DSHW-2012-002706 - 0901a068802c3682

April 3, 2012
8200-FY13-001
Scott T. Anderson, Director
Department of Environmental Quality
Division of Solid and Hazardous Waste
ATTN: Jeff Vandel
P.O. Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
Division of
Solid and Hazardous Waste
APR 0 6 2012
2b\2--0D2:7DL.
RE: ATK Launch Systems Inc. - Promontory Facility, EPA ID# UTD009081357, Corrosion
Investigation Plan for Monitoring Well Screens at ATK Promontory
Dear Mr. Anderson,
ATK has been discussing with Jeff Vandel of your office, the need for a plan to investigate the
amount of corrosion in the stainless steel screens found in the older monitoring wells at our
facility. Attached please find a proposed plan for your approval.
If you or your staff have questions, or need additional information, please contact Paul Hancock
at [phone].
Sincerely,
Paul V. Hancock, Manager
ATK Environmental Services
ATK
Division of
Solid and Hazardous Waste
APR 0 6 2012
2V\Z-CD2J0U>
Corrosion Investigation Plan for Monitoring
Well Screens at ATK Promontory
March 2012
Corrosion Investigation Plan for Monitoring
Well Screens at ATK Promontory
March 2012
Corrosion Investigation Plan for Monitoring Well Screens at ATK Promontory
Purpose
Corrosion of stainless steel well screens in ATK Promontory groundwater monitoring
wells has been established through visual and analytical data. An ongoing concem with
the stainless steel well screens is that corrosion could potentially become heavy enough
to fill in the slots and limit water flow into the well. This plan makes recommendations
for evaluating those well screens
Background
Monitoring 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 amount of particulate with a rusty red appearance, clearly indicating
corrosion. The samples are not filtered prior to collection in nitric acid fixed
bottles for analysis.
• Dedicated stainless steel pumps in the wells have stopped functioning after a few
years and when pulled they are highly corroded. The corrosion has been
identified as the cause of the pump malfunction.
• In 2006, as part of a pilot test of perchlorate remediation, a down-hole camera
was placed in well B-6 to determine if corrosion was present in the well screens.
Heavy layers of corrosion were observed and subsequently the well was cleaned.
A comparison was made of the analytical data between the wells constructed with PVC
screens with wells containing stainless steel screens. From this data it is evident that
corrosion of the stainless steel is the source of the high chromium and molybdenum. This
comparison is found in Attachment 1.
1 I P a g e
Corrosion Invesfigation Plan for Monitoring
Well Screens at ATK Promontory
March 2012
Investigation Plan
The monitoring wells using stainless steel screens were installed in phases starting with
the D series wells in 1986, followed by the A, B, C, E, F and LF series. The amount of
corrosion could be both a function of age and also the groundwater total dissolved solids
in the well. These variables will be part of the investigation. It is also possible that iron
fouling bacteria could be a factor to the corrosion; however, this is more difficult to
establish or investigate.
In 2007, prior to the start of a vegetable oil injection pilot test, several of the D series
wells screens were cleaned using a standard drinking water well cleaning process to
remove potential corrosion. While corrosion in these wells was not visually confirmed, it
was determined to be an important precaution to ensure representative samples were
collected.
ATK has since procured a down hole camera that will be used to inspect the conditions of
the well screens in this investigation. The wells that will be investigated using a down
hole camera are listed in Table 1.
Table 1
Wells to be inspected Using Down-hole Camera
Well .' -^Bjisis.for i^pectw
D-6 Cleaned in 2007, determine
how quickly corrosion
retums and condition of
oldest wells.
A-10 Next oldest well series; in
area of relatively low TDS
Analytical testing indicates
some of the highest
corrosion
B-4 Older well in area with
increasing TDS
E-6 Moderate aged well, in area
with increasing TDS
F-3 Relatively new well in area
with higher TDS
LF-2 Newest Stainless Steel
Well Series
2 I P a g e
Corrosion Investigation Plan for Monitoring
Well Screens at ATK Promontory
March 2012
The down-hole camera allows for videos or pictures to be collected. This visual
information as well as observations recorded in a log book will be assembled for each
well investigated. Once the invesfigation is completed, inferences can be made as to the
main contributor to the well screen corrosion and then further recommendations.
An unknown condition will be the camera visibility in wells containing high particulates
or rust. Other provisions or plan changes may need to be made in those cases. ATK will
contact the Utah Division of Solid and Hazardous Waste (DSHW) in those situations of
significant deviations in the plan.
Investigation Plan Schedule
Once approval of the plan is obtained from the DSHW the investigation will start. It is
anticipated that the investigation will be ongoing through September of 2012, with a
report completed in October 2012.
3 11^ a g e
Attachment 1
Comparison of Metals Concentrations in Wells Completed with Stainless Steel and PVC
Groundwater Chromium and Molybdenum Concentrations (/ig/L) in Stainless Steel and PVC Wells at
Well Number Stainless Steel Wells Well Number Polyvinyl 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 11 G-6 105 0.5
A-9 7880 455 G-7 5 0.5
B-1 9520 356 G-8 12 0.5
B-10 5 0.5 H-1 5 0.5
B-3 10700 467 H-10 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
B-7 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-1 948 61.1 H-8 24 0.5
C-5 6440 266 H-9 5 0.5
C-6 5 53.6 J-1 5 4.1
C-7 7130 174 J-2 11 0.5
C-8 10500 701 J-3 5 0.5
D-1 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-1 8050 166 J-8 5 0.5
E-10 49000 2740 M508-1 109 0.5
E-2 32300 2390 M508-2 120 9.03
E-3 3490 184 M508-3 513 4.4
E-4 6650 258 M508-4 252 3.2
E-5 30100 2560 M508-B1 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-1 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-1 5130 291 P-9 22 0.5
LF-2 11300 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