DSHW-2006-008048 - 0901a06880161bc5

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

RE: Quality Assurance Project Plan for Emission Characterization of Open Burning Waste Propellant Materials
ATK Thiokol – Promontory Facility
EPA ID 009081357

Dear Mr. Gooch:

This letter is in regard to the Quality Assurance Project Plan (QAPP) that was developed for emissions characterization tests that were conducted from June 7 to June 15, 2006 using the
ODOBi test facility at Dugway Proving Ground. The objective of the tests was to characterize the emissions for class 1.3 composite propellant waste materials that are open-burned at
the Promontory facility. The emissions from these materials need to be characterized so that the risk associated with their open burning can be assessed. The Division of Solid and
Hazardous Waste requires a risk assessment as part of the hazardous waste permit application for open burning.

A draft QAPP was submitted to this office for review on March 27, 2006. The Division provided ATK with comments and questions on the draft document and then these were discussed with
your staff and contractor. ATK submitted a final QAPP to the Division along with responses to our comments and questions on June 6, 2006. Based on a review of the submitted response
to comments, all of the Division’s issues were addressed except for the one detailed below.

The final QAPP and response to comments failed to the address the Division’s concerns regarding the adequacy of the analytical method detection limits for the intended use of the data
(number 4 in the second set of comments). One of the intended uses of the data is the risk assessment. In the risk assessment, non-detected concentrations are not equivalent to zero
unless there is compelling rationale that the non-detected chemical is unlikely to be present. If a chemical is not detected and potentially present, one-half of the detection limit
is commonly substituted for non-detect values. The detection limits have the potential to impact decisions regarding the acceptability of the open burning. In addition, the following
compounds were not included in the table of reporting limits (Table 3-2): perchlorate, NH3, CEM gases, HCN, HCl and Cl2.

The testing at the ODOBi facility is complete. Therefore, there is little value in requiring a revision to the QAPP to address the issue identified above. The Division will evaluate
the adequacy of the data when the permit application is reviewed. If you have any questions, please contact Jeff Vandel at 538-9413.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 6/22/06

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

DRD\JV\tm

c: Lloyd C. Berentzen, M.B.A., Health Officer/Director, Bear River Health Dept.
Nancy Morlock, USEPA Region VIII

File to: ATK Thiokol Inc. - Promontory

June 22, 2006
Page 2

June 22, 2006

TN200600732
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

State of Utah

Department of Environmental Quality

Dianne R. Nielson, Ph.D.
Executive Director

DIVISION OF SOLID AND HAZARDOUS WASTE
Dennis R. Downs
Director

JON M. HUNTSMAN, JR.
Governor

GARY HERBERT
Lieutenant Governor