DSHW-1993-002348 - 0901a0688013a1c2

HERCULES
DSHW TN
1993.11244
Hercules Aerospace Company
Space/Strategic Propulsion
Bacchus Works
Magna, Utah 84044-0098
[phone]
July 27, 1993
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Dennis Downs
Director
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
Salt Lake City, UT 84114-4810
Re: Interim Corrective Measure at the Ruorine Station, SA-5
Dear Mr. Downs:
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Hercules proposes to implement an interim corrective measure pursuant to paragraph
20(a) of Stipulation and Consent Order No. 8606396, dated August 16, 1988. The proposed
action is the remediation of the fluorine station, identified as SA-5 in the RFA. The purpose
of this action is to eliminate the potential hazards associated with an accidental fluorine
release from the aging station. This action is currently scheduled for weekends beginning
approximately Saturday, September 18"" running to approximately mid October,
Fifty four (54) fluorine cylinders and 10 tetrafluorohydrazine cylinders remain at the
fluorine station which was last used in 1978. Shipping of these cylinders offsite for disposal
is difficult because of expired pressure test ratings on each of the cylinders. After careful
consideration of different options, Hercules believes that the safest and most expedient
method of remediating these cylmders is to vent them one at a time at their current location.
Yenting would be accomplished by means of a small explosive charge placed on the valve of
each cylinder.
The fluorine station is situated in an open field some 750 feet away from the nearest
building. Venting the cylinders in place is thought to be the safest means of remediation
because of the dispersion area provided by the field and the minimal amount of cylinder
handling that is required. Some of the cylinders may be weakened after continuous exposure
to the elements. These possibly weakened cylinders would not have to be moved until after
they are empty. Once the cylinders are empty they would be triple rinsed with a light caustic
solution and then sent to an appropriate disposal facility.
Interim Corrective Measure at the Fluorine Station, SA-5 Page 2
The tetrafluorohydrazine cylinders are expected to detonate under the impetus of the
explosive charge. Shrapnel from the cylinders will be controlled by placing the cylinders
either in a hole or in some sort of portable enclosure. These cylinders would be remediated
first.
This action is being coordinated with the Division of Air Quality. Modelling
submitted to the DAQ indicates that the operation meets air quahty guidelines and they are
currently reviewing the issue. If you agree that these interim corrective measures are
appropriate and this schedule is acceptable, please let us know by August 15"".
Sincerely,
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E. R. Anderson, Manager
Environmental Engineering
and Hygiene
ERA/JLWaugaman
cc: C. D. Falkenberg
G. B. Thompson
D. Verbica UDSHW