DSHW-1993-002391 - 0901a0688013ad5d

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HERCULES
AUG 0 3 1993
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DSHW TN
1993.11243
Hercules Aerospace Company
Space/Strategic Propulsion
Bacchus Works
Magna, Utah 84044-0098
[phone]
July 28, 1993
Connie S. Nakahara
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
Salt Lake City, UT 84114-4810
Re: Agreements Regarding the Regulatory Status of Demilitarization Projects
Dear Ms. Nakahara:
Hercules requests confirmation of the following agreements resulting from the meeting
between UDSHW representatives (C. Nakahara, S. Anderson, D. Verbica, E. Deputy) and
representatives of Hercules Inc. on 22 July 1993. The discussions specifically concerned the
regulatory status of removing the domes of third stage Minuteman missiles and the nozzles
and igniters of second stage C3 motors. The details and specifics are as follows:
Solid Rocket Motor Disposal (SRMD) Project
Hercules intends to cut-off the fiberglass domes of three Minuteman third stage motors
to provide access to the propellant for washout testing. The domes will be removed
without cutting any propellant. It was agreed to by all parties that the motors would
not be waste jjntil after the domes were removed and cutting off the domes was not
considered hazardous waste treatment. After this point the motors will be properly
managed as hazardous waste with Hercules as the generator. In previous discussions
some confusion arose as to whether or not one of the motors would be "coined".
Environmental Engineering has learned since our July 22 meeting that one of the
motors will be "coined" as a part of a separate Air Force aging and surveillance
project to investigate propellant cracks. At the completion of that project the "coins"
will become part of this demil project. Finally, the motors and "coins" will be
manifested to Thiokol Corporation for testing.
Agreements Regarding the Regulatory
Status of Demilitarization Projects
Hercules Aerospace Company
July 28, 1993
C3 Motor Disassembly Project
In this case Hercules will be receiving C3 second stage motors from the Navy. We
will remove the nozzles and igniters which will be returned to the Navy. It was
agreed that the motors would not become waste until the igniters and bracketry were
removed and the Navy designates the motor for disposal. At that point they will be
properly managed as hazardous waste. The motors will be manifested to the Air Force
Oasis Facility for disposal.
Hercules requests your written concurrence with the above. Please feel free to contact
John Waugaman at 251-3302 if you have any questions or problems.
We appreciate your taking time to discuss this matter. The new demilitarization
business presents unique and complicated regulatory issues. We hope that Hercules and the
UDSHW can work together to responsibly address future demilitarization issues for the
benefit of public health and the environment, Utah, and even the rest of the country.
Sincerely,
E. R. Anderson, Manager
Environmental Engineering
and Hygiene
ERA/JLW
cc: S. Anderson UDSHW
E. Deputy UDSHW
K. W. Farnsworth
D. Verbica UDSHW