DSHW-2024-007919

Michael O. Leavitt
Gorremor
Dianne R. Nielson, Ph.D.
d*q- I d%ffi-fl;ffi*maffi #fffu$fumfu
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF SOLID AND HAZARDOUS WASTE
288 Norttr 1460 West
P.O. Box 144EE0
Salt l-ake City, Utah 84119880
Exeorrtive Dir€ctor
Dennis R. Downs
FROM:
DATE:
SUBJECT:
[phone]
[phone] Fax
(801) 536-Ut4 T.D.D.
FILE
MEMORANDUM
',,',!,
at,"'
''4tr'1David U. iltCCteary, Environmental Scientist
Permitting Section
April 16, lgg3
Hill Air Force Base (HAFB), Utah Test and Training Range (UTTR)
Lithium Battery Deactivation (LBD) Facility, Research, Developement,
and Demonstration (RDD) Permit, Public Participation Document.
Attached is the Public Participation Document prepared pursuit to R315-3-29 for the HAFB,
IITTR, RDD Permit.
DMIvI/dm
Printed on recycled paper
*H
H
Public Participation Docurnent
For
hrblic Comrnent Periods
And
Public Hearings
Concerning the
Research, Ilevelopment, and Demonstration Perrnit
Issued April 1, 1993
Hill Air Force Base
Utah Test and Training Range
Lithium Battery Deactivation Facility
Box Blder County, Utah
Public Cornrnent Periods
August 26, 1992 through October 9, 1992
and
December 1, 1992 through January L4, 1993
Public hearings were held on the followiing dates and locations:
September 29, 1992 and January 6, 1993
Martha Hughes Cannon Building
Salt Lake City, Utah
and
sept',"l;;i:' #3ilt *tffi]uu'
1ee3
Tooele, Utah
.$il
,H
J
H
ru
.Hil
.M
1.
2
2'.
3.
4.
5.
6.
Table of Contents
Tableof Contents... ......1
PublicNotices. "....2:7
Hearing Officer Statements . 8-11
Public Hearing Attendance Sheets 12-15
TranscriptofPublicHearings ....16
Written Comments from HAFB/UTTR with responses and changes made
by the Department of Environmental Quality . t7-25
Administrative Changes made by the Department of Environmental
Quality . .26
H
q
I
i
M
ffi
-I
l
;
I
J,
I
'rlt..il
*
Page I
,'M
H
NOTICE
Ttre Utah Solid and Hazardous Waste Control Board is issuing a Utatr Hazardous Waste
Research, Demonstration, and Development (RDD) Permit to Hill Air Force Base, Uah Test
and Training Range [Permittee] for treatment and deactivation of lithium batteries at their facility
located in Box Elder County, Utah. This permit is the third perrnit renewal for this facility,
which will allow the Permittee to operate for 365 operating days upon issuance of this permil.
The Permittee's application has been reviewed by the Division of Solid and Hazardous Waste
and found to be acceptable. The Utah Solid and Hazardous Wastes Act requires a public
comment period prior to approval of a permit by the Utirh Solid and Hazardous Waste Control
Board. The current nrles provide the general public an opportunity to be notified and participate
in the permit process. All permit conditions of the pernit are subject to this public comment
period and public hearings scheduled.
The public comment period will comrnence on August 26, 1992, when the public notice is
published in the Box Elder News and lournal, the Ogden Examiner, the Herald Journal, the
Tooele Transcript Bulletin, the Salt I-ake Tribune, ild the Deseret News, ild will end on
October 9, L992, at 5:00 p.m. MST.
A public hearing has been scheduled on September 29, L992 at 1:30 pm in room 406 of the
Martha Hughes Cannon Health Building, located at 288 North 1460 West, Salt I:ke City, Utah.
Due to the vicinity of this facility to Tooele County, an additional public hearing will be held
the evening of Wednesday, September 30, 1992 at 7:00 pm in the auditorium at the Tooele
County Courthouse located at 47 South Main, Tooele, Utah.
Copies of the RDD Permit are available for public review and inspection between the hours of
8:00 a.m. and 5:00 p.ffi., Monday through Friday during the comment period at the following
offices:
H
W
,H
tr!
I
Division of Solid and Hazardous Waste
Martha Hughes Cannon Health Building,
4th Floor
288 North 1460 West
Salt l-ake City, Utall
Bear River DisEict Health Department
655 East 1300 North
Ingan, Utah 8432I
Tooele County Health Department
47 South Main, Roorn 220
Tooele, Utah 84074
ose
M
M
Written comments must be received no later than 5:00 p.m. MST on October 9, L992 and
addressed to:
Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board
. State of Utatr
P.0. Box 144880
salt Irke ciry, utah 84114-4880
Any questions concerning the draft permit should be directed to David M. McCleary, Uffi
Division of Solid and Ilazardous Waste, [phone].
M
ry
J
t
,fl
,M
trl
t
I
i
i'l
J
"1A
*
,'.'l
,. {JU3
M
M
NOTICE
The Utah Solid and Hazardous Waste Control Board is issuing a Utah Hazardous Waste
Research, Demonstration, and Development (RDD) Permit to Hill Air Force Base, Utah Test
and Training Range for treatment and deadtivation of lithium batteries at their facility located
in Box Elder County, Utatr. The Utah Solid and Hazardous Wastes Act requires a public
comment period prior to approval of a permit by the Utah Solid and Hazardous Waste Control
Board. Based upon significant comments received during a public comrnent period commencing
on August 26, L992 and ending on October 9, 1992, changes to the draft permit have been
made. Therefore, the changes to the draft permit dated August 26, 1992 and the draft in its
entirety will be subject to a second public comment period and public hearings scheduled.
The public comment period will commence on Derember l, 1992, when the public notice is
published in the Box Elder News and Journal, the Ogden Examiner, the Herald Journal, the
Tooele Transcript Bulletin, the Salt I-ake Tribune, ild the Deseret News, and will end on
January 14, L993, at 5:00 p.m. MST.
A public hearing has been scheduled on January 6, 1993 at 10:00 arn in room 406 of the Martha
Hughes Cannon Health Building, located at 288 North 1460 West, Salt Lake City, Utah.
Due to the vicinity of this facility to Tooele County, an additional public hearing will be held
the evening of Wednesday, January 6, 1993 at 7:00 prn in the auditorium at the Tooele County
Courthouse located at 47 South Main, Tooele, Utah.
Copies of the draft RDD Perrnit and record of changes made to the draft permit are available
for public review and inspection between the hours of 8:00 a.m. and 5:00 p.rn., Monday through
Friday during the comment period at the following officis:
M
W
Division of Solid and Hazardous Waste
Martha Hughes Cannon Health Building,
4th Floor
288 North 1460 West
Salt I-ake City, Uffi
Bear River District Health Department
655 East 1300 North
tngan, Ud 84321
Tooele County Health Department
47 South Main, Roorn 220
Tooele, Utah 84074
il!
ffi
a
,.,rud
-rl
Written comments must be received no later than 5:00 p.m. MST on January 14, 1992 and
addressed to:
Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board
Department of Environmental Quality
P.0. Box 144880
salt Irke city, utah 84114-4880
o,$4
;
i
M
.M
In compliance with the Americans with Disabilities Act, individuals needing special
accomrnodations (including auxiliary communicative aids and services) during this meeting
should notify Brent Bradford, Deputy Director at 168 North 1950 West, SLC, Utah 84114-4810,
536-4413, at least three working days prior to the meeting.
For further information contact David McCleary, Environrnental Scientist, Department of
Environmental Quality, 538-6170 or TDD #563-4414.
M
M
d
fl
q
I
i
i ri
a
.rl
(,lttw/t t fe'/n/ qi I r'i
.$il
M
,M
q
Erccurir.e Direror Salt Lake City, Uuh 8{1 I +4880
Denuis R. Downs GOI) 538-61?0
Dircctor (80t1 538-6715 Fax
September 15, 1992
Karen Brown
National Sales Coordinator
KSL Broadcast House
55 North 300 West
salt I-ake city, uT 84110-1160
Dear Ms. Brown:
Enclosed is a public notice which we would like aired on your radio station three separate times
during the day on Tuesday, September 22, 1992: 1) between 7:00-8:00 f.il. , 2) between 11:30-
1:30 p.m., and 3) once more between 5:00-6:00 p.m.
Please send invoice and affidavit of air time to:
Dennis R. Downs, Director
Division of Solid and Hazardous Waste
Department of Environrnental Quality
P.O. Box 144880
Salt I-ake City, Utah 84114-4880
Sincerely,
Connie S. Nakahara
Permits Section Manager
Utah Division of Solid and Hazardous Waste
CSN/KAB/Kb
Enclosure
c: Iarry Wapensky, EPA Region VIII
John C. Bailey, M.D., M.S.P.H., Health Officer/Department Director, Bear River
District Health Department
Printed on recycled paper {iUb
H
M
Md
ffi
fl
I
o
NOTICE
The Utah Solid and Hazardous Waste Control Board is issuing a Utah Hazardous Waste
Research, Demonstration, and Development Permit to Hill Air Force Base, Utah Test and
Training Range for treatment and deactivation of lithium batteries at their facility located in Box
Elder County, Utah.
A public hearing to discuss the RD&D Permit has been scheduled for September 29, L992 at
1:30 p.m. in room 406 of the Cannon Health Building located at 288 North 1460 West, Salt
I-ake City, Utatr. A second public hearing will be held September 30, 1992 at 7:00 p.m. in the
auditorium at the Tooele County Courthouse located at 47 South Main, Tooele, Utah.
Contact David McCleary of the Department of Environmental Quality at 538-6170 if you have
any questions. Persons with disabilities who require special accommodations should call Brent
Bradford at 538-6621.
:
;
I
.)
ffi *$'7
o
.-H
ffi
STATEMENT OF HEARING OFFICER
FOR PUBLIC HEARING
Hill Air Force Base
Utah Test and Training Range
Box Elder County, Utah
Besearch, Development, and Dernonstration Permit
For the Lithium Battery Deactivation Facility
September
Martha Hughes Cannon Health
Roorn
1:3O
29, 1992
Buildiilg, Salt Lake City, Utah
406
P.M.
M
September 30, 1992
Tooele County Courthouse, Tooele, Utah
South Auditorium
7:0O P.M.
Hearing Officer: David McCleary
Ladies and Gentlemen, we call this hearing to order. This is a hearing to receive
comrnents on the draft Hazardous Waste Research, Demonstration, and Development
(RDDI Permit being issued to Hill Air Force Base, Utah Test and Training Range for
treatment and deactivation of lithium batteries at their facility located in Box Elder
County, Utah. This permit will be the third permit renewal for this facility, which will
allow the Permittee to operate for 365 operating days upon issuance of this permit.
This hearing is being held under the authority of Section 1 9-6-101 through 105 of the
Utah Code.
My name is David McCleary. I represent the Utah Solid and Hazardous Waste Control
Board and have been appointed by the Executive Secretary of the Board as the hearing
officer. Also present at this hearing are other representatives of the Utah Division of
Solid and Hazardous Waste.
The public notice for the draft permit was published in the August 25, 1992 issue of
the Tooele Transcript Bulletin, and in the August 26, issue of the Salt Lake Tribune.
Deseret News. Ogden Standard Examiner, Herald Journal, and the Box Elder News and
Journal. A copy of the draft permit and the adrninistrative record has been made
available for examination at the Department of Environmental Ouality, 288 North
1460 West, Salt Lake City, Utah. A public notice announcing the draft permit was
also published in the newspaper and has been avaitable for public inspection.
$.j{iR
o
a
ffi
M
Opportunity will be provided to any person desiring to participate in these hearings.
Written statements dealing with the draft permit received no later than 5:O0 P.M.,
October 9, 1992 will be accepted for the record. lf anyone desires to make an oral
statement regarding the draft perrnit, please sign the form and leave it with me.
These proceedings are being recorded and a transcript of these proceedings will be
available for public inspection at the Department of Environmental Ouality, Division
of Solid and Hazardous Waste, 4th Floor of the Martha Hughes Cannon Health
Building.
This is an adrninistrative hearing and as such there will be no cross examination of the
witnesses. Those who have questions to ask or statements to make should state
their names and direct their statements to me. I will then determine the
appropriateness of the question and/or staternent and direct your statement to the
appropriate individual. I ask that you confine your remarks to the information in the
draft permit and lirnit them to 1O minutes orless. Comments that are not peftinent
will be ruled out of order.
It is the policy of the Department of Environrnental Ouality that the hearing remain in
session for at least one hour. lf, during that hour, there comes a time when there is
no one desiring to make a statement, the session will be recessed. At the end of the
hour or longer, the hearing will be reconvened and the record reopened. The hearing
will then be concluded after all those who desire to make a statement have done so.
lf there are no additional comments, this hearing will be considered closed. Any
additional written comments will be received until 5:oo F.ffi., october 9, 1992.
Please leave your comments with the secretary at the front desk of the Division of
Solid and Hazardous Waste, Fourth Floor of the Cannon Health Building.
Adjourned atl|l Septernbe r 29,1992
Adjourned at$:0 Z4epternber 30, 1992
M
:
i$ilg
o
I'S.!S,.nfigni*{ji
H
H
STATEMENT OF HEARING OFFICER
FOB PUBLIC HEARING
Hill Air Force Base
Utah Test and Training Range
Box Elder Gounty, Utah
Research, Development, and Demonstration Permit
For the Lithium Battery Deactivation Facility
January 6, 1993
Martha Hughes Cannon Health Building, Salt Lake City, Utah
Room 406
10:OO A.M.
January 6, 1993
Tooele County Courthouse, Tooele, Utah
South Auditorium
7:OO P.M.
Hearing Officer: David McCleary
Ladies and Gentlemen, we call this hearing to order. This is a hearing to receive
comments on the draft Hazardous Waste Research, Demonstration, and Development
(RDD) Permit being issued to Hill Air Force Base, Utah Test and Training Range for
treatment and deactivation of lithium batteries at their facility located in Box Elder
County, Utah. This perrnit wil! be the third permit renewalfor this facility, which will
allow the Permittee to operate for 365 operating days upon issuance of this permit.
This hearing is being held under the authority of Section 19-6-101 through 105 of the
Utah Code.
My name is David McCleary. I represent the Utah Solid and Hazardous Waste Control
Board and have been appointed by the Executive Secretary of the Board as the hearing
officer. Also present at this hearing are other representatives of the Utah Division of
Solid and Hazardous Waste.
The public notice for the draft permit was published in the December 1 , 1992 issues
of the Tooele Transcriot Bulletin, Salt Lake Tribune, Deseret News. Ooden Standar
Examiner. Herald Journal, and the Box Elder News and Journal. A copy of the draft
permit and the administrative record has been made available for examination at the
Department of Environmental Ouality, 288 North 1460 West, Salt Lake City, Utah.
A public notice announcing the draft permit was also published in the newspaper and
has been available for public inspection.
H
i
,tjiO
o
a'
H
M
Opportunity will be provided to any person desiring to participate in these hearings.
Written statements dealing with the draft permit received no later than 5:OO P.M.,
January 14, 1993 will be accepted for the record. lf anyone desires to make an oral
staternent regarding the draft permit, please sign the form and leave it with me.
These proceedings are being recorded and a transcript of these proceedings will be
available for public inspection at the Department of Environmental Ouality, Division
of Solid and Hazardous Waste, 4th Floor of the Martha Hughes Cannon Health
Building.
This is an administrative hearing and as such there will be no cross examination of the
witnesses. Those who have questions to ask or statements to make should state
their names and direct their statements to me. I will then determine the
appropriateness of the question and/or statement and direct your staternent to the
appropriate individual. I ask that you confine your remarks to the information in the
draft permit and limit them to 10 minutes or less. Comrnents that are not pertinent
will be ruled out of order.
It is the policy of the Department of Environmental Ouality that the hearing remain in
session for at least one hour. lf, during that hour, there comes a time when there is
no one desiring to make a statement, the session will be recessed. At the end of the
hour or longer, the hearing will be reconvened and the record reopened. The hearing
will then be concluded after all those who desire to make a statement have done so.
lf there are no additional comments, this hearing will be considered closed. Any
additional written comments will be received until 5:OO F.ffi., January 14, 1993.
Please leave your comments with the secretary at the front desk of the Division of
Solid and Hazardous Waste, Fourth Floor of the Cannon Health Building.
M
H
j
,l
1
i
I
i
,llIil
M
m
)
I
I
I
Adjourned at
Adjourned at
, Jonuary 6, 1993
, Jonuary 6, 1993
g'"\ rr -t
.-:o C
F€a*Y*:
,.
Hill Air Force Base
Utah Test and Training Range
Research, Development, and Dernonstration Permit
For the Lithiurn Battery Deactivation Facility Public Hearing
September 29, 1992
Martha Hughes Cannon Health Building, Salt Lake City, Utah
Room 406
1:3O P.M.
MAILING ADDRESS ORGANIZATIONi NAME COMMENT
(Yes or No)
C(o ,-[ I AF11 / rn tr
IIDtr,Q /NSil I
0o -/7La/ Ln slJy
es
Sr*lE ,/*r ETr< k/
{i^L
*'L'e
o
u$$!e,iffi rt!+stlsdiq;l5E!.!+qitiHiL-fl ;:*'a':'s:<riH3':
COMMENT
(Yes or No)
M
H
Hill Air Force Base'
Utah Test and Training Range
Research, Development, and Demonstration Permit
For the Lithiurn Battery Deactivation Facility Public Hearing
September 30, 1992
Tooele County Courthouse, Tooele, Utah
South Auditorium
7:00 P.M.
MAILING ADDRESS ORGANIZATIONNAME
0vtr fLr-ufrLa
t :/L, *FB T<t^)5 rxlau K*rc ruul
M
q.. s!r-,ur grtttb IEQ /DstlrJ_ h) a
-
tt n bt tt 1t
/V1
il YY rL'.n, v>fitw rutP/ffJt| ffr r ryLb lYf
Esu b /,Ee /osa'J A) o
l 't 1')-T-
Il:lrIl,litlIll
I
IIII
II..I iIIr ",1,. Oi.3IIr 'il1
o
iisrlEi$Fi'q1:*itttrir*\:i*:*;rxiL<u!e
COMMENT
(Yes or No)
.
H
Hill Air Force Base
Utah Test and Training Range
Research, Development, and Demonstration Permit
For the Lithium Battery Deactivation Facility Public Hearing
January 6, 1993
Martha Hughes Cannon Health Building, Salt Lake City, Utah
Roorn 406
1O:O0 A.M.
MAILING ADDRESS ORGANIZATION
-.=\ ,i-
r NAME
I
il
,i/-
/,
M
P -t,, / Ct",rk Lne s y'ry'/ ,4f// t.r<,/f
Sr^ri- Ande,yx rr.S r-+ L*l
57Eu,AJ
Lm St{/rhr"a *Fe
aJoTrcUJ
H o.r, tW-* r+-*r*d\v<-/rys*1
t^S AP
0e oC',LA ,ilott
{-}'i a
'o K}!tj!ilS!$sl(t+;ii:\'i++r"ii'|-"{:rt':}tf'i:+
H
-M
Hill Air Force Base
Utah Test and Training Range
Research, Development, and Demonstration Perrnit
For the Lithium Battery Deactivation Facility Public Hearing
January 6, 1993
Tooele County Courthouse, Tooele, Utah
South Auditorium
7:0O P.M.
MAILING ADDRESS ORGANIZATIONNAME COMMENT
(Yes or No)
7A6 5- €tc 2D
tJ?)
I
i
I
i
q
t
1
ui-5
oI
H
',,
Dick Clark: "Ilrere are enough items here that we would want to submit it in writing, however
I have a couple of questions that perhaps we should ask in clariffig some of these as to how
we feel. Some of them are comrnents such as, incomplete sentences or something, and we
would tike to know just exactly what is meant by this sentence.n
David McCleary: "Comments versus modules or attachments. In ttre permit there are several
modules and then there are attachments. Are your comments to the modules."
Dick Clark: "Yes, to the modules", and some to the attachments."
David McCleary: nI would suggest ttrat you submit those in writing.'
nAny other @mments?"
David McCleary: 'Okay then we will consider this meeting adjourned and reconvene
approximately 2: 30 p. m.
The meeting was reopened at 2:30 p.m. and there were no comments made.
David McCleary: " If there are no additional comments, this hearing will beconsidered closed.
Any additional written comments will be received until5:00 p.m. Octobert 19, 1991. Please
leave your comments with the secretary at the front desk of the Division of Solid and llazardous
Waste, Fourth Floor of the Cannon Healttr Building, Thutk you."H
H
i
,M
H
M
Norman E Bangerter
Governor
Kenneth L Alkema
Executive Director
Dennis & Downs
Director
StmiL* sfl t"]t,ffih
DEPARTMENT OF EI\MIRONMENTAL QUATITY
DTTflSION OF SOLID A}ID }IAZARDOUS WASTE
288 North 1460 West
P. O. Box 144880
salt Lake city, utah 84114-4880
(801) s38-6170
[phone] Fax
1t
il
'1
December 2,1992
CERTTFIED MAIL
REITJRN RECEIPT REOI'ESTED
Jamm R. Van Orman
Director of Environmental Management
Department of the Air Force
Headquarters Ogden Air Logistics Center (AFLC)
Hill Air Force Base, Utah 84056-5990
RE: Comments on Hill Air Force Base QIAFB), Utah Test and Training Range (UTTR), Draft
Research Development, and DemonStration Permit, Lithium Banery Deactivation Facility.
Dear Mr. Van Orman:
Your comments on the HAFB, UTTR, draft Research, Development, and Demonstration Permit for the
Lithium Battery Deactivation Facility in Box Elder County has been received and reviewed by the staff
of the Division of Sol id and Hazardous Waste. We have addressed the comments as follows:
Comment Number I - Table of Contents, page v, line I is as follows: Chuge to read: '8. Research
Plan Contains Pernittee's Research Plan and ttre MESP Lithium Battery Specifications pages 8-1 though
8-5.-.
The Permittee submitted pages 8-1 through 8-5 to replace pages l-l through 1-2 and
pager G-l through G-3, for Research Plan referencing, therefore this change will be
implernented as commented.
Comment Nurnber 2' Table of Contents, page v, line 9 is as ficllows: Change to read: "9. Tank and
Facility Specifications, Drawings and Pertinent Inforrnation Contains Permittee's Tank and Facility
specifications, drawings zurd o$rer pertinent facility information, pages 9-1 through 9-17." .
The Permittee did not resubmit all applicable pages of 9-1 through 9-17 to replace pages
H-l through II-16, therefore this change will not be implemented as commented and will
remain as stated in the August 26, 1992 draft permit.
Comrnent Number 3 - Table of Contens, page vi is as follows: In the definition of "Operating Day",
tfie word "facility" and "calendar" are misspelled.
These words are corrected and spelled as specified in Webster's 9th New Edition
Col legiate Dictionary.
F,t* ld'
0i.'7
.o
', t!
j
t
Iil
,fl
Fl
_t
i
1
I
iJ
H
M
,M
Mr. Van Orman
HAFB, UTIR Droft Pcrmit Comments
Dcccmber 2, lgYz
Pago 2
Comment Number 4 - Module I, page 3, para I.G. is as follows: Change to read: "This permit shall
be effective for a period not to exceed 365 oporating days from date of issuance of this permit, not
including work related maintenarce repairs. " .
This comment is implemented al follows: Condition I.G. is changed to read, .... "not
to exceed 365 operating days ftom date of issuance of this permit", and the definitions
of the Table of Contents section for "operating day" will contain all information of this
comment.
Comment Number 5 - Module I, page 5, para I.M.4. is as follows: This para contains two, incornplete
sentences. Please clarify.
R315€-15(d) is included in sentence one of this permit condition to complete the
sentence and sentence two of this permit condition is as follows: 'The request shall
provide information demonstrating that the proposed mettrod(s) requested to be substituted
is equivalent or superior in terms of sensitivity, accuracy, and precision (i.e.,
reproducibility). "
Comment Number 6 - Module I, page 6, paraI.N. is as follows: The 2nd to last sentence is incornplete.
Should it begin with "Neither"?
The word "neither" is included in this permit condition.
Cornment Number 7 - Module I, page 7, para I.R.2. is as follows: Is R3l5-2-1.9(e) the correct
reference?
This reference is changed to R315-2-11(e).
Comment Number 8 - Module I, page 9, para I.U. is as follows: Appears to be an incomplete sentence.
This permit condition is changed as follows: "The Permittee shall provide a facility
effectiveness report to the Executive Secretuy each rnon0r, which chronicles operations
and conditions of ttre facility."
Comment Number 9 - Module I, page 10, para I.V. is as follows: Is it assumed that this report will
cover a two-year period? Is ttris accurate?
A Biennial Report is required to be submitted following March I in the even nurnbered
years as specified in R315-8-5.6, which documents facility operations in the previous odd
numbered years.
.M
(}"IB
a:
ir
M
M
i
.t
{t
M
Mr. Van Onnan
HAFB, UTTR Draft Permit Comments
Decernb er 2, lgYz
Page 3
Comrnent Number 10 e Module I, page
reference?
This reference is changed
Comment Number 11 - Module I, page
reference?
1 1, para I.BB.4.
to R315-84.2(a).
12, para I.88.6.
is as follows: Is R3 15-8-4-(a) the correet
is as follows: Is R315-8-7.3 the correct
This reference is ehanged to R315-8-7.
Comment Number 12 - Module I[, page 2, para U.E.l. is as follows: ,Due to the numerous OO-ALC
agencies involved with the deactivation facility maintenance and repair, it may not be possible to
determine and submit to the Executive Secretary, an aecurate time schedule within 72 hours. Instead,
a seven (7) day notification time would be more desirable. Obviously, all facitity operations will be
terminated and all required documentation will occur :N soon as the problem is discovered. A seven day
period would, however, allow OO-ALC time to fully coordinate with responding organizations and
would, in most instances allow for problem resolution within this time frame
This comment mnnot be implernented as sated. Seventy-trro Q2) hours is considered
an adequate time frarne for submitting a schedule for remediating deterioration or
malfunctions at this facility.
Comment Number 13 - Module II, page 5, para II.J.3.. is as follows: Is R315-3-3.3 ttre correct
reference?
This reference is changed to R315-3-80).
Comnrent Number 14 - Module II, page 6, para II.K.4. is as follows: Is R315-3-9.1(d) the correct
reference?
This reference is changed to R3l5-3-15(d).
Comment Number 15 - Module II, page'7, pua II.K.8. is as follows: Is R315-8-7.9 the correct
reference?
The reference is changed to R315-8-7.
Comment Number 16 - Module III, page 2, para trI.B.2. is as follows: The word "sixty" should be
"thirt)ru.
The word "sixty" is replaced with the word "thirr1r"
oie
F
ot,
;
ffi
Mr. Van Onnan
HAFB, UTTR Dmft Pcrrnit Commcnts
Deccrnbor 2, l9Y2
Page 4
Comment Number 17 - Module III, page7, pila III.6.1.b. is as follows: Should the reference "III.E.6."
be "III.E.S."?
The permit condition cited in this pennit condition is
Comment Number 18 - Module III, pageg, para UI.[f .4. is as follows:
10"?
changed from III.E.6 to III.E.S.
Should 'R450-8-10" be "R315-8-
M
The reference is changed to R315-8-10.
Comment Number 19 - Module III, page 10, para III.I.1. is as follows: Should 'R450-8-10" be "R315-
8-10"?
The reference is changed to R3l5-8-10.
Comment Number 20 - Module IlI, page 6, paras III.F.6, III.F.6.a, and III.F.8 is as follows: The
secondary containment system that will be used for the below grade process tanks will be ttre placement
of a smaller diameter tank inside of the existing tanks. A leak detection system will be placed in the
annular space between ttre tanks and this area will be covered by a sealing flange to prevent moisture
intrusion. This configuration will make inspections of the secondary containment tal*s difficult.
Inspections at the frequency now required by these Module paragraphs will cause excessive delays in
battery deactivations. It is tlerefore proposed that the above paragraphs be amended as follows:
para II[.F.6. Add "(during operation)" after the word "period"
i
ffil
.M
-
i
I
d
H
para III.F.6.a.
para III.F.8.
Change to read "Integrity of the seconduy containment system sealing flange. "
Change to read: "The Permittee shall, in addition to Condition III.F.7, inspect the
secondary containment systems for the tanks identified in Condition III.B.4 at least once
each year for the following:"
Comment 20 is addressed as follows: Condition III.F.8. will be irnplemented as
stated above and Condition III.F.6. and III.F.6.a. will be churged to read;
III.F.6,The Perrnittee shall, in addition to the Conditions of
I[I.F.2. through II[.F.4., visually inspect each tank
system identified in Conditions If[.8.4. at least once
each operating day for the following:
Integrity of the secondary containment systern sealing
flange;
UI.F.6,a.
Oc;O
I..t
I
I
i
.M
H
Mr. Van Orman
IIAFB, UTTR Draft Pcrmit Commonts
Dcccmbcr 2, l99Z
Pago 5
The following comments to the Attachments of the August 26, L992 draft permit will be implemented as
stated except for the comments for Attachment 3, page 3-4 and Attachment 9, which will not be
implemented:
Attach. 1, (page 1-1, para 2-1), @age l-2, paras 2-2,2-3), (page 1-3, para 2-5), @age 1-11, para 15-1),
(page l-15, Figuro 4) is as follows: New organizational and offrce symbol changes are reflected on
submitted pages.
l
i
iJ
M
Attach. 3, page 3-1, 2nd para.
Attach. 3, page 3-1, 3rd para.
Attach, 3. page 3-4, lst para.
Auach. 3, page 3-5, item (3).
Attach. 3, page 3-6.
Attach. 3, page 3-'l .
Attach 3, page 3-9.
Attach. 3, page 3-10
Attach. 3, pages 3-5,
& 3-10
The reference to "R315-8 .6.2" should be changed t0
"R315-8-2.6".
Change the two references from "Module IV" to
"Module IIIU.
Change the references from "40 CFR 264. 15(c) and
R3 l5-8-10.5(C)" to "40 CFR 264. ls(d) and R3 15:l-
9.6(d)',.
Change telephone number from "'14274" to "72699u.
Add the following to the sentence at the top of the "Pre-
Operation Inspection Logn: "Any discrepancies
discovered during inspection shall be imrnediately
reported to OO-ALC/LMSHY. u.
Add the following to the sentence at the top of the
"Daily Inspection Log": "Irrunediately report all
discrepancies to the identified agencies.".
Change the second sentence at the top of the "Weekly
Inspection Log" to the following: "Any discrepancy
found with the security devices shall be imrnediately
reported to Range Civil Engineering (SUE) - ext. 71545,
Range Security (SUS) - ext 71522, ild LMSHY - ext.
-12699,"
,
Elirninate "First Aid Kit" as an item to be inspected.
Change office symbol "LMMRO" to "LMSHY".
I
,M
H
,!
,i
j
;
i
i
I
ilc
H
3{, 3-9, 3-9,
{.}2j.
It
M
.M
Mr. Van Onnan
HAFB, UTTR Draft Perrnit Comrnents
Dpcernber 2, lgYz
Page 6
Anach . 4, page 4-3.
Attach. 5, page 5-2, item 2.
Attach. 5, page 5-3, item 4.
Attach. 6, page 6-2, itern 2a.
Attach. 6, page 6-2, itern 2c.
Attach. 6, page 6i,, item 2d.
Attach . 6, page 6-3, item 6.
Attach. 6. page 6-4, 7th para.
Attach. 6, page 6-8, Iine 3.
Attach. 6, page 6-10, last pila, lst
Attach. 6, age 6-L2, Figure 1.
Attach . 7, page 7-4, lst para.
Add new para:
"Record keeping Requtementq
Records urust be kept for all individuals participating and
cornpleting the required training courses. Copies of
these records must be kept at the UTTR complex.".
Replace u400" with "1000u and delete "..., 500 gpm
purnp. " from the "Structural purnper".
Replace the word "truck" with "trailer" for the "water
buffalo".
Delete the words "with halon and dry chemical for
engine fires" from the "Ramp patrol vehiclg".
To accurately reflect what is located at ttre deactivation
facility, change to read: "4. Safety equiprnent
maintained at ttre facility specific to the possible hazards
include a deluge shower, eyewash station and wash
down/rinse water. ".
Change to read: "a. Structural purnper - 1000 gallon
storage capacity"
Change to read:
w/purnp)u.
400 gallon "Water Buffalo" (trailer
Eliminate " - halon & dry chemicals"
Eliminate the words "facility andn.
Replace second sentence with "Sulfur dioxide gas is a
colorless gils with a shaqp, pungent odor. ".
Change sentence to read: "The Hill Consolidated
Cornmand Post is notified as per driver's instnrctions on
DD Forrn 836. ",
Change sentence to read: "Immediately after the sentence
ernergency condition is over, the Ernergency Coordinator
or his alternate will determine if any uraterial from the
lithium batteries is still considered hazardous. " .
Update of Hitl AFB office symbols.
Change reference from "R315-8-7.10n to
'R315-8-7. " .
M
o
il
i
l
.d
M
-1
i
M
w
Mr. Van Orman
HAFB, UTTR Draft Perrnit Comments
December 2, lgYz
Pago 7
Attach . 7 , page 7-5, lst para.
Attach. 8, Title page.
Attach. 8, page 1-1.
Attach. 8, page l-2, step 2.
Attach. 8, page l-2.
Attach. G, Title page.
Attach. G, paBB G-l
Attach. G, page G-2.
Attach. G. page G-3.
Attach. 9, Title page.
Attach. 9, page H-l.
Change reference from "40 CFR L64.1 11' to"fi cFR 264.1 I 1.',.
Change Title page to read:
"ATTACIIMENT 8
SECTION 1 . RESEARCTI PLAN
SECTION 2. LITHIUM BATTERY
SPECIFICATIONS ".
Change the page nurnber from "l-1" to n8-1"
Replace '(Lithium Chloride)" in the chernical equation
with " (Sulfur Dioxide)'.
Change the page number from " L-2" to " 8-2" .
Eliminate this page.
Change Title to read: SECTION 2 - LITHIUM
BATTERY SPECIFICATIONS U.
Change figure references from "Figure G-l" and "Figure
G.2" to 'Figure 8-1" and "Figure 8-2" respectively.
Change page number frorn "G-1" to u8-3'.
Change "Figure G-l" to "Figure 8-I ".
Change page number from "G-2" to "g-4".
Change "Figure G-2" to "Figure 8-2".
Chuge page number from "G-3" to "8-5".
Change Title page to read:
"ATTACHMENT 9TANK AND FACILITY SPECIFICATIONS,
DRAWINGS AND PERTINENT INFORMATION".
Change figure references from "Figure H- 1", "Figure H-
2", "Figure H-3", and "Figure H-4" to "Figure 9-1",
"Figure 9-2" , "Figure 9-3 ", and "Figure 9-4"
respectively.
Change page number frorn "H-1" to "9-1".
Change figure reference from "Figure H-3" to "Figure
9-3tt.
Change page number from "H-la" to "9-2".
Attach . 9, page H-la.
{-} j.t
:
.i
-M
H
Mr. Yan Onnan
HAFB, UTTR Draft Permit Cornmentr
Decernber 2, lgYz
Page 8
Attach . 9, page H-2.
Attach. 9, page H-3.
Attach. 9, page H-4.
Attach. 9, page H-5.
Attach . 9, page H-6.
Attach . g, page H-7.
Attach. 9, page H-8.
Attach . 9, page H-9.
Attach. 9, page H-10.
Attach. 9, page H-l l.
Attach . 9, page H-12.
Attach. 9, page H-l3.
Attach . 9, H-14.
Attach. 9, page H-15.
Attach. 9, page H-16.
Change figure references from "Figure H-5", "Figure H-
6", and "Figure H-7n t0 'Figure 9-5n, 'Figure9-6", and
"Figur e 9-7 " respectively.
Change page number frorn "H-2" to "9-3".
Change page number from nH-3 to "94,.
Change figure references from "Figures lr-g and
I{-9' to "Figures 9-8 and 9-9".
Change page nurnber from *H*4" to u9-5',
Changs page umber from "H-5" to ,'!6".
Change "Figure H-ln to "Figure 9-1 ",
Change page number from 'H-6" to "g:l "
Change "Figure H-2" to "Figute 9-2,, .
Change page number frorn ,H ,,,, to "9-g"
Change "H-3", "H-33", "H-3bn, gtc. to appropriate
3", "9-3a", "9-3b", etc. for thg Z drawings.
Change 'Figure H-4" to "Figure 94',.
Change page nurnber from nH-9', to ,'9-10',.
U,-4
i
I
Ii
I
M
Change "Figure H-5" to "Figure 9-5,,
Change page nurnber from "H-10' to
Change "Figure H{" to "Figure 9{,,
Change page nurnber frorn "H-l l " to
Change "Figure H{" to 'Figure 9{"
Change page number from "H-12', to
Change "Figure H-7" to "Figureg-7,,
Change page number from "H-13" to
Change "Figure H-7" to "Figure 9-7"
Change page number from "II- 14" to
Change "Figure H-8" to "Figure 9-8"
Change page number frorn "H-15" to
Change "Figure H4" to "Figure 9-9,,
Change page number fronr "H-16" to
'9-l I "
"9- 12"
t'9- 13 "
" 9- 14"
tt9- 15 "
" 9-16'*
"9- 17"
o
Mr. Varr Onnan
HAFB, UTTR Draft Pcrmit Commcnts
Deccmbcr 2, lgn
Pcgo 9
Ttre inspection schedules urd procedures comments of Comrnent Number 20 are significant deparilres
ftom the August 26,1992 draft permit inspection schedules urd procedures, therefore, the August 26,
1992 draft permit will be re-noticed urd subject to a 45 day public cornrnent Beriod commencing on
December L, L992 and ending on fanuary L4, 1992. A public hearing will be held on Wednesday,
January 6, t992 at 10:00 am, at the following location:
Martha Hughes Cannon
Health Building
Room 406
288 N. 1460 rV.
Salt Lake City, UT 841 16
An additional public hearing will be held in Tooele, Utah at 7:00 P.M. on Wednesday, January 6,
1992 at the:
Tooele County Courttrouse, Auditoriurn
47 Souttr Main
Tooele, Utah
We appreciate HAFB, UTTR allocating time to so thoroughly review and comrnent on the draft
perrnit. Any questions in this regard should be addressed to Mr. David McCleary of my staff at 538-
6170.
Sincerelv vours.R#
Commercial/Federal Facilities Branch
Utah Division of Solid and Hazardous Waste
STA/DMM
c: John C. Bailey, M.D., M.S.P.H., Health Officer/Department Director
Bear River District Health Department
Linda Armington, R.N., M.P.H., Healttr Officer/Director, Tooele County
Health Departrnent
Larry Wapensky, EPA Region VIII
.H
.H
.H
I
i
i
i
i
I.i
l.
t
l
1
'|
!
#
M
rq
I
I
i
Lt
i
I
i
i
I
I
lJ
H
1.
2.
.H
H
Additional Administrative Changes to the Draft RDD Permit
by the Department of Environmental Quality
The Permit will be dated and effective April 1, 1993.
The following page changes to the Table of Contents, page iv, Module III were made:
Module III - Storage and Treatment in Tank Systems Module III
C. TANK SYSTEM INSTALLATION TII.2
E. GENERAL OPERATING CONDITIONS III- 4
H. RECORDKEEPING AND REPORTING Itr- 8
J. TANK CLOSURE M-10
K. PROVISIONS FOR INCOMPATIBLE WASTES III-10
The word "reissued" shall be deleted from Module I, condition I.D.1.
The word "reissuance" shall be deleted from Module I, condition I.D.2.
Module I, condition I.N., regulatory citation R315-3-9 shall be changed to R315-3-15.
Module I, condition I.W., shall be worded as follows to provide clarification:
r.W. OTHERNONCOMPLIANCE
The Permittee shall report in writing all other instances of noncompliance with this
permit not otherwise required to be reported in accordance with permit condition I.R. of
this permit, within seven days of discovering the noncompliance. The reports shall
contain the information listed in permit condition I.R. of this permit. Reporting shall not
constitute a defense for any noncompliance.
Module I, condition I.AA., emergency telephone number shall be changed to 801-536-
4123.
Module I, condition I.BB.2., shall be worded as follows to provide clarification:
I.BB.2.Inspection schedules (Attachment 3), as required by R315-8-2.6O) and a
record of inspections in an inspection log for a period of three (3) years
in accordance with R315-8.2.6(d);
ffi
H
3.
4.
5.
6.
7.
8.d
f,
fl
Page 26