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HomeMy WebLinkAboutDSHW-2007-006043 - 0901a068801630a1 David P. Gosen, P.E. Director, Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, UT 84302-0707 RE: Monitoring Well Completion Reports ATK Launch Systems - Promontory Facility, EPA I.D. #UTD009081357 Dear Mr. Gosen: During the meeting that was held at our office on November 11, 2007, to discuss the priority of projects being worked on at the ATK facilities, a question was raised regarding the status of Monitoring Well Completion Reports for the newer wells installed at the Promontory facility. The intent of this letter is to clarify the status of these reports based on the information that ATK has submitted to the Division. Post-Closure Permit Ccondition IV.D.2.c. states that the Permittee shall submit monitoring well completion reports within 90 days after the installation of the wells are completed. These reports shall, at a minimum, consist of the four following components: a boring log that documents well drilling and associated sampling; a well construction log and well construction diagram (“as built”); well survey information for locations and elevations of the newly completed wells; and a summary that discusses how the groundwater flow model shall be updated based on the data obtained from the installation of the new wells. The detailed information that shall be included for each of the four components is outlined in Attachment 5 of the Permit. As stated in Attachment 5, Monitoring Well Completion Reports should also include a section on hydrogeology. Well completion reports submitted by Thiokol in the past have included cross-sections, fence diagrams, and summary discussions on the hydrogeology of the study area. If pump or slug tests are conducted, the test data should be submitted with the calculations for transmissivity, hydraulic conductivity and groundwater flow rates. ATK has submitted well logs, well construction diagrams and well survey data for the G, H and J series wells, although the logs, diagrams and surveys were done years after the wells were completed. The logs that were submitted are qualified with a note that states that since they were completed years after the wells were installed, “completion details are as accurate as available information allows.” Since the new groundwater model was constructed after these wells were installed, the summary of how the model should be updated (the fourth component) is not needed. The information that was eventually submitted for the G, H and J series wells (not under the cover of a Monitoring Well Completion Report) appears to meet the very minimum requirements. The Division considers these reports to be important sources of information, particularly at the stages of groundwater corrective action that include modeling and corrective measure studies. We strongly encourage ATK to take these reports seriously and give the collection and reporting of this important information the attention it deserves. The latest well that was installed, Well X-5, was completed prior to May 2007, well over 90 days ago. The Division has not received a Monitoring Well Completion Report for this well. Please submit the report for this well within 90 days of receipt of this letter. If you have any questions, please contact Jeff Vandel at 538-6170. Sincerely, ORIGINAL DOCUMENT SIGNED BY SCOTT T. ANDERSON FOR DENNIS R. DOWNS ON 12/26/07 Dennis R. Downs, Director Utah Division of Solid and Hazardous Waste DRD\JV\tjm c: Paul Hancock, ATK Launch Systems File to: ATK Launch Systems – Promontory December 26, 2007 Page 2 TN200701506 December 26, 2007 TN200701506 288 North 1460 West • PO Box 144880 • Salt Lake City, UT 84114-4880 • phone (801) 538-6170 • fax (801) 538-6715 T.D.D. (801) 536-4414 • www.deq.utah.gov State of Utah Department of Environmental Quality Richard W. Sprott Executive Director DIVISION OF SOLID AND HAZARDOUS WASTE Dennis R. Downs Director JON M. HUNTSMAN, JR. Governor GARY HERBERT Lieutenant Governor