DSHW-2024-006379

THATCHER COMPANY
P. 0. Box 27407, Salt Lake City, UT 84127-0407
May 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 May 2024
Dear Utah Division of Waste Management and Radiation Control:
i
CH EM
Thatcher Company has prepared this April 2024 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., aggressive ly 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 calculate the number of Phase 3 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.
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Phase 3 Area and Containers Summary Table
April 15th Container
March Report No. Material May 15th
No. of Line 15th of Management Report No. of
Items Report Remaining Determination -Remaining Line
and/or No. Line Line Items Not Found, No Non-Items and/or
Containers Items and/or Data, and/or Hazardous Containers "In-
(From and/or Containers Used Containers process"/
Baseline Containers "In-(Subtracted (Subtracted (Potential
Area/Trailer Inventory) 1 Remaining process" from Total) from Total) Additions) Comments
Area 1 3 3 3 0 0 3 Not Started.
Area 2 12 12 12 0 0 12 Not Started.
Area 3 5 5 5 0 0 5 Not Started.
There were not any containers
Area 4 0 0 0 0 0 0 identified on the Baseline Inventory.
Active in process.
May
1. Containers not found and/or no
data: 22
2. Container A-05-116 is empty and
is subtracted from total.
3. Shipped 27 containers.
Area 5 130 98 57 22 0 7 Total: 50
1 The Baseline Inventory includes the following spreadsheets.
1. Spreadsheets containing line items with container counts : 1) Disposition Spreadsheets for Area 1 O; and, 2) Trailer spreadsheets .
2. Spreadsheets with line items: Areas 1-14. Line items may contain single or multip le containers.
2
April 15th Container
March Report No. Material May 15th
No. of Line 15th of Management Report No. of
Items Report Remaining Determination -Remaining Line
and/or No. Line Line Items Not Found, No Non-Items and/or
Containers Items and/or Data, and/or Hazardous Containers "In-
(From and/or Containers Used Containers process" I
Baseline Containers "In-(Subtracted (Subtracted (Potential
Area/Trailer Inventory) 1 Remaining process" from Total) from Total) Additions) Comments
Ac t iv e In-Progress (1-c o ntainer per
line item).
May
1. Shipp ed 16 co nta i ners .
2. Non-hazardous containers: 5
Area 6 94 94 94 0 5 73 Total: 21
There w e re not any containers
Area 7 0 0 0 0 0 0 identifi ed on the Baseline Inventory.
Active in process.
May
1. Shipped 3 conta i ners.
2. Used containers: 1
3. Containers not found and/or no
data (these were already subtracted
from total): 5
Area 8 21 9 28 10 1 0 6 Tota l: 4
Area 9 3 3 3 0 0 3 Not Started .
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April 15th Container
March Report No. Material May 15th
No. of Line 15th of Management Report No. of
Items Report Remaining Determination -Remaining Line
and/or No. Line line Items Not Found, No Non-Items and/or
Containers Items and/or Data, and/or Hazardous Containers "In-
(From and/or Containers Used Containers process"/
Baseline Containers "In-(Subtracted (Subtracted (Potential
Area/Trailer Inventory) 1 Remaining process" from Total) from Total) Additions) Comments
Area 10
(Disposition Area 10 (240) and Area 10
List) 771 30 30 23 7 0 Disposi tion (531)
Area 11 24 24 24 0 0 24 Not Started .
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).
May
1. Shipped 58 containers.
2. Non-hazardous containers : 54
3. Containers not found and/or no
data (these were already subtracted
from total): 5
Total excluding the additional 2
Area 12 208 208 208 0 54 96 containers: 112
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April 15th Container
March Report No. Material May 15th
No. of Line 15th of Management Report No. of
Items Report Remaining Determination -Remaining Line
and/or No. Line Line Items Not Found, No Non-Items and/or
Containers Items and/or Data, and/or Hazardous Containers "In-
(From and/or Containers Used Containers process"/
Baseline Containers "In-(Subtracted (Subtracted (Potential
Area/Trailer Inventory) 1 Remaining process" from Total) from Total) Additions) Comments
Active In -Progress (1-container per
line item}.
May
1. Empties subtracted: 2
2. Non-hazardous containers: 2
Area 13 62 62 62 0 2 58 Total: 4
Area 14 3 3 3 0 0 3 Not Started.
Trailer
53323 108 0 0 0 0 0 Trailer completed.
Trailer
532173 147 0 0 0 0 0 Trailer completed.
Trailer 5316 174 0 0 0 0 0 Trailer completed.
Trailer
534325 156 0 0 0 0 0 Trailer completed.
Trailer
53138 47 0 0 0 0 0 Trailer completed.
Trailer
530417 211 0 0 0 0 0 Trailer completed.
Trailer
53113 219 0 0 0 0 0 Trailer completed .
5
April 15th Container
March Report No. Material May 15th
No. of Line 15th of Management Report No. of
Items Report Remaining Determination -Remaining Line
and/or No. Line Line Items Not Found, No Non-Items and/or
Containers Items and/or Data, and/or Hazardous Containers "In-
(From and/or Containers Used Containers process"/
Baseline Containers "In-(Subtracted (Subtracted (Potential
Area/Trailer Inventory) 1 Remaining process" from Total) from Total) Additions) Comments
Trailer Not Started.
53155
(Baseline The June 6, 2022 Baseline Inventory
53165) 115 115 115 0 0 115 listed thi s as 53165. It is 53155.
Totals 2711 685 626 46 68 405
Total with
Potential May
Additions 407 Area 12: 2
6
Containers Not on the Baseline Inventory
Due to a transcription error , trailer 5323 was not included in the Baseline Inventory. Following submittal of the Baseline Inventory, Thatcher Company informed the
Project Team of the error caused by the transcription error for trailer 53323 with trailer 5323 (i.e ., similar numbers).
Containers Not on the Baseline Inventory Table
No. of
Containers No. of
(From Remaining
Baseline Containers "In-
Area/Trailer Inventory) process"
Traile r 5323 98 0
AlO 145
Containers Jan.
2023 Monthly
Report 0 0
Totals 98 0
CONTAINER SHIPMENTS
Container shipments included the following.
Phase 3 Container Shipment Summary Table2
Shipment Date
Container Shipment 58: April 18 , 2024
Container Shipment 59: April 26 , 2024
Comments
This trailer was not accounted for as previously
indicated in the Monthly Reports.
This Trailer has been completed.
Upon further review they were accounted for
already and are not an addition.
Shipping Paper
NH2835-01
017418169FLE
017418160FLE
017418172FLE
017418173FLE
2 Previous weekly container shipment updates will be maintained in the historical files on the DWMRC SharePoint site.
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Shipment Date Shipping Paper
NH3718-01
Container Shipment 60: May 2 , 2024 NH3718-02
017418175FLE
017418176FLE
NH6856-01
Container Shipment 61: May 10, 2024 NH6856-02
017418180FLE
017418181FLE
MANAGEMENT OF CONTAINERS NOT IN GOOD CONDITION
Conta iners described as not in viable condition were not identified during weekly inspections.
INSPECTION RESULTS
There were no reportable observations 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).
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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 affine and imprisonment for knowing violations."
Sincerely ,
ike Mitchell, President
Thatcher Company , Inc.
1900 Fortune Road
Salt Lake City , UT 84104
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