DSHW-1993-004084 - 0901a06880156632

10-05-1993 04:11PM « FROI^HERCULES BfiCCHUS MflGNfi.UT TO 95386715 P.02
DSHW TN
1993.11236
NOTICE
Hercules Aerospace has received permission from ihe Utah Division of SoHd and Hazardous
waste to perfonn an interim corrective measure at the Bacchus Works facility located in Magna
Utah. Approximately 54 fluorine and 10 tetrafluorohydrazine (NjFJ compressed gas cylinders
located at our facilily will be remediated by venting them into the atmosphere. The fluorine
cylinders will be vented one at a time with a maximum of 12 cylinders vented per day. Each
fluorine release will involve a maximum of 8 pounds of fluorine. Each N^F^ release will involve
a maximum of 3.75 pounds of N^F^. This action is scheduled to begin on 11 October 1993 and
be finished by 30 November 1993.
The Utah Division of Air Quality has determined that this action is acceptable under the Utah
Air Conservation Rules and has granted Hercules an Experimental Approval Order for the
operation. Air dispersion modelling conducted in suppon of the Approval Order has
demonstrated that the general public will not be exposed to unacceptable levels of fluorine gas
as a result of this operation. Hercules fenceline fluorine concentrations will not exceed 0.01 ppm.
For funher information, please contact Dave Nicponski, Hercules Public Affairs, at 251-2552,
T.D.D. # 298-9484.
RECEIVED
OCT - 5 1995
OMiim of Solid & Hazardous Waste
m Onivtinsiit of EnvirofliDflita! Qvality
10-05-1993 04:12Pri .FROnv HERCULES BACCHUS MfiGNfl.UT TO 95386715 P.03
THE HERCULES ENVIRONMENTAL MANAGEMENT PROGRAM FACT SHEET NO. 3
September 22 1993
Punx?se
Hercules Incorporated is preparing to remediate fluoxine and tetrafluorohydrazine cylinders at its Bacchus
Works facilities in Magna Utah. This fact sheet has been prepared to noiify local emergency planning committee
(LEPC) members of Hercules intent and the steps taken to assure public health and safety during the operation. Thc
operation is scheduled to begin on October 11,1993 and end by November 30,1993.
Introduction
In the 1970's, Hercules, at its Bacchus Works facilities in Magna, Utah, used gaseous fluorine in the
synthesis of rocket motor ingredients. Tetrafluorohydrazine (NjFJ was also used as a raw ingredient during this
same time frame. At the aid 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. Once full, the cylinders wece then
shuttled to the operating Utility for production purposes.
When the program ended in 1978, approximately 54 fluotine gas cylinders and 10 N2F4 gas cylinders
remained at the Bacchus facility and have since been gathered at the fluorine station. It is unknown at this time
which, if any, of the cylinders actually are full. When full, the fluorine cylinders would be pressurized to 400 psi
and contain approximately 8 pounds of fluorine. Likewise, the N2F4 cytindefs would be pressurized to 120 psi and
contain 1.2S pounds of N^F^.
Hercules has examined sev^al 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 the cylinders is illegal
without special exemption and coordination with the DoT. Stress caused to the cylinders during offsite transportation
is an additional safety risk when considering the ago and reactive nature of the tank contents.
Disposal of the cylinders on site at the Bacchus Works is considered the safest means of remediating ihese
cylinders. This option minimizes the risk of transporting the cylinders, uses developed technology, and can be
accomplished in a manna that protects general public health and safety.
Procedure
Each gas cylinder will be remediated by placing a small explosive charge on the exteriorof each cylinder
and then detonating the charge fronf a remote locadon. The expIosive~charge will breech die wall of thc cylindCT
allowing the compressed gas to escape. Fluorine cylinders will be vented one at a time while three NjF^ cylinders
may be vented during a single operation. Tetrafluorohydrazine is a shock sensitive material. The contenis of these
cylinders are expected to participate in the explosive reaction and compieteiy rupture the bottle. These cylinders will
be placed in a trench to control any shrapnel that may be developed. The fluorine gas cylinders are constructed of
a special steel alloy that will prevent shrapnel from occurring.
Certain roads at the Bacchus facility will have to be closed during the operation. To avoid interferaice with
normal Hercules production, the cylinder venting operations will be performed on weekends (all daylight hours) or
on wedcdays between 4:30 pm and dusk. A maximum of 12 fluorine cylinders may be remediated in any one day.
Operators entering the fluorine transfer station after each operation will be protected by prefer personal protective
equipment.
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10-05-1993 04:12Pn , FROrV HERCULES BACCHUS nnGNfi.UT TO 95386715 P.04
Fluorine released to the air is expected to react with airbome moisture and form hydrogen fluoride,
Hercules will be moniioring for both fluorine and hydrogen fluoride during die operation. The monitming will verify
air dispersion models and assure that Hercules personnel and the general public are not exposed to unacceptable
levds of fluorine gas.
Public Health Concems
The entire thrust of this effort is to assure that these gases are safely dispersed to extremely low
concentrations before leaving Hercules propeny. The fluorine transfer station is located roughly in the middle of
die Hercules Bacchus East facility some 4,150 feet away from the nearest Hercules fenceline. This central location
will allow wide dispersion of any fluorine plume prior to leaving the facility. Fluorine, NjF*, and hydrogen fluoride
are regarded as loxlc gases with grave health implications at moderate airbome concentrations.
Prior 10 granting approval for the operation, the Utah Division of Air Quality (DAQ) required that Hercules
perfonn air dispersion modelling 10 determine the actual fate ofany developed fluorine plume. An Environmental
Protection Agency (EPA) model known as SCREEN was used. Different fluorine release rates, weather conditions,
and wind directions were considered by the model to detennine ideal release conditions. The model results were
compared to standard industrial hygiene and OSHA Threshold Limit Values (TLV) for fluorine with additional safety
factors imposed by the DAQ. In order to meet DAQ guidelines the Hercules fenceline fluorine concentration as
predicted by the model could not exceed 0.01 pans per million (ppm).
It was found that under certain fluorine release rates and environmental conditions, the fluorine cylinders
could be vented and meet the fenceline concentration standard. Based on these results, the DAQ deteimined tfaat
the release of these gases was permissible under Utah Air Conservation Rules and gianted Hercules an Experimental
Approval Order.' Some of the model conditions were incorporated into the Approval Order as restrictions to the
op^ation in order to assure protection of the general populace. These resoictions include 1) tiiat die operation take
place only on days when the clearing index exceeds 500, 2) that only 12 cylinders be vented per day, 3) not more
than one fluorine cylinder be vented per 30-minute time period, 4) that Hercules monitor airbome fluorine
concentrations to verify the model results, and 5) cyhnders will not be vented until the detectable fluorine level is
below the fenceline concentration standard of 0.01 ppm. Under tiiese conditions, the worst fenceline fluorine
concentration predicted by the model was 0.009 ppm.
Witii the incorporation of tiiese restrictions, both Hercules and the DAQ believe that any fluorine released
during these venting opoations will be dispersed to acceptable concentrations by die time the plume reaches
Hercules' plant boundary. No health risk will be imposed on the general populace as these concentrations are
more than 100 times less the accepted TLV for fluorine.
Environmental Peimits
As mentioned above, Hercules has obtained an Experimental Approval Order from the DAQ valid dirou^
November 30,1993. This approval order pennits the release of the fluorine and NJF4 to the atmosphere within thc
restrictions imposed by thc order.
The Hercules Environmental Management Program also includes a Corrective Action Program to identify
and remedy soil and groundwater contaminaticxi that may have resulted from past waste disposal practices. The
Coirective Action Program is administered and conducted by Hercules with oversight from the Utah Division of
Environmental Quahty, Bureau of Soiid and Hazaidous Wastc (BSHW). The fluorine transfer station is onc of the
sites included on the Corrective Action Program and is managed under tiiis effort. The BSHW has reviewed diis
action and concurred that remediation of tiic fluorine and NjF* cylinders constitutes an interim conective measure
under the Corrective Action Program. This concurrence allows Hercules to perfonn tiiese remedial activities on the
fluorine and N^4 cylinders.
Further Information
For furtiier infonnation, please contact Dave Nicponski. H«cules Public Affairs, at 251-2552.