DSHW-2024-008744

THATCHER COMPANY
P. 0. Box 27407, Salt Lake City, UT 84127-0407
October 15, 2024
Phone [phone]
Fax[phone]
Utah DEQ, Division of Waste Management and Radiation Control
P.O. Box 144840
Salt Lake City, UT 84114-4880
c&
CHEM
Reference: Thatcher Phase 3 Materials Management Monthly Letter Report for October 2024
Dear Utah Division of Waste Management and Radiation Control:
Thatcher Company has prepared this Monthly Letter Report as required under the Stipulation and Consent Order dated December 9, 2021, with Utah Department
of Environmental Quality, Division of Waste Management and Radiation Control (DWMRC) and the approved Phase 3 Material Management Plan (P3MMP).
SUMMARY
All areas and trailers are identified as "complete", however, all areas and trailer 53155 will remain "in process" to allow for the potential to manage containers
through 2024. Area and trailer 53155 container numbers were updated in the container tracking spreadsheet for August-September (includes container shipments
through September 16, 2024) and added to the DWMRC SharePoint on October 1, 2024. Thatcher Company will prioritize management of unknowns and/or
known hazardous waste (i.e., aggressively manage). Historical files will be updated and maintained for areas that are mostly completed (i.e., uploaded to the
Share Point).
The Phase 3 Area and Containers Summary Table was updated to correlate with the updates in the container tracking spreadsheet for hazardous waste, non-
hazardous waste, and not found containers.
An updated summary of the number of containers remaining in each area and trailer as compared to the original Baseline count of containers is detailed in the
table below.
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Notable Items
September Report
Container A-02-026 was previously on the not found list; however, this container was found, identified as an unknown and added to the container tracking
spreadsheet Hazardous Waste Action Items Section. Container T-53155-0238 was added to the Hazardous Waste list Pending Shipment of Profile Section and
shipped on August 30, 2024. Some of the "not found" containers have been located and will be added to the container tracking spreadsheet update.
October Report
Container A-02-128 (non-hazardous solids separated from A-02-12A) was added to the container tracking spreadsheet. A-02-026 (unknown) was
characterized/classified and managed as non-hazardous. Not found non-hazardous containers A-05-072 and 119 were found and added to the container tracking
spreadsheet.
All found containers have been shipped for disposal.
Phase 3 Area and Containers Summary Table
No. of Line
Items Sept. 15th Report No. of Oct. 15th Report No. of
and/or Remaining Line Items Remaining Line Items Container Material
Containers Hazardous Waste Hazardous Waste Management
(From and/or Pending and/or Pending Determination -Not Non-
Baseline Containers Analyses for Containers Analyses for Found, No Data, Hazardous
Area/Trailer Inventory) Waste Determination Waste Determination and/or Used!1> Containers Comments
Area 1 3 0 0 0 0 Area 1 completed.
Complete except for not found, no data,
Area 2 12 1 0 6 0 and/or used containers.
Complete except for not found, no data,
Area 3 5 0 0 2 0 and/or used containers.
Phase 3 containers were not identified
Area 4 0 0 0 0 0 on the Baseline Inventory.
Complete except for not found, no data,
and/or used containers.
Newly found non-hazardous containers
Area 5 130 0 0 20 0 A-5-072 and 119 were disposed.
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No. of Line
Items Sept. 15th Report No. of Oct. 15th Report No. of
and/or Remaining Line Items Remaining Line Items Container Material
Containers Hazardous Waste Hazardous Waste Management
(From and/or Pending and/or Pending Determination -Not Non-
Baseline Containers Analyses for Containers Analyses for Found, No Data, Hazardous
Area/Trailer Inventory) Waste Determination Waste Determination and/or Used11l Containers Comments
Complete except for not found, no data,
Area 6 94 0 0 1 0 and/or used containers.
Phase 3 containers were not identified
Area 7 0 0 0 0 0 on the Baseline Inventory.
Area 8 219 0 0 0 0 Area 8 completed.
Area 9 3 0 0 0 0 Area 9 completed.
Area 10
(Disposition Complete except for not found, no data,
List) 771 0 0 6 0 and/or used containers.
Area 11 24 0 0 0 0 Area 11 completed.
Complete except for not found, no data,
and/or used containers.
Container A12-174 was identified as
used and removed from the total of 3-
Area 12 208 0 0 2 0 containers reported in September.
Area 13 62 2 0 0 0 Area 13 complete.
Complete except for not found, no data,
Area 14 3 0 0 2 0 and/or used containers.
Trailer
53323 108 0 0 0 0 Trailer completed.
Trailer
532173 147 0 0 0 0 Trailer completed.
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No. of Line
Items Sept. 15th Report No. of Oct. 15th Report No. of
and/or Remaining Line Items Remaining Line Items Container Material
Containers Hazardous Waste Hazardous Waste Management
(From and/or Pending and/or Pending Determination -Not Non-
Baseline Containers Analyses for Containers Analyses for Found, No Data, Hazardous
Area/Trailer Inventory) Waste Determination Waste Determination and/or Used111 Containers Comments
Trailer 5316 174 0 0 0 0 Trailer completed.
Trailer
534325 156 0 0 0 0 Trailer completed.
Trailer
53138 47 0 0 0 0 Trailer completed.
Trailer
530417 211 0 0 0 0 Trailer completed.
Trailer
53113 219 0 0 0 0 Trailer completed.
Trailer July
53155 Correction
(Baseline Total 120
53165) (Was 115) 0 0 0 0 Trailer completed.
September report for not found, no
data, and/or used container count of 42
was updated for the October report as
follows.
1. Container number A-12-174 was on
the not found, no data, and/or used
container list, was determine to be
used, and removed.
2. Newly found non-hazardous
containers A-5-072 and 119 were
Totals 2596 3 0 39 0 removed.
(1) Used in the process.
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Containers Not on the Baseline Inventory
Two additional containers were identified for Area 12 in June. Five additional containers were identified for Trailer 53155 in July.
Containers Not on the Baseline Inventory Table
No. of
Containers
{From
Baseline No. of Additional
Area/Trailer Inventory) Containers Comments
This trailer was not accounted for as previously
Trailer 5323 0 98 indicated in the Monthly Reports.
AlO 145
Containers
Jan. 2023
Monthly Upon further review containers from this area were
Report 0 0 accounted for already and are not an addition.
June 2024
1-container per line item except for 208 and 209 that
have 2 containers each, which, would add 2-containers
Area 12 208 2 to Area 12 total.
Trailer See Phase 3 Area and Containers Summary Table Above
53155
(Baseline July 2024
53165) 115 5 Additional containers: 5
Totals 323 105
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CONTAINER SHIPMENTS
Container shipments included the following.
Phase 3 Container Shipment Summary Table 1
Shipment Date
Container Shipment 84: September 16, 2024
Container Shipment 85: September 20, 2024
Container Shipment 86: September 27, 2024
Container Shipment 87: October 4, 2024
Container Shipment 88: October 11, 2024
Container Shipment 89: October 11, 2024
Shipping Paper
017418274FLE
017418275FLE
NH50364-01
017418276FLE
NH28519-01
019255622FLE
019255749FLE
019255750FLE
019255751FLE
MANAGEMENT OF CONTAINERS NOT IN GOOD CONDITION
Containers described as not in viable condition were not identified during weekly inspections.
INSPECTION RESULTS
There were no reportable observations noted during weekly inspections.
NOT ABLE ITEMS
DWMRC Notified of Materials Container Detection of Bis(2-chloroetheyl) sulfide (sulfur mustard)
There have not been any additional container sample analyses with detections of sulfur mustard (i.e., reported as zero (0) by Chemtech-Ford).
1 Previous weekly container shipment updates will be maintained in the historical files on the DWMRC SharePoint site.
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Thatcher Company sincerely appreciates this opportunity to provide the P3MMP Monthly Report. Please contact Darren Bauer directly with questions, concerns,
or further comment on the P3MMP Monthly Report.
Certification,
"I certify under penalty of law that this document and any and all attachments were prepared under my direction or supervision according to a system designed to
assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
Sincerely,
, President
Thatcher Company, Inc.
1900 Fortune Road
Salt Lake City, UT 84104
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