DSHW-2016-015019 - 0901a0688068f889

DSHW-2016-015019 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director

December 21, 2016

George Gooch, Manager
Environmental Services
ATK Launch Systems – Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Groundwater Monitoring Data Validation Report
ATK Launch Systems – Promontory Facility
UTD009081357

Dear Mr. Gooch:

The Division of Waste Management and Radiation Control has completed its review of the Data
Validation Reports that were submitted with the Fall 2015 and Spring 2016 Groundwater Monitoring
Reports. This letter is intended to memorialize the discussion that Jeff Vandel had with Al Lee and Paul
Hancock on December 7, 2016 on the following issues:

1. In an effort to evaluate perchlorate analyses conducted at the Promontory Laboratory, ATK sent
eight duplicate samples, collected Fall 2015, to ALS Environmental for analysis in order to
compare results. Overall, the results the two laboratories reported are very similar except for the
well H-4 samples.

The Promontory laboratory reported a result of less than an EQL of 20 ug/L while ALS reported
a result of 81 ug/L. In regard to this discrepancy, ATK indicated that, due to high TDS and
ATK’s experience with analyzing these types of water samples, the less than 20 ug/L result
would be used. Based on the perchlorate results ATK obtained for well H-4 in Spring 2015
(144 ug/L) and Spring 2016 (73 ug/L), it appears that the 81 ug/L result obtained by ALS for the
Fall 2015 sample is more in line with what would be expected and may be the value that should
be used.

(Over)
Although this is only one sample and the results reported by the two laboratories aren’t vastly
different, is ATK’s method for gauging positive interference due to high TDS a potential
problem with perchlorate analyses at the Promontory laboratory?

2. In both the Fall 2015 and Spring 2016 Groundwater Monitoring Reports, duplicate samples are
designated by adding a “1” or “2” to the well number (e.g. duplicate sample number G-31 in the
Fall 2015 Report or H-102 in the Spring 2016 Report). This practice creates problems when
compiling well data in a spreadsheet. Please use the convention of adding a letter to the well
number or indicating that the sample is a duplicate as discussed on December 7, 2016.

3. In the AQS Data Validation Report and ATK’s Case Narrative for the Spring 2016 Groundwater
Monitoring Report, it is indicated that the Continuing Calibration Verification (CCV) standard
recovery was below laboratory limits for 35 VOC analytes in all of the samples that were
validated. This assessment indicates a possible low bias and AQS recommended that the data be
qualified as estimated (“J” flagged).

None of this data was flagged as estimated in the data tables in the report or on the CD. Please
ensure that the data is flagged as appropriate so it can be seen when compiling or using the data
in the future. In addition, a statement is needed regarding the usability of flagged data. For
example, is it appropriate to use data that is flagged as estimated in a Human Health Risk
Assessment?

Finally, has the Promontory Laboratory investigated the cause of the low CCV recoveries and
possible low bias observed in the VOC sample analyses?

Please provide a response to these issues at your earliest convenience. If you have any questions, please
call Jeff Vandel at [phone].

Sincerely,

Scott T. Anderson, Director
Division of Waste Management and Radiation Control

STA/JV/jr

c: Lloyd C. Berentzen, MBA, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Moye Lin, USEPA Region 8
Paul Hancock, ATK Launch Systems
Alan Lee, ATK Launch Systems