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Home My WebLink AboutDSHW-2024-007917:!+ H f.* +.i {1t. *1$t $xrj:: i{i {:l ?:|| l:,; !:,:j'. 'lj-iii .-}1 lir.a:l .rtiiH ;-9b ili l+ .r-s*rhnql ! ti,-,,-* 'it{'* $bk DIVIS Michael O. leavitt Governor Dianne R. Nielson, Ph.D. Executive Director Dennis R. Downs Director NOF 288 North I460 West P.O. Box 144880 Salt Lake City, Utah 841l4-4880 (8ol) 538-6170 (801) 53 8-67 l5 Fax (80r) 536-414 T.D.D. Sept.ember 28 , 19 93 CERTIFIED MAIII - RETI'RN RECEIPT REQI'ESTED James R. Van Orman Director of Environmental Management Depart,ment of the Air Force Headquarters Ogden Air Logistics Center (AFLC) HilI Air Force Base, Utah 84055-5990 RE: Hazardcus Wast,e fnspect,ion Ut,ah TesL and Training Range (UTTR) NOTICE OF VIOLATION No. 9307046 EPA ID No: UT057009001- Dear Mr. Van Orman: Representat.ives from t,he Utah pivision of Solid and Hazardous Waste conducted compliance inspections on August 4 &.25, 1992, and April 26, L993. The encLosed is a NOTICE OF VIOLATION based on findings documented during those inspections. You are hereby requested t,o submit to this office on or before October 22, 1993, writt.en verification that the violations noted in the NOTICE OF VIOLATION have been corrected. Your submitEal should include an explanation of Ehe steps taken to correcE the problems, and a list of corrective actions implemented t.o prevent recurrence. Also, please document. the acEion taken by UTTR to characterize and remediate the contaminated soil from t.he release of hazardous wasLe used oil at the Eagle Range as identified in paragraph 7e. in the NOTTCE OF VIOLATION. In addition, the following issues have been raised and need to be addressed: UTTR is allowed to t,reat hazardous waste propellants, explosives and pyrot,echnics (PEPs), under interim status requlations, at approved sites wichin E,he Thermal TreaEmentUnit. For PEPs which are discovered on test rangres and must be treated in-sit,u for safety reasons, UTTR is required to procure an emergency permit prior t.o treatment of these wastes (R3L5-3-19 ) . Printed on recycled paper The Table of Contents of the PosL-Closure permit for Landfill#5 under Module fI identifies sections F and G, which arerespectively "Preparedness and Prevent,ion, " and "ConLingencyPlan." As one refers to the text, however, bot,h sections aremissing. In order for sections F and G to be added, a C1ass2 permit. modification is necessary. Concerning the treatment of lithium batteries, a number ofquestions need to be answered. Waste analysis must beprovided or generaLor knowledge must be provided at, the point Ehe batteries are declared a waste. Is UTTR considered thegenerator at, the poin! the batteries are declared a wasLe? Atwhat point in the treatment train, and by whom, is thatdeclaration made? Provide information concerning on*going discharges of wastewater potent,ially containing hazardous constituents fromthe vehicle shop at Eagle Tower, to a sump, and finally to adrainfield. Provide informat.ion concerning on-going discharges of wastewat,er potentially containing hazardous constituents from maint.enance shops at UTTR to a sewage Lagoon. Provide information, including material safety daE.a sheets andproposed management procedures, for the unlabeled, open containers of paint, wastes in the MIVR Yard. ff you have questions regarding any of these matt,ers, please contact Jim Salmon at 538-5170. ennis R. Execut ive Utah Solid Downs Secretary and Hazardous Waste Control Board DRD/ SEG/rnvd Enclosures c: Myron Bateman, R. S. , M. P.A. , Health Of f icer/Department DirecEor, Tooele County Health Department .Tohn C. Bailey, M.D., M.S.P.H., Health Officer/DeparEmentDirect,or, Bear River District. Health Department Connie Nakahara, Permits Section Mgr., DSHWLarry Wapensky, USEPA, SHWR-RI Sincer€ly, BEFORE THE UTAH SOLID AND HAZARDOUS WASTE CONTROL BOABD ---oo000--- ln the Matter of:NOTICE OF VIOLATION Utah Test and Training Range uT0570090001 9307046 ---OO0OO--- This NOTICE OF VIOLATION is issued by the UTAH SOLID AND HAZARDOUS WASTE CONTROL BOARD (the Board) pursuantto the Utah Solid and Hazardous Waste Act (the Act), 19-6-101, et seq., Utah Code Annotated 1953, as amended. The Board has delegated tothe Executive Secretary authority to issue such NOTICES in accordance with 19-6-107(7) of the Utah Code. FINDINGS Utah Test and Training Range (UTTR) is a United States Department of the Air Force installation, located in the State of Utah. 1. 2. UTTR is a bombing and strafing range for the United States Air Force. 3. UTTR generates hazardous waste as defined by R315-2 of the Utah Administrative Code (the Rules). 4. UTTR operates a hazardous waste landfill under a Post-Closure Permit, a therma! treatment unit (TTU) under interim status regulations, and a Lithium Battery Deactivation Facility (LBDF) under a Research Development and Demonstration Permit. 5. UTTR is subject to applicable provisions of the Flules and the Permits. 6. Authorized representatives of the Utah Solid and Hazardous Waste Control Board (the inspectors) conducted compliance evaluation inspections of UTTH on August 4 & 25,1992, and April 26, 1993. 7. The following FINDINGS were docurnented during these inspections: A. R315-8-2.7 of the Rules requires personne! training records to be kept at the facility. 2 The inspectors discovered that personnel training records for persons involved with the TTU and LBDF were kept at Hill Air Force Base and not at the facility. b. R315-8-2.4 of the Rules requires that a detailed physical and chemical analysis of the waste be obtained by the operator prior to treatment, storage, or disposal. The inspectors could not determine that detailed analyses were being performed prior to OB/OD operations. From discussions with EOD personnel, the waste often comes crated and verification of the contents (waste analysis) is not made" R315-7-16.3 of the Rules requires a container holding hazardous waste to be closed, except when waste is being added or removed. A container of hazardous waste at hazardous waste satellite accumulation site TU02 in building 40065, was observed by the inspectors to be open, with a funnel in the orifice. No person was in the process of adding or removing waste. d. R315-7-16.2 of the Rules requires containers holding hazardous waste to be in good condition, or if they begin to leak, rernoval of the waste. c. A used oi! bowser at Eagle Range hazardous waste satellite accumulation site TE06 was observed to be leaking. The underlying soilwas discolored, and a bucket had been placed under the drip. Subsequent analysis requested by the inspectors showed the waste oil to exhibit the toxicity characteristic for cadmium and lead. e. F1315-5-9 of the Rules requires that satellite accumulation of hazardous waste be "at or near the point of generation", and "under the control of the operator." The inspectors observed satellite accumulation sites TE06 and TE05 at Eagle Range. Site TE05 was approximately a hundred yards from the operator's station, visible from a window. Site TE06 was located closer to the operator, but was out of view behind a maintenance structure. DETERMINATION OF VIOLATIONS Based on applicable to its the foregoing FINDINGS, facility. Specifically, UTTR UTTR has violated provisions of the Rules has violated the following: 1.R315-8-2.7 by tailing to keep personnel training records at the facility. 4 2.R315-8-2.4 by failing to obtain a detailed physical waste prior to treatrnent, storage, or disposal. o and chernical analysis of the 3. R315-7-16.3 byfailingto keepacontainerholding hazardouswasteclosedexce$ when waste is being added or removed. 4. R315-7-16.2 by failing to keep a container holding hazardous waste in good condition, and failure to remove the container from service once leaking was observed. 5. R315-5-9 by failing to adhere to satellite accumulation regulations which require that hazardous waste be "at or near the point of generation," and "under the control of the operator." Dated this / f day rt- , 1993 Dennis R. Downs, Executive Secretary Utah Solid and Hazardous Waste Control,Board