DSHW-2004-007895 - 0901a06880164dd5

George Gooch
Environmental Services
ATK Thiokol Inc. – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: RCRA Compliance Evaluation Inspection
ATK Thiokol Inc. – Promontory
EPA ID #UTD009081357

Dear Mr. Gooch:

On September 22 and 23, 2004, Division of Solid and Hazardous Waste (the Division) staff members conducted a Compliance Evaluation Inspection (CEI) of the ATK Thiokol Inc. – Promontory
facility. This inspection was performed in order to evaluate Thiokol’s compliance with the State of Utah Hazardous Waste Management Rules (R315 of the Utah Administrative Code), and
its Hazardous Waste Storage and Post-Closure Permits.

Based upon our evaluation, it appears Thiokol is doing a good job in the area of waste management. While no compliance issues were identified during the inspection, Division staff members
did raise a concern regarding the adequacy of an inspection checklist utilized at the M-136 Burn Grounds. Details on the concern are identified below.

The inspection of the M-136 Burn Grounds was focused on the Liquid Thermal Treatment Area (LTTA) caps. The LTTAs are the historic trenches and pits where hazardous wastes were burned
and disposed. These trenches and pits were capped in accordance with an approved Closure Plan in 1992. The Post-Closure Permit requires Thiokol to inspect the LTTA caps quarterly.

Division staff members inspected the caps and looked at recent cap inspection records. Based on these records, the required cap inspections have been conducted. However, it was observed
that someone has been driving on the caps leaving wheel ruts in the rock and gravel surfaces. Although the last inspection of the caps was done only thirteen days prior to our site
visit, there is no mention of ruts left by vehicle tires. This is a significant issue because the small ruts could grow into drainage features, which would advance erosion of the cap.
Items to be inspected on the LTTA inspection checklist include “scouring” and “erosion.” It was agreed during the CEI that these items are basically the same.

The Division requests that Thiokol revise the LTTA inspection checklist so that other problems (e.g. ruts, vegetation or burrows), that could threaten the integrity of the caps, will
be evaluated and if observed, recorded by Thiokol inspectors. The checklist should also provide space to allow the inspectors to provide details on how and when problems were addressed.
In addition to revising the checklist, the Division recommends that Thiokol fill in the tire ruts on the LTTA caps.

Please submit to the Division, by January 7, 2005, a draft of the revised LTTA inspection checklist, a description of how the caps were repaired, and an explanation of how Thiokol will
ensure that the caps will not be driven on in the future. Thank you for your cooperation during the inspection. If you have any questions, please contact Jeff Vandel at 538-9413.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 12/06/04

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

DRD\JV\ts

c: John C. Bailey, M.D., M.S.P.H., Health Officer/Director, Bear River Health Department

File to: ATK Thiokol Inc. - Promontory

December 6, 2004
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 6, 2004

TN200401414.doc
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