DSHW-2012-009609 - 0901a068802ff10e

Division of
Solid and Hazardous Waste
Launch Systems Group
P.O. Box 707
Brigham City. UT 84302
AUG 2 2 2012
www.atk.com
August 22, 2012
8200-FY13-025
Scott T. Anderson, Director
Division of Solid and Hazardous Waste
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4880
Re: ATK Promontory RCRA Permit No. UTD009081357
Dear Mr. Anderson:
ATK Launch Systems Inc. (ATK) is providing written notification of a non-conformance
situation at the ATK Promontory facility. This non-conformance relates to data that is
required to be maintained at the facility as required under RCRA Permit No.
UTD009081357.
The RCRA Permit requires that ATK maintain records of field sampling and water level
measurement data. ATK does not have the field records for groundwater sampling for 2009,
2010 and 2011. ATK does not have the field records for groundwater elevation
measurements which were not associated with sampling. We believe that the field records
and associated data maintained on an ATK laptop are in the possession of an ATK
employee who was deployed in mid-January for active duty in Afghanistan; it is our
understanding that he intended to use the data to assist in the preparation of the 2011 Semi-
Annual Report. As such, since the individual's deployment, the data have not been
maintained at the facility as required by conditions IV.E.l, I.G. 16, and I.K.I of the Permit.
As a result of the missing ground water level data, we also were unable to construct the
annual potentiometric surface map by March 15 as required by conditions IV.D.9, IV.E.2
We have attempted to contact the individual with the records and data but so far have been
unsuccessful due to his location in Afghanistan. We will continue the efforts to reach him.
We will notify the Division when we successfully recover this information and will include
the data in future groundwater reports. ATK is implementing new data control procedures
to ensure that the field data are maintained at the facility as required by the Permit.
We appreciate the understanding of the Division regarding this situation.
and IV.E.5.
4831-9212-2384.1
Scott T. Anderson, Director
August 22, 2012
Page Two
Sincerely,
^H^T
Robert Ingersoll
Director
Environmental Services
ATK Launch Systems
4831-9212-2384.1