DSHW-2010-035779 - 0901a068801a981c

HAND DELIVERED ;ioio. o,3i3^9
JUN 3 0 2ora
R7nnFvnnn UTAH DIVISION OF 8200-FYl 1-013 SOLID & HAZARDOUS WASTE
Mr. Scott T. Anderson, Executive Secretary
State of Utah Department of Environmental Quality •^Uj\f 9 n on«n
Division of Solid and Hazardous Waste ^^'^
195 N.1950 W. ^^VlSmifJ^OF
P.O. Box 144880 ''^^QUALITY
Salt Lake City, Utah 84114-4880
Attention: Jeff Vandel
Re: ATK Launch Systems-Promontory EPA ID number UTD009081357
Lines of Evidence for Sources of Chromium and Risks at ATK Promontory
Monitoring Wells
Dear Mr. Anderson:
ATK has been researching the sources for chromium found in many of the monitoring
wells at Promontory. While our past research into the cluster of wells at an old
photographic drain field by building M-508 has demonstrated a source for chromium due
to old disposal practices, no disposal source was known for the remainder of the many
wells where some high levels were detected. The attached report provides information
we have collected that shows a strong correlation to the corrosion of the 316 stainless
steel used in construction of the wells and the source of the chromium. With this
evidence of the corrosion of the wells, the form of the chromium and also the risks can be
determined. We believe this information will be helpful in the groundwater risk
assessment currently being conducted at Promontory.
If you have any questions conceming this report please contact Paul Hancock at
[phone].
Sincerely
David P. Gosen, P.E., Director
Environmental Services
HAND DELIVERED
JUN 3 0 2010
UTAH DW\SI0r4 OF
SOLID & HAZARDOUS WASTE
Lines of Evidence for the Source of Chromium
and Risks at ATK Promontory Groundwater
Monitoring Wells.
June 2010
Lines of Evidence. Sources of Chromium and Risks
At ATK Promontory Monitoring Wells
June 2010
Lines of Evidence for the Source of Chromium and Risks at ATK Promontory
Groundwater Monitoring Wells,
Data from sampling several of the ATK Promontory groundwater monitoring wells has
shown higher levels of total chromium. In the process of performing a human health and
ecological risk assessment on the Promontory groundwater contamination, the question
has arisen regarding the source ofthe chromium and if the chromium represents a risk to
human health. Data has been collected to answer these questions.
What is the source of the high chromium found in the wells?
While the small cluster of monitoring wells at the old RCRA closed M-508 photographic
drain field has been investigated and known to have been a source for chromium
disposal, other nionitoring wells have been found with higher levels with no known
disposal source. This report documents investigation into those wells.
Moniioring well construction at Promontory started in 1986. At this time, the EPA
requirement was to use stainless steel for monitor well screens and pumps as it was
believed to be inert to solvents or other contamination that may be found in the water. As
a consequence, a large number of wells at Promontory were constructed with 316
stainless steel screens and pumps in these early years. This changed in later years to PVC
screens. However, even these PVC wells were constructed using 316 stainless steel
screen centralizers and connectors. One of the primary ingredients in 316 stainless is
chromium at 16 to 18 percent. Molybdenum is also used at 2 to 3 percent.
The following observations have been made of stainless steel corrosion in the
Promontory monitoring wells.
• While sampling the wells with stainless steel screens, the purge water typically
has a high amouni of particulate whh a rusty red appearance, clearly indicating
corrosion. The samples are not Hltered prior to collection in nitric acid fixed
bottles for analysis.
• Dedicated stainless steel pumps in the wells have stopped fiinctioning after a few
years and when pulled they are highly corroded. The corrosion has been
identified as the cause ofthe pump malfiinction.
• Down-hole camera views ofthe wells show that the stainless sleel screens are
corroded which in some cases has necessitated redevelopment and cleaning of the
screens to bring them back into flill service.
A comparison was made ofthe analytical data between the wells constructed with PVC
screens with wells containing stainless steel screens. From this data it is evident that
1 I Page
Lines of Evidence, Sources of Chromium and Risks
At ATK Promontory Moniioring Weils
June 2010
corro-sion ofthe stainless steei is the source of the high chromium and molybdenum. This
compaiison is found in Attachment 1.
Graphs were made showing chromium analytical data over time for several oflhe
stainless steel wells. This data shows that in most cases, after 2008 there was a
significant increase in chromium reported. This correlates lo a new no-purge sampling
technique called the Hydrasleeve that was implemented in 2008 resulting in higher
amounts of rust particles in the sample. These graphs are in Attachment 2.
The cause ofthe corrosion oflhe stainless sleel is believed lo be the chloride content of
the water and possibly iron fouling bacteria.
Does the chromium in the wells represent a risk to human health?
Chromium exists in two forms, either chromium III or chromium VI. Chromium VI is
known to be toxic and is also mobile.
Dr. Marvin Hawkins, an ATK chemist who specializes in corrosion, was consulted
regarding the stainless steei corrosion in the wells. Attachment 3 is a memo from Dr.
Hawkins describing why the corroding welis at Promontory are in the form of cliromium
IH and an explanation oflhe extreme conditions required to convert chromium III to
chromium VI.
From Dr Hawkins memo, the literature shows that the type of chromium lhat forms the
passivation layer in stainless steel is chromium III, thus the corroded stainless steel
particles contain chromium III. Chromium VI formation requires highly oxidizing and
acidic conditions. ORP measuremenls for several wells and pH ranges including all welis
demonstrate that these conditions are not feasible in groundwater at Promontory.
Anachment 4 contains the ORP values and pH ranges.
The EPA Regional Screening Level for May 2010, has a tapwater chromium III
(insoluble salts) screening level of 55,000 fig/L. The highest chromium reported in the
Promontory wells is 49,000 |ig/L.
Given these multiple lines of evidence. ATK believes that the risk from chromium found
in the corroding wells is negligible as it is in the stable form of chromium III, not mobile,
and could only be ingested if the wells were used as a drinking water source. Even then,
if routinely used for drinking water, regular pumping ofthe well would greatly reduce the
amount ofthe corroded particles that accumulate.
2 I P a ge
Lines of Evidence, Sources of Chiomium and Risks
At ATK Promontory Moniioring Wells
June 2010
significant increase in chromium reported. This correlates to a new no-purge sampling
technique called the Hydrasleeve that was implemented in 2008 resulting in higher
amounts of rusl particles in the sample. These graphs are in AUaclunent 2.
The cause of the corrosion of the stainless steel is believed lo be the chloride content of
the waler and possibly iron fouling bacteria.
Does the chromium in the wells represent a risk to human health?
Chromium exists in two forms, either chromium 111 or chromium VI. Chromium VI is
known lo be toxic and is also mobile.
Dr. Mar\'in Hawkins, an ATK chemist who specializes in corrosion, was consulted
regarding the stainless steel corrosion in the wells. Attachment 3 is a memo from Dr.
Hawkins describing why the corroding wells at Promontory are in the form of chromium
III and an explanation ofthe extreme conditions required to convert chromium III to
chromium VI.
From Dr Hawkins memo, the literature shows that the type of chromium that forms the
passivation layer in stainless steel is chromium 111, thus the corroded stainless steel
particles contain chromium III. Chromium VT formation requires highly oxidizing and
acidic conditions. ORP measurements for several wells and pH ranges including all wells
demonstrate that these conditions are not feasible in groundwater at Promontory.
Attachment 4 contains the ORP values and pH ranges.
The EPA Regional Screening Level for May 2010^ has a tapwater chromium III
(insoluble salts) screening level of 55,000 |ig/L. The highest lotal chromium reported in
the Promontory wells is 49,000 fig/L.
Given these multiple lines of evidence, ATK believes that the risk from chi omium found
in the corroding wells is negligible as il is in the stable fonn of chromium 111, not mobile,
and could only be ingested if the wells were used as a drinking water source. Even then,
if routinely used for drinking water, regular pumping of the well would greatly reduce the
amouni ofthe corroded particles that accumulate.
2|Page
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Attachment 1
Comparison of Metals Concentrations in Wells Completed with Stainless Steel and PVC
Groundwater Chromium and Molybdenum Concentrations (/Jg/L) in Stainless Sleel and PVC Wells at
Promontory
WeH Number Stainless Steel Wells Weil Number PoJv>'inyJ Chloride Wells
Chromium Molybdenum Chromium Molybdenum
A-10 20600 636 G-1 5 0.5
A-2 163 0.5 G-2 73 0.5
A-3 323 19.5 G-3 5 0.5
A-6 5 0.5 G-4 5 0.5
A-7 5 0.5 G-5 5 0.5
A-8 24 I I G-6 105 0.5
A-9 7880 455 G-7 5 0.5
B-1 9520 356 G-8 12 0.5
B-IO 5 0.5 H-I 5 0.5
B-3 10700 467 H-IO 5 0.5
B-4 8910 422 H-2 5 0.5
B-5 3730 122 H-3 5 0.5
B-6 7290 556 H-4 5 0.5
2170 250 H-5 850 0.5
B-8 10500 856 H-6 5 0.5
B-9 293 0.5 H-7 5 0.5
C-I 948 61.1 H-8 24 0.5
C-5 6440 266 H-9 5 0.5
C-6 5 53.6 J-I 5 4.1
C-7 7130 174 J-2 1 i 0.5
C-8 10500 701 J-3 5 0.5
D-l 5 0.5 J-4 5 0.5
D-3 5 38.8 J-5 5 0.5
D-4 39 2.3 J-6 5 0.5
D-5 458 8.8 J-7 5 0.5
E-I 8050 166 J-8 5 0.5
E-iO 49000 2740 M508-I 109 0.5
E-2 32500 2390 M508-2 120 9.03
E-3 3490 184 M 508-3 513 4.4
E-4 6650 258 M 508-4 252 3.2
E-5 30100 2560 M508-BI 156 0.5
E-6 8270 949 M636-B1 5 0.5
E-8 5 0.5 P-1 5 26.3
E-9 2810 99.8 P-2 5 1.6 J
F-l 13300 1020 P-6 5 0.5
F-3 16100 814 P-7 92 0.5
F-4 521 0.5 P-8 42 7.58
LF-I 5130 291 P-9 22 0.5
LF-2 I 1300 1080 X-5 14 0.5
LF-3 8350 605
LF-4 4550 388
X-4 32 7.98
Average
Concentration 7502 464 64 2
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ATK
Memorandum Launch Systems
LWI-FY11 -D0274 P.O. Box 707
Brigham City, UT 84302-0707
Date: June 10, 2010 From: Marvin Hawkins
Subject: Ground Water Chromium (+6) Intrusion From Organization: Analytical Research
Corrosion of Stainless Steel Well Screens
To: Paul Hancock M/S: 242
CC: ping Li. Michael Killpack, Frank Bares Extension: 8476
LWI: n/a Procedure: n/a
Proj./Task: N214-SU18W Instrument ID: n/a
SDG: Reviewed By: Frank Bares
Introduction
Wells that are drilled for either water production or ground water monitoring, contain screens to restrain sand
and rocks from entenng the pump zone. These screens are often nnanufactured from 316 stainless steel or
other corrosion resistant materials such that they will remain intact as long as possible. If the screen material is
stainless steel, it may contain chromium and other alloying materials that increase corrosion resistance. It is the
chromium content that is of interest in this memorandum as it has been considered a potential environmental
contaminant (as CZ^} being dispersed into the ground water due to corrosion of the stainless steel screens.
Evaluation
A limited literature search^"" has provided information to evaluate lhe potential dissolution and dispersal of Cr^^
from the screens as they corrode in the ground water. The concentration of the chromium in the base 316
stainless steel alloy is between 16 and 18%V This is a significant amount of chromium but it is added to the
alloy as elemental chromium not as the hexavalent species. The 316 stainless steel is resistant to chloride (Cl")
attack in potable water up to concentrations of 1000 ppm^ and 400 ppm in sewage sludge^. Typical oxidation of
the elemental chromium would take it to the trivalent Cr*^ oxide state which is stable (-0.744 V EMF") and not
as significant environmental concern as the toxic Cr*^ species. Indeed the premise of the Palmer et. al. paper^
is that the existence of the Cr"^^ can be mitigated and passively remediated due to time and exposure to ground
water and soil/rock.
In order to convert Cr'^ to Cr*^, it requires between 1.232 and 1.350 volts (1232 and 1350 mV respectively)
EMF depending on the chromium specie being considered. In addition, it requires a strongly acidic
environment. If the environment is neutral or basic it will not further oxidize*
Conclusion
The corrosion of the stainless steel screen is most likely associated with chloride attack of the alloy. The Cl'
attacks the oxide layer and improves the solubility ofthe oxides. This weakens the passivating oxide layers of
the iron and chromium. Some of the wells at ATK are probably exposed to higher chlonde levels due to the
proximity to the Great Salt Lake and nominal salinity of local ground waters. The resulting chromium (and iron)
oxidation products, red/brown rust, will be the Cr203 oxide (and Fe203) which are stable in soil and ground
water and poses a much reduced risk relative to the hexavalent Cr species. If there is oxidation to the Cr*^
species the natural attenuation and reduction of the hexavalent species will produce the more benign trivalent
species^. Therefore, the risk of environmental exposure of hexavalent chromium into the ground water is
unlikely and if produced will attenuate rapidly and should not be considered an extreme risk. In addition it is not
recommended to remove or replace the existing screens and placement of 316 stainless steel screens into
future wells should not be considered an environmental exposure.
Marvin Hawkins, Ph.D.
References
1. The "AZo Journal of Materials Online".. AZoM™.com Pty. Ltd., WWW.AZOM.com, ASTM /\240/A240M.
2. Palmer, C. D., Puis, R. W., 1994. Natural Attenuation of Hexavalent Chromium in Groundwater and
Soils. EPA Ground Water Issue, EPA/540/5-94/505.
3. Bradford, S. A. Corrosion Control, Second Edition, p 207.
4. Lide, R. R. Editor-in-Cheif, CRC handbook of Chemistry and Physics, 76'^ Edition, 1995-1996, p 8-22.
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Attachment 4
ORP results for various Promontory wells and springs
Well ORP (mV) Date DO (mg/l) pH range in wells Is 7.2 to 7.6
T-2 -16.5 Jun-07 6.3
A-1 195.7 Jun-07 8.3
-
C-3 -49.3 Jul-07 1.71 To convert Cr III to Cr VI, It takes 1.350 Volts or in
ORP vernacular it takes 1350 mV. In addition it
takes a very strongly acidic environment. If it is
neutral or basic it would not convert.
-D-2 116 Jul-07 7.12
To convert Cr III to Cr VI, It takes 1.350 Volts or in
ORP vernacular it takes 1350 mV. In addition it
takes a very strongly acidic environment. If it is
neutral or basic it would not convert.
-C-2 4.4 Jul-07 3.32
To convert Cr III to Cr VI, It takes 1.350 Volts or in
ORP vernacular it takes 1350 mV. In addition it
takes a very strongly acidic environment. If it is
neutral or basic it would not convert.
-
D-6 211 Jul-07 6.51
To convert Cr III to Cr VI, It takes 1.350 Volts or in
ORP vernacular it takes 1350 mV. In addition it
takes a very strongly acidic environment. If it is
neutral or basic it would not convert.
-
D-3 -149 Jul-07 0.36
To convert Cr III to Cr VI, It takes 1.350 Volts or in
ORP vernacular it takes 1350 mV. In addition it
takes a very strongly acidic environment. If it is
neutral or basic it would not convert.
-
C-1 -41 Jui-07 7.5
To convert Cr III to Cr VI, It takes 1.350 Volts or in
ORP vernacular it takes 1350 mV. In addition it
takes a very strongly acidic environment. If it is
neutral or basic it would not convert.
-
A-5 17.1 Sept. 2007 8.89
-
D-4 -43.6 Jul-07 8.74
T-1 442 Jun-07 2.48
D-6 280 Jun-07 0.6
J-1 -20.3 Sept. 2009
M-636 -22.9 Sept. 2009
M-508-1 -23.7 Sept. 2009
M-508-2 -5.7 Sept. 2009
M-508-B1 3.2 Sept. 2009
M-508-3 -3.1 Sept. 2009
M-508-4 -2.1 Sept. 2009
J-8 -23.5 Sept. 2009
J-2 31 Oct. 2009
J-3 27.9 Oct. 2009
M-114 23 Oct. 2009
J-4 11.2 Oct. 2009
M-39 62 Oct. 2009
J-6 43.2 Oct. 2009
J-5 39.1 Oct. 2009
H-5 144 Oct. 2009
H-6 101.1 Oct. 2009
EW6 -47.2 Oct. 2009
H-l -211.6 Oct. 2009
H-2 19.1 Oct. 2009
H-3 -132 Oct. 2009
H-4 35.1 Oct. 2009
H-7 114.8 Oct. 2009
H-8 104.3 Oct. 2009
H-9 18 Oct. 2009
H-10 -48.9 Oct. 2009
X-5 -32 Oct. 2009
Shotgun -5.5 Oct. 2009
pipe -42.6 Oct. 2009
Fish -49.5 Oct. 2009
Horse -43.1 Oct. 2009 1