DSHW-2024-007328

THATCHER COMPANY
P. 0. Box 27407, Salt Lake City, UT 84127-0407
July 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
Reference: Thatcher Phase 3 Materials Management Monthly Letter Report for July 2024
Dear Utah Division of Waste Management and Radiation Control:
' C H E M
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 will remain "in process" to allow for the potential to manage containers through 2024. Therefore, the container numbers are estimated and
will be finalized when the project is completed. Thatcher Company will prioritize management of unknowns (i.e., aggressively manage). Historical files will be
updated and maintained for areas that are mostly completed (i.e., uploaded to SharePoint).
Two columns have been added to the Phase 3 Area and Containers Summary Table listing: 1) Container Material Management Determination -Not Found, No
Data, and/or Used (Subtracted from Total); and 2) Non-Hazardous Containers (Subtracted from Total). The container numbers in these two columns will be
subtracted from the container count in order to calculate the number of Phase 3 hazardous waste containers to be managed.
An updated summary of the number of containers managed and remaining in each area and trailer as compared to the Baseline count of containers is detailed in
the table below.
Phase 3 Area and Containers Summary Table
No. of Line June 15th Report July 15th Report July
Items No. of Remaining No. of Remaining Container Material
and/or Line Items and/or Line Items and/or Management July
Containers Containers "In-Containers "In-Determination -Not Non-Hazardous
(From process"/ process"/ Found, No Data, and/or Containers
Baseline (Potential (Potential Used (Subtracted from (Subtracted
Area/Trailer lnventory)1 Additions) Additions) Total) from Total) Comments
Active in process. (1-container per
line item).
July 2024
1. Nonhazardous: 1
Area 1 3 3 2 0 1 Total: 1
Active In Progress (1-container per
line item).
Area 2 12 10 10 0 0 July 2024 No Update
Active In Progress (1-container per
Area 3 5 5 5 0 0 line item).
Phase 3 containers were not
Area 4 0 0 0 0 0 identified on the Baseline Inventory.
Area 5 130 0 0 0 0 Area 5 Completed.
1 The Baseline Inventory includes the following spreadsheets.
1. Spreadsheets containing line items with container counts: 1) Disposition Spreadsheets for Area 10; and, 2) Trailer spreadsheets .
2. Spreadsheets with line items: Areas 1-14. Line items may contain single or multiple containers.
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No. of Line June 15th Report July 15th Report July
Items No. of Remaining No. of Remaining Container Material
and/or Line Items and/or Line Items and/or Management July
Containers Containers "In-Containers "In-Determination -Not Non-Hazardous
(From process"/ process"/ Found, No Data, and/or Containers
Baseline (Potential (Potential Used (Subtracted from (Subtracted
Area/Trailer lnventory)1 Additions) Additions) Total) from Total) Comments
Active In-Progress (1-container per
line item).
July 2024
1. Shipped hazardous waste
containers : 14
2. Non-hazardous containers: 3
Area 6 94 31 14 0 3 Total: 17
Phase 3 conta i ners were not
Area 7 0 0 0 0 0 identified on the Baseline Inventory.
Area 8 219 0 0 0 0 Area 8 Comp leted.
Active In Progress (1-container per
Area 9 3 3 3 0 0 line item).
Area 10 Complete
(Disposition Area 10 (240) and Area 10
List) 771 0 0 0 0 Disposition (531)
Hazardous Waste Complete (1 -
container per line item).
July 2024 Completed
1. Shipped: 5 Hazardous
Area 11 24 5 0 0 0 Total: 5
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No. of Line June 15th Report July 15th Report July
Items No. of Remaining No. of Remaining Container Material
and/or Line Items and/or Line Items and/or Management July
Containers Containers "In-Containers "In-Determination -Not Non-Hazardous
(From process"/ process"/ Found, No Data, and/or Containers
Baseline (Potential (Potential Used (Subtracted from (Subtracted
Area/Trailer lnventory)1 Additions) Additions) Total) from Total) Comments
Active In-Progress (1-container per
line item except for 208 and 209
that have 2 containers each, which,
would bring the total to 210).
July 2024
1. Shipped hazardous waste
containers: 26
2. Non-hazardous containers: 3
Area 12 208 30 1 0 3 Total: 29
Active In-Progress (1-container per
line item).
July 2024
1. Shipped hazardous waste
containers: 4
Area 13 62 13 9 0 0 Total: 4
Not Started. (1-container per line
Area 14 3 3 3 0 0 item).
Trailer
53323 108 0 0 0 0 Trailer completed.
Trailer
532173 147 0 0 0 0 Trailer completed.
Trailer 5316 174 0 0 0 0 Trailer completed.
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No. of Line June 15th Report July 15th Report July
Items No. of Remaining No. of Remaining Container Material
and/or Line Items and/or Line Items and/or Management July
Containers Containers "In-Containers "In-Determination -Not Non-Hazardous
(From process"/ process"/ Found, No Data, and/or Containers
Baseline (Potential {Potential Used (Subtracted from (Subtracted
Area/Trailer lnventory)1 Additions) Additions) Total) from Total) Comments
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.
Trai ler
53113 219 0 0 0 0 Trailer completed.
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No. of Line June 15th Report July 15th Report July
Items No. of Remaining No. of Remaining Container Material
and/or Line Items and/or Line Items and/or Management July
Containers Containers "In-Containers "In-Determination -Not Non-Hazardous
(From process"/ process"/ Found, No Data, and/or Containers
Baseline (Potential (Potentia l Used (Subtracted from (Subtracted
Area/Trailer l nventory}1 Additions) Additions) Total) from Total) Comments
Active In-Process
The June 6, 2022 Baseline Inventory
listed this as 53165 . It is 53155.
July 2024
Note: Corrected Previous Count -
Updated to 120 (was 115). Added 3
containers of glycolic acid, and 2
Unknowns. Total : 5.
1. Shipped hazardous waste
containers: 14
2. Non-hazardous containers: 1
Total: 15
Trailer July
53155 Correction Note: Total count was updated, and
(Baseline Total 120 July 15th remaining count includes
53165) (Was 115} 24 14 0 1 the 5 added containers.
Totals 2596 127 61 0 8
Total with Trailer 53155: 5
Potential containers included
Additions NA NA above. NA NA
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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 2
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Shipment Date Shipping Paper
017418202FLE
Container Shipment 67, June 17 2024
017418205FLE
Container Shipment 68 : June 21, 2024 017418206FLE
017418208FLE
017418211FLE
Container Shipment 69: June 24 , 2024
017418213FLE
Container Shipment 70: June 27 , 2024 017418215FLE
017418217FLE
NH5956-01
017418221FLE
Container Sh ipment 71: July 5, 2024 017418222FLE
017418223FLE
NH8899-01
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.
NOTABLE 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).
2 Previous weekly container shipment updates will be maintained in the historical files on the DWMRC Share Point 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,
Mike Mitchell, President
Thatcher Company, Inc.
1900 Fortune Road
Salt Lake City, UT 84104
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