DSHW-2018-010584 - 0901a0688091a633

DSHW-2018-010584 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
November 7, 2018
Kris Blauer, Manager
Environmental Services ATK Launch Systems – Promontory P.O. Box 707 Brigham City, Utah 84302-0707

RE: Spring 2018 Semiannual Groundwater Monitoring Report UTD009081357 Dear Mr. Blauer:

The Division of Waste Management and Radiation Control has completed its review of the Groundwater Monitoring Report for Spring 2018. Based on our review of the Case Narratives and Data Validation Report contained in the Monitoring Report, it appears that a significant portion of the organics data should be qualified as biased low due to continuing calibration verification recoveries that are outside of
quality control limits. This same issue was discussed in our letter to ATK dated April 12, 2018.
AQS’ recommendation to qualify data that has calibration recoveries outside of quality control limits is based on EPA guidance. The Division understands that going back and flagging the data can be a significant burden and that the data is still considered usable. However, there are four issues that the
Division is concerned about regarding data quality at ATK:
1. The problem with potentially biased organics data appears to be a common and recurring issue. For 30 out of the 35 wells included in the Spring 2018 Report, approximately 25% of the organic analytes were outside of quality control limits.
2. How will the use of qualified data affect the results of the Human Health Risk Assessment? 3. Will the use of qualified data be evaluated in the uncertainty section of the risk assessment? 4. If the groundwater data is not flagged in the tables as recommended, will the risk assessor be
aware of biased data? (Over)

Please provide a response at your earliest convenience describing how ATK will address the issues identified above. If you have any questions, please call Jeff Vandel at [phone].

Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control STA/JV/km
c: Lloyd Berentzen, MBA, Health Officer, Bear River Health Department
Grant Koford, EHS, Environmental Health Director, Bear River Health Department Amy Hensley, USEPA, Region 8 Paul Hancock, ATK Launch Systems