.3-5 (Vehicle Types for the Transportation of Hazardous Waste - HS-1, and
HS-3) has been changed to exclude automobiles. Should automobiles be included
in the list, or not?
3.2.3 (Parameters to be Monitored)
Provide information as to how waste streams are monitored through the facility. The
proper handling of wastes at the facility relies heavily on knowledge of the process
of the generation of the waste. Show clearly how the waste is tracked through
generation to final disposal.
3.1.3 (Wastes Generated Off-site)
Every container that is received at the facility from off-site, must be opened and
examined for the presence of free Uquids. If it is determined by visual observation
Hercules NOD - page 7
that free liquids not are present, then a free liquids test (SW-846, Method 9095) need
not be done.
Hercules NOD - page 8
3.2.5.6 (Random Sampling)
Define procedures for compositing the waste from each waste stream. How many
samples will be composited? How will each sample be composited? How will the
composited samples be tracked?
All waste streams must be sampled at a 10% rate. A sliding random sampling for
waste streams will not be accepted.
32.9 (Additional Requirements for Wastes Generated Off-site)
Wastes accepted from off-site must be tested at the facility to assure that the waste
is correctly identified. At a minimum, the procedure should include a chain of
custody form for each container, or a set of analyses that can be performed at the
facility with given tolerance ranges to demonstrate the waste is correctly identified.
Hercules must sample 10% of all of the waste streams coming into the facility,
3.2.10 (Additional Requirements for Ignitable, Reactive or Incompatible Wastes)
Define procedures that assure that stored containerized waste are segregated with
respect to compatibility.
Provide more information on the procedures used to handle reactive wastes at the
facility. This section is too vague in describing the actual handling of ignitable,
reactive, or incompatible waste. Outline the safety procedures used at the facihty.
The sump wastewater is K044 waste, specifically listed. This water is regulated until
Hercules has successfully delisted the waste. It needs to be characterized according
to the regulations. Identify which method is used.
How are the sludges from the settling tanks managed? What test (method number)
is used to characterized this waste stream?
If the waste waters have been adequately separated, there should be no problem in
having a sample analyzed to unquestionably demonstrate that it does not meet
hazardous criteria.
Hercules should provide a generalized list of what types of materials are treated at
NIROP and which materials are sent to U l'l K. This list should be an indicator, not
a restrictive list. The wording should be "includes, but is not limited to:..."
Hercules NOD - page 9
4.2.1 (Temporary Storage of Propellant, Explosive, and Pyrotechnic (PEP) Waste, Building
31)
These areas should be identified and fully described in the application.
5.1.4 (Waming Signs)
Hercules will be required to post warning signs at 100 foot intervals along perimeter
fences of hazardous waste units.
5.3.1.3. (Emergency Equipment)
Is there access to the maintenance and inspection records for the emergency
equipment on site? At a minimum, copies of each of the maintenance and
inspection reports should be available without having to go to the fire department.
5.3.2. (Aisle space requirements)
Hercules should design the storage container configurations with a minimum of two
point five (2,5) feet aisles. Two (2) foot aisles are too restrictive for access to rows
of waste,
6.1.3. (Operations at Bacchus Works)
The text states that there are four (4) storage areas. There are only three storage
areas (HS-1, HS-2, and ES-1), the NIROP Burn Ground is a treatment area,
6.1.4. (Geography and Hydrology)
The shallow groundwater below the NIROP Burning Ground is of concern. What
precautions has Hercules taken to ensure that the shallow groundwater will not be
contaminated from waste that is treated in the burn ground?
6.2.4. (Duties and Responsibilities)
The training that the members of the EER Team receive should be documented in
the personnel training plan,
6.3 (Implementation)
Is Table 6,3-1 (Reportable Quantities of Hazardous Substances) still accurate, or
does it need to be updated?
Hercules NOD - page 10
6.4.1. (Emergency Reporting Procedure)
The emergency telephone line, 22222, should ring directly in to the EER office, as
well as, the other nine (9) areas,
6.4.4 (Control Procedure Guidelines)
Because of Hercules' background in the processes and materials that are managed
on site, it is agreed that Hercules should have primacy for emergencies occurring on
site, however, never should this be used to exempt Hercules from any regulation,
6.4.6 (Storage and Treatment of Released Material)
Is building 31 a ninety (90) day storage building? All units that manage hazardous
waste should be listed in this application, even if they are not regulated RCRA units.
6.6 (Coordination Agreements)
Hercules should draft an agreement letter to submit to all of the support agencies.
Copies of these letters should be included in the application. If the support agencies
do not wish to sign a formal agreement, a copy of the information letter should be
submitted, along with a list of all agencies it was sent to.
6.7 (Evacuation Plan)
Figure 6.7-3 (NIROP Burning Ground Evacuation Plan) is different in the November
1988 plan than in the December 1988 Plan. Which of these configurations is correct?
7.1.2 (Training Content, Frequency, and Technique)
Table 7,1,4 (Training Program Course Requirements) should be amended to include
training for fire department persormel in the following areas: Handling of Explosive
Wastes; Handling Nonexplosive Hazardous Wastes; and Handling Volatile Solvents,
An * should be placed by these three (3) titles unless Hercules can guarantee that
the fire department personnel will never perform one of those functions,
8.1.3.1. (Closure of Container Storage Facilities HS-1, HS-3, and ES-1)
The second to last paragraph of this section states: "There is no intention to break
up and dispose of the concrete pads or catch basins," This is tme for normal closure,
however, Hercules needs to propose a contingency closure plan to be activated if a
unit can not be closed according to the normal closure plan. The contingency closure
plan would be used in the event that during closure contamination was discovered.
Hercules NOD - page 11
This plan should address how contamination will be remediated, and should include
removal of the contamination source or unit,
8.1.3.2. (Closure of NIROP Buming Ground)
A sampling plan should be included in the closure plan for the Burning Ground to
establish if contamination has occurred. The sampling plan should propose sampling
locations and frequencies.
The biuTi pans and cages should be decontaminated prior to disposal. This
decontamination needs to be addressed. The disposal of the decontamination liquid
needs to be addressed,
8.3 (Closure Cost Estimate)
Table 8,4-3 (Continued-2) (Estimated Closure Cost for Closure of NIROP Buming
Ground) is different between the November 1988 Subpart X application and the
September Part B apphcation. The differences should be resolved. The newer
version does not include the reburn area. Is this area no longer existing?
Typographical error: Table 8,4-3 (Continued-4) is mislabeled. This should be page
three, and therefore, (Continued-3), This page begins with item 10) Test for
toxicity, and ends with item 13) Water samples. If this is page four, Hercules should
provide copies of the missing page three,
8.4 (Financial Assurance Mechanism for Closure)
Typographical error: Appendix H referenced here should be Appendix G.
Appendix C (Waste Analysis Data)
Provide the methods for analysis for all of the inorganic compounds. For example,
CHEMTECH listed the methods for all of the organic analyses, but did not give the
methods for inorganic analyses.
The data from Enesco lists method numbers, but does not list the source of the
methods. Provide which standard methods were used.
Appendix D (Waste Stream Descriptions)
How many samples were analyzed to determine the values given for the data
presented?
Demonstrate that these values are representative of the entire waste stream.
Hercules NOD - page 12
Explain fully the process that would characterize a Hercules generated waste when
the source is not known. For example a spill that can not be traced to a specific
source.
The following waste streams need to be fully characterized in Appendix D: 1W800,
1W801, 1W802, 1W803, 1W804, and 1W805, If adequate characterization is
provided, generator knowledge will be acceptable for these waste streams.
Appendix E (Hercules Sensitivity Tests)
Describe Quahty Assurance/Quality Control procedures for each Hercules Method,
Provide information on data reduction, validation, and reporting; internal quality
control checks; performance and system audits; specific routine procedures used to
assess data precision, accuracy, and completeness; corrective action; and quality
assurance reports to management.
Quality Assurance Project Plan
Provide a copy of the Ouality Assurance Project Plan for all SW-846 methods
performed at the Hercules facility. At a minimum the project plan should contain
the 16 essential elements outlined in Chapter One of SW-846.
Hercules NOD - page 13