DSHW-2007-005327 - 0901a068801629fd

David P. Gosen, P.E.
Director, Environmental Services
ATK Launch Systems – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Draft Environmental Covenant for the M-636 Photo Waste Site
ATK Launch Systems - Promontory Facility, EPA I.D. #UTD009081357

Dear Mr. Gosen:

The Division of Solid and Hazardous Waste has completed its review of the draft environmental covenant that was provided by your staff. The Division requested a draft notice to deed
for M-636 in the closure verification letter dated October 10, 2006.

The Division has a few comments and recommended changes, enclosed with this letter, on the draft environmental covenant. Please provide a revised draft environmental covenant by April
20, 2007.

If you have any questions, please contact Jeff Vandel at 801 538-9413.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 4/2/07

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

DRD\JV\tm

c: Paul Hancock, Environmental Remediation Manager, ATK Launch Systems
Lloyd C. Berentzen, MBA Health Officer, Bear River Health Department

General Comments

All references to the “Division of Solid and Hazardous Waste Control” in the draft document should be replaced with the “Division of Solid and Hazardous Waste.”

References to the “Solid and Hazardous Waste Control Board” should be replaced with “Utah Solid and Hazardous Waste Control Board.”

2. Property

The Division requests that a map be included with Exhibit “A” which shows the extent of contamination at the HWMU, and the borders of the restricted property as surveyed.

5. Activity and Use Limitations

The Division requests that language be added to this section that will control the removal of soil from the property, in the event of construction or alteration at the site. The Executive
Secretary of the Utah Solid and Hazardous Waste Control Board shall approve or disapprove of any proposal for the removal of soil from the property. This language should also appear
on the notice addressed in section 10 (Notice upon Conveyance).

9. Compliance Reporting

ATK has requested that the language in this section, regarding the annual documentation verifying that all activity and use limitations remain in place and are being complied with, be
removed from the covenant. The Division considers this request reasonable as long as sections five and ten of the covenant (as they appear in the draft) are complied with.

18. Notice

The reference to Project Manager and the other items following it in the parenthetical should be deleted.

“Division of Environmental Response and Remediation” should be replaced with “Utah Solid and Hazardous Waste Control Board.”

The P.O. Box number in the address should be changed to “144880.”

The zip code in the address should be changed to “84114-4880.”

Dennis R. Downs, “Director” should be replaced with Dennis R. Downs, “Executive Secretary”

“Division of Solid and Hazardous Waste Control” should be replaced with “Utah Solid and Hazardous Waste Control Board.”

1

April 2, 2007

TN200700328
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