DSHW-2014-016071 - 0901a068804c4112

INSPECTION REPORT FOR:
A TK Launch Systems Inc. -Promontory
DATES OF INSPECTION:
May 22 and August 12, 2014
FACILITY ADDRESS:
30 miles northwest of Brigham City, Utah
P.O. Box 707
Brigham City, UT 84302-0707
FACILITY CONTACT:
George Gooch
Manager, Environmental Services
[phone]
NOTIFICATION:
UTD009081357 LQG, TSD
APPLICABLE REQUIREMENTS:
RCRA Permit, UAC R315-8-6
TYPE OF INSPECTION:
Operation and Maintenance Inspection (O&M)
PARTICIPANTS:
JeffVandel, Inspection Leader, DSHW
Jon Parry, DSHW
Paul Hancock, A TK
Alan Lee, A TK
J-01'/-0 J/,1) 71
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WEATHER CONDITIONS:
May 22,2014
Clear, sunny, approximately 65'F
August 12,2014
Clear, sunny, approximately 85'F
TIME IN:
May 22,2014: 10:00 AM
August 12,2014:9:45 AM
TIME OUT:
May 22,2014: 3:00 PM
August 12,2014: 3:20 PM
REPORT PREPARED BY:
Jeff Vandel
Facilitv Description
Thiokol Chernical Corporation first began operations at the ATK Launch Systerns - Promontory
(ATK) facility in 1956. ATK and its predecessors have been primarily involved in the research,
testing and production of rocket motor propellants. The manufacturing processes at ATK -
Promontory include the preparation and mixing of high-energy ingredients, casting and curing of
the propellant formulations, assembly of rocket motor segments and military flares, and quality
control testing of finished products. These activities have included the production and testing of
motors for the Space Shuttle, the wash-out and reloading of Minuternan ICBMs, and many other
projects for the Department of Defense (DOD).
The ATK facility is a 20,000 acre site that is remotely located in Box Elder County,
approximately 30 miles northwest of Brigham City, Utah. The ATK plant is divided into four
major areas designated as: Defense and Launch Vehicle (DLV), Administrative and
Manufacturing Area (or Space), Test Area, and High Performance Propellant Development Area
(or Plant III). There are approximately 675 buildings located on the four areas that comprise the
ATK plant. The closest inhabitants to the facility live approximately one mile to the west of the
adminishation area on a cattle ranch.
Currently, ATK's primary activities consist of: military flare production; work on the next
generation of the Space Launch System, 5 segment solid rocket motor; restoration of stages one
and two of Minuteman motors; destruction of third stage Minuteman motors by open burning;
rocket motor casing work for Castor, GEM 40 and GEM 60 motors and production work on
Trident D-5 motor nozzles.
Facilitv Backsround/Source of Groundwater Contamination
In June of 1986, ATK was issued a Notice of Violation for operating surface impoundments
without interim status or an approved plan. ATK was disposing of wastewaters and solvents
contaminated with propellant in unlined pits at the M-136 Open Bum Grounds. ATK has
estimated that approximately 175,000 gallons of wastewater were disposed of per month from
1962 to 1986. Other source areas that existed at the facility include historic drain fields and
releases from industrial processes. These practices resulted in the contamination of the regional
and perched groundwater aquifers that underlie the facility.
Requirements to address violations associated with these pits, or land disposal units, were
established in a 1987 Consent Order. ATK closed these units, in accordance with its approved
Closure Plan, in May of 1992. A Post-Closure Permit (the Permit) was issued by the Executive
Secretary of the Utah Solid andHazardous Waste Control Board on September l,1992, and
reissued on September 20,2007. Conditions for groundwater monitoring and corrective action
are established in the Permit.
Groundwater Monitoring
ATK has been conducting semiannual groundwater monitoring at the Promontory facility
since 1987. The groundwater protection standard established in the Permit has been
exceeded in the compliance wells and contaminants have migrated down-gradient beyond
the facility boundary. The primary contaminants that have been detected in groundwater
are: TCE, TCA (and their daughter products) and perchlorate. ATK has installed
approximately 95 wells since 1987 in order to define the extent of contamination. Based
on groundwater monitoring results, it appears that two separate contaminant plumes exist
in the regional aquifer in addition to the primary regional plume. Groundwater
contamination has also been detected in a perched aquifer zone east of the primary plume
in the regional aquifer.
Currently, ATK primarily collects water samples using the HydraSleeve, no purge sampling
method. As discussed in the 201I O&M Report, the Division approved the use of this sampling
method in June, 2008 after ATK completed a study that compared results for samples collected
using the conventional, purglng method with sample results obtained by using theHydraSleeve
method.
In 2008, the Division requested that ATK evaluate the condition of wells containing stainless
steel screens since corrosion of dedicated, submersible, stainless steel pumps was observed as
they were removed from wells after they quit working. Furthermore, since ATK was switching
from a purglng sampling method to the HydraSleeve method, it was thought that the condition of
the well screen was an important factor for ensuring unobstructed flow of groundwater through
the well screen and for obtaining representative samples.
WelI Screen Corrosion Investisation
ATK submitted the Coruosion Investigation Reportfur Monitoring Well Screens at ATK
Promontory in May, 2013. ATK investigated six wells for the report by using a down-hole
qlmera to view the extent of corrosion. The wells that were evaluated were: D-6, A-10, B-4,
E-6, F-3 andLF-2. Video of the well investigation was provided on DVDs that were submitted
with the report. In the videos, some areas of the well screens appear to be clogged and
cauliflower-like growths can be seen on the screen walls. ATK believes that these growths are
iron bacteria. They are mainly observed at the joint between the screen and the PVC pipe (see
Photo 4 below). For this report, these growths, and clogging of well screen slots is referred to as
corrosion.
Determining the degree of well screen corrosion based on observing the videos is subjective. ln
addition, the down-hole camera provided images looking directly down the well rather than
looking directly at the wall of the screen. This made it difEcult to determine how clear the slots
in the screen were, but the general degree of corrosion could be observed. Based on these
observations, it appears that moderate to heavy corrosion exists at intervals in wells E-6 and F-3.
The 88 to 104 foot interval (out of a 20 ft. screen) in the well F-3 screen appears to be clogged.
The screen in well E-6 has moderate to heavy corrosion in the 68 to 72 foot interval (out of a 20
ft. screen). Well D-6 was clear since it contains a PVC screen. The other wells that were
investigated (A-10, B-4 and LF-2) had intervals of minor corrosion with spots that appeared
more moderate in degree of corrosion.
After this initial investigation of the well screens, ATK decided to upgrade its down-hole camera
so that the wall of the screen could be observed. The new qlmera has the ability to look both
directly down the well and directly at the wall of the well. In August, 2014, Jon Parry and I
visited the Promontory facility to observe the investigation of wells B-6, B-7, and E-6 using the
new camera.
Based on this investigation, approximately 70Yo of well 8-6 is clogged. As shown in Photo 2
below, the slots in the screen are not visible. Well B-7 is mostly clear, but has a three foot
interval of corrosion. Well E-6 appears less corroded using the upgraded camera than in the
previous investigation, although spotty corrosion is apparerrt in the top two to three feet in the
screen.
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Photo 1 - Well 8-6, photo shows visible screen
slots at a depth of 105.3 ft.
Photo 2 - Well 8-6, photo shows corroded
screen (no slots visible) at a depth of 108.8 ft.
.l*ryffi,
i.i... .:ir l
:1,!l'|lllll.l
ii il;r,tr.,
Photo 3 - Well 8-6, looking down the well at a depth of 117.5 feet. Corrosion (or bacterial
growth?) can be seen covering slots in screen. A small zone where the slots are visible can be
seen on the left side of photo.
Photo
screen
**-*
"- - ;
4 - Well 8-6, photo shows cauliflower-like growth at the joint between the stainless steel
and the PVC pipe.
Installation of Monitorine Well P-10
A new monitoring well, P-10, was drilled and completed in March, 2012. This well was
installed northwest of well P-6 and Building M-585 in the Defense and Launch Vehicle (DLV)
Plant (see Figure I ). The primary objective for the new well was to provide a third
potentiometric surface point (in addition to wells P-6 and P-7) to help determine the direction of
groundwater flow in the perched aquifer below Building M-585. This information was needed to
help assess the investigation of three SWMUs associated with this building. In addition, TCE
has been detected in well P-6 and TCE and perchlorate has been detected in well P-7.
Groundwater was intercepted during the drilling of the well at an elevation of 4,445 feet - 94 feet
below the ground surface. The total depth of the well is 105 feet. Based on the groundwater
elevations of wells P-6,P-7 and P-l0, it appears that groundwater flow is to the east, northeast.
However, ATK has reported that after the well was completed, and a sample was collected, the
well went dry. ATK has tried on several occasions since then to get a groundwater elevation at
the well, but it is only damp and muddy at the bottom.
I - Location of New Moni Well P-10 in the DLV orth Area
TCE was detected in the sample collected from well P-l0 at 9.5 nglL (J-flagged). Perchlorate
was not detected in the sample. In June, 2014, ATK collected a sample from well P-10 using a
passive diffusion bag since there wasn't enough water in the well to collect a sample. TCE was
detected in this sample at 185 ug/L.
ATK submittod a Well Completion Report for Well P-10 on June 13, 2012. The report contains
information on the pu{pose for the well, well construction, well development, geology and a well
1og. The driller's daily logs and the initial analyical results are also included in the report. The
status of this well and the SWMUs associated with Building M-585 will continue to be assessed
by the Division.
Total Depth Measurements of Monitoring Wells
ATK is required by its Post-Closure Permit to measure the total depth of all groundwater
monitoring wells that are completed in unconsolidated sediments, every three years. Measuring
the depth of these wells is required in order to determine if sediment is accumulating in the well
which may affect the function of the well screen. ATK measured these well depths in 2013.
Table 1 below shows the depths measured in20l3 compared to the total depths that were
Table 1 - Total Depth of Monitoring Wells Completed in Unconsolidated Sediments - 2013
Well Total Depth When
Well Was Completed
Total Depth
2013 Well Total Depth When
Well Was Completed
Total Depth
2013
A-7 242 (1987)241.50 P-1 257 (as of2008)256.71
B-5 r76 (1e8e)t77.60 P-2 178 (as of2008)178.30
B-6 t27 (re8e)12s.60 P-5 r27 (reer)t26.51
B-7 97 (le8e)97.75 P-8 r79 (19et)179.20
B-8 110 (1e8e)112.90 P-9 1e3 (1991)t92.50
c-7 108 (1e88)t07.20 H-l 47 (2002)45.88
E-l 126 (ree})t2s.60 H-2 s6 (2002)58.25
E-2 l20 (1990)120.80 H-3r 82 (2003)79.95
E-4 r32 (1990)131.80 H-4 r01 (2003)102.01
E-5 r22 (ree})r20.71 H-5 48 (2003)48.25
E-8 228 (ree})225.80 H-6 s0 (2003)53.65
E-9 234 (ree0)233.20 H-gt lso (2003)140.30
F-1 r07 (ree2)106.21 H-gt 2s (2003)
l2 (as of2008)t2.20
F-2A'1s3 (1991)
1s0 (2008)141.10 H-10 30 (2003)28.30
F-2BI 2r7 (leer)
2t1 (2008\206.80 J-1 t 148 (2004)145.12
F-2CI 322 (reer)
319 (2008)310.50 J-3r r49 (2004)147.25
F-3 r08 (1ee2)107.60 EW-62 206 (as of2008)263.t5
G-1 e7 (ree6)97.70 M508-t 203 (as of2008)202.40
G-2 e8 (1ee6)98.20 M508-2 199 (as of2008)r 99.38
G-3 26 (19e6)26.57 Ms08-3 202 (as of 2008)202.30
G-4 76 (1ee6)76.40 M508-4 200 (as of2008)200.60
LF-1 136 (as of2008)136.80 M508-81 182 (as of2008)l 81 .73
LF-21 153 (as of2008)r49.t0 TCCl 214 (as of2008)214.0s
LF-3 148 (as of2008)148.10
t It uppears that silting in these wells may be an issue.
' Not a completed monitoring well.
measured when the wells were completed. Based on these measurements, it appears silting may
be an issue in the wells identified in the table. As shown in the table, the F-2 nested wells have
total depths measured in 2013 that are approximately l0 feet less than the depths measured in
1991. ATK will be asked to check into the accuracy of these depths. On the other hand, wells
that appear to have significant silting, and are marked as such in the Table, show an approximate
difference of up to 3 feet in depth (e.g. well J-l had a depth of 148 feet when it was completed,
and a depth of 145.1 feet in 2013).
It was also observed that the list of wells that are completed in unconsolidated sediments (and are
measured for depth every three years) is not consistent. Attachment 3 of the Post-Closure Permit
contains a table that lists the wells that should be measured, but some of the wells that are listed
haven't been measured in the past, while some wells that aren't on the list have been measured.
The list of wells in the Permit needs to be reviewed and modified if necessary. ATK will then be
expected to measure all of the wells on the list as required by the Permit. In addition, due to poor
well logs and spotty records for some wells, the original well depths are unknown. Original well
depths for the wells that are measured also need to be established.
OA/OC Data for Groundwater Monitorine Anal*ical Results
The Groundwater Monitoring Module of ATK's Post-Closure Permit requires that ATK submit a
QA/QC data summary with each Semi-Annual Report. The Permit states that the QA/QC
Summary shall be submitted in accordance with the QAPP contained in Attachment 3 of the
Permit. After reviewing the QAPP, it is unclear what QA/QC information should be included in
the data sufirmary. Based on a review of Semi-Annual Reports for the last few years, it appears
that data summaries are not being submitted.
The results of trip and field blanks, and surrogate recoveries are reported but MS/MSD recovery
results are not reported. In addition, a laboratory control sample results sufirmary and sample
extraction and analysis dates and times are also not currently reported.
The Division needs to work with ATK to determine what information should be included in
QA/QC data summaries that will be submitted with the Groundwater Monitoring Reports. This
is an issue that is under discussion with the ATK Bacchus facility as well.
Split Samples for Well H-4. Shoteun Sprine and Pipe Sprine
In May, 2014,I visited the Promontory facility to collect split samples at Pipe Spring, Shotgun
Spring and well H-4. Water samples were collected from these three sources for VOC and
perchlorate analyses. Samples were collected from the springs by just dipping the sample bottles
into the spring pools near the source of the spring. Samples were collected from well H-4 using
a HydraSleeve sampler (see Photo #5). The samples I collected were analyzedby the Utah
Department of Health Unified State Laboratory. The results of these samples are compared with
the ATK laboratoryresults in Table 2 below.
Photo 5 - Collecting a VOC sample from the H leeve Samoler
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N
Table 2 - Split Sample Results for Well H-4, Pipe Spring and Shotgun Spring
Constituent {ugll}Well H4 Pipe Spring Shotgun Spring
ATK DSHW ATK DSHW ATK DSHW
1., 1, 1-TRICH LO ROETHAN E <2 <l-<2 <1 <2 <1
1., 1, 2-TRICH LO ROETHAN E <2 <1 <2 <1 <2 <1
1,1-DICHLOROETHANE <2 <l-<2 <L <2 <L
1,1-DICHLOROETHENE <2 <1 <2 <1 <2 <1
1,2-DICHLOROETHAN E <2 <1 <2 <1 <2 <L
CARBON DISULFIDE <2 <1 <2 <1 <2 <L
CHLOROFORM <2 <1 <2 <1 <2 0.7 J
crs-1,2-
DICHLOROETHENE
<2 <1 <2 <L <2 <1
CONDUCTIVITY (uS/cm)8540 8870 8240 82L0 9930 10010
PERCHLORATE 98 80 5L3 553 77 66
TETRACH LOROETH EN E <2 <L <2 <L <2 <1
TRICHLOROETHENE <2 1.8 5.7 J 6.5 7.6 J 8.2
L0
The results from the two laboratories appear to be in general agreement. No obvious discrepancy
exists in this limited data set. The springs were selected to sample because they are a potential
exposure point - mainly to ecological receptors. Well H-4 was selected because an increasing
trend in perchlorate has been observed in this well and it appears that a portion of the regional
groundwater plume may split off in the vicinity of this well and flow southwest rather than
southeast. Perchlorate concentrations are also going up in Pipe Spring, as expected and predicted
by the solute transport model. Graphs of perchlorate concentrations in well H-4 and the springs
are shown in Figures 2 and 3 below.
The other predominant contaminant that has been observed at Promontory, TCE, is typically
detected in both springs at less than 10 ug/L. Since 2008, TCE has either not been detected in
well H-4 or it has been detected at less than 10 ue/L.
Figure 2
Perchlorate Concentrations in Well H-4 2003
to 2Ot4 (uelL)
120.00
100.00
80.00
b 60.00f
40.00
20.00
0.00 msf<trnrnooooooooooC\NNNC\I-\ '\ \. \. \-Fl el ri Fl Ft\\-\\\.\.OstOslOdFlFi
(o (o N r\ 00 00 0r o) o o Fr r-{ N c\ fo ot slO O O O O O O O r'{ Fl F{ r{ r't Fl F-{ r'{ FloooooooooooooooooC! C! N N N N (\ N N N N N (\ N N N c\I\. -\ -\ \\ '\ \- \. \- '\ '\ \\ \- \. \. -\ \\ -\e{ Fl Fl r'{ r.l Fl r{ Fl rl r.{ F.t F{ Fl Fl d r{ d\\ \\'\ -\ \ \. \. \ -\ \\ \\ \. \- \\ \ \ \s o s o s o sr o s o s o <t o st o sft{ Fl Fl Fl rl r.l Fl d
Date Sample Collected
t7
re3
Perchlorate Concentrations in Pipe and Shotgun
Springs 2000 to 2OL4 (uSlL)
b 400g
co'E rnnh Jvv
coLI
E 200
I
-Pipe
Spring
-shotgun
spring
rft (noottt lL
<f <f rjr IJ1 (o ro 00 0r o) o oOOOOOOOOOFTFi(, l! (, lr (, |I l! (^ lJ- (, lJ-
Sampling Season and Year
Summarv
The findings of the O&M lnspection are summarized below.
1. Based on the investigation ATK has conducted on well screen corrosion, it appears that
this is an issue that may impact the function of an unknown number of wells. Out of the
eight well screens that ATK has investigated with a down-hole camera, at least one (well
8-6) appears to be heavily corroded. Corrosion also appears to be significant in well F-3.
The extent of corrosion, and the degree to which it impacts the function of the well is
subjective, however, the corrosion that can be seen in well 8-6 is likely to impact the
function of the well. Post-Closure Permit condition IV.D.1.b. states that existing
monitoring wells shall be maintained in a fully operational condition for the duration of
the Permit.
It is apparent that all of the wells at Promontory that contain stainless steel screens should
be investigated with the down-hole camera. Wells that have severe corrosion apparent,
like well 8-6, should be scrubbed, or redeveloped as needed to remove the corrosion.
The Division will continue to work with ATK on this issue.
2. ATK is required to measure the total well depths of all wells at the facility - that are
completed in unconsolidated sediments - every three years. Attachment 3 of the Post-
Closure Permit contains a table that lists the wells that should be measured. however. it
FlFlc!NCDCn<l
Fl Fl Fl Fl Fl Fl Fl.tt lL tJt lr (, L (,
Or{r-{(\lNooooou- t, tL (, tr
72
3.
has been observed that the list of wells that are measured is inconsistent. In addition, due
to poor well logs and spotty records for some wells, the original well depths are unknown
for some wells. The Division will work with ATK to review the list of wells in
Attachment 3 and determine if changes should be made to the list. The original well
depths for the wells that are measured should also be established and added to the list of
wells.
ATK is not submitting QA/QC data summaries with the Semi-Annual Groundwater
Monitoring Reports as required. The Permit states that the QA/QC Summary shall be
submitted in accordance with the QAPP contained in Attachment 3 of the Permit. After
reviewing the QAPP, it is unclear what QA/QC information should be included in the
data summary.
The Division will work with ATK to determine what information should be included in
QA/QC data summaries that will be submitted with the Groundwater Monitoring Reports.
This is an issue that is under discussion with the ATK Bacchus facility as well.
An increasing trend in perchlorate concentration has been observed in well H-4 since
2007. In addition, it appears that aportion of the regional groundwater plume may split
off in the vicinity of well H-4 and flow southwest beyond the well rather than southeast.
An additional well down-gradient of well H-4 appears to be needed in order to determine
the extent of contamination in this area. The area where a new well would be needed is
on private property. The Division will request that ATK install the new well and will
work with ATK to determine an appropriate location.
4.
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