DSHW-2018-002785 - 0901a068807d9fac

DSHW-2018-002785 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
April 12, 2018
Kris Blauer, Manager Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, UT 84302-0707
RE: Response to Comments on Groundwater Data Validation Report UTD009081357
Dear Mr. Blauer: The Division of Waste Management and Radiation Control has completed its review of ATK’s responses to Division comments on the data validation that was done for groundwater monitoring data from the Spring of
2016. ATK’s responses regarding perchlorate analyses, the designation of duplicate samples and incorporating flags into the data reported to the Division are adequate. In regard to the low Continuing Calibration Verification (CCV) recoveries, ATK’s response is not understood. Based on the AQS Data Validation Report (dated September 12, 2016), 35 compounds were
identified with CCV recoveries below the lower limit of 80%. Seven of these compounds (1,1,1-TCA, 1,1-DCA, 1,1-DCE, benzene, carbon tetrachloride, chloroform and TCE) were reported as detected but not flagged in the Spring, 2016 Monitoring Report. It is noted by AQS in the Data Validation Report that the results for these compounds should be considered biased low.
ATK’s response states that just three compounds were below the CCV limit and that none of them were detected. It appears that ATK’s response may be based on the Case Narratives only and not the Data Validation Reports generated by AQS.

In addition, according to Section 8.4.4 of SW846 Method 8260B, sample quality control procedures should follow those outlined in SW846 Method 8000. Method 8000 states, “if >10% of the analytes in a multi-analyte method exceed the calibration verification criteria, and instrument maintenance does not correct the problem, then a new initial calibration is necessary.” If 35 out of 83 VOC compounds exceed the
verification criteria, it appears that the >10% standard may have been exceeded as well. (Over)

Please ensure that laboratory quality control procedures for groundwater data submitted in the future are
conducted in accordance with the appropriate method and that data reported to the Division is flagged as noted in the Data Validation Report. 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/km
c: Lloyd Berentzen, MBA, Health Officer, Bear River Health Department Grant Koford, EHS, Environmental Health Director, Bear River Health Department Amy Hensley, USEPA, Region 8
Paul Hancock, ATK Launch Systems