DSHW-2003-008416 - 0901a068801605aa

Paul Hancock, Manager
Environmental Remediation
Thiokol Propulsion Corp
P.O. Box 707
Brigham City, Utah 84302-0707

Re: Sampling and Analysis Plan to Evaluate Areas of
Potential Soil Contamination at M-39 and M-636

Dear Mr. Hancock:

The above referenced sampling and analysis plan is hereby approved. The plan proposes composite soil sampling and use of the sample data to perform a risk assessment. The samples will
be analyzed for cadmium, perchlorate and silver, which have been identified as the contaminants of concern. Soil gas samples are proposed, but will be collected as described in a separate
sampling plan.

The Division has identified several items that should be included in the final closure report, after the proposed sample data is collected:

The Division concurs that, based on the Utah State University (USU) soil study and the water balance calculations provided in the plan, the potential for migration of contamination from
soil to groundwater is minimal. However, to completely address the closure requirements of R315-101-3 (Principle of Non-Degradation), a soil to groundwater evaluation including the
proposed sample data should be included in the final closure report. Comparison of the USU data and EPA soil screening values with the sample results is recommended (see http://risk.lsd.ornl.gov/calc_start.shtml).

Section 3.1.2 does not address management of excess composite soils. The Division recommends returning this soil to the sample location. If not returned to the sample site, the soil
will need to be containerized and characterized.

Sample container types, sample preservation, sample holding times, and spike and duplicate control limits are not specified, and the Division assumes that the guidelines in the proposed
methods will be followed. The final report should include a section on data quality and, at a minimum, should address accuracy, completeness, precision and representativeness. After
review of the data quality section and the sample results as described below, the Division may request complete validated data packages for review.

If possible, please provide an Excel spreadsheet file with the final closure report that includes the following for each sample result: sample location, sample date, extraction and
analysis methods and dates, dilution factor, percent moisture, sample result, method detection limit, reporting limits, flags and other qualifiers. Please include all results including
non-detects and results that fall between the reporting limit and method detection limit (J qualified). Tables describing flags and qualifiers should also be included in the final closure
report.

The Division concurs with the proposed risk assessment approach using preliminary remediation goals (PRG) as a screen. However, depending on the results of the proposed sampling, the
final closure report may need to include site-specific risk assessment data or other information based on Thiokol’s final closure proposal (e.g., risk based residential or industrial
closure or corrective action).

It is assumed that a global positioning system or other methods will be used to locate the grid and the composite sample locations, but the method used to locate samples should be described
in the final closure report.

Please include a map or plate in the final closure report showing the final sample locations, sample numbers and analytical results. Deviations from the plan should also be discussed.

The Division assumes that fill was not placed in the excavations since the original waste removal actions. This should also be discussed in the final closure report.

Please provide a10-day notice prior to all sampling activities. If you have any questions or to provide sampling notification, please call Jeff Vandel or Dave Larsen of my staff at
538-6749.

Sincerely,

Original Document Signed by Dennis R. Downs on 12/15/03

Dennis R. Downs, Executive Secretary
Utah Solid and Hazardous Waste Control Board

DRD/dcl/kk

c: John C. Bailey, M.D., M.S.P.H., Health Officer/Director, Bear River Health Department
Linda Bowling, Region 8 EPA

TN200302432.doc

Page 2

State of Utah

Department of Environmental Quality

Dianne R. Nielson, Ph.D.
Executive Director

DIVISION OF SOLID & HAZARDOUS WASTE
Dennis R. Downs
Director

OLENE S. WALKER
Governor

GAYLE F. McKEACHNIE
Lieutenant Governor

December 15, 2003

288 North 1460 West • PO Box 144880 • Salt Lake City, UT 84114-4880 • phone [phone] • fax [phone]
T.D.D. [phone] • www.deq.utah.gov