DSHW-1993-004065 - 0901a06880156330

HERCULES Hercules Aerospace Company
Space/Strategic Propulsion
Bacchus Works
Magna, Utah 84044-0098
[phone]
August 30, 19^^
DSHW TN
1993.11241
Dennis Downs
Director
Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
Salt Lake City, UT 84114-4810
Re: Additional Information on Interim Corrective Measure Request for Fluorine Station,-!?-
SA-5
Dear Mr, Downs:
A previous letter dated 27 July 1993 proposed that remediation ofthe fluorine station
at the Hercules Plant 1 facility be considered an interim corrective measure. This action
would be pursuant to paragraph 20(a) of Stipulation and Consent Order No. 8606396 dated
August 16, 1988. Mr. Bill Wallner of your staff requested that Hercules provide some
additional information for the DSHW review of this issue. This information is included as an
attachment to this letter.
This action is being coordinated with the Division of Air Quality. The DAQ has used
modelling submitted by Hercules as the basis for a preliminary Approval Order. The
conditions of the Approval Order are listed in the attachment. If you have any further
questions on this issue, please contact me at 251-3574 or Chris Falkenberg of my staff at
251-5313.
Sincerely,
E. Richard Anderson, Manager
Environmental Engineering
and Hygiene
Attachment
ERA/CDFalkenberg/
Interim Corrective Measure for Remediation of Fluorine Transfer Station, SA-5
INTRODUCTION
In the 1970's, Hercules used gaseous fluorine in the synthesis of numerous propellant
ingredients. Tetrafluorohydrazine (N2F4) was also used as a raw ingredient during this same
time frame. Towards the end of the program, liquid fluorine was brought on plant and
transferred into compressed gas cylinders at an area known as the fluorine transfer station.
Facility 9005. The cylinders were then shuttled back and forth between the transfer station
and the operating facility for production of the propellant ingredients.
When the program ended in 1978, a number of cylinders were left behind at the
transfer station and have remained ever since. The following table shows the quantity and
type of cylinders involved with this effort.
Compound
Fluorine
Number of
Cylinders
54
Type of Cylinder
ICC - 3AA 1000, Normally rated to 1000
psi, 400 psig max for fluorine service.
Approximately 11" in diameter, 50" tall
and when full contain 7.9 pounds of
fluorine.
N2F4 10
(Tetrafluorohydrazine)
DOT - 3AA 2015, Each bottle is 7" in
diameter, 30" tall, pressurized to 120 psig,
and contains 1.25 pounds of N2F4. One of
the ten cylinders is substantially larger than
the others, but is believed to be empty.
By design, the fluorine station is situated in an open field some 750 feet away from the
nearest building. The station itself is very simple, it consists merely of a single sided steel ^
barricade designed to protect operators during the fluorine transfer process. As such, the
station doesn't provide any protection from the elements. The compressed gas cylinders at
the station have been exposed to wind, rain, and snow conditions for several years. Rust and
other corrosion has appeared on some of the cylinders.
Hercules has examined several different disposal options for the cylinders in the past
few years. Disposal offsite is difficult as the pressure rating for the cylinders has expired.
Public transport of such cylinders is illegal without special exemption and coordination with
the DoT. Stress caused to the cylinders during offsite transportation is thought to be an
additional safety risk when considering the age and reactive nature of the tank contents.
Interim Corrective Measure for Remediation of Page 3
the Fluorine Transfer Station
Of the onsite disposal options evaluated, venting the cylinders in place is the safest and
requires the least handling of the cylinders. Most of the cylinders will not have to be moved
until after they are empty. The open area of the transfer station also allows for dispersion of
the fluorine before it reaches other facilities on plant. Small explosive charges will be used
to knock the valve off of cylinders one at a time. Hercules, as a manufacturer of explosives,
is very familiar with this technology.
PROPOSED PROCEDURE
The primary consideration for this entire effort is to assure that Hercules personnel and
the general populace are not exposed to unacceptable levels of fluorine gas. An area of
sufficient size to protect plant personnel will be cordoned off during the operation. All
personnel entering this area will be required to wear the proper personal protective equipment.
Test equipment will also be used when in this area to assure that fluorine concentrations are
within safe levels.
Once the area is secured, an explosives team will enter the area. They will secure a
small explosive charge to the valve of a single cylinder. After setting the charge, the team
will retire to a safe drawback site and detonate the explosive charge remotely. The type and
nature of each resultant plume will be recorded. Unless it can be demonstrated that a number
of cylinders are already empty, the cylinders wiU be vented one at a time. Empty cylinders
may be vented several at a time to allow for subsequent washout.
Calculations show that the fluorine cylinders will take approximately 25 seconds to
vent across the valve orifice. After an appropriate dispersal period (estimated to be a half
hour) operators would cautiously reenter the area and determine the airbome fluorine
concentration. Once it is found that the fluorine has dispersed, the charge for the next
cylinder can be set. Using this procedure it is estimated that twelve cylinders could be vented
in a day. The total daily fluorine load would therefore be 12 cylinders/day x 8 lbs/cylinder or
96 pounds/day. The entire operation would take between 5 and 6 days at a total fluorine load
of 432 pounds.
Tetrafluorohydrazine is an extremely sensitive material, these cylinders are expected to
detonate under the impetus of the explosive charge. Shrapnel from the these cylinders will be
controlled by placing the cylinders either in a hole or in some sort of portable enclosure.
Detonation products would include nitrogen dioxide (NOj) and hydrogen fluoride (HF) gases.
Mass balance calculations show that a total of 9.6 pounds of hydrogen fluoride and 11.04
pounds of nitrogen dioxide would be produced from remediating the N2F4 cylinders.
To begin the operation, single fluorine cylinders will be vented approximately 50 feet
north of the fluorine station. These tests will determine the best vent location on the
cylinders and if any unexpected reaction occurs. The use of single, isolated cylinders will
prevent a serious reaction from propagating to other cylinders. After two or three fluorine
cylinders are safely vented in this manner, the other cylinders wiU be vented in their current
location.
Interim Corrective Measure for Remediation of Page 4
the Fluorine Transfer Station
Once the cylinders have all been vented they will be washed out in a light caustic solution
and then sent to an appropriate disposal facility.
A preliminary version of the procedure that will be used is attached to this document as
Appendix A. This document presents additional detail on the step by step instructions for
placing the charges on the cylinders.
CONSENT ORDER CONSIDERATIONS
Consent Order No. 8606396 agreed to between Hercules and the State of Utah Division
of Solid and Hazardous Waste (DSHW) on 16 August 1988 stipulated that Hercules
participate in the RCRA Corrective Action program for a number of sites at our facility. The
Facility Investigation phase of this program identified the fluorine station as a potential
remediation site and assigned it as Salvage Area 5 (SA-5). The Facility Investigation Report
(FIR) recommended that this facility remain in the RCRA Corrective Action program until the
fluorine cylinders were remediated. At the time a number of vendors were being considered
for remediation of the cylinders.
The second phase of the RCRA Corrective Action program after the Facility
Investigation is known as the RCRA Facility Assessment (RFA). For SA-5, the RFA
recommended that the cylinders be removed or treated by a qualified contractor. The RFA
also recommended that the fluorine station (SA-5) should not be dropped from further
consideration in the RCRA Corrective Action process until after the fluorine cylinders have
been treated/removed.
Hercules to date has not identified a vendor that meets all of the technical and cost
requirements for treating the cylinders. In the intervening period, the N2F4 cylinders were
placed at the fluorine station (SA-5) because of the safety risk that they presented at their
original storage location. Hercules also decided to remediate the cylinders internally because ^
of the difficulty in finding a suitable vendor. This type of remediation is allowed in tihe
Consenj Order under Paragraph 20(a) which pertains to interim corrective measures. Such
measures are allowed to prevent or abate a potential immediate threat to public health or the
environment. Both the Executive Secretary of the DSHW and Hercules must agree to the
suitability of the measure.
Successful remediation of the fluorine station (SA-5) may be cause for Hercules to
petition to withdraw SA-5 from the RCRA Corrective Action program. Such a petition will
likely be contingent on soil sample results taken around the station. Such sampling has been
proposed in the draft for the RCRA Facility Investigation Workplan that is currently under
review by the DSHW.
Interim Corrective Measure for Remediation of Page 5
the Fluorine Transfer Station
AIR OUALITY CONCERNS
If all the fluorine cylinders are full, then approximately 432 pounds of fluorine will be
released to the atmosphere. The Utah Division of Air Quality (DAQ) has required Hercules
to conduct air dispersion modeling to determine the impact of this release to our plant
personnel and the general populace. Using the EPA SCREEN model, it was found that upto
12 cylinders of fluorine could be vented a day and still meet air quality and OSHA guidelines
for fluorine exposure. The modeling submitted to the DAQ forms the basis for a preliminary
Approval Order which has already been issued by the DAQ. This document has been
included as Appendix B. It should be noted that through additional negotiations. Items 3 and
6 have been modified. The current wording of each of these items is as follows:
Item 3: Not more than one cylinder will be vented per 30 minute time period and not
more than three cylinders containing tetrafluorohydrazine be vented per two
hour time period.
Item 6: Not more than 96 pounds of fluorine and 12.5 pounds of tetrafluorohydrazine
be vented per day with a total of 432 pounds of fluorine and 12.5 pounds of
tetrafluorohydrazine be vented for the complete operation.
Hercules obtained an experimental approval order from the DAQ under the condition
that Hercules will measure downwind concentrations of fluorine and compare the actual
values to the SCREEN model predictions. Accordingly, a fluorine sensor will be placed in a
strategic location to measure down wind fluorine concentrations.
APPENDIX A
PROCEDURE 25000US05179
Operating Procedure for Venting of Fluorine Cylinders at Facility 9005
Operating Procedure for Venting of Fluorine Cylinders at Facility 9005
1.0 SCOPE
1.1 This document outlines the steps and safety precautions for venting the fluorine
cylinders at the fluorine transfer station (Facility 9005). The cylinders will be
vented by placing a small explosive charge on the exterior of each cylinder.
Cylinders determined beforehand to be empty may be ruptured several at a rime
with FLSC.
1.2 The operations included in this procedure include:
(a) 6.1 Remediation Preparation
(b) 6.3 Entering the Fluorine Station with Possible Airborne Fluorine
Concentrations
(c) 6.4 Setting Charges on Individual Fluorine Cylinders
(d) 6.5 Setting FLSC on Multiple Fluorine Cylinders
(e) 6.6 Observing Vent Operations
2.0 REOUIREMENTS
2.1 Personnel performing these operations are responsible for knowing and adhering
to this procedure.
2.2 A minimum of three persons are required to perform venting operations. Two
persons are required to enter the Fluorine Station area to set charges while a third
person observes from a distance. The third person shall be equipped with the
necessary means to provide for emergency assistance.
2.3 These operations shall be conclucted only during daylight hours and only on days
when the clearing index exceeds 500.
2.4 Fluorine is an extremely reactive gas. Strict adherence to personal protective
safety equipment requirements is necessary to perform these operations
successfully.
*2.5 This document controls all operations up to placement of initiating squibs or caps
on the destiiict charges. GOP 2500US05123 "General Operaring Procedure for the
Hazards Test Area (Pit 38) shall govem the safe placement and iniriarion of squibs
or caps.
Operaring Procedure for Venting of Fluorine
Cylinders at Facility 9005
Page 2
3.0
3.1
APPLICABLE DOCUMENTS
4.0
4.1
21000GM10560
25000US05123
25000US05169
MMSP No. 9-4.4
MMSP No. 9-4.3
MMSP No. 9-7.8
MMSP No. 9-7.9
MSDS
MATERIALS AND EOUIPMENT
Safety Clothing and Equipment
General Operaring Procedure for the Hazards
Test Area (Pit 38)
Detennining Air Ducring for Explosive
Testing
Compressed Gas Cylinders
Gaseous Fluorine
Compressed Air for Respirator Use
Supplied Air Respirator Use
Fluorine Gas
EQUIPMENT DESCRIPTION
Supplied Air Pressure Demand
Respirator
Barricades
MSA Hip-Air with 5-minute Emergency egress
Bottle and 100 Foot Hose Length
Wooden
Emergency Eye Wash/Shower Encon 8-gaIlon Portable System, or equivalent
Faceshield
Firing System
Fluorine Detector
Polycarbonate with Full Face and Side
Protection
Portable Pit 38 EBW System
Sensidyne SS2000 Portable Detector and/or
Drager Tube System
Binoculars NR
Operating Procedure for Venting of Fluorine
Cylinders at Facility 9005
Page 3
4.2
5.0
5.1
Portable Camera/tripod
Video monitor
Wind Speed Indicator
MATERIALS
Compressed Air Cylinders
VHS or 8 mm format
NR
Model HH-FIO
DESCRIPTION
Breathing Air Cylinders, Stores Catalog
Number 0126350B
Yellow Polyethylene Tape with Black
Lettering
Neoprene
Latex, flock lined
Leather
Neoprene Jacket with Drawstring Hood, Bib
Overall Pants
Type RP-80
Composirion C-4 Explosive
Lead Jacketed Jetcord
270 ml Nalgene .
Butterscotch
A minimum of three persons are required to perform venting operations. Two
persons are required to enter the Fluorine Station area to set charges while a third
person observes from a distance. The third person shall be equipped with the
necessary means to provide for emergency assistance.
Barricade Tape
Gloves
Gloves
Gloves
Protective Suit
Initiation Caps
Explosive Charge
FLSC
Plastic Beaker
Tape
SAFETY
Operating Procedure for Venting of Fluorine Page 4
Cylinders at Facility 9005
5.2 Place barricades as necessary on roads to protect plant personnel from fluorine
exposure.
5.3 Wear safety clothing and use protective equipment as required by 21000GM10560.
Fluorine gas presents special health hazards. The following equipment is required
when fluorine may be present in airbome concentrations:
MSA Hip-Air full face supplied air respirator with 5-minute escape bottle
Nonconductive safety shoes
Face shield
Neoprene Gloves
Neoprene Jacket with drawstring hood
Neoprene Pants
Note: leather gloves may be wom if desired, but must be worn over neoprene
gloves.
For employees requiring glasses, spectacle inserts must be used with the MSA full
face respirator.
5.4 Approach fluorine cylinders with caution. Leave area if airbome concentrations
of fluorine exceed 5 parts per million as measured by either a Drager tube or by
the Sensidyne Model SS2000 gas analyzer.
5.5 Do not enter the fluorine station area until a minimum of one half hour after each
shot.
5.6 A portable eyewash/shower system stationed at a convenient location is required
for this operarion.
5.7 _ Contact the firestarion and Unit 51 prior to beginning disposal operarions.
5.8 All personnel involved with this operarion must be trained in use of the MSA
supplied air respirator system as per MMSP 9-7.6 Respiratory Protection Training.
5.9 The inlet pressure of the MSA supplied air respirator system shall be between 65
and 85 psi when using hose lengths of 100 feet.
ft
5.10 Keep supply of explosives to a minimum. The supply of explosives in the
fluorine transfer station area should be no more than required for one shot.
Operaring Procedure for Venring of Fluorine Page 5
Cylinders at Facility 9005
5.11 No operations involving explosives shall be conducted at the approach of or
during an electrical storm.
5.12 Initiating caps are to be carried to the fluorine station in a metal, red-painted,
foam-lined ammo box.
5.13 All persons entering the fluorine station area during these operarions shall be
familiar with emergency response/evacuation procedures including escape routes,
location of the eyewash/shower station, and emergency norification.
5.14 The safety requirements of GOP 25000US05123 regarding firing line shorting
plugs shall be followed.
6.0 OPERATIONS
6.1 REMEDIATION PREPARATION
NOTE: This section contains a number of tasks that must be completed
before daily remediarion operations can begin.
6.1.1 Verify that the clearing index for the day exceeds 500 by calling the Narional
Weather Service at the airport.
6.1.2 Perform ducting calculations for the day as per 25000US05169 "Determining Air
Ducting for Explosive Testing." Proceed only if ducting calculations indicate
acceptable conditions.
6.1.3 Place barricades on applicable plant roads to prevent fluorine exposure to casual
plant personnel.
6.1.4 Place four barricades at comers approximately 50 feet from the fluorine station.
String yellow caution tape between the barricades to prevent unauthorized
personnel entry.
6.1.5 Place the air cylinders for the MSA Hip-air supplied air system approximately 80
feet upwind from the fluorine station. Locate the portable eyewash/shower
station near the supplied air cylinders.
ft
6.1.6 Set-up the Pit 38 portable Exploding Bridge Wire (EBW) system as follows:
Operating Procedure for Venting of Fluorine Page 6
Cylinders at Facility 9005
6.1.6.1 Place the main console for the system in the bunkered area at Building 2284
(Igniter storage building).
6.1.6.2 String the necessary control cable between the firing console and the initiator box
located at the fluorine station. Place the lines undemeath the NG road by
stringing them through the available culvert.
6.1.6.3 Connect the firing lines to the initiator box. Ensure that the system in a shorted
safe (shorted) condition prior to beginning operations.
6.1.7 Place a portable camera/tripod on top of the bunker at Building 2284.
6.1.7.1 Run a signal line from the video camera down into the bunkered site and connect
a video monitor.
Note: Power for the video camera, firing system, and other equipment can be
found inside Utility building 2357.
6.1.8 Contact the fire station and Unit 51 prior to beginning operations.
6.1.9 Prepare destruct charges as follows:
6.1.9.1 Obtain enough nalgene beakers to prepare sufficient destruct charges for the day.
6.1.9.2 Drill or cut a hole in the bottom of each beaker. The hole should be a little larger
than the diameter of the initiating caps to be used.
6.1.9.3 Lightly pack Composition C-4 explosive into each beaker.
Note: Latex rubber gloves shall be wom when ^handling Composition C-4
explosive. " ' ^
6.1.9.4 Place the charges in a suitable box or container until needed for use.
6.2 ENTERING THE FLUORINE STATION WITH POSSIBLE AIRBORNE
FLUORINE CONCENTRATIONS
*6.2.1 Ensure that it has been a minimum of one half hour since the last fluorine shot.
6.2.1.1 Use binoculars and the camera to visually examine the previous fluorine cylinder
that was vented. Ensure that there are no visual signs of escaping gas or
Operating Procedure for Venting of Huorine Page 7
Cylinders at Facility 9005
continuing reactions. If so, wait until such activity ceases before reentering the
fluorine station.
6.2.2 Don the proper safety equipment as required by 21000GM10560 "Safety Clothing
and Equipment" and 25000US05123 "General Operating Procedure for the
Hazards Test Area (Pit 38)." Equipment should be as new and clean as possible
and be free from organic oils and greases.
NOTE: Fluorine gas presents special safety considerations, the following
personal protective clothing is required for this project:
6.2.2.1 Don clean neoprene bib pants ensuring that each pant leg extends past the top of
each boot top.
6.2.2.2 Don a clean neoprene jacket with drawstring hood ensuring that the arm lengths
are sufficient and the hood fits snugly.
6.2.2.3 Don neoprene gloves.
6.2.3 Prepare the Sensidyne SS200 portable gas analyzer and drager tube assembly for
sampling the air near the fluorine station. Set the waming alarm on the Sensidyne
air monitor to 1 ppm fluorine.
6.2.4 Slowly approach the fluorine station from the bunkered site at Building 2284.
Immediately evacuate the area if at any time the smell of fluorine is detected or
the Sensidyne/Drager tube gas indicator detects the presence of fluorine.
WARNING
OBSERVE THE FIRING SYSTEM SAFETY FEATURES (COLORED
CONTINUITY PLUGS) AS DESCRIBED IN 25000US05123 "GENERAL
OPERATING PROCEDURE FOR THE HAZARDS TEST AREA (PIT 38)"
WHEN APPROACHING THE FLUORINE STATION.
NOTE: A minimum of two persons are required when entering the fluorine
station area. A person remaining at the Building 2284 bunker shall
maintain constant visual surveillance on the party setting the
charges. If any situation arises that appears to endanger the health
of the party, the person remaining behind shall immediately call the
Operating Procedure for Venting of Fluorine Page 8
Cylinders at Facility 9005
Plant emergency phone number.
6.2.5 Perform the following tasks upon reaching the supplied air station:
6.2.5.1 Open the cylinder valves and ensure that there is still at least TBD psi remaining
in the tanks.
6.2.5.2 Open the supplied air regulator to a pressure between 65 and 85 psi.
6.2.5.3 Don the MSA Hip-air system and place the mask securely over the face. Perform
positive and negative pressure checks to assure that air is being supplied to the
system and surrounding air is not leaking in.
6.2.5.4 Don a faceshield to protect areas not covered by the supplied air mask and
neoprene hood.
6.2.6 Set the audible alarm on the Sensidyne gas monitor to 5 ppm.
6.2.7 Continue to approach the fluorine station while monitoring for airborne fluorine
concentrations. Immediately leave the area if at any rime the airbome
concentration of fluorine exceeds 5 ppm.
6.3 SETTING CHARGES ON INDIVIDUAL FLUORINE CYLINDERS
6.3.1 Select a fluorine cylinder to be vented.
6.3.2 Place an explosive charge with the open side down on the cylindrical section of
the fluorine cylinder.
6.3.3 _.Tape the charge to the cylinder using butterscotch tape.
6.3.4 Place the initiating cap in the charge using the procedures described in
25000US05123 "General Operating Procedure for the Hazards Test Area (Pit 38)."
6.3.5 Retire to the supplied air station. Remove the supplied air mask and the hip air
breathing apparatus.
*
6.3.5.1 Tum off the regulator for the supplied air system. Tum off the valves on the
supplied air cylinders.
Operating Procedure for Venting of Fluorine Page 9
Cylinders at Facility 9005
6.3.6 Retire to bunker at Building 2284.
6.4 SETTING FLSC ON MULTIPLE FLUORINE CYLINDERS
6.4.1 Tape standoffs to the FLSC prior to entering the fluorine transfer station.
6.4.2 Select a series of fluorine cylinders to be vented.
WARNING
FLSC CAN ONLY BE USED ON FLUORINE CYLINDERS THAT HAVE
BEEN PREDETERMINED TO BE EMPTY.
6.4.3 Place the FLSC across the center of the fluorine cylinders. Tape the standoffs to
the fluorine cylinders.
6.4.4 Place the initiating cap on the FLSC using the procedures described in
25000US05123 "General Operaring Procedure for the Hazards Test Area (Pit 38)."
6.4.5 Retire to the supplied air starion. Remove the supplied air mask and the hip air
breathing apparatus.
6.4.5.1 Tum off the regulator for the supplied air system. Tum off the valves on the
supplied air cylinders.
6.4.6 Retire to bunker at Building 2284.
6.5 OBSERVING VENT OPERATIONS
6.5.1 Adjust the camera so that it is directly observing the cylinder(s) to be vented.
Assure that videotape coverage is in place.
6.5.2 Visually inspect the barricaded roads and area around the fluorine transfer station
to assure that no personnel are in the immediate area.
'6.5.3 Monitor and record the wind speed and direcrion.
6.5.4 Ensure the Sensidyne gas analyzer is on and the audible alarm is set to 1 ppm.
Operaring Procedure for Venring of Fluorine Page 10
Cylinders at Facility 9005
6.5.5 Retire all personnel to behind the bunker.
6.5.6 Iniriate the explosive charge per 25000US05123 "General Operaring Procedure for
the Hazards Test Area (Pit 38)."
6.5.7 Observe and record the results of the vent operation including the presence of any
flame, the direcrion and elevarion of the resultant plume, and any shrapnel or
movement of tanks.
6.5.8 Immediately evacuate the area if at any time the smell of fluorine is detected or
the Sensidyne gas analyzer detects the presence of fluorine.
6.5.9 Call the Plant emergency number if a bmsh fire is started.
-END-
Operating Procedure for Venting of Tetrafluorohydrazine Cylinders at Facility 9005
1.0 SCOPE
1.1 This document outlines the steps and safety precautions for venting the
tetrafluorohy(irazine (N2F4) cylinders at the fluorine transfer starion (Facility 9005).
The cylinders will be vented by placing a small explosive charge on the exterior
of each cylinder. The cylinders are expected to detonate and produce shrapnel.
The cylinders will be placed in an earthen trough (ditch) to control the fragments.
1.2 The operarions included in this procedure include:
(a) 6.1 Remediation Preparation
(b) 6.2 Entering the Fluorine Station
(c) 6.3 Placing Tetrafluorohydrazine Bottles in Ditch
(c) 6.4 Setring Charges on Tetrafluorohydrazine Cylinders
(d) 6.5 Observing Vent Operarions
2.0 REOUIREMENTS
2.1 Personnel performing these operations are responsible for knowing and adhering
to this procedure.
2.2 A minimum of three persons are required to perform venring operations. Two
persons are required to enter the Fluorine Starion area to set charges while a third
person observes from a distance. The third person shall be equipped with the
necessary means to provide for emergency assistance.
2.3 These operations shall be conducted only during daylight hours and only on days
when the clearing index exceeds 500.
2.4 Tetrafluorohydrazine is an extremely leacrive gas. Strict adherence to personal
protective safety equipment requirements is necessary to perform these operations
successfully.
2.5 This document controls all operations up to placement of initiating squibs or caps
on the destmct charges. GOP 2500US05123 "General Operating Procedure for the
Hazards Test Area (Pit 38) shall govern the safe placement and initiation of squibs
or caps.
Operating Procedure for Venring of Fluorine
Cylinders at Facility 9005
Page 2
3.0
3.1
4.0
4.1
APPLICABLE DOCUMENTS
21000GM10560
25000US05123
25000US05169
Safety Clothing and Equipment
General Operaring Procedure for the Hazards
Test Area (Pit 38)
Determining Air Ducting for Explosive
Tesring
MMSP No. 9-4.4
MMSP No. 9-7.8
MMSP No. 9-7.9
MSDS
MATERIALS AND EOUIPMENT
EQUIPMENT DESCRIPTION
Compressed Gas Cylinders
Compressed Air for Respirator Use
Supplied Air Respirator Use
Tetrafluorohydrazine Gas
Supplied Air Pressure Demand
Respirator
Barricades
Emergency Eye Wash/Shower
Faceshield
Firing System
Binoculars
Portable Camera/tripod
Video monitor
MSA Hip-Air with 5-minute Emergency egress
Bottle and 100 Foot Hose Length
Wooden
Encon 8-gallon Portable System, or equivalent
Polycarbonate with Full Face and Side
Protecrion
Portable Pit 38 EBW System
NR
VHS or 8 mm format
NR
Wind Speed Indicator Omega Model HH-FlO
Operaring Procedure for Venring of Fluorine
Cylinders at Facility 9005
Page 3
4.2
5.0
5.1
5.2
5.3
MATERIALS
Compressed Air Cylinders
Barricade Tape
Gloves
Gloves
Gloves
Air Sampling Tubes
Protecrive Suit
Iniriarion Caps
Explosive Charge
Plastic Beaker
Tape
SAFETY
DESCRIPTION
Breathing Air Cylinders, Stores Catalog
Number 0126350B
Yellow Polyethylene Tape with Black
Lettering
Neoprene
Latex, flock lined
Leather
Drager Tubes for HF and NOj
Neoprene Jacket with Drawstring Hood, Bib
Overall Pants
Type RP-80
Composition C-4 Explosive
270 ml Nalgene
Butterscotch
A minimum of three persons are required to perform venting operations. Two
persons are required to enter the Fluorine Starion area to set charges while a third
person observes from a distance. The third person shall be equipped with the
necessary means to provide for emergency assistance.
Place banicades as necessary on roads to protect plant personnel from fluorine
exposure.
Wear safety clothing and use protecrive equipment as required by 21000GM10560.
Tetrafluorohydrazine gas presents special health hazards. The following
equipment is required when tetrafluorohydrazine may be present in airbome
concentrations:
Operating Procedure for Venring of Fluorine Page 4
Cylinders at Facility 9005
MSA Hip-Air full face supplied air respirator with 5-minute escape bottle
Nonconductive safety shoes
Face shield
Neoprene Gloves
Neoprene Jacket with drawstring hood
Neoprene Pants
Note: leather gloves may be wom if desired, but must be wom over neoprene
gloves.
For employees requiring glasses, spectacle inserts must be used with the MSA full
face respirator.
5.4 Approach and handle tetrafluorohydrazine cylinders with extreme caurion.
Tetrafluorohydrazine is shock sensitive when under pressure. Avoid dropping
bottles or accidental contact between botties.
5.5 Do not enter the fluorine station area until a minimum of one half hour after each
shot.
5.6 A portable eyewash/shower system stationed at a convenient location is required
for this operation.
5.7 Contact the firestation and Unit 51 prior to beginning disposal operations.
5.8 All personnel involved with this operation must be trained in use of the MSA
supplied air respirator system as per MMSP 9-7.6 Respiratory Protection Training.
5.9 The inlet pressure of the MSA supplied air respirator system shall be between 65
and 85 psi when using hose lengths of 100 feet.
5.10 Keep supply of explosives to a minimum. The supply of explosives in the
fluorine transfer station area should be no more than required for one shot.
5.11 No operations involving explosives shall be conducted at the approach of or
during an electrical storm.
'5.12 Initiating caps are to be canied to the fluorine station in a metal, red-painted,
foam-lined ammo box.
Operating Procedure for Venting of Fluorine Page 5
Cylinders at Facility 9005
5.13 All persons entering the fluorine station area during these operations shall be
familiar with emergency response/evacuation procedures including escape routes,
location of the eyewash/shower station, and emergency notification.
5.14 The safety requirements of GOP 25000US05123 regarding firing line shorting
plugs shall be followed.
6.0 OPERATIONS
6.1 REMEDIATION PREPARATION
NOTE: This section contains a number of tasks that must be completed
before daily remediation operations can begin.
6.1.1 Verify that the clearing index for the day exceeds 500 by calling the National
Weather Service at the airport.
6.1.2 Perform ducting calculations for the day as per 25000US05169 "Determining Air
Ducting for Explosive Testing." Proceed only if ducting calculations indicate
acceptable conditions.
6.1.3 Place barricades on applicable plant roads to prevent tetrafluorohydrazine exposure
to casual plant personnel.
6.1.4 Place four barricades at comers approximately 50 feet from the fluorine station.
String yellow caution tape between the banicades to prevent unauthorized
personnel entry.
6.1.5 Place the air cylinders for the MSA Hip-air supplied air system approximately 80
feet upwind from the fluorine station. Locate the portable eyewash/shower
station near the supplied air cylinders.
6.1.6 Set-up the Pit 38 portable Exploding Bridge Wire (EBW) system as follows:
6.1.6.1 Place the main console for the system in the bunkered area at Building 2284
(Igniter storage building).
6.1.6.2 String the necessary control cable between the firing console and the initiator box
located at the fluorine station. Place the lines undemeath the NG road by
stringing them through the available culvert.
Operating Procedure for Venting of Ruorine Page 6
Cylinders at Facility 9005
6.1.6.3 Connect the firing lines to the initiator box. Ensure that the system in a shorted
safe (shorted) condition prior to beginning operations.
6.1.7 Place a portable camera/tripod on top of the bunker at Building 2284.
6.1.7.1 Run a signal line from the video camera down into the bunkered site and connect
a video monitor.
Note: Power for the video camera, firing system, and other equipment can be
found inside Utility building 2357.
6.1.8 Contact the fire starion and Unit 51 prior to beginning operarions.
6.1.9 Prepare destmct charges as follows:
6.1.9.1 Obtain enough nalgene beakers to prepare sufficient destruct charges for the day.
6.1.9.2 Drill or cut a hole in the bottom of each beaker. The hole should be a little larger
than the diameter of the iniriaring caps to be used.
6.1.9.3 Lightly pack Composirion C-4 explosive into each beaker.
Note: Latex mbber gloves shall be worn when handling Composition C-4
explosive.
6.1.9.4 Place the charges in a suitable box or container until needed for use.
6.1.10 Using a backhoe, dig a ditch approximately 20 yards due north of the fluorine
station. The ditch must be three feet wide, four feet deep and five feet long.
6.2 ENTERING THE FLUORINE STATION
6.2.1 Ensure that it has been a minimum of one half hour since the last shot.
6.2.1.1 Use binoculars and the camera to visually ensure that there are no visual signs of
escaping gas or continuing reactions from the last shot. If so, wait unril such
activity ceases before reentering the fluorine starion.
'6.2.2 Don the proper safety equipment as required by 21000GM10560 "Safety Clothing
and Equipment" and 25000US05123 "General Operaring Procedure for tiie
Hazards Test Area (Pit 38)." Equipment should be as new and clean as possible
and be free from organic oils and greases.
Operaring Procedure for Venring of Fluorine Page 7
Cylinders at Facility 9005
NOTE: Tetrafluorohydrazine gas presents special safety considerarions, the
following personal protective clothing is required for this project:
6.2.2.1 Don clean neoprene bib pants ensuring that each pant leg extends past the top of
each boot top.
6.2.2.2 Don a clean neoprene jacket with (irawstring hood ensuring that the arm lengths
are sufficient and the hood fits snugly.
6.2.2.3 Don neoprene gloves.
6.2.3 Prepare the drager tube gas analyzing system with tubes for hydrogen fluoride
(HF) and Nitrogen dioxide (NOj).
6.2.4 Slowly approach the fluorine station from the bunkered site at Building 2284.
Immediately evacuate the area if the drager tube indicates the presence of
hydrogen fluoride or nitrogen dioxide in concentrations greater than three ppm.
WARNING
OBSERVE THE FIRING SYSTEM SAFETY FEATURES (COLORED
CONTINUITY PLUGS) AS DESCRIBED IN 25000US05123 "GENERAL
OPERATING PROCEDURE FOR THE HAZARDS TEST AREA (PIT 38)"
WHEN APPROACHING THE FLUORINE STATION.
NOTE: A minimum of two persons are required when entering the fluorine
station area. A person remaining at the Building 2284 bunker shall
maintain constant visual surveillance on the party setting the
charges. If any situation arises that appears to endanger the health
of the party, the person remaining behind shall immediately call the
Plant emergency phone number.
6.2.5 Perform the following tasks upon reaching the supplied air station:
6.2.5.1 Open the cylinder valves and ensure that there is still at least TBD psi remaining
in the tanks.
6.2.5.2 Open the supplied air regulator to a pressure between 65 and 85 psi.
6.2.5.3 Don the MSA Hip-air system and place the mask securely over the face. Perform
positive and negative pressure checks to assure that air is being supplied to the
system and surrounding air is not leaking in.
Operating Procedure for Venting of Fluorine Page 8
Cylinders at Facility 9005
6.2.5.4 Don a faceshield to protect areas not covered by the supplied air mask and
neoprene hood.
6.2.6 Continue to approach the fluorine station while monitoring for airborne
concentrations of HF and NOj. Immediately leave the area if at any time the
airbome concentration of these materials exceeds 3 ppm.
6.3 PLACING TETRAFLUOROHYDRAZINE BOTTLES IN DITCH
6.3.1 Select three tetrafluorohydrazine bottles to be vented.
NOTE: Four of the tetrafluorohydrazine bottles supposedly contain full
amounts of N2F4 while the others contain heels that have been
backfilled with nitrogen. These four bottles of N2F4 should be
scattered over the three shots necessary to dispose of the bottles.
6.3.2 Inspect the ditch where the N2F4 cylinders will be placed. Assure that the bottom
of the ditch is level in order to prevent the cylinders from rolling in the ditch.
6.3.3 Continue to monitor the air near the fluorine station for airbome concentrations
of hydrogen fluoride and nitrogen dioxide.
6.3.4 Pick up a single N2F4 cylinder from the vermiculite filled box at the fluorine
station and slowly carry the cylinder to the ditch.
WARNING
TETRAFLUOROHYDRAZINE CYLINDERS CAN BE SHOCK SENSITIVE.
AVOID DROPPING OR ACCIDENTAL CONTACT BETWEEN THE
CYLINDERS WHEN TRANSPORTING THEM TO THE DITCH.
6.3.5 _ . Carefully place the cylindrical section of the cylinder flat on the bottom of the
ditch. Keep the cylinder about one foot from the end of the ditch. Cylinders
should be placed approximately 8 inches apart from each other.
6.3.6 Repeat steps 6.3.4 and 6.3.5 until three cylinders have been placed in the ditch.
6.4 SETTING CHARGES ON THE TETRAFLUOROHYDRAZINE
CYLINDERS
6.4.1 Set an explosive charge down on the cylindrical section of the first
tetrafluorohydrazine cylinder.
Operaring Procedure for Venring of Fluorine Page 9
Cylinders at Facility 9005
6.4.2 Tape the charge to the cylinder using butterscotch tape.
6.4.3 Repeat steps 6.4.1 and 6.4.2 for the other two N2F4 cylinders.
6.4.4 Place an iniriaring cap in each charge using the procedures described in
25000US05123 "General Operaring Procedure for the Hazards Test Area (Pit 38)."
6.4.5 Retire to the supplied air station. Remove the supplied air mask and the hip air
breathing apparatus.
6.4.5.1 Tum off the regulator for the supplied air system. Turn off the valves on the
supplied air cylinders.
6.4.6 Retire to bunker at Building 2284.
6.5 OBSERVING VENT OPERATIONS
6.5.1 Adjust the camera so that it is directiy observing the cylinder(s) to be vented.
Assure that videotape coverage is in place.
6.5.2 Visually inspect the barricaded roads and area around the fluorine transfer starion
to assure that no personnel are in the immediate area.
6.5.3 Monitor and record the wind speed and direcrion.
6.5.4 Retire all personnel to behind the bunker.
6.5.5 Initiate the explosive charge per 25000US05123 "General Operating Procedure for
the Hazards Test Area (Pit 38)."
6.5.6 Observe and record the results of the vent operation including the presence of any
flame, the direction and elevation of the resultant plume, and any shrapnel or
movement of tanks.
6.5.7 Call the Plant emergency number if a bmsh fire is started.
-END-
APPENDIX B
PRELIMINARY EXPERIMENTAL APPROVAL ORDER FROM DAQ
Manaq-er, invircrj.ental Planning and. Opirn-tiGns
Hefcaies Inc.
? . O . 'Bo:c 9 S
Bacchus Wcrhs
Magna, Utah 34044-0098
F.^i •. Experinental Ag'proval Order for P.einedia-:.C!n or Fluorine Corlindsrs Ht
Harcules Plant; 1
Dear ICr. Anderson:
Your request for an Appro-'.'al Ordsr dated Jime 10, 1993, wa£3 received by the Utah
Diviaicn of Air Quality (DAQ) . In your letter you requested approval for the on
cite uisposal of 54 fluorine Cylindars and 10 tstr^luorohydrazine c^f'-lindery.
Kerculas stated ttiat the shipment of tha xluorine cylinders for offsite disposal
would be diffict.it: because the pressure rating on the cylindars had expired. The
DAQ has reviswec thitJ letter and subsequent inforniation dated June 30, li)93 and
July 30, 1993. Approval tc conduct Fluorine and taCrafluorohydirazine venting and
testing activicies at the plant 1 site specified by Uerciiles Aerospace Ccrapany
ia hereby granted iu accordance with Section 19-2-107 (2e} of the Utah .SLir
Conservation Act under the following conditions:
1. The venting of the cylinders will only occur when the atmospheric
clearing index specified by the Utali DAQ is above 500;
2. Only 12 cylinders will be vented per day;
3. Hot more than one cylinder will be vented per 30 minute time period
and not more than one cylinder containing tetrafluorohydrazine be
vented per two hour time period;
•4. A Sensidyne gas fluorine gas detection instrument, or equivalent,
shall be used to detect the fluorine levels;
5. Cylinders will not be vented until the detectable fluorine level ia
below the acceptable threshold limit values/iOO, 0.01 ppm or G.016
tng/m , set by the American Conference of Government Industrial
Hygienists at a distance not greater than the Hercules plant 1
property line;
6. Wot more than 95 pounds of fluorine and tetrafluorohydrazine he
vented psr day with a total of 4=32 pounds of fluorine and
tetrafluorohydrazine be vented for the complete operation.
7. The venting of the cylinders will be completed before November 30,
1993?
8. A report be submitted to DAQ no later than March 1, 1394, discussing
the measured fluorine concentrations and the iapiications to the
Screen model.
L-Iaase a.:L-3Cz a.ny iLr-quiri-es "to iTsnao '..Isl
Sincerely,
Ruasell A. Roberts, Executive .Secretary'
Utah Air Quality Board
iC-I:
CC: Salt Lake County Health Dspartrasnt
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