DSHW-2007-005333 - 0901a068801629c9 (4)

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

RE: Remediation Plans for Groundwater at Process Supply Well TCC3A, ATK Launch Systems - Promontory Facility, EPA I.D. #UTD009081357

Dear Mr. Gosen:

The Division of Solid and Hazardous Waste has completed its reviews of the plans for the Plant 3, Well TCC3A groundwater treatment system that were submitted to our office on February
7, 2007.

The Division considers the treatment of contaminated water pumped from the aquifer to be a RCRA corrective action interim measure. The requirements for interim measures are outlined
in Module VII, Section D of the Post-Closure Permit currently in effect. The remediation plan that was submitted will be considered to be the Interim Measure Plan that is addressed
by Condition VII.D.6. of the Permit. As you are aware, the permit is currently under revision and is scheduled to be reissued by this September. The requirements for interim measures
in the draft Permit, outlined in Module VI, Section F, are very similar.

Attached to this letter are a number of questions and comments in regard to the treatment system plans. Please submit your replies to these questions and comments no later than April
6, 2007. If you have any questions, please contact Jeff Vandel at 801 538-9413.

Sincerely,

ORIGINAL DOCUMENT SIGNED BY DENNIS R. DOWNS ON 3/19/07

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
Candace C. Cady, P.G., UIC Program Coordinator, Utah DEQ, Division of Water Quality

General Comment:

As stated in our previous letter (dated December 28, 2006), the Division concurs with the findings of the risk assessment that no immediate risk to human health is posed by the current
exposure of contaminated water to workers at Plant 3 - provided that it is not used as a source for drinking water. However, treatment of the water pumped from well TCC3A is required
for several reasons, as discussed below.

Due to the “contained in” policy (Federal Register, 18795, Monday April 29, 1996), the Division considers the water that is pumped from well TCC3A to the storage tank to be hazardous
waste since it contains TCE. Therefore, TCE must be treated to meet the no further action standard of R315-101, or the MCL, in order for the “contained in” designation to no longer
apply and in order to “dispose” of the treated water via the septic tanks and drain fields at Buildings M-201 and M-205.

Based on the treatment system plans, ATK does not appear to be planning on treating the extracted water for perchlorate. Without adequate treatment, wastewater contaminated with perchlorate
will be released to the environment via drain fields. From the drain fields, the perchlorate will degrade the groundwater. The contaminated groundwater may daylight at nearby springs
where ecological receptors and domestic stock could be exposed to unsafe levels of perchlorate. To avoid adversely impacting the State’s groundwater resource and potentially unsafe
exposures to ecological receptors, ATK should select a treatment that is effective for both TCE and perchlorate. Knowingly releasing perchlorate-contaminated water to the environment
is contrary to best management practices for perchlorate wastes.

Please include a section on the groundwater cleanup objectives in the treatment system plans. What are the remediation goals for the contaminants that will be treated?

Construction Plans

Based on studies conducted by the U.S. Army Environmental Center and others, it appears that perchlorate treatment is significantly more effective using commercially available “tailored”
granular activated carbon as opposed to standard granular activated carbon. Has ATK considered using “tailored” activated carbon to remove perchlorate?

Construction Schedule

It is stated in this section that “due to the cost of construction, this project is currently in a capital funding request process.” What is the status of the funding request?

Operational Plans

Are there any plans for inspection of the treatment system; as addressed by draft permit Condition VI.F.3.d.?

As discussed above, the Division recommends that the water pumped from well TCC3A be treated for perchlorate. Therefore, effluent monitoring should include perchlorate analyses. Please
include this in Table 1 of this section of the plan.

The effluent monitoring frequency looks good; however, the plan doesn’t address data quality assurance or data management. The Division recommends that the Post Closure Permit QAPP
and SAP be referenced in the plan and practiced during data collection. How will the monitoring data be managed? What is the expected “turn around” time for sample results? How will
ATK respond to analytical results that exceed remediation goals?

How will the spent carbon that is removed from the treatment vessel be managed?

In regard to reporting requirements, the Division recommends that an Interim Measures Report be submitted within 30 days of the start-up of the treatment system. The report should include
as-built drawings or diagrams, documentation of any deviation from the original design, available effluent data, a summary of treatment effectiveness and other relevant information.
In addition, it is recommended that a section on the treatment system be included, on an annual basis, in the RFI Progress Report. The section should include a summary on the effectiveness
of the treatment system, and other relevant information.

1

March 19, 2007

TN200700295
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