DSHW-1991-001751 - 0901a0688013ef8c

Norman H. Bangerler
Giivcrnor
Suzanne Dandoy. M.t)., M.P.H.
Eypfiuive Dirfiliir
Kennelh L Alkema
[Urci'iMT
DEPARTMENT OF HEALTH
DIVISION OF ENVIRONMENTAL HEALTH
DSHW TN
1991. 30329
Bureau of Solid & Haza'dous Wasie
288 North 1460 West, PO Box 16690
Salt Lake City. Utati 84116 0690
[phone]
MEMORANDUM
TO: Scott Anderson, Chief
Compliance and Enforcement Section
FROM: Rick Page, Engineer
Compliance and Enforcement Section
DATE: 14 February 1991
SUBJECT: Current status and items/issues pending at Hercules
for new facility contact person in Don's Section
An NOV was issued on December 10, 1990, for the inspection that
took place July - September, 1990. Hercules has submitted
several responses both before and after the NOV (attached)
putting forth their position that the issues are very minor at
best. We are now at the stage where we need to decide penalty
amounts, draft a Consent Order and meet with Hercules to
negotiate a settlement. No other issues should need to be
included in the Consent Order.
Following completion of the Consent Order, we need to amend the
August 16, 1988 Consent Order. This will be to change the timing
of submission of the Closure Plans. Draft language for the
change is attached. Rick Rathbun has looked at it and agrees
that it can be done with Executive Secretary approval (no
Committee approval needed). Hercules has not yet seen the
language and will need to concur before the modification can take
place.
The corrective action process at Hercules is governed by the
August 16, 1988 Consent Order. The RFA was completed in January,
1990. The RFI workplan was submitted in April, 1990. Comments
were submitted by the Bureau in the fall of 1990. Hercules is
currently revising the workplan for resubmittal. They have
indicated an interest in meeting with the Bureau (tentatively
within the next month or so) to discuss the changes to the
workplan prior to its resubmittal. Hopefully this will allow the
submittal of an approvable workplan. Hercules anticipates
beginning the sampling under the RFI this summer and finishing
next summer.
The inspection done at Hercules July - September, 1990, was a
CME. Therefore the CME report will need to be done this year.
Don began working on that but I don't know how far he has gotten.
Hercules has quite a complicated groundwater monitoring system as
far as the sampling schedule and parameters to be sampled in each
of the wells. They are also installing more wells to better
define the contamination both on-site and off site. Don is more
familiar with their groundwater monitoring system and can
probably supply better details.
Hercules obtained interim status for storage for the first time
last spring (due to extenuating circumstances). They will
probably be expanding that storage capacity by adding another
building for the storage of explosive waste. I haven't seen the
request come in yet. Hopefully this will end the series of
Emergency Permits that have been issued in the past.