DSHW-2017-006945 - 0901a06880744020

DSHW-2017-006945 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

August 29, 2017

Kris H. Blauer, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham City, UT 84302-0707

RE: Ecological Risk Assessment Waiver
Thermal Treatment Operations
UTD009081357

Dear Mr. Blauer:

The Division of Waste Management and Radiation Control has completed its review of your request,
dated December 19, 2016, for a waiver from the requirement of conducting an ecological risk
assessment for the ATK Promontory Thermal Treatment Unit (TTU).

The following justifications were presented by ATK in support of the waiver application:

1. The ecological receptors will not be affected by any contamination released as a result of TTU
operations.
2. Volatile Organic Compounds (VOCs) do not accumulate in the environment and the inhalation
exposure pathway is insignificant.
3. Modeled environmental metal concentrations in soil are very low and below background levels
established at the site.
4. Modeled environmental semi-volatile organic compounds (SVOCs) concentrations in soil are so
low that they cannot be measured using existing laboratory methods.
5. Modeled environmental concentrations of contaminants in soil are several orders of magnitude
below all available environmental screening levels.
6. Ecological habitats are limited.

Based on the review of information presented, your request for a waiver from the requirement to
conduct an ecological risk assessment is hereby approved.
(Over)

To demonstrate the validity or to corroborate the conclusions that the contaminants generated at the site
as a result of the TTU operations are significantly below any ecological screening levels and cannot be
measured using existing laboratory methods, an annual soil monitoring program shall be required. The
Division is in receipt of ATK’s proposed soil monitoring program and will be providing feedback in the
near future.

In addition, please note that the waiver request included a reference to R315-101-5(j)(3) of the Utah
Administrative Code. This citation is part of the draft revision to R315-101 and therefore is not
appropriate at this time. The correct citation should be R315-101-5.3(a)(8).

If you have any questions, please call Eric Baiden at (80l) 536-0216.

Sincerely,

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

STA/EB/jr

c: Lloyd Berentzen, MBA, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Stephen Foster, Geosyntec
Paul Hancock, ATK Launch Systems