DSHW-2018-009389 - 0901a068808e1783

GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Scott T. Anderson,
Division of Waste
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
Director
Management and Radiation Control
September 26,2018
Kris Blauer, Manager
Environmental Services
ATK Launch Systems - Promontory
P.O. Box 707
Brigham City, Utah 84302-0707
RE: Post-Closure Permit Renewal
ATK Launch Systems - Promontory Facility
uTD009081357
Dear Mr. Blauer:
The Division of Waste Management and Radiation Control has completed its work on the application
from ATK Launch Systems Inc. to renew its Post-Closure Permit. A draft permit went out for public
comment on August 3,2018. The public comment period ended on September 17,2018 and a public
hearing was held on September 5, 2018. No comments were received.
Enclosed is a CD with an electronic copy of the Permit. The cover page and permit page are also
enclosed with this letter. If you have any questions, please call Jeff Vandel at [phone].
(Over)
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. (801) 5364284
www.deq.utah.gw
Printed on I 00% recycled paper
DSHW-2018-009389
STA/JV/km
Enclosure: Post-Closure Permit CD
c: Grant Koford, EHS, Environmental Health Director, Bear River Health Department
Lloyd c. Berentzen, MBA, Health officer, Bear River Health Department
Jesse Newland, USEPA Region 8
Blair Palmer, ATK Launch Systems
Paul Hancock, ATK Launch Systems
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POST-CLOSURE PERMIT
ATK LAUNCH SYSTBMS INC.
uTD009081357
September 261 2018
STATE OF UTAH
POST-CLOSURE PERMIT
September 26,2018
PERMITTEE:
ATK Launch Systems Inc.
Promontory Facility
Brigham City, Utah
EPA Identification Number UTD00908 I 357
Pursuant to the Utah Solid andHazardous Waste Act, 19-6-101, et. seq., Utah Code Annotated 1953, as
amended, and the regulations promulgated by the Waste Management and Radiation Control Board,
codified in the Utah Administrative Code R3l5 and pursuant to the Solid Waste Disposal Act,42 U.S.C.
3251 et. seq., as amended by the Resource Conservation and Recovery Act of 1976,42 U.S.C. 6901 et.
seq., and the Hazardous and Solid Waste Amendments of 1984 (HSWA), a permit is issued to the ATK
Launch Systems Inc. - Promontory facility (hereinafter "Permittee") for post-closure care activities for
the M-136 Liquid Thermal Treatment Area and the M-508 and M-636 Photographic Waste Discharge
Areas at the Permittee's facility located in Box Elder County, Utah at 41 degrees, 39 minutes, 33
seconds north latitude and I 12 degrees, 26 minutes, 17 seconds west longitude. ATK Launch Systems
Inc. is a wholly owned subsidiary of Northrup Grumman Innovation Systems, Inc. and is the operator of
the Promontory facility.
The Permittee shall comply with all the terms and conditions of this permit. The permit consists of
Modules I through VI and Attachments 1 through 6. The Permittee shall also comply with all applicable
State rules, including R305-7, R3l5-101, R3l5-124, R315-260 through R3l5-266, R3l5-268, R315-270
and R315-273 of the Utah Administrative Code.
Applicable rules are those that are in effect on the date of issuance of this permit and any self-
implementing provisions and related rules that, according to the requirements of HSWA, are
automatically applicable to the Permittee's hazardous waste management activities, notwithstanding the
conditions of this permit.
This permit is based on the premise that the information submitted in the original permit application,
dated April 8, 1990, as modified by subsequent amendments, permit modification requests received
throughout the term of the original permit; the permit renewal application received November 12,2002,
as modified by subsequent amendments and permit modification requests received throughout the term
of the permit; and the permit renewal application received March 24,2017, as modified by subsequent
amendments is accurate. The Permittee's failure in the application or during the permit issuance process
to disclose fully all relevant facts, or the Permittee's misrepresentation of any relevant facts at any time,
may be cause for the termination or modification of this permit, the initiation of enforcement action,
including criminal proceedings, or any combination of these remedies. The Permittee shall inform the
Director of the Division of Waste Management and Radiation Control of any deviation from or changes
to the information on which the application was based which would affect the Permittee's ability to
comply with the terms and conditions of this permit.
The Director will enforce all terms and conditions of this permit. Any challenges to any condition of
this permit shall be pursuant to R305-7 of the Utah Administrative Code and Utah Code Section l9-1-
301.s).
This permit is effective as of September 26,2018, and shall remain in effect until September 26,2028
unless revoked and reissued pursuant to R3l5-270-41, terminated pursuant to R3l5-270-43, or
continued in accordance with R3 15-270-51 and the conditions of this permit.
On"r f
Division of Waste Management and Radiation Control
ATK Launch Systems Inc. – Promontory July 2, 2018
Post Closure Permit UTD009081357
ATK LAUNCH SYSTEMS - PROMONTORY
POST-CLOSURE PERMIT
TABLE OF CONTENTS MODULE I – STANDARD CONDITIONS
I.A. DEFINITIONS I.B. EFFECT OF PERMIT
I.C. ENFORCEABILITY
I.D. NO WAIVER OF AUTHORITY I.E. PERMIT ACTIONS

I.F. SEVERABILITY I.G. DUTIES AND REQUIREMENTS
I.G.1. Duty to comply
I.G.2. Duty to reapply I.G.3. Review of permit I.G.4. Permit expiration I.G.5. Post-Closure Care Period Expiration
I.G.6. Need to halt or reduce activity not a defense
I.G.7. Duty to mitigate I.G.8. Proper operation and maintenance I.G.9. Duty to provide information I.G.10. Inspection and entry
I.G.11. Reporting planned changes I.G.12. Anticipated noncompliance I.G.13. Transfer of permit I.G.14. Monitoring methods I.G.15. Quality assurance/quality control
I.G.16. Request for substitution of analytical method I.G.17. Operating Record I.G.18. Reporting noncompliance with the Permit I.G.19. Monitoring Reports I.G.20. Additional copies
I.G.21. Compliance schedules I.G.22. Other information
ATK Launch Systems Inc. – Promontory July 2, 2018
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I.H. CERTIFICATION OF CONSTRUCTION OR MODIFICATION
I.I. SIGNATORY REQUIREMENT I.J. CONFIDENTIAL INFORMATION

I.K. DOCUMENTS TO BE MAINTAINED AT FACILITY SITE I.L. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
I.M. REQUIRED SUBMISSIONS UNDER THIS PERMIT
I.N. REQUIRED NOTIFICATIONS UNDER THIS PERMIT MODULE II – GENERAL FACILITY STANDARDS II.A. POST-CLOSURE MAINTENANCE AND MONITORING II.B. SECURITY
II.C. PERSONNEL TRAINING
II.D. GENERAL INSPECTION REQUIREMENTS II.E. CONTINGENCY PLAN

II.F. RECORD KEEPING AND REPORTING II.G. FINANCIAL ASSURANCE FOR POST-CLOSURE CARE
II.H. LIABILITY REQUIREMENTS
II.I. INCAPACITY OF PERMITTEE, GUARANTORS OR FINANCIAL INSTITUTIONS MODULE III – USE OF PROPERTY AND POST-CLOSURE CARE FOR THE LTTAs AND PHOTOGRAPHIC WASTE DISCHARGE SITES III.A. USE OF PROPERTY III.B. POST-CLOSURE CARE
III.C. INSPECTIONS III.D. COST ESTIMATES FOR POST-CLOSURE CARE

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III.E. FINANCIAL ASSURANCE FOR POST-CLOSURE CARE
III.F. LIABILITY REQUIREMENTS MODULE IV – GROUNDWATER MONITORING IV.A. POST-CLOSURE GROUNDWATER MONITORING IV.B. REQUIRED PROGRAM
IV.C. GROUNDWATER PROTECTION STANDARD
IV.D. GROUNDWATER MONITORING REQUIREMENTS IV.E. REPORTING AND RECORD KEEPING
MODULE V – POST-CLOSURE GROUNDWATER CORRECTIVE ACTION V.A. POST-CLOSURE CORRECTIVE ACTION PROGRAM
V.B. CORRECTIVE MEASURE(S) STUDY
V.C. CORRECTIVE MEASURE(S) IMPLEMENTATION V.D. CORRECTIVE MEASURE(S) IMPLEMENTATION REPORT

V.E. OPERATION AND ASSESSMENT OF THE GROUNDWATER CORRECTIVE MEASURE(S) V.F. DURATION OF CORRECTIVE ACTION PROGRAM

V.G. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION MODULE VI – CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS SCHEDULE OF COMPLIANCE
VI.A. CORRECTIVE ACTION PROGRAM VI.B. STANDARD CONDITIONS
VI.C. RCRA FACILITY INVESTIGATION
VI.D. RFI WORKPLAN VI.E. RFI REPORT

ATK Launch Systems Inc. – Promontory July 2, 2018
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VI.F. ADDITIONAL INVESTIGATION
VI.G. CORRECTIVE ACTION VI.H. DETERMINATION OF NO FURTHER ACTION

VI.I. SITE MANAGEMENT PLAN VI.J. INTERIM MEASURES
VI.K. NOTIFICATION REQUIREMENTS FOR AND ASSESSMENT OF NEWLY
IDENTIFIED SOLID WASTE MANAGEMENT UNITS VI.L. REPORTING REQUIREMENTS
VI.M. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION
VI.N. PUBLIC PARTICIPATION
ATTACHMENTS

Attachment 1 – Security and Maintenance Plan Environmental Covenants for M-136, M-508 and M-636 Attachment 2 – Inspection Schedules and Procedures Table 2-A, M-136 LTTA Quarterly Post-Closure Inspection Checklist Groundwater Monitoring System Annual Inspection Checklist Attachment 3 – Groundwater Monitoring Quality Assurance Project Plan (QAPP) and Sampling and Analysis Plan (SAP) Figure 1 Chain of Custody
Table 1 Sampling and Analytical Methods Requirements Table 2 Groundwater Monitoring Wells Completed in Unconsolidated Material
Attachment 4 – Table 4-A Groundwater Monitoring System
Plate 1a - Well Location Map Plate 1b - Well Location Map Attachment 5 – Monitoring Well Completion Report Requirements
Attachment 6 – Table 6-A Solid Waste Management Unit (SWMU) Groups Table 6-B SWMU List
ATK Launch Systems Inc. – Promontory July 2, 2018
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TABLES
Table I-1 Required Submissions Under This Permit Table I-2 Required Notifications Under This Permit
Table IV-1 Constituents and Groundwater Protection Standard
Table 2-A M-136 LTTA Quarterly Post-Closure Inspection Checklist Table 2-B Groundwater Monitoring System Annual Inspection Checklist
Table 4-A Groundwater Monitoring System Table 6-A ATK Launch Systems – Promontory SWMU Groups
Table 6-B ATK Launch Systems – SWMU LIST
PLATES Plate 1(a) Groundwater Monitoring Well Location Map (Attachment 4) Plate 1(b) Groundwater Monitoring Well Location Map (Attachment 4)

ATTACHMENT 1

SECURITY AND MAINTENANCE PLAN
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1
POST- CLOSURE SECURITY AND MAINTENANCE PLAN

I.A. Purpose and Scope

The M-136 LTTAs, and Photographic Waste Discharge Sites at M-508 and M-636 are all Hazardous Waste Management Units (HWMUs) that
have been closed with waste in-place. Post-closure security and
maintenance requirements apply to these sites in accordance with R315-
264-14 and R315-264-110. The security and maintenance requirements of
this plan apply to the closed LTTAs and Photographic Waste Discharge
Sites as outlined below. I.B. Security

The work performed at the ATK Launch Systems, Promontory facility
primarily involves Department of Defense and NASA contracts; therefore,
comprehensive security agreement measures have been instituted. These security measures include both a twenty-four hour surveillance system and an artificial barrier around the facility to minimize the possibility of
unknown entry of livestock or personnel.

I.B.1. Surveillance System
Entry onto the facility is controlled at gates that are maintained by a trained security force. The security force also provides patrol, escort, and
other activities within the facility. All plant entrances are manned by a
minimum of one security officer twenty-four hours per day, every day. All
other gates are locked and only used when authorized by attending
Security. All employees entering the facility must show identification badges at the gate and wear them in plain sight throughout the day. All visitors and vendors are required to wear special identification badges.

I.B.2. Artificial Barrier

There are artificial or natural barriers surrounding the entire plant. The
primary barrier consists of a chain link and barbed wire fence. The chain link fence runs along Highway 83 until it runs into the gully formed by Blue Creek just west of building M-46. A natural barrier is provided by
the Blue Creek gully which is approximately 15 feet deep with near
vertical sides. This barrier extends for approximately 8,000 feet to a five-
foot, four-strand barbed wire fence. This fence extends to the north,
changes to chain link, and runs around the north end of the Plant. The chain link fences are seven feet high and topped with barbed wire. This
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fence is continued by a five-foot, four-strand barbed wire fence, which
completes the primary barrier by encircling North Plant, Test, and Space
Operations. Plant III is encircled by a five-foot, four-strand barbed wire
fence and also has controlled access at the main entrance. Each hazardous
waste management area also has an artificial barrier as described in the
facility’s Hazardous Waste Storage Permit.
In addition to the barrier described above, a five-foot, four strand barb
wire fence surrounds the M-136 LTTAs. Access to the area is controlled
by a gate which is locked when no one is present.

I.B.3. Warning Signs Signs which read "DANGER, UNAUTHORIZED PERSONNEL KEEP
OUT" shall be posted at the entrance gates to the LTTA and every 100 feet
along the fence surrounding the LTTA and shall be maintained throughout
the post-closure care period. The signs must be legible from a distance of
at least 25 feet in accordance with R315-264-14(c). Signs which read “HAZARDOUS WASTE MANAGEMENT UNIT –
RESTRICTIONS ON LAND USE APPLY” shall be posted at entrances
and every 100 feet around the designated area of HWMUs M-508 and M-
636.
I.B.4. Activity and Use Limitations The Permittee has closed the M-136 LTTAs with waste in place and the
disposal areas have been capped. The M-508 and M-636 Photographic
Waste Discharge Sites have both been closed with residual contamination
remaining that exceeds standards for residential use. The Permittee has entered into Environmental Covenants with the Director
for the M-136 LTTAs and the M-508 and M-636 Photographic Waste Discharge Sites that establish their locations, the land use restrictions that exist at each and identify the contaminants that remain at the sites.

The Environmental Covenants run with the land and a Notice upon
Conveyance is required that informs any new owner of the land use
restrictions that apply to the sites. The Environmental Covenants were recorded with the Box Elder County Recorder and are included in this Attachment.

Based on an assessment of the human health risk associated with the
contamination remaining at the M-508 and M-636 sites, no soil shall be
removed from the surveyed confines of these areas. Use of the property at
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the M-136 LTTA which will disturb the integrity of the caps, containment
system, or groundwater monitoring system is prohibited.

I.C. Maintenance
This section describes the maintenance requirements for the M-136
LTTAs and Photographic Waste Discharge Sites at M-508 and M-636
during the post-closure care period. These requirements are in accordance
with the State of Utah Hazardous Waste Management Rules R315-264-14,
R315-264-110 and R315-264-228.
I.C.1. M-136 LTTAs Post-Closure Maintenance Requirements
In accordance with R315-264-228, post-closure maintenance of the M-136
LTTAs consists of the three primary requirements outlined below:

I.C.1.a. The Permittee shall maintain the integrity and effectiveness of the final cover, or caps, including making repairs to the cap as necessary to correct the effects of settling, subsidence, erosion, or other events.

I.C.1.b. The Permittee shall maintain and monitor the groundwater monitoring
system (as directed by Module IV of this Permit).
I.C.1.c. The Permittee shall prevent run-on and run-off from eroding or otherwise damaging the final cover, or caps. Run-on and run-off at the M-136
Burning Grounds and LTTA caps are controlled by diversion, collection
ditches and trenches. Diversion ditches direct run-on around the M-136
area. Run-off is collected in a ditch on the west end of the area which
drains towards a level spreader, storm water dispersion area. The diversion and collection ditches shall be kept clean of debris and vegetation that may prevent adequate drainage. If debris or vegetation is
found in these structures during inspections that may result in inadequate
drainage, action shall be initiated within seventy-two (72) hours to clear
the drainage structures. The LTTA caps within the M-136 area are
included in the ATK Launch Systems zone of engineering control.
I.C.2. M-508 and M-636 Photographic Waste Discharge Sites Post-Closure Maintenance Requirements

Post-closure maintenance of the M-508 and M-636 sites shall consist of
the following primary requirements:

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I.C.2.a. The Permittee shall maintain the warning signs and other security
equipment.

I.C.2.b. The Permittee shall maintain and monitor the groundwater monitoring
system (as directed by Module IV of this Permit).
I.D. Inspection Requirements for the M-136 LTTAs

The Permittee shall inspect, throughout the post-closure care period, the
twelve M-136 LTTA caps, drainage ditches, security equipment and
groundwater monitoring system as directed by Modules II and III and
Attachment 2 of this Permit. All records of inspections and remedial actions shall be retained in the Operating Record, as indicated by Permit condition I.G.16. Repairs or corrective action for any deterioration or
malfunction discovered by an inspection shall be initiated within seventy-
two (72) hours except for damaged security equipment. As stated in
Permit Condition II.B.3., repairs to damaged security equipment shall
begin within twenty-four (24) hours. Repairs to security equipment shall be completed as soon as practicable, but not later than seventy-two (72) hours after the problem is discovered.

ATTACHMENT 2

INSPECTION SCHEDULES AND PROCEDURES
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INSPECTION SCHEDULES AND PROCEDURES

II.A. Purpose and Scope
Inspections of the M-136 LTTAs and Groundwater Monitoring System are
conducted to promote the detection of malfunctions and deterioration of the
LTTA caps, drainage systems, security equipment and monitoring wells. The
inspection schedules have been designed to detect problems promptly in order to
ensure that the caps, drainage systems and monitoring wells remain in good
condition. The inspection schedules are also used to document problems observed and what corrective action or maintenance was conducted to remedy the problem. Inspections are conducted by personnel trained to identify potential
problem areas and to use the inspection schedule/checklist. The Groundwater
Monitoring System is inspected annually throughout the post-closure period. – the
inspection schedule/checklist is shown below in Table II.B.
II.B. Remedial Action or Maintenance
Repairs or corrective action for any deterioration or malfunction discovered by an
inspection shall be initiated within seventy-two (72) hours except for damaged
security equipment. As stated in Permit Condition II.B.3., repairs to damaged
security equipment shall begin within twenty-four (24) hours. Repairs to security equipment shall be completed as soon as practicable, but not later than seventy-two (72) hours after the problem is discovered. As stated in R315-264-15(c),
where a hazard is imminent or has already occurred, remedial action shall be taken
immediately.

II.C. Inspection Records
All records of inspections and remedial actions shall be retained in the Operating Record, as indicated by condition I.G.16., throughout the post-closure care period.
At a minimum, inspection records shall include the date and time of the
inspection, the name of the inspector, a notation of the observations made, and the
date and nature of any repairs or maintenance taken.
II.D. Inspection of the M-136 LTTAs
The twelve M-136 LTTAs shall be inspected quarterly throughout the post-closure
care period. Inspections are also required within twenty-four (24) hours after a
storm event. A storm event is defined as precipitation in excess of 1.0 inch in a
one-hour period. It shall be documented in the inspection log that the inspection was conducted in response to a storm event. The items or areas that shall be inspected and the potential problems to watch for are included on the inspection
schedule/checklist. A blank inspection schedule/checklist for the M-136 LTTAs
is shown below in Table 2-A. Completed inspection schedule/checklists will be
maintained in the operating record.

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TABLE 2-A M-136 LTTA QUARTERLY POST CLOSURE INSPECTION CHECKLIST
INSPECTED BY
DATE REVIEWED BY DATE
ITEM LTTA AREAS 12 20 21 22 23 24 25 33 32 30 31 11 CAP SURFACE (CHECK IF INSPECTED)
* TIRE RUTS, BURROWS, EROSION, ETC.
* SIGNIFICANT VEGETATION * SETTLING OF CAP ANY CHECKS IN ROWS WITH AN * REQUIRES AN EXPLANATION. ALSO DESCRIBE CORRECTIVE ACTIONS TAKEN.
EXPLANATION:
CHECK WHEN INSPECTED COMMENTS (NOTE PROBLEMS/CORRECTIVE ACTIONS)
DRAINAGE DITCH (WALK ENTIRE SYSTEM)
INTERCEPTOR TRENCHES (SILTING)
CULVERTS CLEAR
DRAINAGE AREAS ( WASHED OUT)
FENCES CONDITION
GATES & LOCKS
SIGNS ("DANGER UNAUTHORIZED PERSONNEL KEEP OUT")
ROADWAYS IN SAFE CONDITION
M-136 PHONE IN WORKING ORDER
CHECK HERE IF INSPECTION IS BECAUSE OF A STORM EVENT
FORWARD COMPLETED FORM TO ENVIRONMENTAL SERVICES AT MAIL STOP 301

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II.E. Inspection of the Groundwater Monitoring System
The Permittee shall inspect, on an annual basis, all groundwater monitoring wells
as identified in Attachment 4. The items that shall be inspected and the potential problems to watch for are identified on the Groundwater Monitoring System Annual Inspection Checklist that is used in the field. The inspection checklist is
shown below.

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Groundwater Monitoring System Annual Inspection Checklist
Inspected by: Reviewed by / Date:
Well inspection: A. Above ground casing; B. Cement apron & surface seal; C. Cap in place and locked;
D. Accessible, visible and identified; E. Verify operation of any dedicated pump
Well Date Condition? Note any corrective action needed Well Date Condition? Note any corrective action needed

For any problems note corrective action taken here
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Quality Assurance Project Plan
For
Orbital ATK
~Utah Facilities~

Approvals

Environmental Group

Kris Blauer Date
Manager

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A2 - Table of Contents
Table of Contents
A2 - Table of Contents .............................................................................................................................. ii
A3 - Distribution List................................................................................................................................. iii
A4 – Project/Task Management ............................................................................................................... 1
A5 – Problem Definition/Background ....................................................................................................... 4
A6 – Project/Task Description ................................................................................................................... 4
A7 – Quality Objectives and Criteria ......................................................................................................... 4
A8 – Special Training/Certification ........................................................................................................... 9
A9 – Documents and Records ................................................................................................................... 9
B – Data Generation and Acquisition .......................................................................................................... 10
B1 – Sampling Process Design ................................................................................................................. 10
B2 – Sampling Methods .......................................................................................................................... 12
B3 – Sample Handling and Custody ........................................................................................................ 12
B4 – Analytical Methods ......................................................................................................................... 13
B5 – Quality Control ................................................................................................................................ 14
B6 – Instrument/Equipment Testing, Inspection and Maintenance ...................................................... 16
B7 – Instrument/Equipment Calibration and Frequency ........................................................................ 17
B8 – Inspection/Acceptance of Supplies and Consumables ................................................................... 17
B9 – Non-Direct Measurements ............................................................................................................. 18
B10 – Data Management ........................................................................................................................ 18
C – Assessment and Oversight .................................................................................................................... 19
C1 – Assessments and Response Actions ............................................................................................... 19
C2 – Reports to Management ................................................................................................................. 20
D – Data Validation and Usability ............................................................................................................... 21
D1 – Data Review, Verification and Validation ....................................................................................... 21
D2 – Verification and Validation Methods .............................................................................................. 23
D3 – Reconciliation with User Requirements ......................................................................................... 25

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Table of Figures
Figure 1 Project Organization ................................................................................................................. 1

Table of Tables
Table 1 - Corrective Action Permits at Bacchus and Promontory ................................................................. 4
Table 2 - Aqueous and Solid Relative Percent Difference Quality Control Limits for Laboratory Control
Samples, Matrix Spikes, and Laboratory Duplicates..................................................................... 6
Table 3 - Laboratory Control Sample and Matrix Spikes Recovery Quality Control Limits for Aqueous and
Solid Samples ................................................................................................................................ 7
Table 4 - Checklist for Developing Sampling and Analysis Plans ................................................................ 11

A3 - Distribution List

Orbital ATK
Environmental Group
Analytical Laboratory
State of Utah Department of Environmental Quality
Division of Water Quality
Division of Solid and Hazardous Waste
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A4 – Project/Task Management
Project management responsibilities are detailed in this section, and are illustrated in
Figure 1. Multiple functions may be performed by one individual.
Figure 1 Project Organization

PROJECT MANAGEMENT
The role of Project Management / Project Manager (PM) is to direct the program with
responsibilities which include:

• Ensuring timely resolution of project-related technical, quality, or waste management
issues.
• Monitoring and evaluating laboratory performance.
• Coordinating and overseeing work performed by field and office technical staff (including
data validation, statistical evaluations, and report preparation).
• Coordinating and overseeing maintenance of all project records.
• Approving the implementation of project corrective action.

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Field Operations
Laboratory Testing
Data Validation
Reports to State
Agencies
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Field Operations
Field Operations activities include:
• Function as communications link between field staff members and laboratory personnel.
• Oversee the mobilization and demobilization of all field equipment and subcontractors.
• Coordinate and manage the Field Technical Staff.
• Ensure proper chain of custody protocol.
• Adhere to the work schedules.
• Be responsible for the maintenance of the site field logbook, and field recordkeeping.
• Initiate field task modification requests when necessary.
• Identify and resolve problems in the field; resolve difficulties; implement and document
corrective action procedures, and provide communication between the field team and
upper management.
• Monitoring QA policies and procedures.
• Conducting systems and performance audits to monitor compliance with environmental
regulations, contractual requirements, QAPP requirements, and corporate policies and
procedures.
• Auditing project records.
• Monitoring subcontractor quality controls and records.
• Document deviations from approved workplans
• Assisting in the development of corrective action plans; ensuring correction of
nonconformance reported in internal or external audits.
• Overseeing the implementation of the QAPP.
• Overseeing and reviewing the development and revision of the QAPP.

Laboratory Testing
The laboratory is responsible for maintaining accreditation with the State of Utah’s Environmental
Laboratory Certification Program as outlined in Utah Administrative Rule R444. The accreditation
requirements include establishing a Quality Management System compliant with ISO/IEC 17025
General requirements for the competence of testing and calibration laboratories.

The laboratory will analyze all samples in accordance with the analytical methods and additional
requirements specified in this QAPP. It also will be the analytical laboratory's responsibility to
properly dispose of unused sample aliquots. Responsibilities of key laboratory personnel are
outlined in the following paragraphs.

Laboratory Director
Responsibilities of the Laboratory Director include the following:

• Support the QA program within the laboratory.
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• Provide management overview of both production and quality-related laboratory activities.
• Maintain adequate staffing and instrumentation to meet project analytical and quality
objectives.
• Approve all laboratory Standard Operating Procedures (SOPs) and QA documents.

Laboratory Quality Assurance Officer
The Laboratory Quality Assurance Officer (QAO) has the overall responsibility for
maintaining the Quality Management System of the laboratory. In addition, the Laboratory QAO
will:

• Oversee laboratory QA.
• Oversee QA/QC documentation.
• Conduct detailed data reviews.
• Determine whether to implement laboratory corrective actions, if required.
• Define appropriate laboratory QA procedures.
• Approve laboratory SOPs.
• Approve Final Reports

Laboratory Sample Custodian
Responsibilities of the Laboratory Sample Custodian include the following:

• Receive and inspect the incoming sample containers.
• Record the condition of the incoming sample containers.
• Verify and sign COC.
• Assign a unique identification number and customer number, and enter each into the
Laboratory Information Management System.
• Control and monitor access/storage of samples

Laboratory Technical Staff
The Laboratory Technical Staff will be responsible for sample analysis and identification of
corrective actions. The staff will report directly to the Laboratory Director.

Data Validation
In addition to the data validation steps established within the laboratory as part of normal QA
operations, third party validation of data may be required. The PM will coordinate getting the
requested data from the laboratory to the data validators and will receive the validation summary
report from the data validator. If there are questions that come up during the data validation process,
the PM will act to resolve these questions. Third party validators will use this QAPP as a guide.
Reporting to State Agencies
The PM will collect data from the laboratory and any supporting documentation from field
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operations and data validation activities and submit a report to the appropriate State Agency at
the frequency required by permit or other agreement.
A5 – Problem Definition/Background
The Orbital ATK facilities at the Bacchus and Promontory locations have known legacy environmental
concerns which are regulated under corrective action permits. The permits require site characterization,
remediation and monitoring activities the goal of which is to protect human health and the
environment. To achieve this goal data must be of known and documented accuracy and precision so
that sound environmental decisions can be made.
A6 – Project/Task Description
This Quality Assurance Project Plan (QAPP) outlines the organization, objectives, and planned
activities for the Quality Assurance/Quality Control (QA/QC) procedures associated with RCRA
corrective action conducted at the Orbital ATK Bacchus and Promontory Facilities. These corrective
actions include both soil investigations and groundwater monitoring. Corrective action is regulated
at each facility by permits. These permits are listed in Table 1

Table 1 - Corrective Action Permits at Bacchus and Promontory
Facility Soil Corrective Action Groundwater Corrective Action
Bacchus HAZARDOUS WASTE STORAGE PERMIT
ALLIANT TECHSYSTEMS, INC.
ATK LAUNCH SYSTEMS INC.
BACCHUS FACILITY - PLANT 1
EPA ID# UTD001705029
MODULE IV – SWMU CORRECTIVE ACTION
PROGRAM
September 30, 2008

HAZARDOUS WASTE STORAGE PERMIT
ALLIANT TECHSYSTEMS, INC.
ATK LAUNCH SYSTEMS INC.
BACCHUS FACILITY - PLANT 1
EPA ID# UTD001705029
MODULE V – GWMU CORRECTIVE ACTION
PROGRAM
September 30, 2008

Promontory Hazardous Waste Post-Closure Permit
ATK Launch Systems INC. Promontory
EPA ID # UTD009081357
Module VI – Corrective Action For Solid
Waste Management Units
Reissued September 20, 2007

Hazardous Waste Post-Closure Permit
ATK Launch Systems INC. Promontory
EPA ID # UTD009081357
Module IV-Groundwater Monitoring
Reissued September 20, 2007

Specific protocols for groundwater sample collection, sample handling and storage, chain-
of-custody, laboratory and field analyses, data validation, and reporting are found or referenced in
the permits listed above. Protocols for other media are addressed in site specific SAPs.
A7 – Quality Objectives and Criteria
Data quality objectives (DQOs) are requirements needed to support decisions relative to various stages
of the project. The data needs associated with this project have been developed based upon evaluation
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of existing site data, requirements in the permits listed above, EPA risk screen and groundwater screen
values and subsequent risk assessment needs. Specific data needs include collection of data to define
the nature and extent of contamination, development of mean contaminant concentrations across the
site and their potential for imparting public health risks and environmental impacts.
In the case of soil investigation activities, the specific concerns of each Solid Waste Management Unit
(SWMU) is unique. Thus, it is important to establish Quality Objectives and Criteria that take the specific
concerns into account. In the process of establishing a Sample Analysis Plan (SAP) a unique set of DQOs
will be developed.
The DQO process is a systematic planning tool based on a logical method for establishing criteria for
data quality. Establishing formal DQOs during the development of SAPs allows clear and unambiguous
definitions of project objectives and decision criteria so that data of sufficient type, quality, and quantity
are generated to meet project objectives. Details such as estimated quantitation limits (EQLs) used by
the Laboratory will be provided in SAPs for each SWMU or group of SWMUs. In developing SAPs, the
latest version of Guidelines for the Data Quality Objectives Process, US EPA, EPA QA/G-4, August 2000,
or other appropriate guidelines will be followed.
The quality of the laboratory data is assessed in terms of precision, accuracy, representativeness,
comparability, and completeness. Definitions of these parameters and the applicable quality control
procedures are given below.
Precision - Precision is a measure of the degree to which two or more measurements are in agreement
and describe the reproducibility of measurements of the same parameter for samples analyzed under
similar conditions. A fundamental tenet of using precision measurements for QC is that precision will be
bounded by known limits. Results outside these predetermined limits trigger corrective actions.
Because of the inherent and unknown heterogeneity of soil samples, the precision of soil field duplicate
samples will be used to gain a perspective on the natural heterogeneity of the soil.
Field precision is assessed by collecting and measuring field duplicates at a rate of 1 duplicate per 20
environmental samples submitted to the laboratory. Acceptance limits for field duplicate samples are:
• 30% relative percent difference for aqueous matrices, and;
• 50% relative percent difference for solid matrices.
This precision estimate encompasses the combined uncertainty associated with sample collection,
homogenization, splitting, handling, laboratory and field storage, digestion or extraction, and analysis.
In contrast, precision estimates obtained from analyzing duplicate laboratory samples incorporate only
homogenization, subsampling, digestion or extraction, laboratory storage, and analysis uncertainties.
Consequently, the field precision estimates (i.e., relative percent difference [RPD] values) should equal
or exceed the laboratory precision estimates, on average, for each analyte. If field duplicate precision is
significantly different from laboratory duplicate precision, the underlying cause will be investigated to
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determine whether the observed difference could be artifacts of sampling and analysis. Considerations
given to this effort include:
• The scale of subsampling for laboratory precision estimates relative to the scale of field
duplicate sample size.
• Analytical measurement precision.
• Precision for repeat analysis of the same solid laboratory control sample (LCS).
• Estimated environmental sample grain size relative to LCS grain size.
• Potential natural soil heterogeneity.

Laboratory precision QC samples (i.e., laboratory duplicates for inorganic chemicals and MSDs for
organic chemicals) will be analyzed with a minimum frequency of 5 percent (i.e., 1 QC sample per 20
environmental samples). Laboratory precision is measured by comparing RPD values with precision
control limits. Precision limits for matrix spike/matrix spike duplicate and laboratory duplicate samples
are displayed in Table 2.
When Precision data falls outside of the listed limits, the laboratory will flag the outlier and provide a
comment relating the cause of the outlier and any effect it may have on the usability of the data. In
cases where the data is not usable, the laboratory will notify the project manager in order to resolve the
issue. In such cases, re-sampling and/or reanalysis may be required in order to obtain usable data for
reporting.
Table 2 - Aqueous and Solid Relative Percent Difference Quality Control Limits for Laboratory
Control Samples, Matrix Spikes, and Laboratory Duplicates

Analytical Method Aqueous Solid
RPD RPD
Explosives Method 8330A 30 50
Trace Metals Method 6010C or 6020A 20 50
Mercury Method 7470/7471 20 50
Perchlorate Method 314.0 20 50
Volatiles Method 8260B 20 50
Semivolatiles Method 8270D 30 50
Conductivity Method 9050A 20 50

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Accuracy - Accuracy is a measure of the closeness of the measured value to the true value. The accuracy
of chemical test results is assessed by "spiking" samples with known standards (surrogate or matrix
spike) and establishing the average recovery. Accuracy measurements will be carried out in accordance
with Contract Laboratory Program (CLP) Statement of Work (SOW) requirements for organic and
inorganic analyses (USEPA CLP OLM04.3 and CLP ILM05.4, respectively) and at a minimum frequency of
1 per analytical batch of up to 20 samples per matrix analyzed (USEPA, 1991).
Accuracy requirements for field measurements are typically ensured through control over the sample
collection and handling and through routine instrument calibration. Accuracy is also typically monitored
through the use of blanks to detect cross-contamination and by monitoring adherence to procedures
that prevent sample contamination or degradation. Accuracy also shall be assured qualitatively through
adherence to all sample handling, preservation, and holding time requirements.
Accuracy in the laboratory is measured through the comparison of a spiked sample or LCS result to a
known or calculated value and is expressed as a percent recovery (%R). It is also assessed by monitoring
the analytical recovery of select surrogate compounds added to samples that are analyzed by organic
chromatographic methods. MS and surrogate compound analyses measure the combined accuracy
effects of the sample matrix, sample preparation, and sample measurement. LCSs are used to assess
the accuracy of laboratory operations with minimal sample matrix effects. Post Digestion spikes (PDSs)
are used to assess the accuracy of the analytical measurement on the sample extract or digestate. The
parameters to be included in spiking mixes and accuracy limits are presented by analytical fraction and
matrix in Table 3. LCS and MS analyses are performed at a frequency no less than 1 per 20 associated
samples of like matrix. Laboratory accuracy is assessed via comparison of calculated %R values to
accuracy control limits
When Accuracy data falls outside of the listed limits, the laboratory will flag the outlier and provide a
comment relating the cause of the outlier and any effect it may have on the usability of the data. In
cases where the data is not usable, the laboratory will notify the project manager in order to resolve the
issue. In such cases, re-sampling and/or reanalysis may be required in order to obtain usable data for
reporting.
Table 3 - Laboratory Control Sample and Matrix Spikes Recovery Quality Control Limits for Aqueous and Solid Samples
Analytical Method
Aqueous Solid
%
Recovery
%
Recovery
Explosives Method 8330A 80-120 80-120
Trace Metals Method 6010C or 6020A 75-125 75-125
Mercury Method 7470/7471 85-115 85-115
Perchlorate Method 314.0 85-115 85-115
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Volatiles Method 8260B 80-120 80-120
Semivolatiles Method 8270D 70-130 70-130
Conductivity Method 9050A 90-110 90-110

Representativeness - Representativeness is an expression of the degree to which the data accurately
and precisely represent a characteristic of a population or environmental condition existing at the site.
Adherence to the project planning documents and use of standardized sampling, handling, preparation,
analysis, and reporting procedures ensures that the final data accurately represent the desired
populations.
To ensure representativeness of field data depends on the proper design of the sampling program and
will be satisfied by ensuring that the project planning documents are followed and that proper sampling
techniques are used.
In cases where alternative sampling techniques are employed, such as Multi-Incremental Sampling
(MIS), to improve representativeness, it may be appropriate to establish data quality objectives specific
to that technique. In such cases, the unique quality control requirements will be included in the
sampling and analysis plan.
Representativeness in the laboratory is ensured or evaluated by using the proper analytical procedures,
meeting sample holding times, and analyzing and evaluating field duplicate samples relative to
laboratory duplicates.
Comparability - Comparability is defined as the confidence with which one data set can be compared
with another (e.g., between sampling points and between sampling events). Comparability is achieved
by using standardized sampling and analysis methods and data reporting formats (including use of
consistent units of measure), and by ensuring that reporting and detection limits are sufficiently low to
satisfy project detection and quantitation criteria for the duration of the project.
Comparability depends on the proper design of the sampling program and will be satisfied by ensuring
that the project planning documents are followed and that proper sampling techniques are used.
Planned analytical data will be comparable when similar sampling and analytical methods are used and
documented. Results will be reported in units that ensure comparability with previous data.
Common sources of data used to assess comparability may include: historical data and data obtained
from split samples sent to a second party laboratory. Caution must be used when comparing data
where dissimilar sampling and/or analysis techniques are employed. For example, when alternative
sampling techniques are used such as Multi-Incremental Sampling (MIS) the data is not directly
comparable to data obtained from discrete sampling. Similarly, data from Gas Chromatography using
Flame Ionization Detectors is not directly comparable to Gas Chromatography using Mass Spectral
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Detectors. While it may be useful to show data from two differing sampling and/or analysis techniques
as a general comparison, any comparison needs to clearly indicate that the data sets were obtained
using differing techniques and recommend that the end user should use caution when making
comparisons.
Completeness - Completeness is defined as the percentage of measurements made which are judged to
be valid measurements. Results will be considered valid if all the precision, accuracy, and
representativeness objectives are met. The target completeness goal for this work is 90% (combined
field and laboratory results) for a given analysis.
A8 – Special Training/Certification

All field personnel will have appropriate training to conduct the field activities to which they are
assigned.

The PM and all field staff, including subcontractors that will be performing work at the facility, shall have
completed training that meets the requirements in OSHA 29 CFR 1910.120. Documentation and skills
certification will be completed as described in OSHA 29 CFR 1910.120. No other certification or special
training requirements are requisite for the completion of this project.

While no other formal training is required for the completion of this project, field safety and
responsibilities will be reviewed prior to field sampling. The purpose of the review is to assign and
review project-specific responsibilities related to field-sampling activities and to discuss any special
conditions or problems that are anticipated such as weather, site access, and personal protective
equipment (PPE) requirements. In addition, discussions and reviews of specific activities such as sample
preservation, sample container requirements, and logbook completion may also be included. These
discussions are brief summaries of the requirements contained in the SAPs.

Personnel will participate in the review based on their anticipated activity and responsibilities; for
example, a driller would not necessarily be expected to participate in the portion of the review related
to filling out a chain of custody form.

The Laboratory will maintain accreditation certificates for the testing involved through the State of
Utah’s Environmental Laboratory Certification Program.
A9 – Documents and Records

The PM is responsible for initiating any revisions to planning documents and is responsible for making
the needed revisions. The QAPP shall be approved by the Director of the Division of Waste
Management and Radiation Control by an official letter from the Division. All revisions or modifications
related to this QAPP thereafter will be accomplished by specifying a revision or modification to the
QAPP in a SAP.
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B – Data Generation and Acquisition
B1 – Sampling Process Design
For groundwater monitoring activities, the sampling sites and frequencies are established in the
groundwater sections of the Bacchus and Promontory permits. For soil investigations, SAPs will be
developed based on the unique data needs associated with the SWMUs and soil and soil gas sampling
procedures will be addressed in the SAPs.
The primary purpose of the SAPs is to define the data quality objectives for each individual SWMU to be
investigated. The SAPs will be developed based upon review of existing analytical data and process
knowledge applicable to each SWMU or group of SWMUs. Table 4 is a checklist for consideration in
developing specific SAPs. In addition, each SAP will contain a discussion of the components of the
sampling strategy, listed below:
1. A methodology for selecting a sampling location and analytical parameters based on the data-
quality objectives (DQOs);
2. A basis for selecting duplicate field samples;
3. Basis for selecting random sampling;
4. Locations within a SWMU where judgmental (biased) sampling is used based on process knowledge;
and
The rationale for selecting the horizontal and vertical sample densities for each SWMU or group of
SWMUs

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Table 4 - Checklist for Developing Sampling and Analysis Plans
SAP Component Specifications
Sampling Sampling Plan
 Development of Data Quality Objectives
 Sample Design/Strategy
 List of Analytes
 List of Sampling Locations
 Analytical Methods
 Analytical Procedures
 Analytical Equipment
 Standard Operating Procedures (SOPs) For Field-Investigation
Activities (such as drilling, sample collection, decon, shipping
etc.)
Field Equipment
 Selection of Sampling and Field Analysis Equipment
 Operation & Maintenance Procedures
 Calibration & Acceptance Criteria
 Calibration Frequencies,
 Decon Procedures
 Investigation and Remediation Derived Waste Generation,
Characterization, Management and Disposal
 Field Data Sheets
 Field Activity Daily Log
 Field Instrumentation Log for Calibration and Maintenance
 Procedure Variance Log
 Photographs
 Sample-Handling and Shipping Procedures
 Containers & Volumes
 Holding Times & Preservation Requirements
 Sample Packaging & Shipping
 Sample Labels & Sample Identification Number
 Analytical Request and Chain of Custody Forms
 Transfer of Custody from Field to Laboratory Receipt and
Acceptance of Samples
Quality Control

Field (as specified in sampling SOPs and SAPs)
 Field Duplicates
 Trip Blanks
 Equipment Blanks
 Field Blanks (soil, water)
Laboratory
 See the Laboratory Quality Assurance Plan (on file with the
laboratory)
 Assess need to add additional Matrix Spikes based on matrix
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SAP Component Specifications
types

Data Quality Objectives  Precision Level (as defined in the QAPP or customized limits
based on unique SWMU or lab conditions)
 Accuracy (as defined in the QAPP or customized limits based
on unique SWMU conditions)
 Representativeness – representativeness will be specified in
each SAP.
 Completeness
 Comparability
 Estimated Quantitation Limits
 Clean-up Levels including based on DQOs (e.g., EPA screen
values, MCLs)

B2 – Sampling Methods
Standard operating procedures (SOPs) are procedures developed by the PM and field staff for field
sampling events. Most field SOPs have been developed for previous sampling and analyses events. The
SOPs will be modified, as necessary, to meet data needs and usage requirements that are specified
during the DQO development process. The SOPs will describe the process for preparation and
decontamination of sampling equipment, including disposal of decontamination by-products; the
selection and preparation of sample containers, sample volumes, and preservation methods; and
maximum holding times to sample extraction and/or analysis. Procedures for groundwater are in the
Bacchus and Promontory permits and Procedures for other media will be addressed are in the SAPs.
B3 – Sample Handling and Custody
Written documentation of sample custody from the time of sample collection through the generation of
data is recognized as a vital aspect of an environmental study. The Chain-of-Custody (COC) of the
physical sample and its corresponding documentation will be maintained throughout the handling of the
sample. All samples will be identified, labeled, and logged onto a COC or Request for Analysis form, as a
part of the procedure designed to assure the integrity of the resulting data. The record of the physical
sample, including the location and time of sampling, will be joined with the analytical results through
accurate accounting of the sample custody. Sample custody applies to both field and laboratory
operations. All laboratories completing chemical analyses will be required to maintain samples in a
secure location with limited access from the time of sample receipt through sample disposal.
Samples collected will be either shipped to the laboratory via a commercial carrier or will be hand-
delivered to the analytical laboratory when possible. All packaging materials and samples will be
reviewed for compliance with changes in air shipment regulations when shipping by commercial carrier.
If the samples are shipped via a commercial carrier, the following procedure will be used for packaging:
1. Inert cushioning material will be utilized when needed;
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2. Sample containers will be sealed in re-sealable plastic bags and placed upright in the cooler;
3. Blue ice or wet ice and additional packaging materials will be placed around the containers;
4. Pertinent paperwork such as the COC/Request for Analysis form will accompany shipping
papers;
5. When using a commercial provider a shipping label will be affixed to the outside of the cooler.
Upon arrival at the laboratory the Chain-of-Custody documents will be signed to relinquish/receive the
samples. The sample packaging and sample integrity will be inspected by the laboratory personnel and
the condition including temperature of samples will be documented. Any problem that may affect the
outcome of the testing will be communicated to the customer at that time in order to determine if the
samples will be tested or if a re-sample is needed. The communication and final decision with regard to
testing will be documented.
B4 – Analytical Methods
Chemical analyses of samples will be completed by using specific laboratory methods in accordance with
turn-around time for the completion of analyses and laboratory data reporting specified in SAPs. These
methods may include analysis of explosives, volatile organic compounds (VOCs), semivolatile
compounds, metals, and perchlorate. Samples will be collected and preserved as described in specific
SAPs. Sample holding times are specific to each group of analytes and analytical methods. Holding
times for specific samples shall be based on the date and the time of sample collection.
If holding times are exceeded, the laboratory will contact the project manager for direction on whether
to analyze the samples out of holding time, (in which case a comment will appear on the final data
report regarding the missed holding time), or whether resampling will be done to obtain data analyzed
within the recommended holding time.
All laboratories involved will be required to read and comply with the QAPP and SAPs before analyzing
samples.
The laboratories chosen to complete the analyses shall not subcontract any portion of the work without
prior written approval from the PM. The laboratory shall use analytical equipment and procedures to
produce data that will meet the DQOs and requirements as specified in SAPs.
If non-standard analytical methods are proposed for use, the method must be approved by the Division
in writing. Detailed descriptions of the analytical method shall be reviewed to ensure that data
generated by the method will meet the minimum data quality objectives and requirements as specified
in SAPs for a SWMU or a group of SWMUs. The review will focus on the method as supplied by the
analytical lab including scope, requirements, applicable documents, materials and equipment,
operations, QC limits, detection limits, QA/QC measures, safety, sample preparation and analysis. The
data validation process for data generated by the method shall follow the protocol specified in this
QAPP and in the pertinent SAP.
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B5 – Quality Control
Quality Control checks of both the field sampling procedures and laboratory sample analyses will be
used to assess and document data quality and to identify discrepancies in the measurement process
that need correction. The minimum analytical laboratory QC samples to be considered for inclusion in
the SAPs is provided in Table 4.
Quality control samples will be used to assess various data quality parameters such as
representativeness of the environmental samples, the precision of sample collection and handling
procedures, the thoroughness of the field equipment decontamination procedures, and the accuracy of
laboratory analyses. To evaluate bias and contamination from field-collection procedures, appropriate
soil or water blanks will be prepared. In addition, all sample containers, preservation methods, and
holding times will be in accordance with QC requirements, as specified in SAPs.
The analytical laboratory will use a series of QC samples as identified in the laboratory QAP and specified
in the standard analytical methods. The types of samples include method blanks, surrogate spikes,
laboratory control samples, laboratory control sample duplicates, matrix spikes, and matrix spike
duplicates. Analyses of QC samples will be performed for samples of similar matrix type and
concentration and for each sample batch.
For QC purposes, the laboratory generally categorizes samples into two matrix types: aqueous and
solids; which often encompasses a wide variety of matrix types. If for any reason a narrower definition
of a matrix is desired (e.g. Clay vs Silty samples being separated), the laboratory may be instructed to
spike discrete samples. This should be clearly communicated to the laboratory as it will most likely be
different from the standard protocol.
Field Quality Control
Field Quality Control Checks
Field equipment, if used, will be calibrated as frequently as recommended in the manufacturer’s
specifications. Each calibration including the results will be documented in the field logbook or on a
data sheet developed for calibration and signed by the PM. Additionally, quality control samples will be
collected during environmental sampling activities. Each type of field quality control sample is defined
below.
Field Duplicate Samples
A field duplicate sample is a second sample collected at the same location as the sample designated for
collection. Field duplicate sample results are used to assess precision, including variability, associated
with both the laboratory analysis and the sample collection process. Field duplicate and regular samples
will be collected simultaneously at a rate of 5% or at least one per project, from the same sample
interval, providing sufficient material exists, and treated in an identical manner during storage,
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transportation, and analysis. When recovery of soil from sampling operations is sufficient, field
duplicate samples will be collected at a frequency to be specified in specific SAPs.
Trip Blanks
A trip blank is a sample of distilled and/or deionized, organic-free water preserved with 0.2 ml of HCl
provided in three VOC bottles (and may vary in the specific SAPs). Trip blanks will be prepared only for
the analysis of VOCs and will be subjected to the same handling as the other samples. The trip blanks
will serve to identify contamination from sample containers or transportation and storage procedures.
A trip blank will accompany each cooler of samples sent to the laboratory for the analysis of VOCs. If the
travel time is brief (e.g. less than 2 hours) this may not be required.
Equipment Blanks
Equipment blanks are collected and analyzed to determine any level of contamination potentially
introduced into samples due to the equipment cleaning technique. Equipment blanks will be collected if
required in the SAP. General procedures for collecting equipment blanks are as follows (and may vary in
the specific SAPs):
Following the collection of a designated sample, the sample collection device will be cleaned using a
phosphate-free detergent and rinsed with water. The device will be inspected to ensure it has been
thoroughly cleaned and rinsed.
When detailed by specific SAPs, a sample of the equipment sample device rinse water will be collected
using the following additional steps:
(1) Collect a sample from the final rinse. Collect the water off the equipment being rinsed into the
required sample bottle(s);
(2) Submit the equipment blank for analysis of all waste constituents sampled at the site. This
equipment blank will be used to help quantify the potential for cross-contamination between
samples due to improperly cleaned sampling devices;
(3) Drum all wash and rinse water generated at the site for characterization and probable permitted
discharge to a sanitary sewer; and
(4) Obtain fresh wash water and rinse water from for cleaning operations at different site.
At the completion of sampling operations, all sampling equipment (augers, drill rods, sampling devices,
tools, etc.) will be pressure washed. Any additional requirements for equipment blanks will be specified
in SAPs.

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Field Blanks
Field blanks consist of empty, clean sample containers to be opened in the field and filled with reagent
grade water prior to collection of a field sample. Upon collection of the sample, the field blank
container is sealed and carried through the same handling, shipping, and analytical procedures as the
field sample. Since the frequency of field blanks is project-specific, field blanks will be specified in the
SAP. Field blanks may also be collected as needed based on field conditions (i.e., heavy exhaust from a
drill rig, etc.).
Laboratory Quality Control
Laboratory analyses will be conducted in accordance with the appropriate analytical methods. Internal
laboratory quality control checks will include:
• surrogate spikes for the respective methods;
• method blank (reagent blank) that is carried through the same analytical process as native
samples;
• matrix spike/matrix spike duplicates with known concentration in accordance with the
laboratory SOPs;
• laboratory control samples/laboratory control sample duplicates that are spiked in accordance
with analytical method and laboratory SOPs for each respective method of analysis.
The Laboratory will document continuing calibration check standards, Laboratory Control Samples,
surrogates, matrix spike and matrix spike duplicate recoveries, and relative percent differences (RPDs)
on statistical control charts.
The laboratory will address all data outliers and add comments in the laboratory database regarding the
effect the outlier may have on the usability of the data. If the QC data indicates a systematic problem
that makes the data unusable, corrective action will be implemented to resolve the problem and any
affected data will be re-analyzed to obtain usable data for reporting.
In order to maintain accreditation the laboratory will participate in a Proficiency Testing program on a
semiannual basis. The laboratory will analyze blind samples provided by a 3rd party vendor and must
receive acceptable results on two of the most recent 3 Proficiency Testing Studies. The laboratory will
report the results to the State of Utah Environmental Laboratory Certification Program office.
Corrective Action Investigations will be performed for analytes that do not pass the study criteria.
B6 – Instrument/Equipment Testing, Inspection and Maintenance
Instruments and Equipment will be tested, inspected and maintained as required by the manufacturer
for optimal performance. Information about the actions taken and the status of the instrument and
Equipment will be recorded in a logbook that is traceable to the specific instrument or Equipment. In
the case where a problem is identified, the instrument or Equipment will be taken out of service until
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the problem is resolved. The actions taken to resolve the problem and the outcome those actions will
also be recorded in the logbook.
Balances –The calibration of Analytical balances will be verified daily or before each use and will be
calibrated by a qualified Metrologist annually. The daily verification will be conducted using two
calibrated weights that bracket the expected balance use range. Balance calibrations checks will be
documented on logsheets.
Refrigerators/Freezers - All refrigerator and freezer temperatures will be monitored. Thermometers
used (either continuous or minimum/maximum) for measurement of refrigerator and freezer
temperatures will be calibrated at a frequency defined by the manufacturer.
Water Supply System - The laboratory will maintain a water supply system which is capable of furnishing
reagent water that is free from target analytes or interfering elements. Such water may be generated
from a system that uses deionization, distillation or some combination thereof and may incorporate
filtration through carbon filters and/or particle filtration. The water system is considered adequate
when reagent blank quality control samples show no positive detections for target analytes or
interfering elements.
B7 – Instrument/Equipment Calibration and Frequency
Calibration at a specified Frequency for Instruments and Equipment will be performed as required by
the manufacturer or per the analytical methodology in use. Documentation of the calibration will be
maintained in a logbook or via the raw data. Acceptance of the calibration will be verified prior to
proceeding with testing.
All laboratory instruments will be calibrated with the appropriate standard solution. All reported
analytes are to be bracketed by an established calibration curve. Because standard methods allow the
lowest standard to be up to ten times the concentration of the MDL, any positive values below this low-
level standard and above the project PQL would be classified as estimated. To avoid quantifications of
data based on this requirement, the contract laboratory is required to analyze an additional low
standard at or near the project PQL. Analytical guidelines and manufacturer specifications determine
the frequency of laboratory instrument calibration necessary. All batches of samples analyzed will be
bracketed by appropriate calibration verification standards. Corrective actions will be taken if the
calibration checks do not meet established criteria.

B8 – Inspection/Acceptance of Supplies and Consumables
Upon receipt of Supplies and consumables the items will be inspected to ensure that they are of the
type and quality required by the methodology in use. Items received that do not meet the criteria
established will be segregated to prevent inadvertent use.
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For Analytical Standards, a Certificate of Analysis that is traceable to a NIST standard will be maintained
on file as part of the quality records for the testing activities.
All standards and standard solutions will be catalogued to identify the supplier, lot number,
purity/concentration, receipt/preparation date, preparer's name, method of preparation, expiration
date, and any other pertinent information. Stock and working standard solutions will be validated
before use and checked regularly for signs of deterioration. Standard solutions will be properly stored
and handled, and all containers will be labeled to identify the chemical(s), concentration, solvent,
expiration date, initials of preparer, and date of preparation. Reagents will be examined for purity by
subjecting an aliquot or subsample to the analytical method in which it will be used. The contract
laboratory will not use a standard or reagent if its expiration date has passed. Expiration date extension
is allowed if it can be documented that the quality is still acceptable for the intended use. Complete
documentation will be maintained for all standards and reagents used

B9 – Non-Direct Measurements
Because many of the activities at the Bacchus and Promontory facilities have taken place for many years
there is a wealth of historical information available. When this type of information is used to establish
the actions taken, the information will be included in a SAP or a report as part of the quality record.

B10 – Data Management
All analytical data produced by Laboratory and the field operations will be stored at each data
producer’s location.
Data transfer and communications must ensure that only validated data are stored in the project
database. The transfer of data from generation, through validation, database entry, and final delivery to
the Division can be summarized as follows:
• All field data will be maintained on file.
• The laboratory generates laboratory validated data and sends the reports to the PM.
• The PM reviews laboratory validated data to ensure it complies with project objectives.
• The PM coordinates third party validation of a percentage of the laboratory-validated data.
• The report from the third party validators are maintained in the project database.
The PM forwards copies of validated data as required in the permit.

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Validation of Laboratory Data
The Laboratory will provide a QC review of their respective data in accordance with the relevant
laboratory QAP. The laboratory will enter validated data into the laboratory information management
system.
The PM may request third party validation of a percentage of the data. The percentage will be
dependent on the DQOs specified in the SAPs.

Validation of Field-Generated Data
All field generated data will be validated by the PM prior to incorporation into the project database. The
PM will validate data generated by the field instrumentation in accordance with instructions supplied
with the instruments.
Use and Storage of Data
Electronic data and documents shall be backed up to avoid loss. Retrieval of project documents is
limited to project personnel who have been granted access to the appropriate electronic files. Sensitive
or final electronic documents may be password protected to prevent unauthorized access or
inadvertent changes. At project closure, these electronic documents will be copied and electronically
stored on a disc or CD. When required an archived hardcopy will be maintained on file.
C – Assessment and Oversight

C1 – Assessments and Response Actions
To provide data having quality measures consistent with the project data quality objectives, the data
shall be reviewed against established criteria for precision, accuracy, representativeness, completeness,
and comparability. Limits are outlined in this QAPP and the individual SAP. Any data failing to meet the
stated limits will be indicated by including data qualifiers on all affected data.
To meet SAP requirements for data quality, periodic assessments may be conducted to assure
adherence to SOP requirements for field sampling, sample custody, equipment operation and
calibration, laboratory sample analysis, and data reporting. Further, the PM will assess the quality of
data generated once sampling and analysis of each project has been accomplished to assure that all data
are scientifically valid and of known and documented quality as specified in the project SAP.
If any information found during data assessments calls into question the usability of the data, the PM
will investigate the impact and corrective action will be taken to address any concerns. Corrective
action may include the need to re-sample and/or re-analyze samples to obtain usable data.
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The assessment process is also intended to ensure that there is an acceptable level of confidence in the
decisions that are made from the data. Data that fail to meet the QC criteria may still be used for
informational purposes, but will be flagged to indicate that the data has limited usability in meeting
project objectives.
Data assessments will be conducted by the PM after each sampling event to assure that the QAPP, SOPs,
and SAPs have been properly implemented. The PM will ensure that corrective actions are executed for
any nonconformance.
Audits may be conducted as a means to determine compliance with this QAPP and SAPs. Specifically,
audits may be conducted for both field and laboratory operations to assess performance to project
requirements. Several factors will be taken into consideration for determining the scope and
frequency for audits as follows:
1. Complexity of the activity;
2. Duration and scope of activity;
3. Degree of QC specified in the SAP;
4. Criteria to achieve quality assurance objectives;
5. Requirements for deliverables;
6. Participation of contractors;
7. Criticality of data collection; and
8. Potential for or frequency of nonconformance.
Addressing Nonconformance: The PM has the authority to stop all or part of the project activities if a
nonconformance occurs and the authority to assure appropriate development and implementation of
the required corrective actions.
Documentation: All auditing processes and results shall be documented.

C2 – Reports to Management

The PM will keep Environmental Services management apprised project performance assessments and
corrective actions. This will be communicated verbally in project progress meetings.
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D – Data Validation and Usability
D1 – Data Review, Verification and Validation

Laboratory Data Reduction and Review
Data reduction is the process of transforming raw data measurements obtained during analysis to final
reported data. This usually involves various calculations, application of dilution or preparation factors,
as well as the use of rounding data values to the appropriate number of significant figures. Reduction of
laboratory analytical data will be completed in accordance with the laboratory’s quality assurance
program and standard operating procedures.
The laboratory will perform the in-house analytical data reduction and QA review under the direction of
the laboratory manager or designee. The laboratory is responsible for assessing data quality and
indicating in the analytical reports any problems with the data that may affect usability. Any QC outlier
will be addressed and a comment in the laboratory database will be made to state any affect the outlier
may have had on the usability of the data. The laboratory will take corrective action were appropriate
to ensure data generated meets method and project objectives. Data reduction, QA review, and
reporting by the laboratory may include the any number of the following QC tasks:
1. The data reviewer will check that preliminary data produced by the analyst are processed and
reviewed for attainment of quality control criteria as outlined in the laboratory QAP.
2. The data reviewer will check all manually entered sample data for entry errors and will check for
transfer errors for all data electronically uploaded from the instrument output into the software
packages used for calculations and generation of report forms and will decide whether any
sample re-analysis is required.
3. The data reviewer will review initial and continuing calibration data, and calculation of response
factors, surrogate recoveries, matrix spike/matrix spike duplicate recoveries, internal standard
recoveries, laboratory control sample recoveries, sample results, and other relevant QC
measures.
4. Upon acceptance of the preliminary reports by the laboratory data reviewer, the Laboratory QA
Officer will review and approve the data packages prior to report submittal to the PM.
The signing of the Certified Analytical Data Report by the QA Officer indicates that the QC review tasks
have been accomplished.

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Laboratory Data Package Delivery Requirements
Data deliverables will be provided in a tiered approached as indicated in the SAPs for the individual
projects. The tiers, ranging from the simplest data reporting level to the more complex deliverable, are
described below:
Certificate of Analysis: A certified report listing all analytical and preparation methods used, sampling
dates/times, EQLs, MDLs, dilutions, analysis dates/times, analyst, and results with units of measure, dry
weight reporting. Also attached will be any sample receiving documents including Chain-of-custody
forms. The final report will include comments indicating any problems with sample receipt, data
analysis, or quality control issues that may affect the usability of the data, including explanation of what
qualified and flagged data us acceptable for use.
Certificate of Analysis with Quality Control Summary: the next level of complexity in data deliverables
would be to include with the Certificate of Analysis a Quality Control Summary report. This report
shows the results analysis batch quality control samples, such as blanks, laboratory control samples,
matrix spikes, duplicates, initial and continuing calibration verification standards and any other method
specific quality control samples. The report will indicated the expected range of acceptability for the
quality control samples and flag any data that fall outside of acceptance limits. Where outlier data
exists, a comment by the laboratory as to the effect on the usability of the data will be included in the
analytical report.
Additional Data on File : The laboratory will maintain on file a full record of the analytical testing and
include the following types of information:
1. Calibration/Standardization plots and equations.
2. Initial and continuing calibration verification summary sheets with results of true values
compared to found values.
3. Copies of laboratory notebook pages showing data not otherwise recorded and calculations.
4. Digestion and preparation logs
5. Chromatograms
6. Enhanced or background subtracted mass spectra.
7. ICP interference check sample summary.
8. Internal standard area (or recovery) and retention time summary information.
9. Analysis data (including printer tapes, strip charts, etc.) for analysis/reanalysis, calibrations,
diluted/undiluted samples, and QC samples.
10. Quantitation and integration reports.
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11. Surrogate recovery information.
12. When used: Laboratory generated library standard spectra. For tentatively identified
compounds provide the reference mass spectrum or spectra from the software-spectra library.
Electronic Data Deliverable: Any of the above deliverables may be provided in electronic format. The
complexity of the electronic deliverable may vary as the needs of the project require.
Field Data Reduction and Review
The PM is responsible for recording data generated by field instruments including but not limited to
PIDs, thermometers, barometers, and field analytical test kits in accordance with SOPs provided by the
manufacturer or in the SAPs. Data shall be reported in a format to be provided in SAPs and shall include,
at a minimum the following QC checks:
1. The PM will check that data produced by the instrument are within the calibration range of the
instrumentation and other QC measures relevant to the field instruments. The degree to which
the data meet DQOs will be provided in the data report.
2. The PM will check field logs and cross check field sampling locations and procedures with the
field data for representativeness.
3. The PM will check all manually entered field data for entry errors and will check for transfer
errors for all data electronically uploaded from an instrument output where appropriate.

D2 – Verification and Validation Methods

Laboratory Data Validation
The first level of review will be conducted by the Laboratory. Laboratories have the initial responsibility
for the correctness and completeness of the data they generate. The laboratory data reviewer will
evaluate the quality of the analytical data based on an established set of laboratory guidelines
(laboratory QAP and SOPs). This person will review the data deliverables to confirm at a minimum, the
following:
1. Sample preparation information is correct and complete;
2. Analysis information is correct and complete;
3. The appropriate SOPs have been followed;
4. Analytical results are correct and complete;
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5. QC sample results are within established control limits and if not, why data is useable;
6. Blank results are within appropriate QC limits;
7. Analytical results for QC sample spikes, sample duplicates, initial and continuing calibration
verifications of standards and blanks, standard procedural blanks, and laboratory control
samples are correct and complete;
8. Tabulation of reporting limits related to the sample is correct and complete; and
9. Documentation is complete (all anomalies in the preparation and analysis have been
documented; holding times are documented).
The second level of review will include data validation conducted on a minimum of ten percent of the
certificates of analysis by a third party. The sample-specific requirement review conducted by the third
party validator shall include the following:
1) Blanks Analyses
2) Organic Analyses
a) Holding Times
b) Surrogate Spike Results
b) Matrix Spike/Matrix Spike Duplicate (MS/MSD) Sample Analysis
c) When required: Tentatively Identified Compound Identification
d) Field Duplicate Agreement
e) Comparison of EQLs and MDLs with project DQOs (RSL, MCL etc.)
3) Metals and Inorganic Analyses
a) Holding Times
b) Duplicate Sample Analysis
c) Matrix Spike Sample Analysis
d) Matrix spike duplicate or laboratory duplicate precision
g) Field Duplicate Agreement
e) Comparison of EQLs and MDLs with project DQOs (RSL, MCL etc.)

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The data package delivery requirements as specified in this QAPP and SAPs will be reviewed for
completeness. Data determined to be outside acceptance criteria, using professional judgement, and
any conclusions reached concerning usability of the suspect data will be described in the third party data
validation reports.
Field Data Validation
The purpose of the validation process is to evaluate the usability of field data that are collected or
documented in accordance with specified protocols outlined in the SAPs. Field data will be reviewed
for data usability and adherence the project objectives outlined in the SAPs and this QAPP
D3 – Reconciliation with User Requirements
Once the data verification and validation procedures have been completed, the PM will evaluate the
results to determine if project DQOs have been met for field operations and laboratory analyses,
respectively. The calculations specified in other sections of this QAPP and in SAPs will be used to
determine if numeric acceptance criteria have been met. Data, which do not meet the requirements for
their intended use, will be flagged accordingly and the flags entered into the project database, so that all
data reports used for decision making are clearly noted

______________________________________________________________________________ Attachment 3 SAP 1 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

ATK LAUNCH SYSTEMS (ATK) PROMONTORY
FACILITY
POST-CLOSURE PERMIT

GROUNDWATER SAMPLING AND ANALYSIS PLAN

______________________________________________________________________________ Attachment 3 SAP 2 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
CONTENTS 1.0 PURPOSE AND SCOPE .................................................................................................... 4 2.0 QUALITY OBJECTIVES AND CRITERIA FOR MEASURMENT DATA ................... 4

2.1 DATA QUALITY OBJECTIVES ...................................................................................... 4 2.1.1 Statement of Problem .................................................................................................. 4 2.1.2 Decision Statement ..................................................................................................... 5
2.1.3 Decision Inputs ........................................................................................................... 5
2.1.4 Study Boundaries ........................................................................................................ 5 2.1.5 Decision Rule .............................................................................................................. 5 2.1.6 Tolerable Limits on Decision Errors........................................................................... 6 2.1.7 Selected Sampling Design .......................................................................................... 6

2.2 QUANTITATIVE OBJECTIVES ...................................................................................... 7 2.3 QUALITATIVE OBJECTIVES ......................................................................................... 8
2.4 AUDITS AND REPORTING ............................................................................................. 8
3.0 SAMPLE COLLECTION ................................................................................................... 9 3.1 WATER LEVEL MEASUREMENT ............................................................................... 10

3.2 PURGING THE MONITORING WELLS ....................................................................... 10 3.2.1 Purging High-Yield Formations ............................................................................... 10 3.2.2 Purging Low Yield Formations ................................................................................ 11
3.2.3 Purging and Sampling Equipment……………………………………………. ……11
3.2.4 Nested Multi-Screened Well………………………………………………………..11 3.3 SAMPLING PROCEDURE FOR MONITORING WELLS……………………………12
3.3.1 HydraSleeve………………………………………………………………………..13
3.4 FIELD QUALITY ASSURANCE AND CONTROL PROGRAM ................................. 13 3.4.1 Trip Blanks, Field blanks and Field Duplicates ........................................................ 13
3.4.2 Blind Controls and Spiking Samples ........................................................................ 14
3.4.3 Sample Handling ....................................................................................................... 14 3.4.4 Labeling Samples ...................................................................................................... 15 3.4.5 Field Book ................................................................................................................. 15 3.4.6 Chain-of-Custody Control Procedures ...................................................................... 16
3.4.7 Field Equipment Calibration Procedure.................................................................... 16
______________________________________________________________________________ Attachment 3 SAP 3 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

3.5 SAMPLE COLLECTION SCHEDULE ........................................................................... 16 4.0 ANALYSIS OF GROUND WATER SAMPLES ............................................................ 16
4.1 ANALYTICAL LABORATORY .................................................................................... 16
5.0 REPORTS ......................................................................................................................... 17 5.1 PRESENTATION OF ANALYTICAL RESULTS ......................................................... 17

5.1.1 Listing of Data .......................................................................................................... 17
FIGURES
Figure 1 Example of Chain of Custody Form
TABLES Table 1 Sampling and Analytical Methods Requirements Table 2 Groundwater Monitoring Wells Completed in Unconsolidated Sediments
______________________________________________________________________________ Attachment 3 SAP 4 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
ATK LAUNCH SYSTEMS
GROUND WATER SAMPLING AND ANALYSIS PLAN
FOR POST-CLOSURE PERMIT MONITORING

1.0 PURPOSE AND SCOPE
ATK Launch Systems (ATK) has developed this plan to satisfy the requirements for a ground water sampling and analysis plan as referenced in R315-264-97 of the Utah Administrative Code and this Permit.
The plan specifically addresses the sampling of ground water monitoring wells at ATK Launch systems Promontory, Utah-based Operations. The location, number, and description of each well have been submitted previously to the Utah DWMRC. The plan addresses all procedures for taking ground water samples, shipping the samples for analysis, and methods for analyzing samples.
The goal of this plan is to collect groundwater samples that are representative of in-situ groundwater conditions and to minimize changes in groundwater chemistry during sample collection and handling. DNAPL’s are not known to be present in any screened interval of any well. If DNAPL’s are discovered to be present in a well, this document is not sufficient, and
protocol for sampling will be developed prior to sample collection.

2.0 QUALITY OBJECTIVES AND CRITERIA FOR MEASURMENT DATA
This section presents the DQOs for the project and the performance criteria necessary to meet
these DQOs. Included are discussions of the project DQOs, quantitative DQOs (precision, accuracy, and completeness), and qualitative DQOs (comparability and representativeness). The overall QC objective is to generate data that are of known, documented, and defensible quality.
2.1 DATA QUALITY OBJECTIVES
DQOs are statements that specify the quantity and quality of the data required to support project decisions. DQOs were developed for this project using the seven-step process listed in Data Quality
Objectives Process for Hazardous Waste Site Investigations (U.S. EPA, 2000). The QC procedures as well as the associated sampling procedures for this project will be focused on achieving these DQOs in a timely, cost-effective, and safe manner. Deviations from the DQOs will require defining the cause or causes for noncompliance and will initiate the process of
determining whether additional sampling and analyses will be required to attain project goals.
2.1.1 Statement of Problem
Groundwater monitoring at the ATK facility has shown that, due to waste management practices of the past, contaminants have been released to the groundwater. Some of the contaminants have
______________________________________________________________________________ Attachment 3 SAP 5 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
routinely been detected at concentrations exceeding the Groundwater Protection Standard
(GWPS) established in Module IV of this Permit. Pursuant to R315-264-90, and this Permit, ATK is required to establish a corrective action program when the GWPS is exceeded. Groundwater monitoring data collected in accordance with this SAP will be used for assessing the human health and ecological risk associated with the contaminated groundwater in order to
determine the appropriate corrective action. Monitoring data will also be used to update
groundwater flow and transport models that are used to predict the migration of contaminants and how points of exposure may be affected. Therefore, the goal of this plan is to outline the methodologies for collection of groundwater samples that are representative of in-situ groundwater conditions and to minimize changes in groundwater chemistry during sample
collection and handling.
2.1.2 Decision Statement
Decision statements identify the key questions that the study should address and alternative
actions that may be taken, depending on the answer to the study questions. The key questions
associated with groundwater sampling at the Promontory facility are:
• Where do the contaminant concentrations exceed the GWPS? and;
• Does the site contamination pose an unacceptable risk to human health and the environment? The decision statement for this program is to determine where contaminant concentrations exceed the GWPS site-wide and what response is appropriate for those areas. The appropriate
response (e.g. removal or treatment of contaminants, site management, or continued monitoring) will be based on the results of groundwater models, human health and ecological risk assessments and a corrective measures study.
2.1.3 Decision Inputs
The most appropriate resolution of the decision statement will require the collection of groundwater samples and potentiometric surface data on a regular schedule. These samples will be analyzed for the constituents shown in Table 1 of this SAP. The analytical methods that will
be used are also shown in the table. These data along with historic groundwater data, will be
used as inputs to groundwater models and human health and ecological risk assessments. All of this information will be considered and appropriate corrective measures will be proposed in a Corrective Measures Study. 2.1.4 Study Boundaries Groundwater contamination at the facility exists in at least three separate plumes and in two different aquifers. The boundary of the study is defined by the extent of groundwater
contamination and is not limited to the ATK property. The Area of Compliance is defined as all
monitoring wells, piezometers and springs located within impacted aquifers and displaying
______________________________________________________________________________ Attachment 3 SAP 6 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
concentrations that exceed the Groundwater Protection Standard as defined in section IV.C. of
Module IV. The monitoring wells and springs that may be sampled are listed in Table 4-A of Attachment 4. Wells are selected for sampling on an annual basis. Shotgun and Pipe Springs are sampled
semiannually, once in the Spring and once in the Fall. Well and spring locations are shown on
Plates 1(a) and 1(b), Attachment 4.
2.1.5 Decision Rule
As stated above, groundwater monitoring at the site has shown that the GWPS has been
exceeded for a number of constituents. The GWPS for constituents that have been detected at
the site are listed in Table IV-1 of the Permit. Based on the requirements of R315-264-90 and this Permit, if the GWPS is exceeded then a corrective action program shall be initiated. In accordance with Module V, Section A, ATK is currently conducting human health and
ecological risk assessments, as part of the corrective action program, using the Director approved
groundwater flow and contaminant transport models. The risk assessments are being conducted in accordance with the State of Utah R315-101 Cleanup Action and Risk-Based Closure Standards. The characterization and evaluation of risk is based on developing concentration terms for contaminants (generally the 95% upper confidence limit of the mean) and calculating
the reasonable maximum exposure for all exposure pathways. The appropriate response action
that will be taken at the site will be dependent on the results of the risk assessments.
2.1.6 Tolerable Limits on Decision Errors
Tolerable error limits assist in the development of sampling designs to ensure that the spatial
variability and sampling frequency are within specified limits. However, the location, number,
and frequency of sampling at the Promontory facility has been previously determined by the requirements of the Post Closure Permit and compliance monitoring downgradient of identified Solid Waste Management Units. The selection of the well locations was based on professional judgment rather than statistics. Therefore, error limits are not used to determine sampling
locations or frequency. There is no need to define the “gray region” or the tolerable limits on the
decision error, since these only apply to statistical designs. In general, the steps necessary to minimize errors and produce good quality data will be incorporated into quality assurance/quality control (QA/QC) protocols in this plan.
2.1.7 Selected Sampling Design
The proposed sampling locations (monitoring wells) were drilled in areas based on best professional judgment, site history, aerial photos, and results of previous environmental investigations. A statistical design for collecting groundwater samples will not be used. The
Post-Closure care period began in 1992 for the M-136 impoundments. The location of
contaminant plumes have been identified based on this collection of data. In addition, due to the large number of wells that exist, plans are submitted annually for which wells will be sampled.
______________________________________________________________________________ Attachment 3 SAP 7 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
The selection of wells to sample is based on an evaluation of what data is the most pertinent at
the time the sampling plan is generated.

2.2 QUANTITATIVE OBJECTIVES

Precision quantifies the repeatability of a given measurement. Precision is estimated by
calculating the relative percent difference (RPD) of field duplicates, as shown in the following
equation:

x100Result)/2 Duplicate(Result
Result DuplicateResult%)RPD +
−=(
The laboratory will review the QC samples to ensure that internal QC data lies within the limits of acceptability. Any suspect trends will be investigated and corrective actions taken. The
laboratory will document the calculation for %RPD or other statistical treatment used. The results will be compared to the acceptance criteria as published in the mandated test method. Where there are no established criteria, the laboratory will determine internal criteria and document the method used to establish the limits
Accuracy refers to the percentage of a known amount of analyte recovered from a given matrix. Percent recoveries are estimated using the following equation and can be calculated for the project-specific matrix (i.e., water).
Recovery Laboratory Control Standard (LCS) and Surrogate Internal Standard
(SIS) (%) = x100 AmountSpike Added
Recovered) Spike(Amount
Recovery Matrix Spike/Matrix Spike Duplicate
(MS/MSD)(%)=x100 AddedSpike
Result) (SampleResult) Sample (Spiked −
The recovery of most spiked organic compounds is expected to fall within a range of 70 to 130%.
Completeness refers to the percentage of valid data received from actual testing done in the laboratory. Completeness is calculated as shown in the following equation. The target
completeness goal for all compounds is 100%. However, where data are not complete, decisions
regarding re-sampling and/or reanalysis will be made by a collaborative process involving ATK Environmental personnel, laboratory personnel, and regulatory personnel. The completeness goal for holding times will be 100%.
______________________________________________________________________________ Attachment 3 SAP 8 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
Completeness % =x100tsMeasuremen ofNumber Total
Valid Judged tsMeasuremen ofNumber

2.3 QUALITATIVE OBJECTIVES
Comparability is the degree to which one data set can be compared to another. To ensure comparability, samples will be collected at specified intervals and in a similar manner, and will
be analyzed within the required holding times by accepted and comparable methods.
Comparability will be obtained through the use of standard sampling procedures and trained personnel, and through standard analytical methods used by the laboratory. Additionally, adherence to the procedures and QC approach contained in the QAPP will provide for comparable data throughout the sampling events. All data and units used in reporting for this
project will be consistent with accepted conventions for environmental matrix analyses. This
approach will ensure direct comparability between the results from one sampling event to the next sampling event using the methods presented in this SAP. Representativeness is the degree to which a sample or group of samples is indicative of the
population being studied. Over the course of a project, samples will be collected in a manner
such that they are representative of both the chemical composition and the physical state of the sample at the time of sampling.

2.4 AUDITS AND REPORTING

A Performance Audit will be conducted during a sampling round at least once in a five year period. The performance audit will be used to determine the status and effectiveness of field and laboratory measurement systems.
For the laboratory, this will involve the use of PE samples with known concentrations of
constituents that will be analyzed as unknowns in the laboratory. Results of the laboratory analysis will be calculated for accuracy against the known concentration and acceptance limits provided by the supplier or manufacturer.
Field performance will be evaluated using field blanks, trip blanks, field duplicates, and
equipment blanks as described in Section B5 of the QAPP. A Data Quality Audit will be conducted following the procedures specified in Section C2 of the QAPP to assess the effectiveness and documentation of the data collection and generation
processes. Data-quality audits will be conducted by the DVSM at least once during a five year
period. A Technical System Audit (TSA) will be performed once each five years. A TSA is a thorough and systematic qualitative onsite audit where equipment, personnel, training, procedures, and
______________________________________________________________________________ Attachment 3 SAP 9 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
record keeping are examined for conformance with requirements of the QAPP. The TSA will
encompass field sampling activities, data validation, and data management. All findings will be documented in writing to the OPM and communicated to the PM when the assessment is complete. A copy of the TSA report will be provided to the Division for review, together with a discussion of all proposed corrective actions and corrective actions taken as a result of the audit.

The TSA will include a field audit to check on sample collection and sample handling procedures. The field audit will include: • A review of compliance with requirements of the QAPP and Sampling Plans
• On-site visits, which will include observation of field personnel as they perform
all aspects of the sampling programs: field equipment calibration, equipment decontamination, sample collection, sample packaging, and documentation. The on-site visits will also include a review of data collection forms, COC forms, calibration procedures, etc. The auditor will also talk individually with field
personnel to determine consistency of sampling procedures and adherence to the
approved sampling plan.
3.0 SAMPLE COLLECTION

As of March, 2012, 102 groundwater monitoring wells have been installed at the ATK-
Promontory facility. The first series of wells was installed in 1985. The RCRA Groundwater Monitoring Technical Enforcement Guidance Document (TEGD) was used as a guide for the installation of monitoring wells once the document was published in 1986. Wells have been completed in both bedrock and unconsolidated sediments and from depths ranging from 25 feet
to over 600 feet deep. 20 foot well screens and dedicated pumps were used in the earlier wells
that were installed. More recent wells that have been installed utilize 10 foot well screens without dedicated pumps. ATK collects groundwater samples, in accordance with the November 1992 TEGD, using the
pumps described in Section 3.2.3 below or HydraSleeve, no purge groundwater samplers, as
described in Section 3.3.1 below. Occasionally, bailers may be used for collecting samples from the deepest wells at the facility. In general, if the well still has an operating, dedicated pump the sample will be collected with the pump using the well purging and sampling methods described below.

In the Spring of 2006, ATK began a study to evaluate the use of the HydraSleeve, no purge sampling method. A plan to evaluate the accuracy of the collection method was submitted to the Division of Solid and Hazardous Waste (the Division) in April of 2006. The study showed that samples collected with the HydraSleeve compared very well with samples collected using the
conventional method. The Division approved the use of the HydraSleeve sampler on June 20,
2008. This SAP includes the use of the HydraSleeve sampler as an option for collecting groundwater samples.
______________________________________________________________________________ Attachment 3 SAP 10 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
The HydraSleeve sampler will be used in all applicable wells, unless the wells have a
functioning dedicated pump system.

3.1 WATER LEVEL MEASUREMENT

Before sampling any ground water monitoring wells, a water level measurement will be recorded
using an electronic water level indicator to the nearest 0.01 feet. The water level will be recorded in the field book before each monitoring well is sampled. The total depth of all monitoring wells that are completed in unconsolidated sediments will be measured every three years beginning in 2008 and will be recorded to the nearest 0.1 feet in the field book. The
northern edge of the (inner) PVC casing shall be used as the reference point. Table 2 contains a
list of all wells at the facility that were completed in unconsolidated sediments.

3.2 PURGING THE MONITORING WELLS

The ground water monitoring wells will be purged before sampling begins, unless the well will
be sampled using the HydraSleeve sampling method. Monitoring wells shall be purged so that stagnant waters, which are not representative of the waters in the aquifer, can be removed before sampling. The amount of water to be removed from the well will be dependant upon the ground water yield for the formation in which the well is located. Although specific purge and sample
systems are described below, other methods may be employed if they meet guidelines approved
by the USEPA and Utah DSHW.
3.2.1 Purging High-Yield Formations
A. For high-yield formations (which produce greater than 1 gpm), three casing volumes of
water will be removed from the well or until the pH, temperature, and conductance has stabilized
within approximately 10% over at least two measurements. A casing volume is defined as the volume of water between the water level measured and the total depth of the monitoring well. The casing volume will be calculated during each sampling period, so that a consistent volume of standing water can be removed prior to each sampling.
B. Low-flow Purging (consistently yields the highest level of data quality), <1 L/min (.26 gpm), Low-flow Sampling < 300 ml/min (0.3 L/min or 0.1 gpm). During purging, the water level in the well should not decrease significantly and should stabilize after purging for a few minutes. Purge the well until the pH, temperature, and conductance have stabilized within approximately
10% over at least two measurements. The pump intake will be positioned within the lower
screened interval.
______________________________________________________________________________ Attachment 3 SAP 11 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

3.2.2 Purging Low Yield Formations
For low-yield formations (which produce less than approximately 1 gpm), wells should be purged at or below their recovery rate so that migration of water in the formation above the well
screen does not occur. A low purge rate also will reduce the possibility of stripping VOCs from
the water, and will reduce the likelihood of mobilizing colloids in the subsurface that are immobile under natural flow conditions. Make sure that purging does not cause formation water to cascade down the sides of the well screen. At no time should a well be purged to dryness if recharge caused the formation water to cascade down the sides of the screen, as this will cause an
accelerated loss of volatiles. Water should be purged from the well at a rate that does not cause
recharge water to be excessively agitated until the pH, temperature and conductance has stabilized within approximately 10% over at least two measurements. The pump intake will be positioned within the lower screened interval.
3.2.3 Purging and Sampling Equipment

Wells less than 250 feet deep may be purged and sampled with a variable frequency pump or a bladder pump. Wells greater than 250 feet deep may be purged and sampled using a pneumatic-operated tubing-vented piston pump or a bladder pump. Wells greater than 250 feet with a dedicated system may use a submersible pump for purging and a bladder pump for collection of
volatile organic samples or a variable frequency 4” diameter Pump or a bladder pump. Wells
greater than 500 feet deep may be purged using a submersible pump and sampled with a bailer or a bladder pump may be used. Variable speed low rate centrifugal pumps and bladder pumps may also be used for both purging and sampling. When dedicated equipment is not used for sampling it should be cleaned in the following manner: Wash the equipment with a non-phosphate
detergent. Rinse the equipment with tap water. Rinse the equipment with reagent water.
Decontamination fluids should be put in the waste water collection tank and disposed of with the collected well water. Equipment blanks will be taken on approximately 10% of all wells sampled not using dedicated equipment.
The HydraSleeve groundwater sampler can be used in wells that do not have a functioning,
dedicated sampling system.
3.2.4 Nested Multi-Screened Well
Wells B-2 and F-2 consist of three two inch inside-diameter well casings nested within an eight-
inch diameter borehole. Each casing is screened at a different depth in the aquifer. These wells
are also sampled using a HydraSleeve. If a pump is used, purging and sampling is accomplished by using a pneumatic-operated tubing-vented piston pump or a centrifugal, variable speed, low-rate pump. Each casing shall be purged of three casing volumes prior to sampling, or until parameters stabilize.
______________________________________________________________________________ Attachment 3 SAP 12 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

3.3 SAMPLING PROCEDURE FOR MONITORING WELLS
Each well will be sampled using the following procedure. These procedures will describe specifically the following steps for sampling the wells.

(1) Each well will be purged before removing a sample unless the well will be sampled using the HydraSleeve sampling method as described below. (2) If purging is required, the sampling pump will be operated to produce a stream of ground
water. Before taking a sample, the pH, specific conductance, and temperature will be
measured using portable meters. Samples will be taken when the pH, conductance, and temperature have stabilized to within approximately 10% over at least two readings, or after three casing volumes of water have been purged. A sample from the pump will be put into an appropriate container.

(3) For volatile organic compounds, the flow rate will be restricted to less than 100ml/minute while taking the samples. To minimize the possibility of volatilization of organic constituents, no headspace should exist in the containers of samples containing volatile organics.

(4) The samples will be taken in the following order: 1) Volatiles 2) Anions 3) TDS
4) Metals 5) Other Constituents (5) The number, size and type of sample containers required for the constituents that will be sampled are given in Table 1.
(6) If samples are being split, the samples will be taken directly from the ground water monitoring well. This process will be done in order to minimize volatilization of sensitive organics.
3.3.1 HydraSleeve The HydraSleeve is a discrete interval, no-purge groundwater sampler. A representative sample is collected by the sampler when it is raised through the water column in the screened interval of the well. A new, clean HydraSleeve sampler is used each time a
sample is collected by this method. One or more HydraSleeves are weighted and placed within the screened interval of the monitoring well. Typically a dedicated pre-measured line allows for the required depth to
______________________________________________________________________________ Attachment 3 SAP 13 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
be achieved during each sampling event. It is typically left in the well for a period of
time to allow the well to re-equilibrate following sampler deployment. To activate, the sampler is pulled up a distance equal to 1 to 2 times the sampler length. The HydraSleeve collects a sample with no drawdown and minimal agitation or displacement of the water column. Once the sampler is full, the one-way reed valve closes, which prohibits any
more water from entering the sampler. An alternate approach to activating the sampler is
to raise and lower it multiple times over a distance equal to the sampler length. This approach is less attractive because the raising and lowering of the sampler can result in increased agitation of the water in the well and higher turbidity levels in the sample.
The best way to remove a sample from the HydraSleeve with the least amount of aeration
and agitation is with the short plastic discharge tube included with each sampler. First, squeeze the full sampler just below the tip to expel water resting above the flexible check valve. Then, push the pointed discharge tube through the outer polyethylene sleeve about 3-4 inches below the white reinforcing strips. Discharge the sampler into the desired
containers (per sampling protocol). Raising and lowering the bottom of the sampler or
pinching the sample sleeve just below the discharge tube will control the flow of the sampler. The sample sleeve can also be squeezed, forcing fluid up through the discharge tube, similar to squeezing a tube of toothpaste.

3.4 FIELD QUALITY ASSURANCE AND CONTROL PROGRAM
The field QA/QC program is described in the Post-Closure Permit Quality Assurance Project Plan. A general description is given below.
A QA/QC officer has been appointed to oversee the Ground Water QA/QC Plan, implement all
phases of the Field Quality Assurance and Control Program, and to periodically audit the laboratory’s QA/QC Program. The QA/QC officer will work with the sampling staff and the laboratory’s QA/QC officer to assure that the data collected from the ground water is accurate. The QA/QC officer duties include:

1. Making sure that the Ground Water Sampling Plan is followed. 2. Making sure the laboratory follows their QA/QC plan.

3. Send spiked samples periodically to the laboratory to audit the QA/QC program.
3.4.1 Trip Blanks, Field Blanks and Field Duplicates
Trip blanks, when collecting VOC’s, will consist of not less than ten percent of the total of
samples, and will be made of deionized water, prepared at the laboratory immediately before
leaving on a sampling run. The trip blanks are then placed in a cooler which will be filled by
______________________________________________________________________________ Attachment 3 SAP 14 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
other samples: the trip blanks are handled in the same manner as other samples. Holding times
for a trip blank begins when groundwater samples are being collected. Field Blanks (field rinsate blank, decontamination blank, equipment blank)
Collect one field blank for every 10 samples collected. Decontaminate the sampling equipment
for the field blank the same way you do when collecting other samples. After decontaminating the sampling device (e.g., bailer or pump), fill it with laboratory reagent grade water, then collect a sample of the reagent grade water, this is your field blank. The field blank should be analyzed for the same parameters as the samples. Field blanks are not required if you used dedicated
sampling equipment (permanently left in the well) or disposable sampling equipment.
Field duplicates, consisting of not less than ten percent of the total samples, will be collected and stored with the water samples. The field duplicates are collected and handled at the same time and in the same manner as a regular sample. The results of these samples are compared against
those of the appropriate regular sample.
3.4.2 Blind Controls and Spiking Samples
Annually, the QA/QC officers will send a spiked sample or a blind control to the laboratory to audit the laboratory’s QA/QC program. A blind control and a spiked sample both are samples
with a known amount of solute in a solvent. The difference between a blind control and a spiked
sample is the following: 1) Blind Control – An unannounced spiked sample sent to the laboratory.
2) Spiked Sample – An announced spiked sample sent to the laboratory.
The level of contamination in either case is not divulged to the laboratory. The QA/QC officer will review the spike or blind control recovery. If the spike or
blind control recovery is out of line with the laboratory’s surrogate spike and
matrix spike recoveries, the laboratory’s QA/QC officer will be contacted to resolve the problem.
3.4.3 Sample Handling

Sampling equipment and techniques have been designed so that the ground water sample is not
contaminated or altered. A critical part of obtaining samples is proper sample handling. All of these procedures will be followed for handling ground water samples. All samples requiring refrigeration will be stored in a secured refrigerator or ice chest with ice.
Sample preservation requirements and maximum holding times for the constituents that will be
collected are shown in Table 1. All samples will be labeled and accompanied by a laboratory request and chain of custody sheets.
______________________________________________________________________________ Attachment 3 SAP 15 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
3.4.4 Labeling Samples
All sample containers will be labeled with the following information: 1) Sampling date and time
2) Sample number
3) Name of person taking samples 4) Parameters to be analyzed in sample 5) Location of sampling point 6) Preservative added (if applicable)
3.4.5 Field Book
During each sampling period, the person sampling the ground water wells will keep a field book into which all relevant information regarding sampling will be recorded. The data must be entered in the book using permanent ink. The following information will be entered into the
field book as applicable to the sampling method:
1) Signature and date of person(s) conducting the sampling. 2) General weather conditions.

3) Date and time each well is sampled. 4) Sample number and location of sample (i.e., well number).
5) Static water level in well.
6) Volume of a casing of well (if applicable). 7) Well depth

8) Flow rate, and purge start and stop times. 9) Well purging procedure and equipment
10) Well yield (high or low) and well recovery after purging (slow, fast)
11) PH, specific conductance, and temperature measured during stabilization of well. 12) Sample withdrawal procedure and equipment

13) Internal temperature of field and shipping containers 14) Conductance and pH meter calibration date.
______________________________________________________________________________ Attachment 3 SAP 16 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit
15) Any irregularities in the sampling procedures or in the conditions of the wells.
16) Any other information the sampler deems necessary or important during sampling.
3.4.6 Chain-of-Custody Control Procedures

All samples will be controlled by chain-of-custody procedures. All samples shall be accompanied by a chain-of-custody form. This form must be completely filled out, signed, and dated by the sampler. An example of the form is found on Figure 1.
The containers will be placed in a lockable cold storage box, or refrigerator. This box will be in
the possession of the person charged with the custody of the samples or the box will be locked and placed in a secure place. Under no circumstances will the box with the samples be left unlocked or unattended. A copy of all the Chain-of-Custody forms will be reviewed for accuracy and filed by the QA/QC officer.
3.4.7 Field Equipment Calibration Procedure
The pH and conductivity meters will be calibrated with a standardized solution in accordance with the manufacturer’s specification each day they are used when collecting samples. Record of these calibrations will be kept in the Field Log Book.

3.5 SAMPLE COLLECTION SCHEDULE
The ground water monitoring wells will be sampled annually in accordance with Module IV. Shotgun and Pipe Springs are sampled semiannually, once in the Spring and once in the Fall.

4.0 ANALYSIS OF GROUND WATER SAMPLES
Wells will be sampled for constituents specified in the post-closure permit. Samples will also be analyzed for the field water quality parameters pH, temperature, and conductance as applicable.
4.1 ANALYTICAL LABORATORY
All samples will be analyzed by a state certified laboratory using EPA or State approved analytical methods. If there is not an established EPA or State approved analytical method, the Utah Director of DWMRC will be notified for approval of the proposed analytical method.

If the laboratory is not State certified to do a specific analysis, the laboratory will subcontract a State certified laboratory to do the analysis. Table 1, contains a listing of analytes, methods, containers, and holding times.
______________________________________________________________________________ Attachment 3 SAP 17 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

5.0 REPORTS
Reports submitted annually to the Utah DEQ will include raw analytical data and analysis of data as described in Section D of the QAPP.

5.1 PRESENTATION OF ANALYTICAL RESULTS
The analytical results received from the laboratory will be placed on a computer for easy data manipulation and presented in the following manner:

5.1.1 Listing of Data
All the collected monitoring data will be presented in a list. This list will be presented according to monitoring well and will include all of the data produced from sampling the monitoring well.
The list will include the following data:
- Ground water contaminant constituents - Monitoring well number - Date sample was taken - Concentration of constituents
- Units - Laboratory detection limits (including the method detection limit and estimated quantitation limit)
______________________________________________________________________________ Attachment 3 SAP 18 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

FIGURE 1
CHAIN OF CUSTODY Page ____ of _____ ATK Launch Systems, Promontory Utah
Collected by: Project:
Contact: Collection Location:
Telephone: Work Order:
Turn Around Time:

SAMPLE NUMBER LAB DATE SAMPLED TIME SAMPLED NUMBER OF BOTTLES ANALYSIS REQUESTED

Relinquished by: Received by: Date/Time

______________________________________________________________________________ Attachment 3 SAP 19 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

TABLE 1. SAMPLING AND ANALYTICAL METHODS REQUIREMENTS

Parameter Matrix Analytical Method Containers per sample (number, size, and
type)
Preservation Requirements (temperature, chemical)
Maximum Holding Time (to extraction)
Lab Holding Time (after
extraction)
Volatile Organic Compounds Water
USEPA
Method 8260B - ATK SOP 401

3-40 ml glassTeflon cap
Cool 4o C HCl to pH<2 14 Days 40 days
Perchlorate Water
USEPA Method 314-
ATK SOP 314
250 ml
nalgene Cool 4o C 28 days 28 days
Metals: As, Ba, Be, Co, Cr, Mo Water
USEPA
Method 6010B-ATK SOP 364 USEPA
Method
7471A-ATK SOP 373
500 ml nalgene
Cool 4o C HNO3 to pH<2
28 days (Hg); 6 months
(other)
40 days
RDX Water
HMX Water
Nitrate Water
______________________________________________________________________________ Attachment 3 SAP 20 ATK Launch Systems Inc. - Promontory July 2, 2018 Post Closure Permit

Table 2 – Groundwater Monitoring Wells Completed in
Unconsolidated Material

Well Total Depth Well Total Depth Well Total Depth
A-7 242.00 G-1 97.70 LF-2 154.75
B-5 178.20 G-2 98.60 LF-3 153.80
B-6 127.00 G-3 26.00 M-508-1 203.00
B-7 97.00 G-4 76.35 M-508-2 199.40 B-8 112.95 H-1 47.00 M-508-3 202.29
C-7 108.30 H-2 58.30 M-508-4 200.68
E-1 126.25 H-3 81.30 M-508-B1 182.00 E-2 120.00 H-5 48.30 P-1 257.00
E-4 132.90 H-6 53.58 P-2 178.48
E-5 122.00 H-8 143.70 P-5 127.00
E-8 228.00 H-9 12.85 P-6 93.25 E-9 234.00 H-10 30.0 P-7 90.58
F-1 107.00 J-1 145.00 P-8 179.20
F-2A 151.75 J-3 147.70 P-9 193.00 F-2B 217.20 J-7 146.25 P-10 105.00
F-2C 319.15 J-8 166.35
F-3 108.00 LF-1 136.95

ATK Launch Systems Inc. - Promontory
Post Closure Permit TABLE 4-A
Groundwater Monitoring System
July 2, 2018
UTD009081357
Table 4-A, Attachment 4.xls
MONITORING WELL/WELL COLLAR SCREENED INTERVAL (FT. MSL)PIEZOMETER ELEVATION (FT. MSL)TOP BOTTOM
A1 4625.03 4292.50 4272.50
A2 4730.49 4552.90 4532.90
A3 4702.71 4558.20 4538.20
A4 4643.22 4282.70 4262.70
A5 4618.54 4289.00 4269.00
A6 4482.05 4277.50 4257.50
A7 4471.15 4246.60 4226.60
A8 4486.60 4290.10 4270.10
A9 4509.80 4291.30 4271.30
A101 4772.43 4544.90 4524.90
B1 4596.22 4288.70 4268.70
B2A 4499.31 4284.80 4274.80
B2B "4270.80 4260.80
B2C "4246.80 4236.80
B3 4610.75 4290.20 4270.20
B4 4507.29 4287.80 4267.80
B5 4429.09 4270.60 4250.60
B6 4367.02 4259.50 4239.50
B7 4340.16 4257.60 4237.60
B8 4363.72 4271.20 4251.20
B9 4697.79 4552.30 4542.30
B10 4649.06 4526.10 4516.10
C1 4523.73 4280.00 4260.00
C2 4584.56 4270.30 4250.30
C3 4621.62 4268.10 4248.10
C4 4714.68 4312.70 4292.70
C5 4448.47 4296.90 4276.90
C61 4527.02 4273.50 4253.50
C7 4379.73 4291.80 4271.80
C81 4414.12 4300.60 4280.60
D12 4696.93 4554.40 4534.40
D22 4605.08 4277.60 4257.60
D32 4553.87 4276.40 4256.40
D42 4522.35 4259.80 4239.80
D52 4524.26 4246.70 4226.70
D62 4564.16 4271.70 4251.70
D72 4367.11
E1 4381.06 4272.80 4252.80
E2 4372.32 4269.60 4249.60
E3 4375.68 4269.30 4249.30
E4 4360.16 4247.60 4227.60
E5 4344.55 4242.90 4222.90
E6 4332.01 4262.30 4242.30
E7 4367.11 4146.80 4136.80
E8 4462.06 4253.00 4233.00
E9 4495.38 4283.20 4263.20
E10 4761.21 4285.10 4265.10
ATK Launch Systems Inc. - Promontory
Post Closure Permit TABLE 4-A
Groundwater Monitoring System
July 2, 2018
UTD009081357
Table 4-A, Attachment 4.xls
MONITORING WELL/WELL COLLAR SCREENED INTERVAL (FT. MSL)PIEZOMETER ELEVATION (FT. MSL)TOP BOTTOM
F1 4378.19 4292.00 4272.00
F2A 4382.35 4239.80 4229.80
F2B "4175.70 4165.70
F2C "4070.30 4060.30
F3 4362.79 4274.70 4254.70
F4 4437.14 4271.70 4251.70
F5 4367.23 4067.10 4047.10
G1 4352.31 4265.81 4255.81
G2 4324.63 4235.63 4225.63
G3 4275.89 4258.89 4248.89
G4 4330.94 4262.14 4252.14
G5 4391.22 4259.22 4249.22
G6 4325.83 4258.83 4248.83
G7 4386.35 4246.35 4236.35
G8 4477.81 4236.81 4226.81
H1 4294.74 4257.74 4246.74
H2 4306.83 4261.83 4251.83
H3 4327.98 4252.98 4242.98
H4 4354.66 4262.66 4252.66
H5 4300.15 4262.15 4252.15
H6 4308.68 4268.68 4258.68
H7 4380.62 4260.62 4250.62
H8 4386.17 4246.17 4236.17
H9 4259.27 4244.27 4234.27
H10 4246.27 4226.27 4216.27
J1 4455.00 4316.00 4306.00
J2 4658.58 4303.58 4293.58
J3 4590.71 4451.71 4441.71
J4 4560.17 4251.17 4241.17
J5 4308.65 4240.65 4230.65
J6 4321.70 4232.70 4222.70
J7 4448.96 4313.96 4303.96
J8 4451.53 4296.53 4286.53
J9 4819.73 4249.73 4239.73
LF1 4421.71 4303.11 4283.11
LF2 4434.77 4303.27 4283.27
LF3 4419.92 4296.72 4276.72
LF4 4453.07 4303.07 4283.07
M508-1 4506.68 4326.68 4306.68
M508-2 4514.41 4334.41 4314.41
M508-3 4506.37 4326.37 4306.37
M508-4 4511.99 4331.99 4311.99
M508-B1 4512.08 approx. 4340 approx. 4320
M39-B1 4631.88 approx. 4412 approx. 4392
M114-B1 4560.14 approx. 4395 approx. 4375
M636-B1 4656.91 approx. 4572 approx. 4552
P1 4549.32 4319.32 4289.32P24539.21 4389.71 4359.71
ATK Launch Systems Inc. - Promontory
Post Closure Permit TABLE 4-A
Groundwater Monitoring System
July 2, 2018
UTD009081357
Table 4-A, Attachment 4.xls
MONITORING WELL/WELL COLLAR SCREENED INTERVAL (FT. MSL)
PIEZOMETER ELEVATION (FT. MSL)TOP BOTTOM
P3 4498.30
P5 4498.17 4390.23 4370.23
P6 4540.93 4470.20 4450.20
P7 4529.52 4461.46 4441.46
P8 4517.80 4363.16 4338.16
P9 4530.70 4365.43 4335.43
P-10 4538.40 4453.40 4433.40
T12 4365.83 4263.83 4243.83
T22 4591.62 4282.62 4262.62
X4 4861.35 4253.80 4233.80
X5 4491.31 4231.31 4211.31
BC13 4235.43 4180.40 4170.40
BC23 4298.37 4263.40 4253.40
BC33 4287.33 4262.30 4252.30
BC43 4271.86 4204.80 4194.80
BC53 4253.96 4223.90 4213.90
BC63 4271.94 4242.90 4232.90
Shotgun Spring approx. elevation 4260 ft. n.a.n.a.
Pipe Spring approx. elevation 4260 ft.n.a.n.a.
Fish Spring approx. elevation 4250 ft.n.a.n.a.
Horse Spring A approx. elevation 4250 ft.n.a.n.a.
Horse Spring B approx. elevation 4260 ft.n.a.n.a.
Fork Spring approx. elevation 4250 ft.n.a.n.a.
Horse Pasture Spring approx. elevation 4250 ft.n.a.n.a.
Connor Spring approx. elevation 4250 ft.n.a.n.a.
1 background wells
2 not constructed in accordance with the EPA Technical Enforcement Guidance Document
3 piezometer
ATK Launch Systems Inc. – Promontory July 2, 2018
Post Closure Permit UTD009081357
1

Monitoring Well Completion Report Requirements

Introduction The Monitoring Well Completion Report requirements that are addressed in this attachment are based on the EPA RCRA Groundwater Monitoring Technical Enforcement Guidance
Document (OSWER-9950.1, November 1992), and subsequent addenda. The Monitoring
Well Completion Reports shall, at a minimum, consist of the four following components: 1. A boring log that documents well drilling and associated sampling;
2. A well construction log and well construction diagram (“as built”);
3. Well survey information for locations and elevations of the newly completed wells, with a map showing the well locations, and
4. A summary that discusses how the groundwater flow model shall be updated
based on the data obtained from the installation of the new wells. The detailed information that shall be included for each of the four components is outlined below.

Additional Information In addition to the four main components, the Well Completion Reports shall include a description of the purpose of the new wells (e.g. definition of the extent of groundwater
contamination plumes) and a discussion on deviations from the Monitoring Well Installation
Plan. In addition, Monitoring Well Completion Reports shall include sections on geology and hydrogeology. Well Completion Reports submitted by Thiokol in the past have included
cross-sections, fence diagrams, and summary discussions on the geology and hydrogeology
of the new wells. If pump or slug tests are conducted, the test data should be submitted with calculations for transmissivity, hydraulic conductivity and groundwater flow rates. Boring Logs and Field Records

Drilling logs and field records should be prepared detailing the following information: · The lithology or pedology (i.e., geologic or soil classification) of each geologic and soil unit in the unsaturated and saturated zones, including the confining
layer. The classification system used for lithologic and pedologic descriptions
should be a system described in the literature, and should be summarized or referenced in the permit application. For example, soils may be described
ATK Launch Systems Inc. – Promontory July 2, 2018
Post Closure Permit UTD009081357
2
using the Unified Soil Classification System, and rock may be described using
the classification schemes of Dunham (1962) for carbonates, Pettijohn et al. (1972) for sandstones, Potter et al. (1980) for shales, and the common textural and compositional classification schemes for igneous and metamorphic rock (e.g., rhyolite, granite, basalt, schist, slate, marble, gneiss, etc.). Examples of
these classifications schemes are presented in Appendix 2;
· Descriptions of the structural features encountered. As applicable, this should include a description of planar features (e.g., bedding planes, graded bedding), lineations, and other features related to vegetation, and discontinuities. The
orientation of these features should be measured and described when possible;
· Moisture content (saturated, moist, dry), degree of weathering, color (referenced to standardized colors when possible (e.g., Munsell color for moist soil and unconsolidated materials)), and stain (e.g., presence of mottles, Fe203),
as applicable;
· If a field monitoring device (e.g., FID, PID) is used, the data from these measurements, including sampling method, background and sample concentrations, probe type, span setting, and calibration gas type and concentration, should be provided to EPA as part of the boring log or field
record; · Depth to the water table; · Depth to water-bearing unit(s) and vertical extent of each water-bearing unit;
· Depth of borehole and reason for termination of borehole; · Depth, location, and identification of any evidence of contamination (e.g., odor, staining) encountered in borehole;
· Observations made during drilling (e.g., advance rate, water loss); and · Observations made during soil, unconsolidated material, or rock sampling (e.g., blow counts, sample recovery).
The subsurface boring log should contain at least the information identified with an "X" in the Table below (Aller et al., 1989 provide an example format for a field boring log).
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Well Construction Log and Diagram
In accordance with Condition VI.B.5, all documents pertaining to the design, construction, and development of RCRA monitoring wells shall be kept by the Permittee in the facility operating record and submitted as part of the operating permit. The well
construction log and well construction diagram should present the following information
(including dimensions, as appropriate): · Well name/number; · Date/time of well construction;
· Borehole diameter and well casing diameter;
· Well depth (±0.1 ft); · Casing length; · Casing materials; · Casing and screen joint type;
· Screened interval(s);
· Screen materials; · Screen slot size/design; · Filter pack material and size; · Filter pack volume (calculated and actual);
· Filter pack placement method;
· Annular sealant composition; · Annular seal placement method; · Annular sealant volume (calculated and actual); · Surface sealant composition;
· Surface seal placement method;
· Surface sealant volume (calculated and actual); · Surface seal and well apron design/construction; · Well development procedure and ground-water turbidity measured at the completion of well development;
· Type and design/construction of protective casing;
· Well cap and lock; The owner/operator should document that the following well completion activities were performed appropriately:

· Selection of construction materials for the casing and screen; · Selection of the well diameter, screen length, and screen slot size; · Selection and emplacement of the appropriate filter pack; · Selection and emplacement of the annular sealants;
· Providing proper security of the well; and
· Adequately developing the well.

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Monitoring Well Survey Information and Map
· Ground surface elevation (±0.01 ft); · Survey reference point elevation (±0.01 ft) on well casing; · Top of monitoring well casing elevation (±0.01 ft);
· Top of protective steel casing elevation (±0.01 ft); and
· Surveyed well locations; and · Map showing new monitoring well locations. Groundwater Flow Model Update Summary

A summary shall be included that discusses how the groundwater flow model shall be updated based on the data obtained from the installation of the new wells. Examples of the type of information that may be discussed include: presence of contamination (if data is available when report is prepared); geology and hydrology (if not discussed in other sections
of the report); potentiometric surface; implications regarding the groundwater flow and
transport model; receptors or threats to human health and the environment; etc.
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TABLE 6-A
ATK Launch Systems - Promontory SWMU Groups

Group Description # in Group Notes
A Permitted hazardous waste storage 6
B Open burning units 36
C Photographic waste discharge sites 10
D 90-day hazardous waste docks 113 Most are NFA Closed
E Satellite accumulation areas 46 Most are NFA Closed
F Sumps 105
G Landfills, disposal areas 31
H Spill sites 11
I Hazardous material tanks 18
J Historic hazardous waste storage 2
K Building discharge to surface 129
L Building discharge to subsurface 45
M Wastewater impoundments 12
N Dust and grit blast collectors 24
O Underground storage tanks 3
P Mine tailings 2
Q Hazardous material storage 5
R Paint Booth Overspray Collection 1
S Wet Scrubber 1
T Fluorescein dye test area 1
U Dispersion areas 2
V Magnesium grinding area 1
W Activated sludge treatment plant 1

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SWMU Group Building SWMU Description Status
1 A M-186A PERMITTED DRUM STORAGE AREA Active Site
2 A E-501 PERMITTED DRUM STORAGE AREA Active Site
021 A T-029 HYDRAZINE TREATMENT FACILITY NFA Closed
203 A M-203 OLD DRUM STORAGE AREA RFI 2000 Report
295 A T-029B HYDRAZINE DILUTION AREA Active Site
635 A M-705 HAZ WASTE CONSOLIDATION ROOM Active Site
003 B M-136 HIGH ENERGY OPEN BURNING TRENCHES Nos. 16, 17, 18 AND 19 Investigated
004 B M-136 HIGH ENERGY OPEN BURNING TRENCHES Nos. 14 AND 15 Investigated
005 B M-136 COMPOSITE OPEN BURNING TRENCHES Nos. 4, 5, 6, AND 7 Investigated
006 B M-136 ILLUMINANT OPEN BURNING TRENCHES Nos. 3 AND 13 Investigated
007 B M-136 WASTE SOLVENT PIT #12 Closed with monitoring
008 B M-136 SOLVENT PIT #11 Closed with monitoring
009 B M-136 NITRATE PIT #20 Closed with monitoring
010 B M-136 AP PIT #21 Closed with monitoring
011 B M-136 HMX TRUCK WASH OUT PIT #22 Closed with monitoring
012 B M-136 HMX POND #25 Closed with monitoring
013 B M-136 HMX POND #24 Closed with monitoring
014 B M-136 HMX POND #23 Closed with monitoring
015 B M-136 WEST SODIUM AZIDE PIT #26E Closed with monitoring
016 B M-136 LOWER SODIUM AZIDE PIT Closed with monitoring
017 B M-136 PROPELLANT WASTE WATER PIT #27N Closed with monitoring
018 B M-136 PROPELLANT WASTE WATER PIT #27S Closed with monitoring
019 B M-225 OPEN BURN AREA Old sites NFA closed
022 B M-224 EARTHEN SHOT POND NFA Closed
195 B M-174 OLD OPEN BURNING AREA RFI 2000 Report
201 B T-035 BERYLLIUM TEST AREA RFI 2000 Report
202 B M-243 OLD OPEN BURNING AREA RFI 2000 Report
207 B M-136 OLD HMX WASTE WATER PIT Investigated
233 B M-067 OLD BURNING GROUNDS TO THE SOUTH RFI 2000 Report
243 B M-136 OLD OPEN BURNING AREA RFI 2000 Report
292 B M-136 METAL POWDER PITS 1 & 2 Investigated
293 B M-136 HIGH ENERGY BURN PITS 8, 9, 10 & 11 Investigated
294 B I-010 BURNING CAGE & FLARE BURNING AREA NFA Closed
504 B M-136 SLUDGE BURNING PAN (A)NFA Closed
505 B M-136 SLUDGE BURNING PAN (D)NFA Closed
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506 B M-136 SLUDGE BURNING PAN (B)NFA Closed
507 B M-136 SLUDGE BURNING PAN (C)NFA Closed
546 B M-136 SLUDGE BURNING PAN (E)NFA Closed
548 B T-103 OLD BURNING GROUNDS FOR MINUTEMAN RFI 2000 Report
556 B M-136 OLD LTTA LOCATION
653 B I-10 Moton Ignitor Burn Tray Area Voluntary Clean-up
668 B M-225 DETONATION PIT RFI 2000 Report
020 C M-508 OLD PHOTOGRAPHIC WASTE DISCHARGE AREA Closed with monitoring
023 C M-114 OLD PHOTOGRAPHIC WASTE DISCHARGE AREA Closed with monitoring
024 C M-636 OLD PHOTOGRAPHIC WASTE DISCHARGE AREA Closed with monitoring
191 C A-002 OLD PHOTOGRAPHIC WASTE DRAINFIELD RFI 2000 Report
290 C M-039 OLD PHOTOGRAPHIC DISCHARGE AREA NFA Closed
367 C M-636SW ACTIVE PHOTOGRAPHIC BUILDING DISCHARGE Closed with Deed Note
423 C M-508 INACTIVE PHOTOGRAPHIC DISCHARGE AREA Closed with monitoring
553 C M-019A OLD PHOTOGRAPHIC PROCESSING DISCHARGE AREA RFI 2000 Report
560 C A-002 PHOTO DEVELOPER AND RINSE DISCHARGE RFI 2000 Report
648 C T-001 SEPTIC SYSTEM RECEIVING PHOTOGRAPHIC SOLUTION RFI 2000 Report
025 D M-056 OLD WASTE DOCK LOCATION NFA Closed
026 D M-009B OLD WASTE DOCK LOCATION NFA Closed
027 D M-519 WASTE PROPELLANT DOCK NFA Closed
028 D M-523 WASTE PROPELLANT DOCK NFA Closed
029 D M-585 WASTE PROPELLANT DOCK NFA Closed
030 D M-596/M-597 WASTE PROPELLANT DOCK NFA Closed
031 D M-208 WASTE PROPELLANT DOCK NFA Closed
032 D M-504 WASTE PROPELLANT DOCK NFA Closed
033 D M-621 WASTE PROPELLANT DOCK NFA Closed
34 D M-075 WASTE PROPELLANT DOCK RFI 2016
035 D M-013 WASTE PROPELLANT DOCK NFA Closed
036 D M-606 WASTE PROPELLANT DOCK NFA Closed
037 D M-218 OLD WASTE DOCK LOCATION NFA Closed
038 D M-125/M-126 WASTE PROPELLANT DOCK NFA Closed
039 D M-012 OLD WASTE DOCK LOCATION NFA Closed
040 D M-629 WASTE PROPELLANT DOCK NFA Closed
041 D M-120 WASTE PROPELLANT DOCK NFA Closed
042 D I-010 WASTE PROPELLANT DOCK NFA Closed
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043 D M-034 WASTE PROPELLANT DOCK NFA Closed
044 D M-628 WASTE PROPELLANT DOCK NFA Closed
046 D M-020 OLD WASTE DOCK LOCATION NFA Closed
047 D M-043 WASTE PROPELLANT DOCK NFA Closed
048 D M-016 WASTE PROPELLANT DOCK NFA Closed
049 D M-027 WASTE PROPELLANT DOCK NFA Closed
050 D M-026 WASTE PROPELLANT DOCK NFA Closed
051 D M-032 WASTE PROPELLANT DOCK NFA Closed
052 D M-053 OLD WASTE PROPELLANT DOCK NFA Closed
053 D M-605 WASTE PROPELLANT DOCK NFA Closed
054 D M-622 WASTE PROPELLANT DOCK NFA Closed
055 D M-623 INACTIVE WASTE DOCK LOCATION NFA Closed
057 D M-580 WASTE PROPELLANT DOCK NFA Closed
058 D M-524 WASTE PROPELLANT DOCK NFA Closed
059 D M-512 WASTE PROPELLANT DOCK NFA Closed
060 D M-693 WASTE PROPELLANT DOCK NFA Closed
061 D M-694 WASTE PROPELLANT DOCK NFA Closed
062 D M-191 WASTE PROPELLANT DOCK NFA Closed
063 D M-689 WASTE PROPELLANT DOCK NFA Closed
064 D M-309 WASTE PROPELLANT DOCK NFA Closed
065 D M-019A WASTE PROPELLANT DOCK NFA Closed
066 D M-076/M-163 WASTE PROPELLANT DOCK NFA Closed
067 D M-174 WASTE PROPELLANT DOCK NFA Closed
069 D M-594/M-595 WASTE PROPELLANT DOCK NFA Closed
070 D M-601 WASTE PROPELLANT DOCK NFA Closed
71 D M-602 WASTE PROPELLANT DOCK NFA Closed
72 D M-603 WASTE PROPELLANT DOCK NFA Closed
073 D M-604 WASTE PROPELLANT DOCK NFA Closed
074 D T-021 OLD WASTE PROPELLANT DOCK NFA Closed
076 D M-690 WASTE PROPELLANT DOCK NFA Closed
081 D M-623 INACTIVE HAZARDOUS WASTE DOCK NFA Closed
082 D M-590 90-DAY HAZARDOUS WASTE DOCK NFA Closed
083 D M-057A WASTE PROPELLANT DOCK NFA Closed
084 D M-516 OLD HAZARDOUS WASTE DOCK NFA Closed
085 D M-629 OLD HAZARDOUS WASTE DOCK NFA Closed
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086 D M-621 OLD HAZARDOUS WASTE DOCK NFA Closed
087 D M-622 OLD HAZARDOUS WASTE DOCK NFA Closed
088 D T-014 OLD HAZARDOUS WASTE DOCK LOCATION NFA Closed
090 D M-016 90-DAY HAZARDOUS WASTE DOCK (2 DOCKS)NFA Closed
091 D M-043 90-DAY HAZARDOUS WASTE DOCK NFA Closed
092 D M-179 90-DAY HAZARDOUS WASTE DOCK NFA Closed
093 D E-512 90-DAY HAZARDOUS WASTE DOCK NFA Closed
094 D M-301 OLD HAZARDOUS WASTE DOCK NFA Closed
095 D M-032 OLD HAZARDOUS WASTE DOCK NFA Closed
96 D M-111 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
098 D M-627 OLD HAZARDOUS WASTE DOCK NFA Closed
099 D M-628 90-DAY HAZARDOUS WASTE DOCK NFA Closed
100 D M-052 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
101 D M-053 90-DAY HAZARDOUS WASTE DOCK NFA Closed
102 D M-068 90-DAY HAZARDOUS WASTE DOCK NFA Closed
104 D M-508 90-DAY HAZARDOUS WASTE DOCK NFA Closed
105 D M-113 90-DAY HAZARDOUS WASTE DOCK NFA Closed
106 D E-517 90-DAY HAZARDOUS WASTE DOCK NFA Closed
108 D M-010 OLD HAZARDOUS WASTE DOCK NFA Closed
110 D M-585 EAST AND SOUTH 90-DAY HAZARDOUS WASTE DOCKS NFA Closed
300 D M-241 WASTE PROPELLANT DOCK NFA Closed
301 D M-209 WASTE PROPELLANT DOCK NFA Closed
302 D T-092 90-DAY HAZARDOUS WASTE DOCK NFA Closed
303 D T-001 OLD HAZARDOUS WASTE DOCK NFA Closed
304 D T-004C 90-DAY HAZARDOUS WASTE STORAGE DOCK NFA Closed
305 D T-004C WASTE PROPELLANT DOCK NFA Closed
306 D T-092 WASTE PROPELLANT DOCK NFA Closed
315 D M-689 90-DAY HAZARDOUS WASTE DOCK NFA Closed
318 D M-115 HAZARDOUS WASTE DOCK NFA Closed
329 D M-019A 90-DAY HAZARDOUS WASTE DOCK NFA Closed
330 D T-018 OLD HAZARDOUS WASTE DOCK NFA Closed
336 D M-024 OLD HAZARDOUS WASTE DOCK NFA Closed
339 D M-076 OLD HAZARDOUS WASTE DOCK NFA Closed
350 D M-079 WASTE PROPELLANT DOCK NFA Closed
482 D M-197 WASTE PROPELLANT DOCK NFA Closed
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490 D M-320A WASTE PROPELLANT DOCK NFA Closed
512 D M-193 WASTE PROPELLANT DOCK NFA Closed
514 D M-321 90-DAY HAZARDOUS WASTE DOCK NFA Closed
531 D M-705 GONDOLA 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
561 D M-303 90-DAY HAZARDOUS WASTE DOCK NFA Closed
563 D M-079 90-DAY HAZARDOUS WASTE DOCK NFA Closed
564 D M-120 90-DAY HAZARDOUS WASTE DOCK NFA Closed
565 D M-027 90-DAY HAZARDOUS WASTE DOCK NFA Closed
566 D M-512 90-DAY HAZARDOUS WASTE DOCK NFA Closed
567 D M-573 90-DAY HAZARDOUS WASTE DOCK NFA Closed
568 D S-633 90-DAY HAZARDOUS WASTE DOCK NFA Closed
569 D M-224 WASTE PROPELLANT DOCK NFA Closed
570 D M-590 WASTE PROPELLANT DOCK NFA Closed
571 D M-638 WASTE PROPELLANT DOCK NFA Closed
576 D M-137A 90-DAY HAZARDOUS WASTE DOCK NFA Closed
579 D A-002 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
580 D E-516 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
581 D M-191 90-HAZARDOUS WASTE STORAGE NFA Closed
582 D M-193 90-HAZARDOUS WASTE STORAGE NFA Closed
583 D M-325 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
584 D M-593 90-DAY HAZARDOUS WASTE STORAGE NFA Closed
585 D M-303 WASTE PROPELLANT DOCK NFA Closed
586 D M-354 WASTE PROPELLANT DOCK RFI 2016
588 D M-705 WASTE PROPELLANT DOCK NFA Closed
641 D M-528 WASTE PROPELLANT DOCK NFA Closed
089 E M-209 SATELLITE ACCUMULATION AREA NFA Closed
97 E M-605 SATELLITE ACCUMULATION AREA NFA Closed
103 E M-504 SATELLITE ACCUMULATION AREA NFA Closed
107 E M-066 SATELLITE ACCUMULATION AREA NFA Closed
109 E M-002 SATELLITE ACCUMULATION AREA NFA Closed
309 E A-002 PALLETAINER SATELLITE ACCUMULATION AREA NFA Closed
337 E T-097 SATELLITE ACCUMULATION NFA Closed
338 E M-104 SATELLITE ACCUMULATION AREA NFA Closed
340 E M-067 SATELLITE ACCUMULATION (8)NFA Closed
341 E M-072 SATELLITE ACCUMULATION AREA NFA Closed
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342 E T-O93 SATELLITE ACCUMULATION SITE NFA Closed
349 E M-605 SATELLITE ACCUMULATION AREA NFA Closed
467 E M-005 SATELLITE ACCUMULATION NFA Closed
475 E M-113A SATELLITE ACCUMULATION NFA Closed
478 E M-120 SATELLITE ACCUMULATION AREA NFA Closed
484 E M-197 SATELLITE ACCUMULATION AREA NFA Closed
485 E M-303 SATELLITE ACCUMULATION NFA Closed
486 E M-304 SATELLITE ACCUMULATION NFA Closed
492 E T-004 SATELLITE ACCUMULATION AREA NFA Closed
495 E T-024 SATELLITE ACCUMULATION NFA Closed
521 E M-512 SATELLITE ACCUMULATION NFA Closed
523 E M-514 SATELLITE ACCUMULATION AREA NFA Closed
524 E M-572 SATELLITE ACCUMULATION NFA Closed
536 E M-016 SATELLITE ACCUMULATION RFI 2016
539 E M-115 SATELLITE ACCUMULATION AREA NFA Closed
550 E M-184 SATELLITE ACCUMULATION AREA (3)NFA Closed
572 E M-212 SATELLITE ACCUMULATION AREA NFA Closed
577 E T-017 SATELLITE ACCUMULATION AREA NFA Closed
578 E T-091 SATELLITE ACCUMULATION AREA NFA Closed
589 E E-516 SATELLITE ACCUMULATION AREA NFA Closed
590 E E-517 SATELLITE ACCUMULATION AREA NFA Closed
591 E E-529 SATELLITE ACCUMULATION AREA NFA Closed
592 E M-006 SATELLITE ACCUMULATION AREA NFA Closed
593 E M-019A SATELLITE ACCUMULATION AREA NFA Closed
594 E M-027 SATELLITE ACCUMULATION AREA RFI 2016
595 E M-043 SATELLITE ACCUMULATION AREA RFI 2016
596 E M-055 SATELLITE ACCUMULATION AREA NFA Closed
597 E M-057A SATELLITE ACCUMULATION AREA NFA Closed
598 E M-071 SATELLITE ACCUMULATION AREA NFA Closed
599 E M-102 SATELLITE ACCUMULATION AREA NFA Closed
600 E M-111 SATELLITE ACCUMULATION AREA NFA Closed
601 E M-174 SATELLITE ACCUMULATION AREA NFA Closed
602 E M-208 SATELLITE ACCUMULATION AREA NFA Closed
603 E T-029B SATELLITE ACCUMULATION AREA NFA Closed
604 E M-241 SATELLITE ACCUMULATION AREA NFA Closed
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605 E T-096 SATELLITE ACCUMULATION AREA NFA Closed
111 F M-009B SUMP
112 F M-013 SOUTH SUMP
113 F M-013 WEST SUMP
114 F M-013 OLD EAST SUMP LOCATION RFI 2000 Report
115 F M-016 OLD SUMP LOCATION RFI 2000 Report
116 F M-020 SUMP
117 F M-022 SUMP
118 F M-023 OLD SUMP LOCATION RFI 2000 Report
119 F M-024 SUMP
120 F M-027 SUMP
121 F M-042 SUMP RFI 2000 Report
122 F M-043 NON-HAZARDOUS WASTE SUMP
123 F M-056 SUMP
124 F M-057 SPILL CONTAINMENT SUMP RFI 2000 Report
128 F M-115 RECIRCULATION SUMP
129 F M-120 SUMP
130 F M-174 SOUTH SUMP
131 F M-605 NORTH SUMP
132 F M-605 SOUTH SUMP
133 F M-605 WEST SUMP
134 F M-605 EAST SUMP
135 F M-504 NORTH SUMP
136 F M-504 SOUTH 2 SUMPS
137 F M-519 SUMP
138 F M-522 INACTIVE SUMP RFI 2000 Report
139 F M-085 DEACTIVATED SUMP RFI 2000 Report
140 F M-590 NORTH SUMP
141 F M-590 SOUTH SUMP
142 F M-520 INACTIVE SUMP RFI 2000 Report
143 F M-521 SUMP
144 F M-523 SUMP
145 F M-201 SUMP
146 F M-208 EMERGENCY CONTAINMENT SUMP RFI 2000 Report
147 F M-209 SUMP
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148 F M-210 SUMP
149 F M-212 OLD NORTH SUMP LOCATION RFI 2000 Report
150 F M-212 OLD SOUTH SUMP LOCATION RFI 2000 Report
151 F M-214 SUMP
152 F M-218 SUMP
153 F M-528 SUMP
154 F M-588 EMERGENCY CONTAINMENT SUMP RFI 2000 Report
155 F M-034 SUMP
156 F M-693 SUMP
157 F M-694 SUMP
160 F M-125 NORTH SUMP
161 F M-125 SOUTH SUMP
162 F M-126 OLD NORTH SUMP LOCATION RFI 2000 Report
163 F M-126 OLD MIDDLE SUMP LOCATION RFI 2000 Report
164 F M-126 SOUTH SUMP
165 F M-087 EMERGENCY CONTAINMENT SUMP RFI 2000 Report
166 F M-526 SUMP
167 F M-571 NORTH SUMP
168 F M-571 SOUTH SUMP
169 F M-572 SUMP
170 F M-573 WEST SUMP
171 F M-081 SUMP
172 F M-606 NORTH SUMP
173 F M-606 SOUTH SUMP
174 F M-145 SUMP
175 F M-055 GARAGE BAY PIT AND SUMP
176 F M-309 SUMP
177 F E-502 OLD SUMP LOCATION RFI 2000 Report
178 F M-570 SUMP
179 F M-524 SUMP
180 F M-207 SUMP
181 F M-025 SUMP
182 F T-091 NON-HAZARDOUS WASTE SUMP
183 F M-508 SUMP
184 F M-590 EAST SUMP
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186 F M-687 OLD SUMP LOCATION RFI 2000 Report
187 F E-512 SUMP
188 F M-629 SUMP
189 F E-517 NON-HAZARDOUS WASTE SUMP
190 F M-174 WEST SUMP
196 F M-034 OLD PERCHLORIC ACID SUMP LOCATION RFI 2000 Report
310 F M-323 SUMP
311 F M-157 OLD SUMP LOCATION RFI 2000 Report
312 F M-305 OLD GARAGE SUMP LOCATION
313 F S-608 SUMP
314 F M-571 SOUTH SUMP
316 F M-622 2 INACTIVE SUMPS RFI 2000 Report
317 F M-638 SUMP
323 F M-115 INACTIVE SUMP
324 F M-115 SUMP
327 F M-115 TACTICAL WASHOUT SUMP
328 F M-115 TACTICAL WASHOUT SUMP
333 F M-573 EAST SUMP
346 F M-087 SOUTH SUMP (EMERGENCY CONTAINMENT)
351 F T-112 SUMP
454 F M-043 EAST SUMP
456 F M-056 PRODUCT SOLVENT CONTAINMENT SUMP
457 F M-083 OLD SUMP LOCATION RFI 2000 Report
465 F M-002-1 LAUNDRY SUMP AND DRAINFIELD RFI 2000 Report
473 F M-052 DEGREASER SUMP
487 F M-320 WEST SUMP
488 F M-320 EAST SUMP
489 F M-320 NORTH SUMP
497 F T-053 SUMP RFI 2000 Report
535 F M-013 OLD SUMP LOCATION
540 F T-021 OLD SUMP LOCATION RFI 2000 Report
541 F M-179 DEGREASER SUMP
552 F M-174 EAST SUMP
573 F M-701 SUMP
574 F M-702 EAST SUMP
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575 F M-702 WEST SUMP
193 G M-174 OLD HYDROGEN FLUORIDE PIT
194 G M-147 OLD MINUTEMAN CANISTERS AND DEBRIS RFI 2000 Report
200 G T-035 BERYLLIUM CONTAMINATED WASTES DISPOSAL AREA RFI 2000 Report
204 G M-227 CS DISPOSAL SITE
208 G M-136 OLD WASTE OIL PIT RFI 2000 Report
209 G M-136 LANDFILL
212 G M-186 OLD INDUSTRIAL WASTE LANDFILL RFI 2000 Report
213 G M-136 ASBESTOS WASTE TRENCH
214 G M-136 INDUSTRIAL WASTE TRENCH
215 G M-136 INDUSTRIAL WASTE TRENCH
216 G M-136 INDUSTRIAL WASTE TRENCH
217 G M-136 INDUSTRIAL WASTE TRENCHES A, B, & C
218 G M-136 INDUSTRIAL WASTE TRENCH
219 G M-136 INDUSTRIAL WASTE TRENCH
220 G M-136 INDUSTRIAL WASTE TRENCH
221 G M-136 WASTE TRENCH
222 G M-136 WASTE DISPOSAL PIT
223 G M-136 WASTE TRENCHES
224 G M-336 SANITARY LANDFILL RFI 2000 Report
296 G M-046 POINT OF THE MOUNTAIN LANDFILL SITE RFI 2000 Report
334 G M-136 INDUSTRIAL WASTE TRENCH
335 G M-136 INDUSTRIAL WASTE TRENCHES A, B, & C
462 G M-225 LANDFILL SITE TO THE EAST
481 G M-174 BUILDING DEBRIS DISPOSAL
534 G X-9 SHREDDED PAPER DISPOSAL AREA
547 G M-311 EXCESS ROAD OIL DISPOSAL AREA RFI 2000 Report
549 G I-019 OLD TEST AREA LANDFILL
554 G M-136 OLD INDURSTRIAL WASTE TRENCHES
555 G M-186 OLD INDUSTRIAL LANDFILL TO THE EAST RFI 2000 Report
637 G PLT-3 HOLMGREN LANDFILL Voluntray Cleanup
654 G S OF M-636 Construction Debris Disposal
236 H M-034 PERCHLORIC ACID SPILL SITE
237 H M-080 PCB SPILL SITE
238 H M-052 METHYLCHLOROFORM SPILL SITE
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
469 H M-014 FUEL OIL SPILL
530 H M-705 TANK RUPTURE AREA Voluntray Cleanup
647 H M-136 PYRIDINE CONTAMINATED SOILS NOV Cleanup
675 H M-576 BOILER SPILL CONTAINING PERCHLORATE Investigated
677 H M-721 RELEASE Investigated
680 H M-115 PERCHLORATE WASHOUT LINE LEAK UNDER BLDG. M-115 Assessment
681 H M-705 Perchlorate trench release under building Assessment
682 H M-115 Perchlorate release from building to south hillside Assessment
683 H M-590 M-590 NaOH release under building Nov 2015, no clean-up standard Assessment
239 I M-636 PHOTOGRAPHIC WASTE TANK
240 I M-039 SPENT FIXER TANK
241 I M-114 FIXER AND DEVELOPER TANKS
242 I M-508 PHOTOGRAPHIC WASTE RECOVERY TANKS
307 I M-009 FIXER TANK AND CONTAINMENT SUMP
308 I A-001 PHOTOGRAPHIC WASTE TANK
347 I A-002 PHOTOGRAPHIC WASTE TANK (UPPER)
348 I M-197 FIXER AND DEVELOPER TANKS
450 I A-002 FIXER ACCUMULATION TANKS
461 I M-224 STAINLESS STEEL TANK
496 I T-024 INACTIVE PROPELLANT WASHOUT TANKS
500 I E-516 MOBILE WASTE OIL TANK
510 I M-186 PHOTOGRAPHIC FIXER TANK AND WASTE OIL TANKS
511 I M-191 M0BILE CONTAINER
513 I M-193 MOBILE CONTAINER
515 I M-392 VESSELS (4)RFI 2000 Report
522 I M-512 VACUUM COLLECTION DRUMS
656 I M-305 Transporter Maintenance Floor Wash Collection
291 J M-136 DRUM STORAGE NFA Closed
551 J M-187 OLD DRUM STORAGE AREA RFI 2000 Report
230 K E-516 NORTH DRAINAGE DITCH NFA Closed
235 K E-516 BUILDING DISCHARGE TO E-534; HISTORICALLY TO NDD NFA Closed
250 K M-085 SURFACE DISCHARGE (NOT FOUND DURING RFA)
251 K M-086 AUTOCLAVE COOLING DISCHARGE
252 K M-087 SURFACE DISCHARGE (NOT FOUND DURING RFA)
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
253 K M-111 BUILDING DISCHARGE
255 K M-179N SURFACE BUILDING DISCHARGE NFA Closed
256 K M-179SE COOLING WATER DISCHARGE NFA Closed
257 K M-014N SURFACE BUILDING DISCHARGE NFA Closed
258 K M-033B SURFACE BUILDING DISCHARGE NFA Closed
259 K M-053E SURFACE BUILDING DISCHARGE RFI 2000 Report
260 K M-053-BP SURFACE BUILDING DISCHARGE NFA Closed
261 K M-067 SURFACE BUILDING DISCHARGE NFA Closed
263 K M-072 SURFACE BUILDING DISCHARGE NFA Closed
264 K M-641 BUILDING DISCHARGE NFA Closed
265 K M-642 BUILDING DISCHARGE
266 K S-501 BOILER DISCHARGE NFA Closed
267 K A-009 BOILER DISCHARGE NFA Closed
268 K M-008 SURFACE BUILDING DISCHARGE NFA Closed
269 K M-010 SURFACE BUILDING DISCHARGE NFA Closed
270 K M-014S SURFACE BUILDING DISCHARGE NFA Closed
271 K M-576-N BUILDING DISCHARGE RFI 2000 Report
272 K M-576-S COOLING WATER DISCHARGE
273 K M-585 BUILDING DISCHARGE RFI 2000 Report
273 K M-585-N LABORATORY BUILDING SURFACE DISCHARGE RFI 2000 Report
274 K M-593 BUILDING DISCHARGE NFA Closed
275 K M-600 BUILDING DISCHARGE
276 K M-601 BUILDING DISCHARGE
277 K M-629 SURFACE DISCHARGE (NO FLOW FOUND IN RFA)
278 K M-639 BUILDING DISCHARGE
279 K E-502 FORMER BOILER DISCHARGE; HISTORICALLY TO NDD NFA Closed
280 K E-512 BUILDING DISCHARGE TO BLUE CREEK; HISTORICALLY TO NDD IRP Report
281 K E-516 BUILDING DISCHARGE TO E-534; HISTORICALLY TO NDD NFA Closed
282 K E-517-W BUILDING DISCHARGE TO THE NORTH DRAINAGE DITCH NFA Closed
283 K E-529 BUILDING DISCHARGE TO BLUE CREEK; HISTORICALLY TO NDD NFA Closed
284 K M-508 BUILDING DISCHARGE TO BLUE CREEK; HISTORICALLY TO NDD NFA Closed
285 K M-570 BUILDING DISCHARGE RFI 2000 Report
286 K M-205 SURFACE BUILDING DISCHARGE RFI 2000 Report
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
287 K T-006A SURFACE BUILDING DISCHARGE RFI 2000 Report
289 K T-021A BUILDING DISCHARGE
326 K E-515 ACID DRAIN NFA Closed
357 K E-519 BUILDING DISCHARGE TO BLUE CREEK; HISTORICALLY TO NDD NFA Closed
358 K M-113 BUILDING DISCHARGE
359 K M-113 BUILDING DISCHARGE
360 K M-197BP COOLING DISCHARGES RFI 2000 Report
363 K M-594 BUILDING DISCHARGE
364 K M-598 BUILDING DISCHARGE
365 K M-602 BUILDING DISCHARGE
366 K M-636SE BOILER AND COOLING DISCHARGE
370 K M-694 BOILER DISCHARGE
371 K M-689 COOLING DISCHARGE
373 K M-508 BUILDING DISCHARGE TO BLUE CREEK; HISTORICALLY TO NDD NFA Closed
374 K M-585 BUILDING DISCHARGE
375 K M-621 BUILDING DISCHARGE
376 K M-622 BUILDING DISCHARGE
377 K M-623 BUILDING DISCHARGE
381 K M-640 BOILER AND COOLING DISCHARGE RFI 2000 Report
384 K M-591 BUILDING DISCHARGE
385 K M-595 BUILDING DISCHARGE
386 K M-599 BUILDING DISCHARGE
387 K M-603 BUILDING DISCHARGE
388 K M-596 BUILDING DISCHARGE
390 K M-604 BUILDING DISCHARGE
392 K M-597 BUILDING DISCHARGE
394 K M-605 BOILER CONDENSATE DISCHARGE IN EMERGENCIES
398 K T-017A BUILDING DISCHARGE
399 K T-018A BUILDING DISCHARGE
400 K T-023 BUILDING DISCHARGE
405 K M-005 BOILER CONDENSATE (NO KNOWN DISCHARGE)
406 K M-006 BOILER CONDENSATE (NO KNOWN DISCHARGE)
408 K M-009 BUILDING DISCHARGE
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
409 K M-010 SURFACE BUILDING DISCHARGE NFA Closed
413 K M-033C SURFACE BUILDING DISCHARGE NFA Closed
417 K E-512 BUILDING DISCHARGE TO BLUE CREEK; HISTORICALLY TO NDD NFA Closed
419 K E-516 BUILDING DISCHARGE TO E-534; HISTORICALLY TO NDD NFA Closed
424 K M-011 BUILDING DISCHARGE
425 K M-039 ACTIVE X-RAY BLDG DISCHARGE TO INJ WELL THEN SURFACE Closed with monitoring
426 K M-114 X-RAY BUILDING DISCHARGE Closed with monitoring
429 K M-111 BUILDING DISCHARGE
431 K M-179SE COOLING WATER DISCHARGE
432 K M-066 SURFACE BUILDING DISCHARGE RFI 2000 Report
433 K M-067 SURFACE BUILDING DISCHARGE NFA Closed
435 K M-086 BUILDING DISCHARGE
443 K M-043 BOILER CONDENSATE (NOT FOUND DURING RFA)
451 K A-002 SURFACE WATER DISCHARGE RFI 2000 Report
459 K M-087 VACUUM PUMP DISCHARGE
470 K M-033 AIR COMPRESSOR DISCHARGE
472 K M-052 SURFACE BUILDING DISCHARGE NFA Closed
483 K M-197 X-RAY BUILDING DISCHARGE RFI 2000 Report
491 K T-004A BUILDING DISCHARGE
498 K M-521 DISCHARGE TO BLUE CREEK
503 K E-519 ACID DRAIN NFA Closed
516 K M-504 LOW PRESSURE STEAM LINE DISCHARGE
517 K M-504 HYDRAULIC PUMP COOLING DISCHARGE
520 K M-512 BOILER DISCHARGE
526 K M-590 BOILER DISCHARGE
527 K M-606 BUILDING DISCHARGE RFI 2000 Report
528 K M-628 BOILER DISCHARGE RFI 2000 Report
529 K M-638 BOILER DISCHARGE
532 K M-705 BOILER DISCHARGE
533 K T-091 BOILER DISCHARGE
557 K T-051A BUILDING DISCHARGE
559 K T-021D SURFACE BUILDING DISCHARGE RFI 2000 Report
606 K M-627 SURFACE DISCHARGE
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
610 K M-627 BOILER CONDENSATE DISCHARGE
611 K M-009 SURFACE BUILDING DISCHARGE NFA Closed
612 K M-010 BOILER DISCHARGE
613 K M-052W DEGREASER SUMP DISCHARGE
614 K M-056 BOILER CONDENSATE DISCHARGE
615 K M-057 SURFACE BUILDING DISCHARGE RFI 2000 Report
617 K E-522 FIRE STATION VEHICLE WASH DISCHARGE
618 K M-514 BAC COOLING DISCHARGE RFI 2000 Report
619 K M-627 BUILDING DISCHARGE
620 K M-702 BUILDING DISCHARGE RFI 2000 Report
621 K M-055W SURFACE BUILDING DISCHARGE RFI 2000 Report
622 K M-364 BUILDING DISCHARGE
623 K M-055E SURFACE DISCHARGE
642 K M-040 SURFACE BUILDING DISCHARGE NFA Closed
644 K I-005 SURFACE DISCHARGE
649 K M-585 STRAND BURNER EXHAUST DISCHARGE TO GROUND RFI 2000 Report
650 K M-019A SURFACE BUILDING DISCHARGE RFI 2000 Report
651 K M-009-NE STRAND BURNER EXHAUST DISCHARGE TO GROUND RFI 2000 Report
652 K M-009 MORTON IGNITOR BURN TRAY AREA RFI 2000 Report
657 K M-52 STORM DRAIN DISCHARGE AREA
659 K E-512 E-512 DRAINAGE DITCH IRP Report
660 K FAUST VALLEY DRAINAGE COURSE RFI 2000 Report
661 K BLUE CREEK NFA Closed
673 K M-120 SURFACE DISCHARGE RFI 2000 Report
674 K T-112 INTERIOR FLOOR DRAIN LEAK Investigated
227 L M-585 OLD FRENCH DRAIN SYSTEM IRP Report
228 L M-053-MH LAB SINK DISCHARGE RFI 2000 Report
234 L I-010-S SOUTH SINK DRYWELL RFI 2000 Report
254 L M-117 SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
353 L T-053A SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
354 L T-097A SUBSURFACE BUILDING DISCHARGE
355 L T-111 SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
395 L M-348 SUBSURFACE BOILER DISCHARGE RFI 2000 Report
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
397 L T-015A SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
401 L T-024A SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
402 L T-051A SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
436 L I-010-SE SOUTHEAST SINK DRYWELL RFI 2000 Report
444 L M-019A DRYWELL NFA Closed
446 L T-003 SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
493 L T-014A SUBSURFACE BUILDING DISCHARGE RFI 2000 Report
558 L T-051A OLD DRYWELL LOCATION
608 L M-338 FRENCH DRAIN FOR BOILER DISCHARGE RFI 2000 Report
609 L M-009NE ABANDONED DRYWELL (POSSIBLY REMOVED)RFI 2000 Report
624 L T-051A-S BUILDING DISCHARGE TO A DRYWELL
625 L M-153 SEPTIC DRAINFIELDS A, B, AND C RFI 2000 Report
626 L M-002-2 ABANDONED SEPTIC DRAINFIELD SYSTEM RFI 2000 Report
627 L M-002-3 SEPTIC DRAINFIELD SYSTEM RFI 2000 Report
628 L M-019A SEPTIC DRAINFIELD SYSTEM RFI 2000 Report
629 L M-057 SEPTIC DRAINFIELD
630 L M-072 SEPTIC DRAINFIELD RFI 2000 Report
631 L M-191-S SEPTIC DRAINFIELD RFI 2000 Report
632 L M-193-N SEPTIC DRAINFIELD RFI 2000 Report
633 L M-043 SEPTIC DRAINFIELD
636 L T-051A-2 DRYWELL
638 L M-193-S SEPTIC DRAINFIELD RFI 2000 Report
639 L M-585 SEPTIC SYSTEM
640 L M-009SW SOUTH WEST ABANDONED DRYWELL RFI 2000 Report
643 L M-009SE SOUTH EAST ABANDONED DRYWELL RFI 2000 Report
645 L I-010NE DRYWELL RFI 2000 Report
646 L M-071 SEPTIC SYSTEM RFI 2000 Report
662 L M-015A DRYWELL RFI 2000 Report
663 L M-015A SEPTIC DRAINFIELD RFI 2000 Report
664 L I-10 SEPTIC DRAINFIELD RFI 2000 Report
665 L M-53 SUBSURFACE DISCHARGE RFI 2000 Report
666 L M-056 DRYWELL RFI 2000 Report
667 L I-5 SEPTIC DRAINFIELD RFI 2000 Report
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
671 L M-58 DRYWELL RFI 2000 Report
676 L M-397 FLOOR DRAIN CONNECTED TO DRAIN PIPE RFI 2000 Report
678 L M-201 SEPTIC DRAIN SYSTEM
679 L M-205 SEPTIC DRAIN SYSTEM
192 M M-227 INACTIVE NEUTRALIZATION AND CONTAINMENT PONDS NFA Closed
210 M M-186 OIL SEPARATION POND (NORTH POND)NFA Closed
211 M M-186 NEUTRALIZATION POND (SOUTH POND)NFA Closed
231 M M-115 OLD INDUSTRIAL WASTEWATER POND Investigated
232 M M-115 OLD INDUSTRIAL WASTEWATER POND Investigated
320 M M-345 OLD NORTH DRAINAGE DITCH DRAIN PONDS (3)NFA Closed
321 M M-345 OLD NORTH DRAINAGE DITCH DRAIN PONDS (3)NFA Closed
322 M M-345 OLD NORTH DRAINAGE DITCH DRAIN PONDS (3)NFA Closed
345 M M-014 BOILER DISCHARGE COLLECTION POND NFA Closed
658 M E-534 SANITARY SEWAGE TREATMENT EVAPORATION POND RFI 2000 Report
669 M M-13 DRYING PONDS (2)RFI 2000 Report
670 M M-16 DRYING PONDS (2)RFI 2000 Report
452 N M-008 DUST AND GRIT BLAST COLLECTORS RFI 2016
453 N M-043 GRIT BLAST COLLECTORS RFI 2016
455 N M-053 DUST COLLECTORS RFI 2016
458 N M-086 DUST COLLECTOR RFI 2016
460 N M-210 DUST COLLECTOR RFI 2016
466 N M-005 DUST COLLECTORS RFI 2016
468 N M-006 DUST COLLECTORS RFI 2016
471 N M-052 GRIT BLAST COLLECTORS RFI 2016
474 N M-066 GRIT BLASTING AREA
476 N M-113 GRIT BLAST COLLECTION RFI 2016
477 N M-113 DUST COLLECTORS RFI 2016
480 N M-174 DUST COLLECTOR RFI 2016
499 N E-512 DUST AND GRIT BLAST COLLECTORS RFI 2016
501 N E-517 NORTH DUST COLLECTORS RFI 2016
502 N E-517 DUST COLLECTORS RFI 2016
508 N M-179 DUST COLLECTORS RFI 2016
509 N M-179 GRIT BLAST COLLECTOR RFI 2016
ATK Launch Systems Inc. - Promontory
Post Closure Permit
Attachment 6 July 2, 2018
UTD009081357
SWMU Group Building SWMU Description Status
518 N M-508 SOUTH DUST COLLECTORS RFI 2016
519 N M-508 DUST COLLECTORS ON EAST SIDE RFI 2016
525 N M-585 DUST COLLECTORS
537 N M-079 DUST COLLECTORS RFI 2016
538 N M-103 DUST AND GRIT BLAST COLLECTOR RFI 2016
542 N M-508 GRIT BLAST COLLECTION
545 N M-013 AP DUST COLLECTION
297 O M-043 8 OLD UNDERGROUND STORAGE PIPES RFI 2000 Report
607 O M-055 REMOVED UNDERGROUND WASTE OIL STORAGE TANK
616 O M-137A REMOVED UNDERGROUND STORAGE TANK RFI 2000 Report
225 P M-046 MINE TAILINGS NFA Closed
226 P M-046 MINE TAILINGS NFA Closed
197 Q M-139 OLD HYDRAZINIUM DIPERCHLORATE STORAGE
198 Q M-132 OLD HYDRAZINIUM DIPERCHLORATE STORAGE
199 Q M-057 OLD HYDRAZINIUM DIPERCHLORATE STORAGE RFI 2000 Report
205 Q M-224 OLD HYDRAZINIUM DIPERCHLORATE STORAGE
206 Q M-223 OLD BERYLLIUM PROPELLANT STORAGE
463 R M-052 PAINT BOOTH OVERSPRAY COLLECTION
464 S E-517 WET SCRUBBER
494 T T-018 FLUORESCEIN DYE TEST AREA
479 U M-187 NORTH DISPERSION AREA TO THE WEST RFI 2000 Report
634 U M-148 SOUTH DISPERSION AREA RFI 2000 Report
655 V M-40 Magnesium Grinding Area RFI 2000 Report
672 W E-534 ACTIVATED SLUDGE TREATMENT PLANT RFI 2000 Report

ATK Launch Systems – Promontory UTD009081357

Draft Post-Closure Permit

July 30, 2018

Prepared by: The Utah Department of Environmental Quality Division of Waste Management and Radiation Control Corrective Action Section
ATK Launch Systems Inc. – Promontory July 2, 2018 Post Closure Permit UTD009081357
1
MODULE I - STANDARD CONDITIONS

I.A. DEFINITIONS

I.A.1. For the purposes of this permit, terms used herein shall have the same meaning as
those in R315-260 through R315-273 and R315-101 through R315-102 unless this permit specifically provides otherwise; where terms are not defined in the regulations, or the permit, the meaning associated with such terms shall be defined
by a standard dictionary reference or the generally accepted scientific or industrial
meaning of the term.

I.A.2. “ACL” means Alternative Concentration Limit.
I.A.3. "Days" means Calendar Days.

I.A.4. “Director” means the Director of the Division of Waste Management and
Radiation Control.

I.A.5. “Hazardous Waste Constituent” means a constituent that caused the Board to list the hazardous waste I R315-261.
I.A.6. “Operating Record" means all monitoring and operational data reports
maintained by the Permittee.

I.A.7. “LTTA” is the Permitee’s term for Liquid Thermal Treatment Area. The LTTA
consists of the twelve surface impoundments that were closed with waste in place.
The twelve units that were used for the disposal of hazardous waste and waste-
waters were capped and are located within the M-136 Open Burning Grounds. For the purposes of this Permit, in identifying the area to undergo monitoring and corrective action, the closed units will be referred to as the LTTA and M-136
surface impoundments. These terms may be used synonymously and
interchangeably.

I.A.8. “Permittee” means the owner/operator of a facility responsible for implementation of the conditions of this permit.

I.A.9. “Photographic Waste Discharge Sites” is the term that is used to refer to
Hazardous Waste Management Units (HWMUs) M-508 and M-636. These HWMUs have been closed, however post-closure requirements apply to these sites due to contaminated groundwater and restrictions on land use at sites M-508
and M-636.

I.A.10. “Post-Closure Care Period” means the period during which the Permittee provides post-closure care for the LTTA surface impoundments and Photographic Waste Discharge Sites. This period has a term of thirty (30) years, as defined in
ATK Launch Systems Inc. – Promontory July 2, 2018 Post Closure Permit UTD009081357
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R315-264-117(a)(1), which commenced on September 21, 1992 for the LTTA surface impoundments and on September 20, 2007 for the Photographic Waste
Discharge Sites. The Post-Closure Care Period may be shortened or extended in
accordance with R315-264-117(a)(2).

I.A.11. “QAPP” means Quality Assurance Project Plan

I.A.12. "R315", or "Utah Administrative Code (UAC) R315", means R315 of the
Utah Administrative Code.
I.A.13. “Release” means any spilling, leaking, pouring, emitting, emptying, discharging,
injecting, pumping, escaping, leaching, dumping, or disposing of hazardous
wastes (including hazardous waste constituents) into the environment (including
the abandonment or discarding of barrels, containers, and other closed receptacles containing hazardous wastes or hazardous constituents.)
I.A.14. “SAP” means Sampling and Analysis Plan

I.A.15. “Solid Waste Management Unit (SWMU)” means any discernible area at which
solid wastes have been placed at any time, irrespective of whether the area was
intended for the management of solid or hazardous waste. Such areas include any
part of a facility at which solid wastes have been routinely and systematically
released.

I.A.16. "Qualified Utah Registered Professional Engineer" means any individual who
is qualified by experience and educated in the appropriate field and is licensed as
a Professional Engineer by the Utah Division of Professional Licensing.
I.B. EFFECT OF PERMIT
I.B.1. In accordance with the conditions of this permit, the Permittee shall inspect the
M-136 Liquid Thermal Treatment Area (LTTA), monitor groundwater and, as
appropriate, extract, and/or treat, hazardous waste constituents and contaminated
groundwater resulting from past practices at the Promontory facility. The Permittee shall also maintain site management procedures and control the use of property, as directed by this permit, at the LTTA and Photographic Waste
Discharge sites M-508 and M-636.

I.B.2. Issuance of this permit does not convey property rights of any sort or any
exclusive privilege; nor does it authorize any injury to persons or property, any
invasion of other private rights, or any infringement of State or local laws or regulations. Compliance with the terms of this permit does not constitute a defense to any order issued or any action brought under Section 3013 or Section
7003 of RCRA, Section 106(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. § 9606(a)), commonly
ATK Launch Systems Inc. – Promontory July 2, 2018 Post Closure Permit UTD009081357
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known as CERCLA or Superfund), or any other law providing for protection of human health or the environment.

I.B.3. This permit has been developed in accordance with the applicable requirements of
R315-260 through R315-273 and R315-101 through R315-102 of the Utah
Hazardous Waste Management Rules. All conditions within this permit shall supercede conflicting statements, requirements, or procedures found within attachments to this permit or R315-260 through R315-273 and R315-101 through
R315-102.

I.C. ENFORCEABILITY I.C.1. Violations documented through the enforcement process pursuant to Utah Code § 19-6-112 may result in penalties assessed in accordance with R315-102.

I.D. NO WAIVER OF AUTHORITY

I.D.1. The Director expressly reserves any right of entry provided by law and any authority to order or perform emergency or other response activities as authorized by law.
I.E. PERMIT ACTIONS

I.E.1. This permit may be modified, revoked, and reissued, or terminated for cause as
specified in R315-270-41 and R315-270-43. If the Director determines that cause exists to modify, revoke, and reissue, or terminate this permit, the action will proceed in accordance with R315-124-5.

I.E.2. The permit may be modified or terminated at the request of the Permittee
according to the procedures of R315-270-42. All modification requests involving
design drawings, calculations, sketches, etc., shall be reviewed and stamped by a qualified Utah registered professional engineer. All relevant drawings, calculations, sketches, etc., shall be included with the modification request. The
permit may also be modified through petition for an ACL in accordance with
R315-101. The filing of a request for a permit modification, revocation,
reissuance, termination, or the notification of planned changes or anticipated
noncompliance on the part of the Permittee does not stay the applicability or enforceability of any permit condition.
I.E.3. The Director may modify this permit when the standards or rules on which this
permit was based have been changed by statute, regulations, publication of new
standards or by judicial decision after the effective date of the permit.

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4
I.F. SEVERABILITY
I.F.1. The provisions of this permit are severable, and if any provision of this permit, or
the application of any provision of this permit to any circumstance is held invalid,
the application of such provision to other circumstances and the remainder of this
permit shall not be affected thereby. Invalidation of any state or federal statutory or regulatory provision which forms the basis for any condition of this permit does not affect the validity of any other state or federal statutory or regulatory basis for
said condition.

I.G. DUTIES AND REQUIREMENTS I.G.1. Duty to Comply: The Permittee shall comply with all conditions of this permit,
except to the extent and for the duration such noncompliance is authorized by an
emergency permit, issued in accordance with R315-270-61. Any permit
noncompliance, other than noncompliance authorized by an emergency permit,
constitutes a violation of the Utah Administrative Rules and may be grounds for enforcement action, permit termination, revocation and reissuance, or modification of the permit.

I.G.2. Duty to Reapply: At least 180 days before the expiration of this permit, the
Permittee shall submit a complete application pursuant to R315-270-14 and applicable requirements of R315-270-10 through 29.
I.G.3. Review of Permit: In accordance with the Utah Solid and Hazardous Waste Act,
UCA § 19-6-108(13), this permit shall be reviewed at five-year intervals after the effective date and modified, if necessary.
I.G.4. Permit Expiration: The permit shall expire ten years from the date of issuance.
This permit and all conditions herein will remain in effect beyond the permit's
expiration date until such time as the Director has issued a new permit, pursuant to R315-264-117(a), or the Director has terminated this Permit.
I.G.5. Post-Closure Care Period Expiration: Ninety-days prior to the expiration of the
thirty (30) year post closure periods specified in Condition I.A.10, the Permittee
shall submit to the Director for approval a Class 2 Modification to this Permit to extend the Post-Closure Care Period and associated financial assurance or a justification to not extend the Post-Closure Care Period. Until the Director
modifies this Permit to extend the post closure period and financial assurance, the
Permittee shall comply with the existing financial assurance for post-closure care
requirements in accordance with Condition II.G.
I.G.6. Need to Halt or Reduce Activity Not a Defense: It shall not be a defense for the
Permittee, in any enforcement action that it would have been necessary, to halt or
ATK Launch Systems Inc. – Promontory July 2, 2018 Post Closure Permit UTD009081357
5
reduce the permitted activity in order to maintain compliance with the conditions of this permit.

I.G.7. Duty to Mitigate: In the event of noncompliance with the permit, the Permittee
shall take all reasonable steps to minimize releases of hazardous waste constituents to the environment and shall carry out such measures as are
reasonable to prevent significant adverse impacts on human health or the
environment.

I.G.8. Proper Operation and Maintenance: The Permittee shall at all times properly operate and maintain all facilities and systems of treatment, control and
monitoring (and related apparatus) which are installed or used by the Permittee to
achieve compliance with the conditions of this permit. Proper operation and
maintenance includes effective performance, adequate funding, adequate operator
staffing and training, and adequate laboratory and process controls, including
appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions of the permit.

I.G.9. Duty to Provide Information: The Permittee shall furnish to the Director, within the time specified within the Director’s request any relevant information to determine whether cause exists for modifying, revoking or reissuing this permit,
or to determine compliance with this permit. The Permittee shall also furnish to
the Director upon request, copies of records required to be kept by this permit.

I.G.10. Inspection and Entry: Pursuant to Utah Code § 19-6-109, the Permittee shall allow the Director, or an authorized representative, upon the presentation of
credentials and other documents as may be required by law to;

I.G.10.a. Enter at reasonable times upon the Permittee's premises where a regulated facility
or activity is located or conducted, or where records must be kept under the conditions of this permit;
I.G.10.b. Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit;

I.G.10.c. Inspect at reasonable times any facilities, equipment (including monitoring and
control equipment), practices, or operations regulated or required under this permit;

I.G.10.d. Sample or monitor, at reasonable times, for the purposes of assuring permit
compliance or as otherwise authorized by the Utah Solid and Hazardous Waste
Act, any substances or parameters at any location; and

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I.G.10.e. Make a record of inspections by photographic, electronic, video tape, or any other reasonable medium. No audio recording devices shall be used without notice to
all individuals in recording range prior to activation of the recording device.
Photographic and video recording shall comply with the safety and security
requirements of the Permittee.

I.G.11. Reporting Planned Changes: The Permittee shall give notice to the Director
sixty (60) days prior to any planned physical alteration to the closed facility or
permitted activity.

I.G.12. Anticipated Noncompliance: The Permittee shall give thirty (30) days advance
notice to the Director of any planned changes in the closed facility or permitted
activity which may result in noncompliance with permit requirements. Advance
notice shall not excuse any noncompliance.

I.G.13. Transfer of Permit: This permit may be transferred to a new Permittee, only if it
is modified or revoked and reissued under R315-270-40 to identify the new
Permittee and incorporate such other requirements as may be necessary under the
appropriate Act.
I.G.14. Monitoring and Records: Samples and measurements taken for the purpose of
monitoring shall be accurate and representative of the monitored activity. The
method used to obtain representative samples shall be an appropriate method as
specified in the SAP and QAPP included in Attachment 3. Laboratory methods
must be those specified in "Test Methods for Evaluating Solid Waste; Physical/Chemical Methods SW-846 (Third Edition, Revision 6, February 2007)"or the most currently promulgated edition, "Standard Methods for
Examination of Water and Wastewater (17th Edition or most current editions).";
An equivalent method may be allowed if approved in writing by the Director and
incorporated in the SAP and QAPP included in Attachment 3. The analysis of all
samples shall be conducted by Utah State certified laboratories. I.G.15. The Permittee shall follow the Quality Assurance/Quality Control procedures for
sample collection and analysis as described in the Quality Assurance Project Plan
and Sampling and Analysis Plan contained in Attachment 3 of this Permit.

I.G.16. Any request for a substitution of an analytical method which is equivalent to the
method specifically approved for use in this permit shall be submitted to the Director for review and approval in accordance with R315-260-21. The request
shall provide information demonstrating that the proposed method requested to be
substituted is equivalent or superior in terms of sensitivity, accuracy, and
precision (i.e. reproducibility).

I.G.17. The Permittee shall retain as part of the Operating Record at the Promontory facility, all records or reports generated as a result of this permit for the duration
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of the post-closure period. This period may be extended by request of the Director at any time and is automatically extended during the course of any
unresolved enforcement action regarding this facility.

I.G.18. Reporting Requirements: The Permittee shall report to the Director any non-compliance with the permit. Reporting shall not constitute a defense for any
noncompliance. Reporting shall include, at a minimum, the following:

I.G.18.a. Information concerning the non-compliance which may endanger public drinking
water supplies; human health or the environment. Such information shall be
reported orally as soon as possible and no later than twenty-four (24) hours from the time the Permittee becomes aware of the circumstances. The description of the occurrence and its cause shall include:

I.G.18.a.i. Name, address, and telephone number of the Permittee;

I.G.18.a.ii. Name, address, and telephone number of the individual making the report; I.G.18.a.iii. Date, time and type of incident;

I.G.18.a.iv. Description and quantity of materials involved;

I.G.18.a.v. The extent of injuries, if any; I.G.18.a.vi. An assessment of actual or potential hazard to the environment and health outside
the facility, where this is applicable; and

I.G.18.a.vii. Estimated quantity and disposition of recovered material that resulted from the
incident.
I.G.18.b. A written submission shall also be provided within seven days of the time the Permittee becomes aware of the circumstances. The written submission shall
contain, at a minimum; a description of the non-compliance and its cause; the
periods of non-compliance (including exact dates and times); whether the non-
compliance has been corrected; and if not, the anticipated time it is expected to
continue and steps taken or planned to reduce, eliminate, and prevent recurrence of the non-compliance. The Permittee need not comply with the seven day written notice requirement if the Director waives the requirement and the Permittee
submits a written report within fifteen (15) days of the time the Permittee
becomes aware of the circumstances.

I.G.18.c. If the non-compliance does not endanger human health or the environment, a written submission shall be provided to the Director within twenty-one (21) days of the time the Permittee becomes aware of the circumstances. The description of
the occurrence shall include, but not be limited to, all items as listed in Conditions
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I.G.18.a.i. through I.G.18.a.vii. The written submission shall contain, at a minimum; a description of the non-compliance and its cause; the periods of non-
compliance (including exact dates and times); whether the non-compliance has
been corrected; and if not, the anticipated time it is expected to continue and steps
taken or planned to reduce, eliminate, and prevent recurrence of the non-
compliance.
I.G.19. Monitoring Reports: Monitoring reports shall be submitted to the Director at the
intervals specified elsewhere in this permit.

I.G.20. The Permittee shall submit additional copies of each plan, report, notification, or other submissions required by this permit, as requested by the Director.
I.G.21. Compliance Schedules: Reports of compliance or non-compliance with, or any
progress reports on, interim and final requirements contained in any compliance
schedule of this permit shall be submitted to the Director no later than fourteen (14) days following each scheduled event.
I.G.22. Other Information: Whenever the Permittee becomes aware that he failed to
submit any relevant facts in the permit application or submitted incorrect information in a permit application or in any report to the Director, the Permittee shall submit such facts or corrected information to the Director within seven days
of discovery.

I.H. CERTIFICATION OF CONSTRUCTION OR MODIFICATION
I.H.1. The Permittee may not commence storage, treatment, or disposal of hazardous waste in any newly permitted unit or in a modified portion of an existing, permitted unit, as provided for in R315-270-42, until the Permittee has submitted
by certified mail, express mail, or hand delivery to the Director:

I.H.1.a. A letter signed by the Permittee and an independent, Utah registered, professional
engineer qualified by experience and education in an appropriate engineering field, certifying that the permitted unit at Promontory has been constructed or modified in accordance with the approved modification request and this Permit;

I.H.1.b. As built engineering plans and specifications; and

I.H.1.c. The Director, or designated representative, has reviewed and inspected the modified or newly constructed unit and has notified the Permittee in writing that the unit was found to be in compliance with the conditions of this Permit and the
modification request; or

I.H.1.d. If, within fifteen (15) days of the date of submission of the letter required by
Condition I.H.1., the Permittee has not received notice from the Director of the
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intent to inspect, prior inspection is waived and the Permittee may commence treatment, storage, or disposal of hazardous waste in the permitted unit if certified
in accordance with Condition I.H.1.

I.I. SIGNATORY REQUIREMENT I.I.1. All applications, reports or other information requested by or submitted to the Director shall be signed and certified as required by R315-270-11.

I.J. CONFIDENTIAL INFORMATION

I.J.1. The Permittee may make a claim for confidentiality of any information required to be submitted by this permit in accordance with Utah Code §§ 19-1-306, 63G-2-309 and R315-270-12.

I.K. DOCUMENTS TO BE MAINTAINED AT FACILITY SITE

I.K.1. The Permittee shall maintain at the Promontory facility, for the duration of the post-closure care period, the following documents and amendments, revisions and modifications to these documents:
I.K.1.a. The post-closure permit application;

I.K.1.b. Post-closure monitoring records, to include groundwater monitoring records and
analytical results, groundwater treatment system unit records and analytical results, and records of the effectiveness of the groundwater treatment system, as required by this permit;

I.K.1.c. Certification of closure as required by R315-264-115;

I.K.1.d. Personnel training documents and records as required by R315-264-16(d) and this permit;
I.K.1.e. Inspection schedules as required by R315-264-15(b) and this permit;

I.K.1.f. The Operating Record required by R315-264-73 and this permit; and
I.K.1.g. Copies of all required submittals as listed in Tables I-1 and I-2 of this Module.
I.L. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

I.L.1. Pursuant to Section 3005(c)(3) of RCRA (Section 212 of HSWA) and R315-270-
32(b)(2) , this permit contains those terms and conditions determined necessary to
protect human health and the environment.
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I.M. REQUIRED SUBMISSIONS UNDER THIS PERMIT
I.M.1. The Permittee shall submit the following documents to the Director as specified
by permit conditions:
TABLE I - 1

REQUIRED SUBMISSION PERMIT CONDITION DATE OR EVENT
1. Application for permit reissuance I.G.2. 180 days before expiration of permit
2. Financial Assurance Certification II.G. In accordance with Conditions II.G.
3. Annual adjustment of post-closure cost estimate III.D.2. In accordance with Condition III.D.2.
4. Post-closure cost estimate III.D.5. 30 days after modification of permit as appropriate
5. Annual Groundwater Monitoring Plan IV.B.2.a. 30 days prior to collection of
samples
6. Total monitoring well depth data IV.D.1.c. In accordance with Condition IV.E.2.
7. Monitoring Well Completion Reports IV.D.2.c. 90 days after well completion
8. Annual Groundwater Monitoring Reports IV.E.2. In accordance with Condition IV.E.2. and Table IV-2
9. Semiannual Spring Sampling Results IV.B.2.b. In accordance with Conditions IV.B.2.b. and IV.E.2.c.
10. Groundwater Flow and Contaminant
Transport Model V.E.2. In accordance with Condition
IV.E.2.j.
11. Human Health Risk Assessment for Groundwater V.A.2. In accordance with Condition
V.A.2.
12. Ecological Risk Assessment for Groundwater V.A.3. One year after approval of the
Groundwater Model
13. Corrective Measures Study for Groundwater Corrective Action V.B.1. 90 days after approval of the Risk
Assessments
14. Corrective Measure Implementation Plan for Groundwater V.C.1. 90 days after approval of the
Corrective Measures Study
15. Corrective Measure Implementation Report for Groundwater V.D.1.
90 days after completing
construction of corrective
measure(s)
16. Annual calibration of Groundwater Flow and Contaminant Transport Model V.E.2. In accordance with Condition
IV.E.2.j.
17. Summary on the Effectiveness of the Corrective Action Program for Groundwater V.E.3. In accordance with Condition
IV.E.2.
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TABLE I-1 (Continued)

REQUIRED SUBMISSION PERMIT CONDITION DATE OR EVENT
18. Corrective Measure Completion Report V.F.1. Upon attaining the Corrective Measure Completion Criteria
19. Schedule for submitting RFI Workplans VI.C.3. By January 15th of each year
20. RFI Work Plans VI.C.1. In accordance with the approved schedule (VI.C.3.)
21. RFI Report VI.E.1. In accordance with RFI Workplan
approved schedule (VI.D.2.i.)
22. Phase II RFI Work Plan for
additional investigations (as
applicable)
VI.F.1.
In accordance with RFI Report
approved schedule (VI.E.1.i.)
23. Corrective Measures Study for
SWMUs (as applicable) VI.G.3. In accordance with VI.G.
24. Corrective Action Plan for SWMUs VI.G.1. In accordance with RFI Report
approved schedule (VI.E.1.i.)
25. Corrective Action Report for SWMUs VI.G.6.
In accordance with Corrective
Action Plan approved schedule
(VI.G.4.k.)
26. Human Health and Ecological Risk Assessment (as applicable) VI.H.2. In accordance with Section VI.H.
27. Site Management Plan (as applicable) VI.I.2. In accordance with VI.I.2.
28. Interim Measure Plan (as applicable) VI.J.2. In accordance with VI.J.2.
29. Semiannual RFI Progress Reports VI.L. In accordance with VI.L.2.

I.M.2. All reports, modifications, notifications, or other submittals that are required to be
provided to the Director under these permit provisions shall be sent by certified
mail or other means with proof of delivery to: Director, Division of Waste Management and Radiation Control
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
Phone [phone]
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I.M.3. All hand-delivered submissions shall be made during normal business hours, at the Multi Agency State Office Building 195 North 1950 West, Second Floor, Salt
Lake City, Utah.

I.N. REQUIRED NOTIFICATIONS UNDER THIS PERMIT I.N.1. The Permittee shall make the following notifications to the Director as specified by permit conditions:
TABLE I - 2

REQUIRED NOTIFICATION PERMIT
CONDITION DATE OR EVENT
1. Planned alteration to the closed LTTAs or permit activity I.G.10. 60 days before planned alteration
2. Anticipated non-compliance I.G.11. 30 days before planned change
3. Non-compliance with the permit I.G.17.a. 24 hours after discovery (oral)
4. Non-compliance with the permit I.G.17.b. 7 days after discovery
5. Non-compliance with the permit I.G.17.c. 21 days after discovery
6. Compliance schedule requirements I.G.20. 14 days after scheduled event
7. Missing or incorrect information I.G.21. 7 days after discovery
8. Certification of construction or modification I.H.1. In accordance with Condition I.H.1.
9. Reporting releases of hazardous
constituents II.E.2. In accordance with Condition
II.E.2.
10. Incapacity of financial assurance
requirement II.I.1. In accordance with Condition
II.I.1.
11. Improperly operating groundwater
monitoring well IV.D.1.b. 7 days after discovery
12. Improperly operating groundwater treatment system V.E.5. 7 days after discovery
13. RFI Field Work/Sampling VI.B.4. 7 days prior to conducting field work
14. Release of hazardous constituents from a SWMU VI.J. Upon discovery
15. Newly identified SWMUs VI.K.1. 30 days after discovery of
SWMU

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MODULE II - GENERAL FACILITY STANDARDS

II.A. POST-CLOSURE MAINTENANCE AND MONITORING

II.A.1. The Permittee shall inspect and monitor the closed LTTAs throughout the post-
closure care period, in a manner that will ensure detection of a release of hazardous waste, hazardous waste constituents, leachate, contaminated runoff or hazardous waste decomposition products to the soil, groundwater, or surface
water from the closed facility. The Permittee shall maintain all treatment,
containment and monitoring equipment through the post-closure care period in a
manner that will ensure detection of a release from the closed facility and
minimize the possibility of fire, explosion, or any sudden or non-sudden release of hazardous waste constituents to air, soil, surface water, or groundwater which could threaten human health or the environment.

II.B. SECURITY

II.B.1. The Permittee shall comply with the following security conditions: II.B.1.a. A fence with locked gates surrounding the closed LTTAs on all sides, which
prevents unauthorized entry, shall be maintained throughout the post-closure care
period; and

II.B.1.b. Signs which read "DANGER, UNAUTHORIZED PERSONNEL KEEP OUT" shall be posted at the entrance gates to the LTTA and every 100 feet along the fence surrounding the LTTA and shall be maintained throughout the post-closure
care period. The signs must be legible from a distance of at least 25 feet in
compliance with R315-264-14(c).

II.B.1.c. Signs which read “HAZARDOUS WASTE MANAGEMENT UNIT –
RESTRICTIONS ON LAND USE APPLY” shall be posted at entrances and every 100 feet around the designated area of HWMUs M-508 and M-636.
II.B.2. All security equipment shall be inspected throughout the post-closure care period
in accordance with the Inspection Schedules and Procedures, Attachment 2. The
Permittee shall incorporate those security items (i.e. fence, signs of vandalism,
etc.) to be inspected and the frequency of inspection on the inspection checklist. II.B.3. Damaged security equipment shall be noted in the inspection checklist and repairs
shall begin within twenty-four (24) hours. Repairs shall be completed as soon as
practicable, but not later than seventy-two (72) hours after the problem is
discovered, in compliance with R315-264-15(c).

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II.B.4. The Permittee shall comply with all other security procedures as specified in
Attachment 1.

II.C. PERSONNEL TRAINING
II.C.1. The Permittee shall conduct personnel training as required by R315-264-16. II.C.2. The Permittee shall maintain training documents and records as required by R315-
264-16(d) and (e), and shall record the type and amount of training received by
each employee involved in hazardous waste management.

II.C.3. New personnel shall complete the required personnel training within six months of their hire date. Training records shall indicate the type and amount of training received.

II.D. GENERAL INSPECTION REQUIREMENTS

II.D.1. The Permittee shall follow the inspection schedules as specified in Attachment 2. II.D.2. Repairs or maintenance for any deterioration or malfunction discovered by an
inspection shall be initiated by the Permittee within seventy-two (72) hours except
for damaged security equipment. As stated in Permit Condition II.B.3., repairs to
damaged security equipment shall begin within twenty-four (24) hours. Repairs to
security equipment shall be completed as soon as practicable, but not later than seventy-two (72) hours after the problem is discovered.
II.D.3. Any problem which could endanger human health or the environment shall be
corrected as soon as possible. Corrective action shall start no later than the next
working day from the time the problem is discovered.

II.D.4. The Permittee shall inspect the closed portions of the facility within twenty-four (24) hours after a storm event. A storm event shall be defined as precipitation in excess of 1.00 inch in a one hour period as measured by the equipment required in
II.D.4.a. It shall be documented in the inspection log that the inspection was
conducted in response to a storm event.

II.D.4.a. The Permittee shall install, on its premises, equipment appropriate to measure and record precipitation in order to determine the occurrence of storm events.
II.D.5. The Permittee shall inspect on an annual basis all monitoring wells, extraction
wells, and injection wells that are part of the groundwater monitoring system as
specified below and in Section II.E., Attachment 2:
II.D.5.a. Inspect for damage to the above ground casing;
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II.D.5.b. Inspect for damage to cement apron and assure that the annulus is properly sealed;

II.D.5.c. If permanent, dedicated, pumps are used, verify proper operation;

II.D.5.d. Check for visible damage and tampering to locks and monitoring well caps; and II.D.5.e. Insure that the wells are accessible and visible.

II.D.6. Records of inspections shall be kept at the Promontory facility, Box Elder County,
Utah as indicated by condition I.G.16., throughout the post-closure care period.
The Groundwater Monitoring System Annual Inspection Checklist (as shown in Attachment 2) shall be submitted with the Annual Groundwater Monitoring Report (See Condition IV.E.2.)

II.E. CONTINGENCY PLAN

II.E.1. Content of Plan. The Permittee shall maintain a Contingency Plan, Attachment 4 of this permit, for the duration of the permit, which meets the requirements of
R315-264-52.

II.E.2. Implementation of Plan. When dictated by the Contingency Plan, Attachment 4, of the Hazardous Waste Storage Permit, the Permittee shall immediately carry out the provisions of the plan, and follow the emergency procedures described by
R315-264-56. Whenever there is a fire, explosion, or release of a reportable
quantity of hazardous waste or hazardous waste constituents, the Permittee shall
comply with R315-263-30 in reporting releases to the Director.

II.E.3. Copies of Plan. The Permittee shall comply with the requirements of R315-264-
53.

II.E.4. Amendments to Plan. The Permittee shall review and immediately amend, if necessary, the Contingency Plan, Attachment 4, as required by R315-264-54.

II.F. RECORD KEEPING AND REPORTING

II.F.1. The Permittee shall submit reports as required to the Director documenting post-closure monitoring activities and results from analyses of samples collected in compliance with closure and post-closure monitoring requirements. Copies of
all Permit-related records shall be maintained, as specified in Condition I.G.16.

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II.G. FINANCIAL ASSURANCE FOR POST-CLOSURE CARE

II.G.1. The Permittee shall demonstrate continuous compliance with the financial
assurance requirements by providing a third party financial assurance certification
of at least the amount of the post-closure cost estimate established in Condition
III.D. The Permittee may substitute other instruments of financial assurance provided the method, funding and wording requirements of R315-264-143 are followed and approved in writing by the Director.

II.G.2. The financial assurance document shall be updated, including adjusting the post-
closure cost estimate for inflation, within sixty (60) days of the anniversary date of
the establishment of the financial assurance instrument or within sixty (60) days of the Director’s approval of a revised post-closure cost estimate in accordance with R315-264-143. Changes in financial assurance mechanisms must be
approved in writing by the Director at least sixty (60) days prior to such a change.

II.H. LIABILITY REQUIREMENTS II.H.1. The Permittee shall demonstrate continuous compliance with the requirements of R315-264-147(b) to have and maintain liability coverage for non-sudden
accidental occurrences.

II.H.2. Changes in liability coverage mechanisms shall be approved in writing by the
Director at least sixty (60) days prior to such a change. II.I. INCAPACITY OF PERMITTEE, GUARANTORS OR FINANCIAL
INSTITUTIONS

II.I.1. The Permittee shall comply with the notification and financial requirements of
R315-264-148.

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MODULE III - USE OF PROPERTY AND POST-CLOSURE CARE FOR THE LTTAs
AND PHOTOGRAPHIC WASTE DISCHARGE SITES

III.A. USE OF PROPERTY III.A.1. The Permittee has closed and capped the M-136 LTTAs with waste in place. The M-508 and M-636 Photographic Waste Discharge Sites have both been closed
with residual contamination remaining that exceeds standards for residential use.

III.A.2. The Permittee and the Director entered into Environmental Covenants for the M-
136 LTTAs and the M-508 and M-636 Photographic Waste Discharge sites. The
Environmental Covenants establish the sites’ locations, specify the land use
restrictions, and identify the contaminants that remain at each site.
III.A.3. The Environmental Covenants run with the land and a Notice upon Conveyance is required that informs any new owner of the land use restrictions that apply to the
sites. The Environmental Covenants were recorded with the Box Elder County
Recorder and are included in Attachment 1.

III.B. POST-CLOSURE CARE III.B.1. The Permittee shall conduct all post-closure care activities in accordance with
this permit, and in compliance with R315-264-110 and R315-264-117 for the duration of the post-closure period.
III.B.2. The Permittee shall maintain and monitor the LTTAs and Photographic Waste
Discharge Sites M-508 and M-636, after completion of closure and corrective
action activities, in compliance with R315-264-228, R315-264-117 and this
permit. The Permittee shall: III.B.2.a. Maintain the integrity and effectiveness of the final LTTA covers in compliance
with R315-264-228(b)(1) and Attachments 1 and 2 of the permit, including
making repairs to the caps as necessary to correct the effects of settling,
subsidence, erosion or other events;
III.B.2.b. Maintain the signs and other security equipment at the Photographic Waste Discharge Sites M-508 and M-636.

III.B.2.c. Maintain and monitor the groundwater monitoring system and the groundwater
treatment and containment system in compliance with R315-264-228(b)(3), R315-
264-90 and Modules V and VI of this permit; III.B.2.d. Prevent run-on and run-off from eroding or otherwise damaging the final LTTA
covers in compliance with R315-264-228(b)(4);

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III.B.2.e. Prohibit post-closure use of the property at M-136, which will disturb the integrity of the final cover, containment systems, or monitoring system; and,

III.B.2.f. Protect and maintain surveyed benchmarks.

III.C. INSPECTIONS III.C.1. Inspections of the LTTAs shall be conducted during the post-closure care period
in compliance with the procedures specified in Condition II.D and Attachment 2.
All records of inspections and remedial actions shall be retained in the Operating
Record, as required by condition I.G.16., throughout the post-closure care period.
Any deterioration or malfunction discovered by an inspection shall be remedied in accordance with Condition II.D.2.
III.D. COST ESTIMATES FOR POST-CLOSURE CARE

III.D.1. The Permittee’s post-closure cost estimate shall be prepared in accordance with
R315-264-144. III.D.2. The Permittee shall adjust the post-closure cost estimate for inflation as specified by R315-264-144(b) each year and submit a copy of the adjusted cost estimate to
the Director for written approval.

III.D.3. Before each new hazardous waste management unit is placed in operation, an
updated closure/post-closure cost estimate including the new unit shall be prepared. This revised cost shall be submitted at least sixty (60) days prior to placing the unit in operation.

III.D.4. A revised closure/post-closure cost estimate shall be submitted to the Director for
written approval within sixty (60) days after an unexpected event that affects the
cost estimate. III.D.5. The Permittee shall revise the post-closure cost estimate within thirty (30) days
after the Director has approved a request to modify this permit and has determined
the permit modification impacts the cost estimate.

III.D.6. The Permittee shall keep at the facility the latest closure cost estimate as required by R315-264-144(d) as part of the facility Operating Record.
III.E. FINANCIAL ASSURANCE FOR POST-CLOSURE CARE

III.E.1. The Permittee shall maintain financial assurance for post-closure care as required
by Conditions II.G.1. and II.G.2.

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III.F. LIABILITY REQUIREMENTS

III.F.1. The Permittee shall comply with the liability requirements as specified in Conditions II.H.1. and II.H.2.

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MODULE IV - GROUNDWATER MONITORING
IV.A. POST-CLOSURE GROUNDWATER MONITORING

IV.A.1. Hazardous constituents have been released from the M-136 LTTAs, the M-508
Photographic Waste Discharge Site and other waste management sites at the facility.
The Permittee shall monitor groundwater in the impacted aquifers as described in this Module and Attachment 3. The Permittee shall maintain compliance with R315-264-90 Groundwater Protection during the post-closure care period as defined
in Condition IV.A.6.

IV.A.2. The Permittee shall maintain a groundwater monitoring system. The monitoring
well system consists of all wells dedicated to monitoring the release of hazardous constituents from M-136, M-508 and other waste management sites at the facility. The monitoring well system shall consist of the wells, piezometers and springs
specified in Table 4-A of Attachment 4. The monitoring well, piezometer and
spring locations are also presented in Attachment 4, Plates 1A and 1B.

IV.A.3. The Area of Compliance is defined as all monitoring wells, piezometers and springs located within impacted aquifers and displaying concentrations that exceed the Groundwater Protection Standard as defined in section IV.C. of this Permit module.
IV.A.4. The Permittee shall implement the corrective action program, as described in
Module V, upon exceedance of the Groundwater Protection Standard within the
Area of Compliance.

IV.A.5. Solid waste management units (SWMUs) may be subject to certain provisions of
this Module. The Director shall determine which SWMUs may be subject to
some or all of the provisions of this Module.
IV.A.6. The Permittee shall monitor the groundwater throughout the post-closure care period. If any of the Groundwater Protection Standards, or approved Alternate
Concentration Limits, are still exceeded after thirty (30) years, the Permittee shall
continue corrective action as specified in Condition V.F.

IV.A.7. The Permittee shall maintain a searchable data base so that a complete record of the
chemical and well specific groundwater monitoring data, collected in accordance with this Module, is available.

IV.B. REQUIRED PROGRAM

IV.B.1. The Permittee shall monitor groundwater, in accordance with Section IV.B., for the
hazardous constituents listed below in Table IV-1.
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IV.B.1.a. The groundwater quality assessment, completed by the Permittee, determined the
hazardous constituents listed in Table IV-1 below were released at the site, entered the impacted aquifer, and have been detected beyond the compliance point. Some constituents have been detected beyond the facility boundary. The Permittee shall
monitor the groundwater for the constituents listed in Table IV-1 as specified in the
Sampling and Analysis Plan, Attachment 3.

TABLE IV-1 CONSTITUENTS AND GROUNDWATER PROTECTION STANDARD

Constituent GWPS (ug/L) Constituent GWPS (ug/L)
1,1-Dichloroethene 7.0 1 Trans-1,2-dichloroethene 100 1
1,1-Dichloroethane 2.82 Trichloroethene 5.0 1
1,2-Dichloroethane 5.0 1 Trichlorofluoromethane 5,200 2
1,1,1-Trichloroethane 200 1 Vinyl Chloride 2.0 1
1,1,2-Trichloroethane 5.0 1 Xylene 10,000 1
Acetone 14,000 2 Arsenic 10 1
Benzene 5.0 1 Barium 2,000 1
Carbon Tetrachloride 5.0 1 Beryllium 4.0 1
Chlorobenzene 100 1 Chromium (total) 1001
Chloroform 802,3 Chromium VI 0.0352
Cis-1,2-Dichloroethene 70 1 Cobalt 62
Methyl Ethyl Ketone
(2-Butanone) 5,6002 Molybdenum 1002
Methylene Chloride 5 1 Perchlorate 142
Tetrachloroethene 5.0 1 Nitrate 10,000 1
Toluene 1,000 1 RDX 0.72
HMX 1,0002
1 Maximum Contaminant Levels (MCLs), EPA, 2017
2 EPA Regional Screening Levels (RSLs) for Tapwater, June 2017
3 The MCL for chloroform applies to the Total Trihalomethanes, which also include
bromodichloromethane, bromoform, and dibromochloromethane
IV.B.2. The Permittee shall collect and analyze samples from the groundwater monitoring system at least annually as described below:

IV.B.2.a. Thirty (30) days prior to the collection of samples, the Permittee shall submit an
annual Groundwater Monitoring Plan to the Director for approval. The monitoring
plan shall include a list of monitoring wells and springs proposed for sampling, the
constituents that will be sampled for in each well, a map highlighting the well locations, and the rationale for the proposed well selections and constituents.
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IV.B.2.b. The Permittee shall collect and analyze samples from Shotgun and Pipe Springs
semiannually, once in the Spring and once in the Fall. The Permittee shall submit the analytical results for spring samples collected in the Fall with the Annual Groundwater Monitoring Report (Condition IV.E.2). The results for the spring
samples collected in the Spring shall be submitted to the Director in writing by the
Permittee within ninety (90) days of collecting the samples.

IV.B.3. The Permittee shall not implement the proposed Groundwater Monitoring Plan without Director written approval. The Director may, upon written notification to the Permittee, require any or all of the monitoring wells, springs or piezometers
listed in Table 1 of Attachment 4 be sampled for any or all of the constituents listed
in Table IV-1.
IV.C. GROUNDWATER PROTECTION STANDARD IV.C.1. The concentrations listed for each hazardous waste constituent in Table
IV-1 shall comprise the groundwater protection standard. The Permittee shall
sample and analyze the groundwater monitoring system for these constituents, as
described in Condition IV.B.
IV.C.2. The Permittee may apply for Alternate Concentration Limits (ACL). A petition may be submitted if:
IV.C.2.a. The approved corrective measures, as described in Modules V and VI, fail to meet
the groundwater protection standard defined by Condition IV.C.1., (Table IV-1) and
the Permittee has demonstrated that all other technically feasible methods have been
used to meet the concentration limits, or IV.C.2.b. A risk assessment, conducted in accordance with R315-101, concludes that a
contaminant concentration greater than the groundwater protection standard poses
no unacceptable risk to human health or the environment.

IV.C.3. If submitted, the Director shall determine, the appropriateness of any ACL petition, and either accept, or reject, the proposed concentration level. If the Director determines that the level is appropriate, the Permittee shall initiate a modification to
the permit in accordance with Condition I.E.2.

IV.C.4. The Permittee may request to have one or more constituents removed from the
groundwater monitoring constituent list (Table IV-1). The Director shall determine if it is appropriate to remove constituent(s), based on the rationale provided by the Permittee and monitoring results. If the Director determines that it is appropriate to
remove constituents as requested, the Permittee shall initiate a modification to the
permit in accordance with Condition I.E.2.

IV.C.5. The Permittee shall use the SW-846 test methods and detection limits listed in
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Table 1 of Attachment 3 to analyze groundwater samples. If an alternate test
method is proposed, the Permittee shall request a permit modification in accordance with Condition I.E.2. If, at any time during the duration of this permit, the Director determines that the test methods specified in Attachment 3 are not sensitive enough
to produce the required results, the Director may require the Permittee to use
alternate test methods. If the Director requires a change to the test method(s), the
Permittee shall modify the permit.
IV.D. GROUNDWATER MONITORING REQUIREMENTS
IV.D.1 The Permittee shall comply with the following general requirements for
groundwater monitoring:
IV.D.1.a. The groundwater monitoring system shall consist of the wells, piezometers and springs specified in Table 1 of Attachment 4.
IV.D.1.b. Existing monitoring wells shall be maintained in a fully operational condition for
the duration of this permit. The Permittee shall notify the Director within seven
days when a well is no longer properly functioning (including the presence of sandy
or silty materials that impacts the well function and cracked or broken casings). The
Director must approve in writing the conditions for replacement or correction of improperly operating well(s).
IV.D.1.c. The Permittee shall measure the total depth of all groundwater monitoring wells
that are completed in unconsolidated sediments (listed in Table 2, Attachment 3)
every five years. Total well depth measurements shall be compared to the original
total depths for each well and submitted to the Director with the Annual Groundwater Monitoring Report in the year following total well depth measurements. If a problem is observed, the Permittee shall follow the procedures
described above in Condition IV.D.1.b. regarding notification and corrective
procedures.

IV.D.1.d. The permanent removal of any wells in the groundwater monitoring system (Table 1, Attachment 4) shall be approved by the Director in writing. A request for the removal of wells shall constitute a permit modification.

IV.D.1.e. The Permittee shall install additional groundwater monitoring wells to maintain
compliance with this Module if subsurface conditions significantly change after
permit issuance. Such changes may include, but are not limited to, water level elevation or apparent flow direction changes, or detection of one of the hazardous constituents in a monitoring well. If hazardous waste constituents exceed the
groundwater protection standard concentration limits, as defined in Section IV.C.
of this Module, in the furthest most hydraulically down-gradient monitoring
well(s), the Permittee shall install additional groundwater monitoring wells further
down-gradient.
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IV.D.1.f. Upon notification by the Director in writing, or as a result of an enforcement action, the Permittee may be required to install and sample additional wells at any time during the post-closure or compliance periods if new information or unforeseen
circumstances reveal a need for additional monitoring to protect human health and
the environment.

IV.D.1.g. The Permittee shall not add or remove any groundwater monitoring wells without prior written approval of the Director. The Permittee shall submit to the Director an application for a permit modification (for Attachment 4) within ninety (90) days of
when new wells are added to or removed from the groundwater monitoring system.

IV.D.2. The Permittee shall locate, install, construct, and maintain new groundwater
monitoring wells as specified below: IV.D.2.a. Well construction shall follow the techniques described in the Technical
Enforcement Guidance Document (TEGD), OSWER-9950.1, November 1992, or
most current, approved edition. All monitoring wells shall be cased in a manner that
maintains the integrity of the monitoring well bore hole. This casing shall be
screened or perforated, and packed with gravel or sand, depending on the formation, to enable collection of groundwater samples. The annular space, the space between the bore hole and well casing above the sampling depth, shall be sealed with bentonite grout to prevent contamination of samples and the groundwater.

IV.D.2.b. The Permittee shall construct and maintain new monitoring wells and piezometers
in accordance with plans and specifications to be submitted to the Director for
approval. The Director will approve in writing the following: number, location, depth, and design of all new wells and piezometers prior to installation.

IV.D.2.c. The Permittee shall submit monitoring well completion reports within ninety (90)
days after completion of any new wells installed. These reports shall, at a
minimum, consist of the following components: a boring log that documents well
drilling and associated sampling; a well construction log and well construction diagram (“as built”); well survey information for locations and elevations of the newly completed wells, the results of pump tests or slug tests, and a summary that
discusses how the groundwater flow model shall be updated based on the data
obtained from the installation of the new wells. The detailed information that shall
be included for each of the four components is outlined in Attachment 5.
IV.D.2.d. The Permittee shall properly dispose all contaminated groundwater generated during groundwater monitoring well sampling and during the development of new
monitoring wells.

IV.D.2.e. The Permittee shall permanently remove wells from the monitoring well system in
accordance with the plugging and abandonment procedures described in the
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Technical Enforcement Guidance Document (TEGD), OSWER-9950.1, November
1992, and subsequent addenda and as specified in Condition IV.D.1.d. above. IV.D.3. The Permittee shall include and maintain sampling and analysis procedures in the
groundwater monitoring program that are designed to ensure reliable monitoring
results. As required by R315-264-97(d), the program shall include procedures and
techniques for:
IV.D.3.a. sample collection;
IV.D.3.b. sample preservation and shipment;

IV.D.3.c. analytical procedures;
IV.D.3.d. chain-of-custody control; and
IV.D.3.e. quality assurance and quality control.

IV.D.4. The sampling and analytical methods must be appropriate for groundwater sampling
and accurately measure hazardous waste constituents in groundwater samples, as
required by R315-264-97(e). IV.D.5. The Permittee shall use the following techniques and procedures when obtaining
samples and analyzing samples from the groundwater monitoring wells, piezometers
and springs:

IV.D.5.a. The Permittee shall collect, preserve, and transport all samples from monitoring wells, piezometers and springs in accordance with the procedures specified in the Sampling and Quality Assurance Project Plans, presented in Attachment 3;

IV.D.5.b. Changes to the sampling or analysis procedures specified in Attachment 3, Module
IV, or Module V, shall require a permit modification;
IV.D.5.c. The Permittee shall ensure all samples will be analyzed according to the test methods shown in Table 1 of the Groundwater Sampling and Analysis Plan,
Attachment 3, or an equivalent EPA-approved method that has been pre-approved,
by the Director in writing as per Condition I.G.13. In addition:

IV.D.5.c.i. All major analytical peaks greater than 25% of the peak height of the closest internal standard shall be identified using the most current National Bureau of Standards (NBS) Library. The quantity of these compounds shall be estimated and reported
based upon the closest internal standard;

IV.D.5.c.ii. Any major analytical peak found during the analysis may become a target parameter
for that constituent.
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IV.D.5.c.iii. All data shall be collected and validated as outlined in the Sampling and Quality Assurance Project Plans contained in Attachment 3. The Permittee shall resample all wells from which data is rejected.

IV.D.5.c.iv. The Director may request at any time all laboratory QA/QC documentation and
supporting data on any sampling episode in the previous 5 years. The raw organics
information for required sampling and analysis, including organics gas chromatographic printouts, mass spectral analyses, and QA/QC surrogate and spiking results shall be retained by the Permittee at the Promontory facility and
made available within fifteen (15) working days of request throughout the post-
closure care period.

IV.D.5.c.v. All samples shall be tracked and controlled using the chain-of-custody procedures specified in the Sampling and Quality Assurance Project Plans contained in Attachment 3.

IV.D.5.c.vi. In case of loss of sample integrity (e.g. breakage, loss), resampling shall take place
within seven days of the loss of sample integrity.
IV.D.6. The Permittee shall determine the groundwater surface elevation in all monitoring wells listed in Table 4-A, Attachment 4 annually. The Permittee shall determine the groundwater surface elevation in the piezometers listed in Table 4-A, Attachment 4,
on an as needed basis as determined by the Director.

IV.D.7. The Permittee shall maintain a record of the piezometer locations and mark the
locations of piezometers in the field so that they may be found as needed. IV.D.8. The Permittee shall, on an annual basis, construct maps of the potentiometric
surface, based on the groundwater surface elevation data collected as described in
Condition IV.D.6. If, based on annual monitoring, the Director determines that
additional potentiometric data is needed, the Permittee shall install additional
monitoring wells or piezometers. IV.D.9. The Permittee shall determine the groundwater flow rate and direction in the
impacted aquifers based on groundwater surface elevation measurements. An
updated potentiometric map shall be submitted to the Director on an annual basis as
specified in Condition IV.E.2.
IV.D.10. If the Director receives information indicating that the surveyed well casing elevations of the wells in the groundwater monitoring system, as specified in
Condition IV.A.2., exceed 0.01 feet from a fixed datum the Permittee shall resurvey
any or all of these well casing elevations.

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IV.D.11. The Permittee shall submit plume maps, as specified in Section IV.E. to show the
concentration of hazardous constituents detected in impacted aquifers. Plume maps shall be submitted for the following constituents: trichloroethene, 1,1,1-trichloroethane, 1,1-dichloroethene, 1,1-dichloroethane, cis-1,2-dichloroethene,
chloroform and perchlorate.

IV.E. REPORTING AND RECORD KEEPING IV.E.1. The Permittee shall keep a record of all monitoring, testing and analytical data obtained pursuant to the groundwater monitoring requirements contained in this
Module. This data shall be managed as part of the Operating Record until closure
of the facility in accordance with R315-264-73(b)(6).

IV.E.2. The Permittee shall submit to the Director, for approval, annual Groundwater Monitoring Reports compiling the results of groundwater monitoring and assessing the effectiveness of the corrective action program. These reports shall be submitted
no later than March 15 of each year and shall contain the following information:

IV.E.2.a. An Introduction and list of wells describing the monitoring that was conducted, a
summary of the analytical results and a description of the QA/QC results;
IV.E.2.b. Results of sample analysis including the concentration of hazardous constituents, units of measurement, well or spring sampled, date sample was collected, the EQL
and MDL;

IV.E.2.c. Results of sample analysis for samples collected in the Fall from Pipe and Shotgun
Springs; IV.E.2.d. QA/QC information including Case Narratives from the laboratory and Data
Validation Reports as described in Section D2 of the QAPP (Attachment 3);
IV.E.2.e. Measurements of static water levels as directed by Condition IV.D.6.;
IV.E.2.f. Potentiometric surface maps of the impacted aquifer(s). This map shall indicate the rate and direction of groundwater flow, as indicated by Conditions IV.D.8. and
IV.D.9.

IV.E.2.g. Groundwater Monitoring Well Inspection Checklist (Attachment 2);
IV.E.2.h. Total monitoring well depth data in the year following total well depth measurements for wells listed in Table 2, Attachment 3, as directed by Condition
IV.D.1.c.

IV.E.2.i. Plume maps showing contaminant concentrations of the impacted aquifers, as
directed by Condition IV.D.11.;
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IV.E.2.j. Results of annual model recalibration and a summary analysis of annual model results, as directed by Conditions V.E.2. and IV.E.3.;
IV.E.2.k. Identification of potential “hot spots”meriting attention for further evaluation
(subsequent report will identify trends if any anomalies persist and propose
corrective action or modification to the system).
IV.E.3. If new groundwater surface or contaminant data does not show any discernable differences from the previous groundwater model calibration, and if the previous
groundwater model calibration was deemed satisfactory by the Director, the
Permittee may petition the Director to postpone the groundwater model
recalibration for one year.
IV.E.4. The annual groundwater monitoring reports identified in Conditions IV.E.2. through IV.E.2.k. shall also be submitted electronically. Data submitted
electronically shall be in a format approved by the Director.

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MODULE V - POST-CLOSURE GROUNDWATER CORRECTIVE ACTION

V.A. POST-CLOSURE CORRECTIVE ACTION PROGRAM V.A.1. The Permittee shall maintain a corrective action program as specified in R315-264-100. The purpose of this program shall be to remove or treat hazardous
constituents in the groundwater and to monitor the migration of the hazardous
constituents as outlined in Module IV. The corrective action program shall follow
the requirements of R315-264-90, and this permit. The corrective action program
is intended to be flexible and iterative; therefore, elements of the Corrective Measures Study (CMS) and Corrective Measures Implementation (CMI) may be combined or removed by the Permittee with the written approval of the Director.

V.A.2. As part of the corrective action program, the Permittee shall maintain the
groundwater flow and contaminant transport model approved by the Director. In
accordance with R315-101, the Permittee shall continue to develop a human-
health risk assessment until approved by the Director in writing. V.A.3. In accordance with R315-101, the Permittee shall continue to develop an
ecological risk assessment until approved by the Director in writing.

V.B. CORRECTIVE MEASURE(S) STUDY V.B.1. The Permittee shall submit a CMS to the Director for approval no later than ninety (90) days after approval of both the human-health and ecological risk assessments.
The CMS shall include the following elements:

V.B.1.a. An introduction describing the overall purpose of the CMS;
V.B.1.b. A summary on the current conditions of the contaminant plume in the Area of Compliance, the findings of the groundwater flow/contaminant transport model
and risk assessments;

V.B.1.c. Corrective measure objectives, including proposed media cleanup standards;
V.B.1.d. An evaluation of potential corrective measure technologies which includes an assessment of the long-term reliability, effectiveness and implementability of the
alternatives;

V.B.1.e. A detailed description of any proposed pilot, laboratory and bench scale studies
(pilot or bench scale studies already conducted by the Permittee may be incorporated into the CMS);
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V.B.1.f. A proposal for corrective measure(s) that shall satisfy corrective measure objectives, attain proposed media cleanup standards, control the sources of
releases, and comply with applicable standards for the management of wastes; and

V.B.1.g. A Public Involvement Plan.
V.C. CORRECTIVE MEASURE(S) IMPLEMENTATION
V.C.1. Within ninety (90) days of written approval of the CMS by the Director, the
Permittee shall submit a Corrective Measure Implementation Plan (CMI). The
CMI Plan shall be submitted to the Director for written approval. The CMI Plan
shall describe in detail how the approved corrective measure(s) for contaminated groundwater will be implemented. The CMI Plan shall include:
V.C.1.a. An introduction describing the overall purpose of the CMI Plan;

V.C.1.b. A summary/review of the approved corrective measure(s):

V.C.1.c. Design plans and specifications for the approved corrective measure(s); V.C.1.d. A Construction Work Plan with construction quality assurance objectives;

V.C.1.e. An Operation and Maintenance Plan for the corrective measure(s);

V.C.1.f. A Groundwater Monitoring Plan to demonstrate the effectiveness of the corrective action program;
V.C.1.g. Corrective Measure(s) Completion Criteria to determine when corrective
measure(s) have achieved the cleanup objectives;

V.C.1.h. Data management and documentation procedures; V.C.1.i. Waste management practices;

V.C.1.j. An account of the permits required for the corrective measure(s);

V.C.1.k. A Public Involvement Plan; and V.C.1.l. A schedule for the implementation of corrective measures.

V.C.2. Within thirty (30) days of approval of the CMI Plan by the Director, the Permittee
shall implement the corrective measure(s) according to the schedule contained in
the CMI Plan, and the Permittee shall update the Post-Closure Cost Estimate of Condition III.D. to account for any and all costs associated with the corrective measure(s) project.
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V.D. CORRECTIVE MEASURE(S) IMPLEMENTATION REPORT

V.D.1. Within ninety (90) days of completing construction of the corrective measure(s),
the Permittee shall submit for the Director’s approval in writing a Corrective Measure Implementation Report. In the report, the Permittee shall certify, in accordance with R315-270-11(b), that the project was built according to the
design plans and specifications, and that the corrective measure(s) are performing
adequately. The report shall also include, at a minimum, the following elements:

V.D.1.a. A summary on the construction of the corrective measure(s), including any deviation or modification to the design plans and specifications;
V.D.1.b. Construction quality assurance documentation; and

V.D.1.c. As built drawings or photographs.

V.E. OPERATION AND ASSESSMENT OF THE GROUNDWATER CORRECTIVE MEASURE(S)
V.E.1. The Permittee shall conduct corrective measure(s) as described in the approved
CMI Plan.

V.E.2. The Permittee shall recalibrate the groundwater flow and solute transport model annually. The results of the model recalibration and a summary analysis of the results shall be prepared by the Permittee and submitted as outlined in IV.E.2. If
new groundwater surface or contaminant data does not show any discernable
differences from the previous groundwater model calibration, and if the previous
groundwater model calibration was deemed satisfactory by the Director, the
Permittee may petition the Director to postpone the groundwater model recalibration for one year (IV.E.3.).
V.E.3. The Permittee shall provide a summary on the effectiveness of the corrective
action program in each annual report as required by Condition IV.E.2.

V.E.4. If the Director determines that the Corrective Measure(s) Completion Criteria are not being attained, the Permittee shall modify the permit to install additional corrective measure(s) designed to achieve these cleanup goals. The modification
request shall be submitted within ninety (90) days of the Director’s determination.

V.E.5. If the Permittee discovers that the corrective measure(s) are not operating as
intended, or that operation of the corrective measures are adversely affecting the quality of the groundwater down-gradient, he shall notify the Director within seven days.
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V.F. DURATION OF CORRECTIVE ACTION PROGRAM

V.F.1. The Permittee shall prepare a Corrective Measure(s) Completion Report when the
Permittee believes that the Corrective Measure(s) Completion Criteria have been
attained. The purpose of the Corrective Measure(s) Completion Report is to fully document how the Corrective Measure(s) Completion Criteria have been met and to justify why the corrective measure(s) and/or groundwater monitoring may
cease.

V.F.2. The Permittee shall continue the corrective measures and groundwater monitoring
until the Permittee receives written notification from the Director approving the request to cease corrective measure(s) and/or groundwater monitoring as proposed in the Corrective Measure(s) Completion Report.

V.G. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION

V.G.1. The Permittee shall be financially responsible for the development and implementation of the corrective action program.
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MODULE VI - CORRECTIVE ACTION FOR SOLID WASTE MANAGEMENT UNITS SCHEDULE OF COMPLIANCE VI.A. CORRECTIVE ACTION PROGRAM VI.A.1. The Permittee shall conduct corrective action in accordance with Module VI, for each Solid Waste Management Unit (SWMU) listed in Table 6-B, Attachment 6.
VI.A.2. On or before January 15th of each year, the Permittee shall update Table 6-B,
Attachment 6 to this permit, to specify the status of each SWMU. The most recent update to Table 6-B shall be maintained in the Operating Record and incorporated by reference into Module VI.
VI.A.3. The Director may add SWMUs to Table 6-B, Attachment 6 of this permit, in
accordance with Condition I.E.2. and Condition VI.K. VI.A.4. The Permittee shall submit a facility-wide ecological risk assessment to the Director for approval within 180 days of completing of the Corrective Action
Program.
VI.B. STANDARD CONDITIONS VI.B.1. As specified in the conditions below, the Permittee shall submit all Corrective
Action plans, reports, and schedules, in both hard copy and electronic format, to
the Director for written approval. The Permittee shall revise and resubmit any Corrective Action plans, reports, and schedules as required by the Director in writing and within the time frames specified. Upon request by the Permittee, the Director may approve in writing an extension to any date to submit revised Corrective Action plans, report or schedules.
VI.B.2. All plans for corrective action or interim action shall identify site-specific procedures for containment and classification of any hazardous waste that is expected to be generated. The Permittee shall manage waste generated as a result of a corrective action in a manner to minimize dispersion of the waste to the
environment. The Permittee shall characterize all waste within ninety (90) days of generation/excavation. VI.B.3. Upon written approval by the Director, all final plans, schedules, and reports required by the conditions in Module VI are incorporated by reference into
Module VI. Any non-compliance with such approved plans and schedules shall be deemed non-compliance with this permit and may be subject to enforcement action.
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VI.B.4. The Permittee shall notify the Director of planned fieldwork once the plan for the specific fieldwork has been approved by the Director. The Permittee shall notify the Director at least seven days prior to conducting any sampling or other activities specified in the approved plans and reports described in this Module.

VI.B.5. All raw data, such as sample results, laboratory reports, drilling logs, bench scale or pilot scale data, survey data and other supporting information gathered or generated during activities undertaken pursuant to Conditions in this Module shall be maintained at ATK during the Post-Closure Care Period, unless the Director
approves in writing alternate timeframes upon request of the Permittee. The
Permittee shall provide copies of reports, logs, and other data to the Director upon request. VI.B.6. Failure of the Permittee to submit the information required in this Module or
falsification of any information submitted to the Director is ground for
enforcement action. VI.C. RCRA FACILITY INVESTIGATION
VI.C.1. The Permittee shall conduct a RCRA Facility Investigation (RFI) to determine the
nature, magnitude and extent of known and suspected releases of hazardous wastes or hazardous constituents from each SWMU at the Facility, as identified in Table 6-B, Attachment 6. The data collected during the RFI shall be used to support the evaluation of risk to human health and the environment. The goal of the evaluation is to determine if additional investigation, corrective action, no
further action, or site management is appropriate for each SWMU investigated. The Permittee shall conduct the RFI in accordance with this Module. VI.C.2. The Permittee has submitted RFI Work plans and a RFI Phase I Report for SWMUs as indicated in Table 6-B. Upon review of the Phase I Report by the
Director, the Permittee shall, as directed by this Module, initiate additional investigation, implement corrective action, or take no further action for each SWMU included in the Phase I Report. The Permittee shall conduct the proposed action as approved by the Director.
VI.C.3. By January 15th of each year, the Permittee shall submit, for Director written approval, annual schedules for the SWMUs to be investigated during the next reporting period. The annual update to Table 6-B, required by Condition VI.A.2, shall be included with the annual schedule. The schedule shall identify when the
Permittee plans to conduct work or submit RFI, CAP, Interim Measure, or other
work plans and reports as appropriate for the SWMUs identified in Table 6-B. VI.C.4. The Permittee shall notify the Director of all newly identified SWMUs in accordance with Section VI.K. of this Module.

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VI.C.5. Flexibility in the corrective action process may be allowed in order to promote
efficiency. Therefore, elements of the RFI Work plans, Corrective Action Plans, Interim Measure Plans or their associated reports may be combined or removed by the Permittee upon written approval by the Director. VI.D. RFI WORK PLAN VI.D.1. RFI Work plans, for SWMUs as identified in Table 6-B, shall be submitted to the Director for written approval. The objective of the RFI Work plan is to describe in detail how the nature, magnitude, and extent of known and suspected releases
of solid and hazardous wastes and constituents will be determined. The Permittee
shall implement all RFI Work plans according to the schedule provided in each RFI Work plan as approved by the Director in writing. The Permittee may modify the RFI implementation schedule upon written approval by the Director.
VI.D.2. The RFI Work plan shall be developed based on a site-specific conceptual model
for each SWMU or SWMU group and R315-101. Specifically, the RFI Work plan shall include: VI.D.2.a. A legal description or Global Positioning System (GPS) coordinates for the site;

VI.D.2.b. Historical land use and ownership of the site; VI.D.2.c. Maps or aerial photos showing physical structures, buildings, spill areas, source areas or waste units as appropriate;

VI.D.2.d. Information and maps to describe the geology, hydrogeologic conditions and surface water at the site; VI.D.2.e. An inventory of all current and past waste streams managed at the site, including
process descriptions and suspected contamination source information;
VI.D.2.f. Data quality objectives; VI.D.2.g. A Quality Assurance Plan that describes procedures for sampling and analysis
activities, in accordance with the Attachment 3 QAPP, that will generate data that
meets the data quality objectives. Site-specific data quality requirements shall be addressed as needed; VI.D.2.h. Sampling and analysis plans; and

VI.D.2.i. A schedule for completing the investigation and for submitting the RFI Report. VI.D.3. Upon Director written approval, the Permittee shall implement the RFI according to the Work plan schedule.

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VI.E. RFI REPORT VI.E.1. Upon completion of the RFI, the Permittee shall submit a RFI Report to the Director for written approval according to the RFI Work plan approved schedule. This schedule may be updated as needed based on the progress of the RFI. The
RFI Report shall include:
VI.E.1.a. All data collected during the RFI, including QA/QC information, and other relevant data held by the Permittee;
VI.E.1.b. An analysis and summary of the investigation describing the nature, magnitude
and extent of contamination at the site; VI.E.1.c. Maps, photos and diagrams as appropriate to show the site, sample locations and other relevant features;

VI.E.1.d. Background concentrations of naturally occurring compounds as appropriate; VI.E.1.e. A discussion of the potential for impacts to human health and the environment considering contaminant migration pathways;

VI.E.1.f. A discussion on data gaps and the need for collecting additional samples, if the Permittee recommends additional investigation; VI.E.1.g. A recommendation for additional investigation, corrective action, no further
action, or site management for each SWMU investigated under the RFI Work
plan; VI.E.1.h. A Human Health and Ecological Risk Assessment for each SWMU investigated under the RFI Work plan if the Permittee recommends no further action or site
management; and
VI.E.1.i. A schedule for submitting a Phase II RFI Work Plan, Corrective Action Plan, Site Management Plan or Human Health and Ecological Risk Assessment.
VI.F. ADDITIONAL INVESTIGATION VI.F.1. If the Permittee recommends additional investigation in the RFI Report, the Permittee shall submit a Phase II RFI Work Plan to the Director for written approval in accordance with Condition VI.E.1.i. The Phase II RFI Work Plan
shall include:
VI.F.1.a. An updated conceptual site model based on the results of the RFI; VI.F.1.b. Sampling and analysis plans for Phase II of the RFI;

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VI.F.1.c. Data quality objectives;
VI.F.1.d. Other information as needed to achieve the objective of the RFI; and VI.F.1.e. A schedule for completing the investigation and for submitting the Phase II RFI
Report.
VI.G. CORRECTIVE ACTION VI.G.1. If the Permittee recommends corrective action in the RFI Report or Phase II RFI
Report, the Permittee shall submit a Corrective Action Plan to the Director for
written approval in accordance with Condition VI.E.1.i. VI.G.2. The Director may approve the corrective action method proposed in the Corrective Action Plan, or may require a Corrective Measures Study be prepared
and submitted to the Director for written approval.
VI.G.3. If a corrective measures study is required, it shall include a summary of potential corrective action technologies evaluated by the Permittee. The Permittee shall address the long-term reliability, effectiveness and implementability of the
alternatives.
VI.G.4. The Corrective Action Plan (CAP) shall include: VI.G.4.a. An introduction describing the overall purpose of the CAP;

VI.G.4.b. A summary of the current conditions and conceptual site model for SWMUs included in the CAP; VI.G.4.c. Corrective action objectives, including proposed media cleanup standards;

VI.G.4.d. A proposal for corrective action that shall satisfy corrective action objectives, attain cleanup standards, control the sources of releases, and comply with applicable standards for the management of wastes;
VI.G.4.e. A detailed description of how the corrective action will be implemented;
VI.G.4.f. Engineering design plans and specifications for the corrective action, if applicable; VI.G.4.g. An Operation and Maintenance Plan for the corrective action process, if
applicable; VI.G.4.h. Corrective action completion criteria to determine when corrective measures have achieved the cleanup objectives;

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VI.G.4.i. A monitoring plan, if applicable, that describes how the effectiveness of the
corrective action will be assessed; VI.G.4.j. Detailed plans for confirmation soil sampling or other sampling as appropriate. Data quality objectives and a data quality assurance plan shall be included with
the sampling plan. Site specific data quality requirements shall be addressed as
needed; and VI.G.4.k. A schedule for the implementation of the corrective action and submittal of progress reports and final Corrective Action Report.

VI.G.5. Upon written approval of the CAP, the Permittee shall implement the corrective action according to the schedule contained in the CAP. VI.G.6. The Permittee shall submit a Corrective Action Report in accordance with the
schedule in the approved CAP. The Corrective Action Report shall include:
VI.G.6.a. A description of the corrective actions that were conducted, including any actions that deviated from the approved plan;
VI.G.6.b. An analysis and summary of the corrective action results and whether the
approved corrective action objectives and cleanup standards were met; VI.G.6.c. All data and quality assurance collected from confirmation or other sampling conducted to determine if cleanup standards have been met;

VI.G.6.d. Recommendations for additional corrective action, no further action, or site management for the SWMUs addressed in the Corrective Action Report; and VI.G.6.e. A schedule for submitting a revised Corrective Action Plan or Human Health and
Ecological Risk Assessments.
VI.H. DETERMINATION OF NO FURTHER ACTION VI.H.1. At any time during an investigation of a SWMU, the Permittee may petition the
Director for a determination of no further action (NFA).
VI.H.2. If the Permittee recommends NFA in the RFI Report, Phase II RFI Report, Interim Measures Report or after corrective action for a SWMU has been completed, the Permittee shall submit Human Health and Ecological Risk Assessments to the Director for written approval.
VI.H.3. The Human Health and Ecological Risk Assessments shall be conducted in accordance with R315-101.
VI.H.4. A proposal for NFA shall contain information based on the SWMU Assessment
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Report, identified in Condition VI.K.2., the RFI Report, the Interim Measure
Report, the Corrective Action Report or any other information that demonstrates that: VI.H.4.a. Hazardous waste or hazardous constituents are not detected; or

VI.H.4.b. Hazardous waste or hazardous constituents have been detected, but are below background concentrations; or VI.H.4.c. Hazardous waste or hazardous constituents have been detected, but do not pose a
threat to human health or the environment; in accordance with R315-101.
VI.H.5. A determination of NFA, in accordance with Condition VI.H.1., shall not preclude the Director from requiring further investigations, studies, or remediation at a later date if new information or subsequent analysis indicates a
release or potential of a release from a SWMU at the Permittee’s facility.
VI.I. SITE MANAGEMENT PLAN VI.I.1. Any SWMU that does not meet the NFA requirements of Condition VI.H.
following corrective action, or otherwise needs site management, as described in
R315-101, shall be managed to control the risk to human health and the environment. VI.I.2. If the Permittee proposes site management for SWMUs that do not qualify for NFA, the Permittee shall submit to the Director for written approval a Site
Management Plan (SMP). The SMP shall be based on the results of a Human Health and Ecological Risk Assessment conducted in accordance with R315-101. The Risk Assessments and Site Management Plan shall meet the requirements of R315-101 and at a minimum include the following:
VI.I.2.a. A description of the SWMU and summary of the site characterization as described in the RFI Report, including a summary of the magnitude, nature, and extent of the contamination; VI.I.2.b. A summary of the conclusions of the Human Health and Ecological Risk
Assessment, including identification of all potential receptors, and a conceptual model that describes the actual and potential human and environmental impact(s) from the residual contaminants at the site; VI.I.2.c. A detailed description of how the risk at the SWMU will be managed to protect
human health and the environment (e.g., fencing, inspection, maintenance, monitoring, etc.); VI.I.2.d. An inspection program that will be used to monitor the SWMU or group of SWMUs to ensure that the site conditions have not changed and that the site
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conceptual model is still appropriate. The inspection program shall include a
description of what will be inspected, the inspection frequency, a description of what the inspector should evaluate, how to document and resolve problems, and an inspection checklist;
VI.I.2.e. Photos and figures of the SWMU or group of SWMUs, as needed, to show the
location, explain access, and highlight distinctive features; VI.I.2.f. An environmental covenant developed in accordance with Utah Code Section 57-25-101 et seq., and;

VI.I.2.g. A legal description and survey plat of the property. VI.I.3. The Director may provide for public participation prior to approving a SMP as required by R315-101-7.
.
VI.I.4. The Permittee shall implement the SMP within thirty (30) days of receipt of written approval by the Director. If approval of the SMP or environmental covenant is delayed, the Director may require the Permittee to begin inspection, maintenance, monitoring, or other activities prior to SMP approval.

VI.J. INTERIM MEASURES VI.J. The Permittee shall notify the Director upon discovery of a release of hazardous
constituents from a SWMU. If the Permittee or the Director determines that a
release or potential release of hazardous waste or hazardous waste constituents
from a SWMU poses a threat to human health or the environment, the Director may require the Permittee to perform interim measures. The Permittee may also voluntarily perform interim measures. In determining the need for interim measures, the Director or the Permittee shall consider the following: VI.J.1.a The actual or potential exposure to human or environmental receptors; VI.J.1.b. The potential for further environmental degradation without interim measures; VI.J.1.c. The presence of containers of hazardous waste, or hazardous waste constituents
that may result in a release; VI.J.1.d. Presence and concentration of hazardous waste, or hazardous waste constituents in the soil that have the potential to migrate to surface or ground water;
VI.J.1.e. Weather conditions that may promote the spread of contamination; VI.J.1.f. Risks of fire, explosion, or accident; VI.J.1.g. The time required to develop and implement a final remedy;
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VI.J.1.h. Funding, contracting, or other administrative situations; and VI.J.1.i. Other situations which may pose a threat to human health or the environment.
VI.J.2. If the Director or the Permittee determines that interim measures are needed, the
Permittee shall submit an Interim Measures Plan (IMP) for Director approval. VI.J.3. The IMP shall identify specific actions to be taken to implement the interim measures for removing the threat to human health or the environment. The IMP
may be subject to public comment as determined necessary by the Director. The
IMP shall include, but not be limited to the following: VI.J.3.a. Proposed mitigation measures for the potential threat to human health and the environment that will be consistent with any long-term solution;

VI.J.3.b. Sampling and data collection plan, data quality objectives, and quality assurance plan; VI.J.3.c. Design plans and specifications, construction requirements, operation and
maintenance requirements, project schedules;
VI.J.3.d. Construction quality assurance objectives, inspection and documentation requirements; and,
VI.J.3.e. A schedule for the implementation of the interim measures and the submittal of
progress reports and final Interim Measures Report. VI.J.4. Upon written approval by the Director, the Permittee shall implement the interim measures as described in the approved IMP.

VI.J.5. The Permittee shall submit an Interim Measures Report to the Director for written approval in accordance with the schedule in the approved IMP. The Interim Measures Report shall include:
VI.J.5.a. A description of the interim measures that were conducted, including any
measures that deviated from the approved plan; VI.J.5.b. An analysis and summary of the interim measures results including whether the threat to human health or the environment was successfully removed or mitigated;

VI.J.5.c. All data and quality assurance collected from confirmation or other sampling conducted to determine if the objectives of the interim measures were met; VI.J.5.d. Recommendations for additional corrective action, no further action, or site
management for the SWMUs addressed in the Interim Measures Report;
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VI.J.5.e. A schedule for submitting a RFI Work plan, Corrective Action Plan or Human Health and Ecological Risk Assessment. VI.K. NOTIFICATION REQUIREMENTS FOR AND ASSESSMENT OF NEWLY IDENTIFIED SOLID WASTE MANAGEMENT UNITS VI.K.1. The Permittee shall notify the Director in writing within thirty (30) days of discovery of any newly identified sites, which the Permittee believes may meet the definition of a SWMU. The notification shall include all available
information about the site as needed to justify a decision about the status of the
site. VI.K.2. Based on the information provided by the Permittee, and a possible site visit, the Director will determine whether the site should be declared a SWMU, or the site
should be addressed through the interim measures process outlined in Section
VI.J. of this Module (if managed as an interim measure the site does not need to be added to Table 6-B of Attachment 6). VI.K.3. If it is determined that the site should be declared a SWMU, it shall be addressed
through the RFI process outlined in Sections VI.D. and VI.E. of this Module and
it shall be added to Table 6-B when it is updated in accordance with VI.A.2. VI.K.4. Within thirty (30) days of making a decision as described in Condition VI.K.2., the Permittee shall provide a schedule for the submittal of an Interim Measures
Plan or RFI Work Plan.
VI.L. REPORTING REQUIREMENTS VI.L.1. The Permittee shall submit to the Director written Semiannual Progress Reports
of all activities conducted pursuant to the Conditions of Module VI.
VI.L.2. The Semiannual Progress Reports shall be submitted each year on March 15th and September 15th and shall contain:
VI.L.2.a. An update on the status of RFI work conducted with a description of the work
completed; VI.L.2.b. Summaries of all problems or delays encountered during the reporting period and actions taken or to be taken to rectify problems; and
VI.L.2.c. A description of any work that deviated from the approved RFI Work plan. VI.L.3. Upon written approval from the Director, the Permittee may receive extensions for report due dates for the submittals required by Module VI.

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VI.L.4. The Director may require the Permittee to conduct new or more extensive
assessments, investigations, or studies, as needed, based on information provided in these progress reports or other supporting information. IV.M. FINANCIAL ASSURANCE FOR CORRECTIVE ACTION
IV.M.1. The Permittee shall be financially responsible for the development and implementation of the corrective action program in accordance with R315-264-101(b).
IV.N. PUBLIC PARTICIPATION IV.N.1. Prior to approving any RFI, CAP, IMP, SMP, or NFA petition, the Director may provide for public participation as defined by R315-101-7.