DSHW-2011-001336 - 0901a068801f79e0

Launch Systems Group
P.O. Box 707
Brigham City, UT 84302
www.atk.com JAN 2 0 2011
. , UTAH DIVISION OF
20 January 2011 g^LID & HAZARDOUS WASTE
8200-FYl 1-060 ' ,^
;ioii.ooi^<^
Scott T Anderson
Executive Secretary,
c/o UDEQ Division of Solid and Hazardous Waste
PO Box 144880
SALT LAKE CITY UT 84114-4880
Subject: ATK Launch Systems Promontory Facility, Post Closure Permit Modification Request,
Promontory EPA ID #UTD00908I357
Dear Mr. Anderson
ATK is requesting approval to modify the September 20, 2007 Promontory Post Closure Permit.
These permit modifications are as follows:
Add the following monitoring wells to Table 4-1, Groundwater Monitoring System: M-508-
1, M-508-2, M-508-3, M-508-4, M-508-B1. These wells were inadvertently left off of the
table at the time the permit was written.
Add new monitoring wells X-5 and J-9 to Table 4-1. These wells were drilled after the
Permit was issued.
In Table 4-1, Ground Water Monitoring System, create a designation for the piezometers,
BC-1, BC-2, BC-3, BC-4, BC-5, BC-6. This designation would be. Requires Static Water
Level Measurement Only as Warranted. The piezometers would still remain part of the
Groundwater Management System; however, there would not be a requirement for routine
static water level measurements. The basis for this modification is that ATK now has an
approved groundwater model, and static water levels in these remote down gradient
piezimeters would not add valuable data at this time. Also, water levels have not
significantly fluctuated over the 20 + years these have been measured.
Change the frequency of the static water level measurements in Condition IV.D.7 and Table
IV-2 from semi-annual to annual. The reasons for this change are that ATK now has an
approved groundwater model and level fluctuations overall have not been significant over
the 20 + years of measurement.
Change the submittal dates for the semi-amiual Groundwater Monitoring reports in Condition
IV.E.2 to March 15 and September 15. This would allow more time for preparation of the
reports from the end of the monitoring periods in December and June. This is justified by the
relatively stable groundwater contaminant levels seen over the 20+ years of monitoring.
ATK understands from previous discussions with Jeff Vandel that these requested changes will
require a Class 1 modification with prior approval from your office.
If you have questions regarding these requested changes, please contact Paul Hancock at (435) 863-
3344.
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations.
Sincerely,
David P. Gosen, P.E., Dirk
Environmental Services