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