FINAL WORK PLAN FOR GROUNDWATER MONITORING WELL...

FINAL WORK PLAN FOR GROUNDWATER MONITORING WELL DECOMMISSIONING AT

FORMER NAVAL AIR STATION MOFFETT FIELD MOFFETT FIELD, CALIFORNIA

ENVIRONMENTAL MULTIPLE AWARD CONTRACT Contract Number N62473-09-D-2610 Contract Task Order 0004 DCN: ATJV-2610-0004-0005

Prepared for:

Base Realignment and Closure Program Management Office West Mr. Wilson Doctor, Remedial Project Manager 1455 Frazee Road, Suite 900 San Diego, California 92108-4310

Prepared by:

317 East Main Street Ventura, California 93001

October 6, 2010

Work Plan for Groundwater Monitoring Well Decommissioning at Former Naval Air Station Moffett Field Moffett Field, California

i

TABLE OF CONTENTS 1.0 INTRODUCTION...............................................................................................................1

1.1 Project Personnel and Roles.........................................................................................1

1.2 Project Scope and Objectives .......................................................................................2

2.0 BACKGROUND................................................................................................................3

2.1 Site Location and Description........................................................................................3

2.2 Facility History and Current Operations ........................................................................3

2.3 Physiography.................................................................................................................3

2.4 Climate ..........................................................................................................................4

2.5 Site Geology..................................................................................................................4

2.6 Site Hydrogeology.........................................................................................................4

2.7 Background on Wells to be Decommissioned...............................................................5

3.0 WELL DECOMMISSIONING ACTIVITIES .......................................................................7

3.1 Pre-Field Activities.........................................................................................................7

3.1.1 Site Access................................................................................................................7

3.2 Mobilization and Decommissioning Activities................................................................7

3.2.1 Equipment and IDW Storage Areas ..........................................................................7

3.2.2 Wells to be Decommissioned – Moffett Field Main Premises ...................................8

3.2.3 Wells to be Decommissioned – Shenandoah Housing Complex ..............................8

3.2.4 Well Decommissioning Methodology ........................................................................9

3.2.5 IDW Disposal...........................................................................................................11

3.2.6 Reporting.................................................................................................................11

4.0 HEALTH AND SAFETY..................................................................................................12

5.0 QUALITY CONTROL PLAN...........................................................................................13

6.0 DEFINABLE FEATURES OF WORK.............................................................................16

7.0 REPORTING...................................................................................................................17


ii

8.0 PROJECT SCHEDULE ..................................................................................................18

9.0 REFERENCES................................................................................................................19

FIGURES Figure 1 Site Location Map

Figure 2 Site Plan

Figure 3 Monitoring Well Location Map, Former NAS Moffett Main Premises

Figure 4 Monitoring Well Location Map, Shenandoah Housing Complex

TABLES Table 1 Project Team .........................................................................................................1

Table 2 Groundwater Monitoring Well Coordinates and Locations ....................................9

Table 3 Groundwater Monitoring Well Construction Details.............................................10

Table 4 AIS-TN&A JV Core Management Team Organization Chart...............................13

APPENDICES Appendix A Available Construction Documentation for Groundwater Monitoring Wells to be

Decommissioned

Appendix B Authorization Letters/Construction Quality Management Certificates, Project QC Manager and CQC Engineer

Appendix C Response to Comments on Draft Work Plan


iii

ACRONYMS AND ABBREVIATIONS AHA Activity Hazard Analysis

AIS-TN&A JV AIS-TN & Associates Joint Venture

APP Accident Prevention Plan

bgs Below ground surface

BRAC Base Realignment and Closure

CANG California Air National Guard

CDWR California Department of Water Resources

CQC Contractor Quality Control

CO Contracting Officer

DEH Department of Environmental Health

DFOW Definable Feature of Work

EPA United States Environmental Protection Agency

FTL Field Team Leader

ft/ft feet per foot

HAZWOPER Hazardous Waste Operation and Emergency Response

IDW Investigation-derived waste

msl mean sea level

NAS Naval Air Station

NASA National Aeronautics and Space Association

NAVFAC SW Naval Facilities Engineering Command Southwest

Navy U.S. Department of the Navy

OSHA Occupational Safety and Health Administration

PMO Program Management Office

POC Point of contact

PPE Personal protective equipment

QC Quality Control

QCP Quality Control Plan

RD/RA Remedial Design/Remedial Action

ROICC Resident Officer in Charge of Construction

RPM Remedial Project Manager

RTM Remedial Technical Manager


iv

ACRONYMS AND ABBREVIATIONS, Continued SCVWD Santa Clara Valley Water District

SOW Statement of work

SSHO Site Safety and Health Officer

SSHP Site Safety and Health Plan

USFWS United States Fish and Wildlife Service

Water Board California Regional Water Quality Control Board


1

1.0 INTRODUCTION AIS-TN & Associates Joint Venture (AIS-TN&A JV) has been contracted by the United States Department of the Navy (Navy) Naval Facilities Engineering Command Southwest (NAVFAC SW) under Contract N62473-09-D-2610, Delivery Order 0004, to perform groundwater monitoring well decommissioning at multiple sites at Former Naval Air Station (NAS) Moffett Field near Mountain View, California (hereinafter referred to as “Moffett Field;” Figures 1 and 2). This Work Plan describes the technical approach and work to be performed in association with well decommissioning activities.

The work will be performed in accordance with the Navy’s scope of work (SOW) dated September 15, 2009; the final approved Work Plan; and the Accident Prevention Plan (APP)/Site Safety and Health Plan (SSHP). The combined APP/SSHP is being submitted under separate cover. Any modifications to the SOW or the above-mentioned plans shall receive prior approval from the Navy Remedial Project Manager (RPM) and Contracting Officer (CO). All site access, well abandonment, and any other permits required for the project will be coordinated and/or obtained by AIS-TN&A JV.

1.1 PROJECT PERSONNEL AND ROLES

The project team and contact information is provided in Table 1. The Navy’s Base Realignment and Closure (BRAC) Program Management Office West is responsible for scoping, review, and overall direction of this project, as well as for contracting, technical and administrative management, technical review, safety and health oversight, and coordination among the stakeholders.

Table 1 Project Team

Association Name Job Title Office Phone

BRAC PMO West Wilson Doctor Remedial Project Manager (619) 532-0928

BRAC PMO West Angela Lind Lead Remedial Project Manager (619) 532-0922

BRAC PMO West Maryann Hough Contract Specialist (619) 532-0791

BRAC PMO West Carl Bonura Remedial Technical Manager (RTM) (619) 532-0947

BRAC PMO West David R. Smith ROICC (650) 603-9836

BRAC PMO West Gary Munekawa ROICC (650) 603-9834

AIS-TN&A JV Tim Garvey Program Manager (805) 585-6386

AIS-TN&A JV Suman Sharma Project Manager (510) 260-6463

AIS-TN&A JV Carolann Wolfgang Project Quality Control (QC) Manager (805) 585-6394

AIS-TN&A JV Lik-See Chung Project Contractor Quality Control (CQC) Engineer/Site Safety and Health Officer (SSHO)

(650) 504-5122

AIS-TN&A JV James Lenzen Field Team Leader (510) 301-8135

AIS-TN&A JV Edmund Gonzales Contract Manager (805) 585-6388

AIS-TN&A JV will provide technical review, oversight, and management of this project, in addition to well decommissioning services, Investigation Derived Waste (IDW) management and disposal, field safety and health oversight, and completion report preparation.


2

Regulatory oversight of this project site is provided by the California Regional Water Quality Control Board – San Francisco Bay Region (Water Board), United States Environmental Protection Agency Region IX (EPA), Santa Clara Valley Water District (SCVWD), and Santa Clara County Department of Environmental Health (DEH).

1.2 PROJECT SCOPE AND OBJECTIVES

The Navy’s objective for this project is to decommission 13 groundwater monitoring wells at Moffett Field. These groundwater monitoring wells are no longer needed because the Navy obtained closure or no further action determination from the Water Board, which is the lead regulatory agency, for the petroleum sites associated with these wells.

The project scope includes the following key activities:

Initial Site Reconnaissance and Work Plan preparation;

Mobilization/Demobilization of a drilling rig, associated equipment, and personnel;

Proper decommissioning of monitoring wells to mitigate potential threats to the groundwater, in accordance with SCVWD permit requirements;

Management and disposal of the IDW; and

Documentation of all site activities in a well decommissioning report.


3

2.0 BACKGROUND

2.1 SITE LOCATION AND DESCRIPTION

Moffett Field is located about one mile south of the San Francisco Bay in Santa Clara County, California (Figure 1). It is bounded by United States Fish and Wildlife Service (USFWS) property to the north; by Stevens Creek to the west; by U.S. Highway 101 to the south; and by Macon Road and E. Patrol Road to the east (Figure 1).

In 1994, the operation of Moffett Field was transferred from the Navy to National Aeronautics and Space Association (NASA) Ames Research Center, the current property operator, as part of the Department of the Navy’s BRAC program. After transfer, the Navy retained responsibility for its former environmental sites at Moffett Field.

The groundwater monitoring wells to be decommissioned were installed in various locations at Former NAS Moffett Field and offsite, in support of a site closure effort associated with the Navy’s petroleum underground storage tank program at Moffett Field. Because the Navy obtained closure or no further action determination from the Water Board, which is the lead regulatory agency for the petroleum sites associated with these wells, they are no longer needed and can be decommissioned.

2.2 FACILITY HISTORY AND CURRENT OPERATIONS

Moffett Field was originally commissioned as NAS Sunnyvale in 1933 and was later renamed NAS Moffett Field. In 1994, Moffett Field was closed as an active Navy base under the Department of Defense BRAC program (FWENC 2002).

The majority of the property was transferred to NASA on July 1, 1994, and the facility was renamed Moffett Federal Airfield. The military housing (including the Shenandoah housing complex) was transferred to the U.S. Air Force, and subsequently to the U.S. Army. In 2002, NASA changed the name to NASA Ames Research Center. “Former NAS Moffett Field” is being used in Navy documents.

Federal and state tenants located at Moffett Field include the U.S. Army, U.S. Air Force, and California Air National Guard (CANG). Current Moffett Field uses include airfield operations, military facilities, and NASA research facilities. Moffett Field has a fully functional federal airport, and facilities for military personnel and their families, including family housing, a commissary, a military clinic, a service station, tennis courts, and an 18-hole golf course (FWENC 2002).

2.3 PHYSIOGRAPHY

Moffett Field is located at the northern end of Santa Clara Valley Basin. The land is relatively flat, ranging from 2 feet below to 36 feet above mean sea level (msl). The basin is a large, northwest-trending structural depression between the San Andreas and Hayward faults, and is bordered on the west by the Santa Cruz Mountains and on the east by the Diablo Range (TTEMI 2003).


4

2.4 CLIMATE

The climate at Moffett Field typically consists of dry summers and cool winters. During the summer, morning and night high fog impact the area. The average temperature is 58 °F, with an average high of 65 °F in September and an average low of 45 °F in January. Maximum and minimum temperatures of 100 °F and 22 °F have been observed during the June-September and December-January intervals, respectively.

The average annual rainfall is 14.1 inches with a maximum monthly average of 2.8 inches in January. The driest months, May through September, have less than 0.5 inch per month (National Ocean and Atmospheric Administration 2005). The average annual wind velocity is seven miles per hour with moderate winds from the north and southwest during the day, and from the west during the evening.

2.5 SITE GEOLOGY

The geology of the Santa Clara Valley contains up to 1,500 feet of Tertiary- and Quaternary-age interbedded alluvial, fluvial, and estuarine deposits that directly overlie early Tertiary or older bedrock (Iwamura, 1980). Locally, these sediments consist of varying combinations of unconsolidated to moderately consolidated clay, silt, sand, and gravel that represent interfingering of estuarine and fluvial depositional environments. The fluvial sediments were derived from the Santa Cruz highlands west of the basin and deposited on an alluvial plain bounded by alluvial fan deposits to the west and baylands to the northeast. These sediments most likely were deposited during the Holocene period when the worldwide sea level was rising toward its present elevation (Iwamura 1980).

A continuous clay layer (A/B aquitard) between 45 and 65 feet below mean sea level (msl) has been observed in soil borings across Moffett Field. This clay layer does not correspond to a worldwide rise in sea level; instead, its deposition appears to be of late Pleistocene age. An even deeper (100 to 160 feet below msl) clay layer (B/C aquitard) corresponds to Sangamon-age interglacial deposits (PRC and JMM 1992; Sangines and others 1995). Beneath this aquitard are undifferentiated alluvial gravels, sands, silts, and clays that make up the mid- to early-Pleistocene-age deposits and the Pliocene/Pleistocene-age Santa Clara Formation.

2.6 SITE HYDROGEOLOGY

Aquifer descriptions are based on existing data and lithologic interpretation of soil borings and cone penetrometer testing results. The shallow aquifer (upper 250 feet) is subdivided into the A, B, and C aquifers. A laterally extensive clay aquitard (B/C) effectively isolates the C aquifer (160 to 250 feet below ground surface [bgs]) from the upper aquifers. The A/B aquitard may be locally continuous under Moffett Field (TTEMI 2003). Only the A aquifer is discussed below since it is the aquifer of concern in this well decommissioning project.

The A aquifer consists of sands and gravels between depths of about 5 and 65 feet. The A aquifer is further subdivided into the A1- and A2-aquifer zones by a discontinuous, low-permeability horizontal layer (A1/A2 aquitard) located between 25 and 30 feet bgs. Fine-grained sediments in the A aquifer consist of greenish-gray to yellow-brown silts and clays that often contain rust-colored staining of oxidized iron. Coarse materials in the A aquifer are sands and gravels. Coarse-grained channel deposits appear to have an individual maximum thickness of 20 feet on the western side of Moffett and 10 feet on the eastern side


5

of Moffett. The coarse-grained deposits were incised in, and are interbedded with, the fine-grain sediments. Channel orientation is generally south to north (TTEMI 2003).

Groundwater flow is toward San Francisco Bay (north) with a horizontal gradient of 0.004 to 0.005 feet of drop per foot of distance (ft/ft). The horizontal gradient for the eastern side of Moffett Field has been reported as slightly more gentle (0.002 to 0.003 ft/ft) than the western side (PRC 1996). Aquifer porosity estimated from samples submitted for physical analysis ranges from 20 to 45 percent (PRC and JMM 1992). Hydraulic conductivity was estimated from the results of aquifer testing, and ranges from 5.7 to 240 feet per day for the aquifer (PRC 1996). The low to moderate hydraulic conductivity at Moffett Field and the distance from the bay decrease the effects of surface water and tidal fluctuations on groundwater flow direction and velocity such that the effects are negligible (Iwamura 1980; PRC and JMM 1992).

2.7 BACKGROUND ON WELLS TO BE DECOMMISSIONED

Wells W61-1, W29-6, W9SC-09, W9SC-10, and W9SC-19 (Figure 3) were installed in the upper part of the A aquifer in the Site 9-foot print. The Navy received closure from the Regional Water Quality Control Board for petroleum sites in the Site 9 area. Two of these wells (W29-6 and W9SC-10) were previously excavated or decommissioned. The Navy will provide available closure documentation for these wells. It is possible that wells W9SC-09 and W9SC-19 may have been abandoned as well. Available documentation concerning the decommissioning of these wells is currently being sought from the SCVWD, and will be included with the report documenting completion of well abandonment activities, as appropriate. It is noted that wells W9SC-9, W9SC-10, and W29-6 were not included in the Navy’s Well Atlas for Moffett Field (Tetra Tech EC 2006), which may indicate they no longer exist.

Well W61-1 (Figure 3) was installed to evaluate releases from Sump 61 at the northeastern corner of Building 45. The Navy removed this sump in 1991 and received a no further action letter from the USEPA dated December 17, 1993. Subsequent to closure, the Navy used this well as an extraction well in the Site 9 Source Control Measure it completed on groundwater in the area bound by Wescoat Road, McCord Avenue, Bushnell Road, and Cummins Avenue. The Site 9 Source Control Measure was subsequently replaced by the Westside Aquifer Treatment System (WATS). Well W61-1 was sampled and analyzed for VOCs intermittently between December 1990 and October 2001.

Well W29-6 was installed as part of the Navy’s original investigation of Building 29 and the underground storage tanks (UST) associated with this building. The well was installed in 1991 with its screen interval at the top of the A aquifer. This well was destroyed when the Navy excavated the USTs. The tanks were removed in 1994.

Wells W9SC-09, W9SC-10, and W9-SC19 were installed as part of the Site 9 Source Control Measure. These wells were used to characterize hydrogeologic properties and contaminant chemistry of the A Aquifer. They were also considered for use as potential extraction wells for the Source Control Measure. Well W9SC-10 was decommissioned in accordance with SCVWD regulations in the early 2000s because it interfered with ongoing operations at NAS Moffett Field.

The Navy developed a Sampling and Analysis Plan (SES-Tech 2008) for groundwater sampling and well gauging at IR Site 28, the West-side Aquifers Treatment System (WATS)


6

area, to characterize the VOC plume. None of these wells are included in the Sampling and Analysis Plan.

There are numerous wells installed within 100 feet of wells W61-1, W9SC-09, W9SC-10, and W9SC-19 that are screened in the upper part of the A aquifer (see Figure 5 of SES-Tech 2008 enclosed). The wells identified for sampling and water level measurements in the Sampling and Analysis Plan provide adequate hydrologic control of the shallow aquifer. The long-term monitoring program will not be affected if these wells are decommissioned.

Wells WSR-1, WSR-2, and WSR-3 (Figure 3) were installed to assess petroleum releases to groundwater from the former wash rack that the Navy operated at the site. The RWQCB approved closure of this site with no further action required in a letter to the Navy dated April 27, 2009. In the letter the RWQCB directed the Navy to properly decommission any unused wells. These wells have not been used for any other purpose.

Wells MW-1, MW-2, MW-3, and MW-4 (Figure 4) were installed to assess releases from USTs 121 and 122. These USTs were located on the Shenandoah Housing project on Moffett Boulevard. The Navy completed several investigations of this site, and requested closure with no further action. The RWQCB approved closure with no further action in a letter dated September 2, 2008. In the letter the RWQCB directed the Navy to properly decommission any unused wells. These wells have not been used for any other purpose.

Well W5-9 (Figure 3) was installed by the Navy in 1989 as part of the remedial investigation of Site 5. This well was installed upgradient of all known or suspected sources of groundwater contamination at NAS Moffett Field. Numerous other wells have subsequently been installed closer to Site 5. This well was not monitored for several years, and was decommissioned and sealed on May 14, 2003 under permit #03D00163. The Navy will provide available closure documentation for this well.


7

3.0 WELL DECOMMISSIONING ACTIVITIES

3.1 PRE-FIELD ACTIVITIES

Well abandonment at NAS Moffett Field requires permitting through the SCVWD. Well destruction permit applications will be completed and submitted to the SCVWD by a State-licensed C-57 drilling subcontractor AIS-TN&A JV will utilize for the project. Construction permit planning clearance applications will also be submitted to NASA at least six weeks prior to implementing well decommissioning field activities, in accordance with NASA requirements.

Prior to processing permits for well destruction, verification that proposed wells have not been decommissioned or abandoned yet will be performed, by checking records with California Department of Water Resources.

3.1.1 Site Access

Prior to any site visit or planned work activity, at least 48 hours notice will be given to the proper Facility Contact. Nine of the monitoring wells (WSR-MW01, WSR-MW02, WSR-MW03, W05-09, W29-6, W61-1, W9SC-9, W9SC-10 and W9SC-19) are located on the Moffett Field main premises (Figure 3). For access to these wells, prior notification will be made to offices of NASA, the CANG, and the US Air Force, as appropriate.

Four of the monitoring wells (MW-1, MW-2, MW-3, and MW-4) are located in the Shenandoah Housing complex located approximately one mile south of the Moffett Field main gate on Moffett Boulevard (Figure 4). For access to monitoring wells within the Shenandoah Housing complex, coordination with offices of the US Army and the Shenandoah Housing real estate property manager will be required. A Right of Entry Agreement between the Navy and the Army may be necessary before work is implemented on Shenandoah Housing complex property. This will be coordinated by the Navy through the BRAC Real Estate Specialist.

The AIS-TN&A JV team will coordinate access issues for well decommissioning activities with the Navy RPM and the office of the Navy Resident Officer in Charge of Construction (ROICC).

The AIS-TN&A JV team will document all site visits and planned work activities via digital photography. Prior authorization for the use of cameras on site will be obtained from each Facility Contact.

3.2 MOBILIZATION AND DECOMMISSIONING ACTIVITIES

3.2.1 Equipment and IDW Storage Areas

Upon mobilization for site activities, care will be taken to minimize potential disruptions to ongoing operations at Moffett Field. In the unlikely event that it is necessary to leave any boreholes open and unsupervised (e.g., over night), they will be appropriately covered and barricaded. The AIS-TN&A JV Field Manager will strictly enforce all contractor safety and traffic control measures.

At each of the two areas where well decommissioning activities will be conducted, as described above, there will be a designated area for any temporary storage of materials. All materials will arrive with the drilling subcontractor. Examples of bulk materials that will be temporarily stored onsite include miscellaneous drilling equipment and sacks of cement and


8

bentonite used for the grout mixture and surface completions. IDW generated during decommissioning activities is anticipated to be primarily concrete and metal debris. Site activities are not anticipated to generate any type of hazardous waste (i.e. soil or water). All concrete and metal debris will be segregated and temporarily stored until decommissioning activities have been completed and disposal of the materials can be arranged. Materials will be properly staged to minimize disruption to ongoing operations in the area. Signs, temporary fencing, etc., will be used as necessary to secure and identify materials while they remain onsite.

3.2.2 Wells to be Decommissioned – Moffett Field Main Premises

A total of nine (9) groundwater monitoring wells located on the Moffett Field main premises have been selected for decommissioning. Groundwater monitoring well coordinates and location data are summarized in Table 2. Available construction information for each well to be decommissioned is available in Table 3. A site map showing the well locations is provided as Figure 3. Below, is a breakdown of the nine monitoring well locations:

Based on X-Y coordinates, three monitoring wells (WSR-MW01, WSR-MW02 and WSR-MW03) appear to be located on west side of Building 548 between Johnny Luv Lane and Macon Road. After well locations are firmly verified, the AIS-TN&A JV team will determine if any traffic delineation is required during field activities.

Based on X-Y coordinates, monitoring well W05-09 appears to be located between Building 680 and Building 681, and on the west side of Macon Road.

Monitoring well W29-6 is located in the Commissary parking lot on the west side of Severyns Avenue. During site reconnaissance, this well location appeared to be paved over, and therefore was not evident from the ground surface. The AIS-TN&A JV team will use geophysical locating technique in an attempt to identify the approximate location of W29-6. Based on our site reconnaissance, it is understood that traffic delineation will be required during decommissioning field activities at this location.

Two wells (W9SC-9 and W9SC-10) appear to be located underneath a portable storage box situated next to and on the eastern side of Building 29. The AIS-TN&A JV team will coordinate relocation of the storage box to access these wells through the ROICC.

Monitoring well W61-1 is located inside the fenced area on the south side of the West-Side Aquifers Treatment System.

Monitoring well W9SC-19 appears to be underneath a portable storage box inside the fenced area on the south side of the WATS system. The AIS-TN&A JV team will coordinate relocation of storage box to access these wells through the ROICC.

Soil boring logs, well completion diagrams and related SCVWD completion notices, as available, are presented in Appendix A.

3.2.3 Wells to be Decommissioned – Shenandoah Housing Complex

A total of four (4) groundwater monitoring wells (MW-1 through MW-4) are located at Shenandoah Housing complex, and each has been selected for decommissioning.


9

Groundwater monitoring well coordinates and location data are summarized in Table 2. Available construction information for each well to be decommissioned is available in Table 3. A site map showing the well locations is also provided as Figure 4. Traffic delineation will be required during well decommissioning field activities at Shenandoah Housing complex.

Table 2 Groundwater Monitoring Well Coordinates and Locations

Well ID Easting X-coordinate

Northing Y - coordinate Datum Location/Description

WSR-MW01 6114329.7 1975890.0 NAD 83 Zn 3 West of Macon Road and Building 548



W05-09 1553067.7 334107.9 --

West of Macon Road between Buildings 680 and 681

W29-6 6109850.9 1976682.8 --

West of Hangar 1 and Severyns Ave in Commissary parking lot

W61-1 6110020.9 1976740.8 --

Inside fenced area on south side of WATS

W9SC-9 6109859.9 1976799.8 --

East of Building 29, next to Severyns Ave

W9SC-10 6109857.9 1976803.8 --

East of Building 29, next to Severyns Ave

W9SC-19 6110028.9 1976769.8 --

Inside fenced area on south side of WATS

MW-1 6104946.9 1972728.5 CCS83 Zn 3 In Shenandoah Housing Complex




Although boring logs and well completion diagrams are not currently available for these wells, DWR completion notices were obtained for wells MW-1 through MW-3, and are included in Appendix A.

3.2.4 Well Decommissioning Methodology

All well decommissioning activities will be performed by a California-licensed C-57 drilling subcontractor in accordance with SCVWD’s District Well Ordinance 90-1 (SCVWD 1990) and, as appropriate, California Department of Water Resources (CDWR) regulations under CDWR Bulletin 74-81 and the supplemental bulletin 74-90. Applicable details related to SCVWD and CDWR standards are as follows:

An authorized SCVWD representative will determine the appropriate well destruction methodology based on well construction and/or administrative issues Typically accepted destruction methods are:


10

o Overdrilling to the true total depth of the original boring and backfilling with neat cement grout, 10-sack sand cement grout, or hydrated high solids 20 percent bentonite slurry; or

o Pressure-grouting in place using neat cement and a minimum of 25 pounds per square inch, maintained for five minutes or until pumping refusal.

All debris, silt, and pumping hardware, as applicable, must be removed from the well before backfilling.

A Tremie pipe must be used to place the cement sealing material if the well is more than 30 feet deep or if more than 3 feet of water is present in the well.

All waste generated during destruction activities must be properly managed, including all waters generated during debris removal or seal placement.

All SCVWD requirements specific to the subject wells will be identified during the permit application process, and will be strictly adhered to during well destruction activities. Inspection of well decommissioning activities during the grouting phase is required by SCVWD. We will coordinate and schedule those inspections in advance of implementing field activities.

Table 3 Groundwater Monitoring Well Construction Details

Well ID Installation Date

Casing Diameter (inches)

Total Depth (feet bgs)

Screen Interval

(feet bgs)

Surface Completion

Native Surface Material

WSR-MW01 6/27/2007 2 15 7-12 Monument Concrete



W05-09 3/2/1988 4 28 11.9-16.9 Monument Asphalt

W29-6 3/28/1991 2 21 10.5-20.5 Monument Asphalt

W61-1 12/7/1990 4 20 8-18 Monument Asphalt

W9SC-9 3/10/1994 2 19.5 16.5-19.5 Monument Asphalt

W9SC-10 3/10/1994 2 27 24-27 Monument Asphalt

W9SC-19 3/10/1994 2 13.5 10.5-13.5 Monument Asphalt

MW-1 8/2/1995 4 27 12-27 Monument Soil

MW-2 8/2/1995 4 27 12-27 Monument Soil

MW-3 8/2/1995 4 27 12-27 Monument Soil

MW-4 8/2/1995 4 16 5-15 Monument Soil

bgs = below ground surface


11

3.2.5 IDW Disposal

Pending disposal through a licensed waste disposal subcontractor, and subject to approval by the California Army National Guard, IDW will be stored on the biopad near the Macon gate. It is anticipated that analysis and disposal of IDW will be completed within approximately 30 days of generation of the waste. To facilitate disposal, IDW will be analyzed in accordance with specific requirements of the waste disposal facility to include, at a minimum:

Purgeable and extractable petroleum hydrocarbons using Environmental Protection Agency (EPA) Method 8015B;

Volatile organic compounds using EPA Method 8260B; and

Metals using EPA Method 6010B.

The waste disposal subcontractor will provide services including, but not limited to, handling, transportation, and disposal of IDW. AIS-TN&A JV will be responsible for securing approval from the BRAC Caretaker Site Office for the methods/location of IDW disposal, and for coordination of signing bills of lading/waste manifests for all off-site transportation and disposal.

3.2.6 Reporting

Following completion of groundwater monitoring well decommissioning activities, as described above, the AIS-TN&A JV team will prepare a well destruction completion report in accordance with the requirements of District Well Ordinance 90-1 and with Article 3, Chapter 10, Division 7 of the State Water Code. This report will include the SCVWD-approved well destruction permits and certification of proper well destruction by a State-licensed C-57 drilling contractor.


12

4.0 HEALTH AND SAFETY All site operations will be performed in strict conformance with the safety and health policies and procedures set forth in the Accident Prevention Plan/Site Safety and Health Plan (APP/SSHP) developed for this project (under separate cover). Specific Activity Hazard Analyses (AHA) for the decommissioning activities (e.g., drilling and waste management) are incorporated into the APP.

All site personnel will have completed the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-hour training in accordance with 29 Code of Federal Regulations 1910.120(e), and have current 8-hour Refresher Training Certification. During the course of this project, any additional personnel brought on-site by the Navy Point of Contact (POC) or AIS-TN&A JV must comply with the HAZWOPER training requirements.

It is anticipated that Level D personal protective equipment (PPE) will be required, consisting of regular work clothes, steel-toed and steel-shank safety boots, hardhats, safety glasses, hearing protection, a reflective safety vest, and hand protection (as appropriate). The designated Site Safety and Health Officer (SSHO) will monitor site safety and health and determine if site conditions require an increased level of personnel protection. The SSHO has completed the OSHA 30-hour Construction Safety course as required per EM 385-1-1; Sec 01.A.17 (ACOE 2008). A copy of the course certificate is included in the APP. Any observed safety and health related issues, such as a non-compliance or conformance occurrence or incident will be documented by the SSHO and remedied. The corrective action will be documented in the daily Quality Control Reports and base personnel notified as necessary.


13

5.0 QUALITY CONTROL PLAN This Quality Control Plan (QCP) defines the AIS-TN&A JV team’s project quality management team organization and identifies key procedures for planning and implementing project quality controls. As the primary contractor, AIS-TN&A JV will perform all project management and oversight activities. The AIS-TN&A JV team’s core management team, along with Navy oversight, is identified in the following table:

Table 4 AIS-TN&A JV Core Management Team Organization Chart

The Project QC Manager, Dr. Carolann Wolfgang, will provide overall project quality control oversight, certify that the project has been completed in accordance with the Work Plan, and coordinate correspondence and submittals on QC issues with the Navy RPM, as appropriate. In the event that a corrective measure is required, the Project QC Manager will verify that the corrective action is approved by the Project Manager and has been implemented accordingly.

The Construction Quality Control (CQC) Engineer, Mr. Lik-See Chung, is the lead on-site person responsible for determining that project field activities are being performed in compliance with the Work Plan. No work will be performed without Quality Control Engineer


14

oversight. Mr. Chung will also serve as the SSHO, and he will be responsible for ensuring that the APP/SSHP is fully implemented. Authorization letters and construction quality management certificates are provided for the Project QC Manager and CQC Engineer in Appendix B.

The Field Team Leader, Mr. James Lenzen, will be responsible for overseeing all field activities at the site, including safety, quality, and production. He will maintain a physical presence at the site at all times when site work is being performed. The Field Team Leader has the authority to stop work for safety violations and remove personnel that fail to comply with the safety program (including subcontractors).

To ensure that the project complies with the Work Plan and applicable contract requirements, the project team will implement a three-phase QC system, as follows:

Preparatory Phase: prior to beginning each definable feature of work (DFOW), the following will be performed:

o Reviewing the work plan

o Ensuring that the materials and/or equipment have been tested, submitted, and approved

o Ensuring that provisions have been made to provide required quality control inspection and testing

o Ensuring that provisions have been made to provide for off-site inspectors for approval

o Examining the work area to ensure that required preliminary work has been completed and is in compliance with the approved requirements

o Conducting a physical examination of the required materials and equipment to ensure that they are properly delivered to the site, conform to approved shop drawings or specifications, and properly stored.

o Reviewing the appropriate AHAs with site workers to ensure that safety requirements are met, and that the required MSDS are submitted

o Discussing specific controls used and the construction methods and the approach that will be used to provide quality construction by planning ahead and identifying potential problems for each DFOW.

The ROICC shall be notified at least 2 working days in advance of the preparatory phase activity. This phase shall include a meeting conducted by the Field CQC Engineer and the Field Team Leader and any personnel involved in performing this task. The issues discussed during the preparatory phase meetings will be documented on the Preparatory Inspection checklist and attach it to the Daily CQC report.

Initial Phase: Implementation of controls developed for the project during the Preparatory Phase and performance of the work to the required level of workmanship are verified, including:


15

o Verifying full compliance, including required control inspection and testing;

o Checking safety requirements to include compliance with the applicable AHAs, APP, and SSHP

In addition, the CQC Engineer will document initial inspections for each item using the Initial Inspection checklist and attach it to the Daily CQC report.

Follow-Up Phase: Ongoing checks to ensure continuing compliance with the Work Plan and contract requirements are performed, including control testing as necessary, and all potential deficiencies are corrected before they can adversely affect the project.

Near completion of the work, the Project QC Manager will perform an inspection with on-site personnel to verify that the work is completed in accordance with the Work Plan. If any potential deficiencies are identified, the QC Manager will develop a punch list of activities intended to correct those deficiencies. All items on the list, as necessary, will be corrected before a final inspection is performed.

The Field Manager will maintain on-site current records of all control activities and tests, as appropriate. These will include evidence that the required control phases and tests have been performed, including the number and results, nature of defects, causes for rejection, defective features, proposed remedial action, and a statement that all supplies and materials incorporated in the work are in full compliance with the terms of the contract.


16

6.0 DEFINABLE FEATURES OF WORK A definable feature of work (DFOW) is a task that is separate and distinct from other tasks, has separate control requirements, and may be identified by different trades or disciplines, or it may be work by the same trade in a different environment.

The field activities of this project have been divided into 5 DFOWs. The testing requirements and quality control measures for each feature are described below. The definable features of work for this project include the following:

Mobilization and site preparation; work zones, i.e., locations of wells being decommissioned, will be established to buffer the surrounding environment from any potential hazards and to regulate entry into the work areas;

Well Decommissioning Setup and Operation; this includes setup and positioning of drill rig in well locations and operating the drill rig to overdrill and pressure grout each well.

Site Restoration; this includes final surface completion on each well decommissioning to match surrounding conditions as well.

Off-Site Waste Transport of material (i.e., water, soil and annular well materials, as appropriate) generated from well decommissioning. There is a possibility water will be treated through the WATS.

Demobilization; this includes moving, disposing, decontaminating of equipment and tools, and securing site.


17

7.0 REPORTING Upon completion of all site activities, the AIS-TN&A JV team will prepare a Well Decommissioning Report for review by the Navy and regulatory agencies. The report will summarize background information and the technical approach employed to complete well decommissioning activities. In addition, all documentation associated with the work (e.g., field notes and photographs, well destruction permits, and IDW disposal documentation) will be included as appendices to the report.


18

8.0 PROJECT SCHEDULE We anticipate that field activities will be implemented within one month of receiving approval of the Final Work Plan and receipt of NASA’s Construction permit, and will require approximately three to five working days to complete. A detailed progress and reporting schedule will be developed with the Navy and regulatory agencies pending review and approval of this Work Plan.


19

9.0 REFERENCES California, State of, Department of Water Resources Bulletin Number 74-81, Water Well

Standards: State of California, December 1981.

California, State of, Department of Water Resources Bulletin Number 74-90 (Supplement to 74-81), California Well Standards, June 1991.

Foster Wheeler Environmental Corporation (FWENC). 2002. Final First Annual Groundwater Report for WATS and EATS (Includes 1999 and 2000 Data and August 2000 and November 2000 Quarterly Reports). January 9.

Iwamura, T. 1980. Saltwater Intrusion Investigation in the Santa Clara Valley Baylands Area, California. Santa Clara Valley Water District. September.

National Ocean and Atmospheric Administration. 2005. Climatological Data for City of San Jose. Available at www.ncdc.noaa.gov.

PRC Environmental Management, Inc. (PRC) and James M. Montgomery Consulting Engineering, Inc. (JMM). 1992. Technical Memorandum Geology and Hydrogeology of NAS Moffett Field, California. July.

PRC, 1996. Final Stationwide Remedial Investigation Report, Moffett Federal Airfield, California. May.

Sangines, E.M., D.W. Anderson, and A.V. Buising. 1995. “Recent Geologic Studies in the San Francisco Bay Area. Symposium for the Society of Economic Paleontologists and Mineralogists (SEPM), Pacific Section. SEPM, Volume 76. May 3-5.

Santa Clara Valley Water District (SCVWD). 1990. District Well Ordinance 90-1: Standards for the Construction and Destruction of Wells and other Deep Excavations in Santa Clara County. June.

Tetra Tech, EMI (TTEMI). 2003. Final Basewide Petroleum Site Evaluation Methodology Technical Memorandum Phase III Basewide Tank Closure Report No Further Action, Former Naval Air Station Moffett Field, California. December.

U.S. Army Corps of Engineers, Safety and Health Requirements Manual, EM 385-1-1, 15 September 2008

Figures

G:\arc\projects\Moffett Well Abandonment\Figure_1.mxd

FORMER NASMOFFETT FIELD

Primary Highway Hard SurfaceSecondary Highway Hard surfaceInterstate RouteU.S. RouteState Route

Legend

±Scale in Miles

0 5 10 15 20

WORK PLAN FOR MONITORING WELLDECOMMISSIONING AT MULTIPLE SITES,

FORMER NAVAL AIR STATION, MOFFETT FIELD

DRAWN BY: MWCHECKED BY: JMDATE: DECEMBER 2009

FIGURE 1SITE LOCATION MAP

FORMER NAS MOFFETTMOFFETT FIELD, CA

FORMER NASMOFFETT FIELD

SHENANDOAHHOUSING COMPLEX

ORION PARKHOUSING

AREA

NASA AMESRESEARCH

CENTER

£¤101

£¤101

85

237

E. PA

TROL

ROAD

1ST AVENUE

3RD AVENUE

5TH AVENUE

ELLIS

ST.

MACON ROAD

N. WH

ISMAN

ROAD

TYRE

LLA A

VENU

E

MOFFETT

BLVD

.

LA AVENIDA ST.

STEV

ENS C

REEK

STORMWATERRETENTION

BASIN

U.S. FISH ANDWILDLIFE SERVICE

BUILDING 191

U.S.FISHAND

WILDLIFESERVICE

MACON ROADNORTH PATROL ROAD

FORMER JAGEL SLOUGH

#

"

"

"

G:\arc\projects\Moffett Well Abanment\Figure_2.mxd

0 500 1,000 1,500 2,000Scale in Feet

LegendRoadWaterRunwayBuilding

±




FIGURE 2SITE PLAN

FORMER NAS MOFFETTMOFFETT FIELD, CA

#

"

Former NAS Moffett FieldNASA Ames Research CenterOrion Park Housing AreaWescoat Housing Area

Location of Wells (See Figure 3)Location of Wells (See Figure 4)

0 250 500 750 1,000Scale in Feet

±

REVISION: 1AUTHOR: JMFILE NUMBER: FIGURE_3.mxd

MOFFETT FIELD, CA



!A

!A

!A

!A

!A

!A!A!A!A

HANGAR 2

HANGAR 3

MACON ROAD

MCCORD AVENUE

681

680

683

679

549548

301

301A 52649

513124

WESCOTT RD.

HANGAR 1

JOHNNY LUV LANES. AKRON AVE.N. AKRON AVE.

BUSHNELL RD.

CUMMINS AVE,

SEVERYNS AVE.

MCCORD AVE.

W5-09

WSR-MW03WSR-MW02

WSR-MW01

REFERENCE: AFTER TTECI 2005 ANNUAL GROUNDWATER REPORT FOR WATS AND EATS, AUGUST 2006

FIGURE 3MONITORING WELL LOCATION MAP

FORMER NAS MOFFETT MAIN PREMISES

!A

!A!A

!A

!A

SEVERYNS AVENUE

CUMMINS AVENUE

N. AKRON AVENUE

W29-6

W9SC-10

W9SC-9

W61-1

W9SC-1929

LEGEND!A MONITORING WELL PROPOSED FOR DESTRUCTION

ROAD

RUNWAY

BUILDING

SEE INSET BELOW

INSET

!A!A!A!A

SHENANDOAHHOUSING COMPLEX

£¤101

85

N. W

HISM

AN R

D.

TYRE

LLA A

VE.

MOFFETT

BLVD

.

LA AVENIDA ST.

W.MIDDLEFIELD

RD.

MARINER DR.

TERRA BELL AVE

SAN LUCAS AVE.

SAN

RAFA

EL AV

E.

LINDA

VIST

A AVE

.

SAN CARLOS AVE.

SAN PABLO DR.

SHERLAND AVE.

MURLAGAN AVE.

EVANDALE AVE.

DEVONSHIRE AVE.

FAIRCHILD DR.

EMILY DR.

LEONG DR.

EASY

ST.

WALKER DR.

PLAZ

ZA D

R.

G:\arc\projects\Moffett Well Abanment\Figure_4.mxd

0 250 500 750 1,000Scale in Feet

Legend!A Monitoring Well Proposed for Destruction

RoadWaterBuilding ±




FIGURE 4MONITORING WELL LOCATION MAPSHENANDOAH HOUSING COMPLEX

MOFFETT FIELD, CAFormer NAS Moffett FieldNASA Ames Research CenterOrion Park Housing AreaWescoat Housing Area

!A

!A

!A

!A

938

933

932926

927

930

931

MW-4MW-1

MW-3

MW-2

0 50 100Scale in FeetINSET

SEEINSET

SOURCE: RECORD OF SURVEY FORMER NAS MOFFETT FIELD, MARCH 200, NASA

Appendix A

Available Construction Documentation for Groundwater Monitoring Wells to be Decommissioned

Appendix B

Authorization Letters/Construction Quality Management Certificates Project QC Manager and CQC Engineer

2 F fll o I F II -{II FI

ltr IrrI 2 o I z trl

l|I F I z a o o 3 3 z t'

rtr o = -{ t { FI

ltr -{

FU F

E!E

FI

I- qa

,

Ctt

i F

FH

T

rr7

1-

^-,H

ll

|tr

| v,

rl!

I -

r

=f

|-{'

}=

"J

-

E E

II

ll

P

!'

GIF

FI

A v

s ? F a !:: o o \ G' :3. NH

R.;

tsi.

=

s6

: .2

,,o

Ab

N B

f;S

:.

Uj

q

TE

s !i

s t

R*E .5

Fs

f4 SE

(ra

Ft

$v b \ o o ls F} R R o ;

a ln z .{ (t ar)

o (D o o F! r.t o ! v) (D i o I DI r+ I ts F.

.s'

\e t\J s t\3 ,E

26 tp <3

Irr

PA

I

99

..:.

f

A'

St

38

{'r

.l P.

=.

t 0c o o o .l g 5 AI

C} o .l

:l - -tt o o o fl r+ tl :lr tsr

a !) C} o FI o e) F tr a f+t o E 9l o t) rl Ut

xl i o t I |+ r o

0q g) f ! e) 5r a 5 e) o o sl 'l D 3

{tr

.|:

!lv ='6

'=

. oc

oo

6F

=?

!3 tg

o

I o 0q o E

DI

'l x o s 3 0q F

Appendix C

Response to Comments on Draft Work Plan

RESPONSE TO COMMENTS (June 2010)

Draft Work Plan for Groundwater Monitoring Well Decommissioning, Former Naval Air Station Moffett Field, Moffett Field, CA

AIS/TN&A JV Contract Number: N62473-09-D-8817, CTO 0004 DCN: ATJV-2610-0004-0003

Page 1 of 7

# Doc Section/Pages Comment Response/Contractor Comments from Alana Lee, USEPA Region 9, via email dated May 13, 2010 1 Work

Plan General EPA understands that the wells

proposed for decommissioning are for the petroleum sites. For those wells within the MEW Regional Groundwater plume, the work plan should justify why these wells are not needed to assess water levels and/or VOC concentrations (e.g., proximity of nearby wells in monitoring program).

Wells W61-1, W29-6, W9SC-9, W9SC-10, and W9SC-19 were installed in the upper part of the A aquifer in the Site 9 foot print. In December 2004, the Navy received closure from the Regional Water Quality Control Board for petroleum sites in the Site 9 area. Two of these wells (W29-6 and W9SC-10) were previously excavated or decommissioned. The Navy will provide closure documentation for these wells. It is possible that wells W9SC-9 and W9SC-19 may have been abandoned as well. Available documentation concerning the decommissioning of these wells is currently being sought from the SCVWD, and will be included with the report documenting completion of well abandonment activities, as appropriate. It is noted that wells W9SC-9, W9SC-10, and W29-6 were not included in the Navy’s Well Atlas for Moffett Field (Tetra Tech EC, March 2006), which may indicate they no longer exist. Well W61-1 was installed to evaluate releases from Sump 61 at the northeastern corner of Building 45. The Navy removed this sump in 1991 and received a no further action letter from the USEPA dated December 17, 1993. Subsequent to closure, the Navy used this well as an extraction well in the Site 9 Source Control Measure it completed on groundwater in the area bound by Wescoat Road, McCord Avenue, Bushnell Road, and Cummins Avenue. The Site 9 Source Control Measure was subsequently replaced by the Westside Aquifer Treatment System (WATS). Well W61-1 was sampled and analyzed for VOCs intermittently between January 1991 and October 2001. Well W29-6 was installed as part of the Navy’s original investigation of Building 29 and the underground storage tanks (UST) associated with this building. The well was installed in 1991 with its screen interval at the top of the A aquifer. This well was destroyed when the Navy excavated the USTs. The tanks were removed in 1994. Wells W9SC-9, W9SC-10, and W9SC-19 were installed as part of the Site 9 Source Control Measure. These wells were used to characterize hydrogeologic properties and contaminant chemistry of the A Aquifer. They were also considered for use as potential extraction wells for the Source Control Measure. Well W9SC-10 was decommissioned in accordance with SCVWD regulations in the early 2000s because it interfered with ongoing operations at NAS Moffett Field. The Navy developed a Sampling and Analysis Plan (SES-Tech, November 2008) for groundwater sampling and well gauging at IR Site 28, the West-side Aquifers Treatment System (WATS) area, to characterize the VOC plume. None of these wells are included in the Sampling and Analysis Plan.




Page 2 of 7

# Doc Section/Pages Comment Response/Contractor There are numerous wells installed within 100 feet of wells W61-1, W9SC-9, W9SC-10, and W9SC-19 that are screened in the upper part of the A aquifer. The wells identified for sampling and water level measurements in the Sampling and Analysis Plan provide adequate characterization of the shallow aquifer. The long-term monitoring program will not be affected if these wells are decommissioned. Please see enclosed figure and table showing well locations and use. The information provided above will be incorporated into a new Section 2.7 Background on Wells to be Decommissioned.

2 Work Plan

General In addition, the Work Plan should provide a summary of table (sic) of previous VOC data. The wells may need to be sampled for VOCs prior to decommissioning. The Work Plan should include additional details about the wells proposed for decommissioning (i.e., well construction/boring logs, including well screen intervals).

Available well construction data, including total depth and screen interval, is provided for each well to be decommissioned in Table 3. Soil boring logs, well completion diagrams and related regulatory completion notices, as available, will be presented in Appendix A. The text in Sections 3.2.2 and 3.2.3 has been revised to note Appendix A. Among the wells within the regional groundwater study area, the only well with available VOC data is well W61-1; please see enclosed data from October 2001. As mentioned in response 1 above, there are nearby wells in the upper part of the A aquifer that are sampled and gauged for the regional groundwater study area; therefore, sampling the wells to be decommissioned is not proposed. Wells W9SC-1 and W9-31 are gauged and sampled. Wells W9SC-2, W9SC-4, W9SC-5, and W9SC-18 are gauged. Under the Navy’s Site 28 (WATS area) monitoring program for well W9SC-7, it is proposed to continue gauging but discontinue sampling. Please see enclosed figure and table showing well locations and use.

3 Work Plan

General After completion of the well destruction activities, the Navy must submit a well destruction completion report to the Agencies and include the well destruction permits signed off by Santa Clara Valley Water District and certification that the wells were destroyed properly.

The text has been revised to include the following Section: 3.2.6 Reporting Following completion of groundwater monitoring well decommissioning activities in accordance with the requirements of District Well Ordinance 90-1 and with Article 3, Chapter 10, Division 7 of the State Water Code, a well destruction completion report will be provided. This report will include the SCVWD-approved well destruction permits and certification of proper well destruction by a State-licensed C-57 drilling contractor.




Page 3 of 7

# Doc Section/Pages Comment Response/Contractor Comments from Elizabeth K. Wells, San Francisco Bay Regional Water Quality Control Board, via email dated May 20, 2010 1 Work

Plan General Provide the rationale for

decommissioning each well. Specify what site or feature (e.g., underground storage tank, sump, etc.) each well is associated with and why the well is no longer needed.

See response to USEPA Comment #1 above regarding wells W61-1, W9SC-9, and W9SC-19; Wells WSR-1, WSR-2, and WSR-3 were installed to assess petroleum releases to groundwater from the former wash rack that the Navy operated at the site. The RWQCB approved closure of this site with no further action required in a letter to the Navy dated April 27, 2009. In the letter the RWQCB directed the Navy to properly decommission any unused wells. These wells have not been used for any other purpose. Wells MW-1, MW-2, MW-3, and MW-4 were installed to assess releases from USTs 121 and 122. These USTs were located on the Shenandoah Housing project on Moffett Boulevard. The Navy completed several investigations of this site, and requested closure with no further action. The RWQCB approved closure with no further action in a letter dated September 2, 2008. In the letter the RWQCB directed the Navy to properly decommission any unused wells. These wells have not been used for any other purpose. Well W5-9 was installed by the Navy in 1989 as part of the remedial investigation of Site 5. It was also used to monitor groundwater near former Navy UST 18, which was removed in 1994. This well was installed upgradient of all known or suspected sources of groundwater contamination at NAS Moffett Field. The Navy received a closure letter for UST 18 from the Water Board on August 8, 2000. Numerous other wells have subsequently been installed closer to Site 5. This well was not monitored for several years, and was decommissioned and sealed on May 14, 2003 under permit #03D00163. The Navy will provide available closure documentation for this well. Consistent with the response to USEPA General Comment #1 above, this information will be incorporated into a new Section 2.7 Background on Wells to be Decommissioned.

2 Work Plan

General Provide a summary of the most recent analytical data for wells proposed for destruction that are located with the regional groundwater study area. If chemicals of concern (i.e., chlorinated volatile organic compounds) were detected in

See response to USEPA Comments #1 and #2 above.




Page 4 of 7

# Doc Section/Pages Comment Response/Contractor samples from any of these wells, provide justification for why the well or wells should be destroyed.

3 Work Plan

General Provide the status of each of the wells in the table below. Based on information provided by the Navy in January 2009, the wells listed below are no longer in use. If these wells are not being used for another purpose, include them in the work plan. If these wells have already been destroyed, provide a copy of the well destruction report.

The Navy provided the requested information under separate cover, and no revision to the document is required. Wells MW-1 through MW-3 and MW-4 associated with USTs 121 & 122 at Shenandoah Housing are proposed for decommissioning as part of this Work Plan.

Site/Feature/Well ID Site 12/W12-1, W12-2, W12-3 USTs 3 & 114/MW-1 - MW-4 UST 29/UST 29-MW03 UST 55/WT55-1 USTs 47-50/FP9-1

[Continued on next page] UST 53/W53-1, W53-2, GW53-1 USTs 56B-56D/FP9-2 UST 69/WT69-1 USTs 86A & B/WT86B-1 USTs 121 & 122/MW-1 - MW-3

1 Work Plan

Specific Comment Section 3.2.2, 3.2.3, and 3.2.4

Revise the text, which discusses well construction and surface completion details, to correctly reference Table 3. Clarify the purpose of Table 2 and include a reference to it in the text where appropriate.

Reference to Tables 2 and 3 have been revised in the introductory paragraph for Sections 3.2.2 and 3.2.3 as follows: Groundwater monitoring well coordinates and location data are summarized in Table 2. Available construction information for each well to be decommissioned is available in Table 3. Likewise, the first bullet in Section 3.2.4 has been amended to indicate reference to Table 3.




Page 5 of 7

# Doc Section/Pages Comment Response/Contractor 2 Work

Plan Specific Comment Section 3.2.3

Clarify if wells MW-1 through MW-4 are the only wells located at Shenandoah Housing Complex. The text implies more wells could be present by stating these four wells were “selected: for destruction.

The first sentence in Section 3.2.3 has been revised as follows: A total of four (4) groundwater monitoring wells (MW-1 through MW-4) are located at Shenandoah Housing complex, and each has been selected for decommissioning.

3 Work Plan

Specific Comment: Section 3.2.4

Speak to the Santa Clara Valley Water District (SCVSD) to confirm that well destruction methodology will be completed in accordance with applicable SCVWD requirements, including Well Ordinance 90-1 (http://www.valleywater.org/Programs/DistrictWell Ordinance 901.aspx#1). Water Board staff spoke with a representative of the SCVWD to confirm its requirements (Peter Thiemann, personal communication, May 20, 2010).

Based on the discussion: SCVWD standards are

operative, and in some cases, more restrictive than the California Department of Water Resources standards;

In accordance with communication with SCVWD staff on June 1, 2010, Section 3.2.4 has been revised as follows: All well decommissioning activities will be performed by a California-licensed C-57 drilling subcontractor in accordance with SCVWD’s District Well Ordinance 90-1 (SCVWD, 1990) and, as appropriate, California Department of Water Resources (CDWR) regulations under CDWR Bulletin 74-81 and the supplemental bulletin 74-90. Applicable details related to SCVWD and CDWR standards are as follows: An authorized SCVWD representative will determine the appropriate well destruction

methodology based on well construction (Table 3) and/or administrative issues. Typically accepted destruction methods are:

o Overdrilling to the true total depth of the original boring and backfilling with neat cement

grout, 10-sack sand cement grout, or hydrated high solids 20 percent bentonite slurry; or o Pressure-grouting in place using neat cement and a minimum of 25 pounds per square

inch, maintained for five minutes or until pumping refusal.

All debris, silt, and pumping hardware, as applicable, must be removed from the well before backfilling.

A Tremie pipe must be used to place the cement sealing material if the well is more than 30

feet deep or if more than 3 feet of water is present in the well. All waste generated during destruction activities must be properly managed, including all

waters generated during debris removal or seal placement.

[Continued on next page]




Page 6 of 7

# Doc Section/Pages Comment Response/Contractor Pressure grouting protocols

have changed since the publication of Ordinance 90-1 and the Navy should contact SCVWD directly to confirm protocols;

SCVWD does not permit

bentonite/Portland cement mixtures for pressure grouting wells (as proposed in the Work Plan);

Pressure grout the wells

prior to disturbing/potentially damaging the annular seal, then Overdrill the top 5 feet (the reverse of what is proposed in the Work Plan);

If a well takes 1.3 times the

casing volume of sealing material (and is grouted to the surface), then additional pressure is not required to be applied (the entire 5 minutes at 25 psi isn’t required by SCVWD); and

If a well takes over 1.3 times

the casing volume and requires additional grout, at that time bentonite can be added to the sealing material.

All SCVWD requirements specific to the subject wells will be identified during the permit application process, and will be strictly adhered to during well destruction activities. Inspection of well decommissioning activities during the grouting phase is required by SCVWD. We will coordinate and schedule those inspections in advance of implementing field activities.




Page 7 of 7

# Doc Section/Pages Comment Response/Contractor 4 Work

Plan Specific Comment Section 3.2.5

Clarify where the investigation-derived waste (IDW) will be stored prior to disposal. In addition, provide details regarding sampling and characterization of the IDW.

The first paragraph of Section 3.2.5 has been revised as follows: Pending disposal through a licensed waste disposal subcontractor, and subject to approval by the California Army National Guard, IDW will be stored on the biopad near the Macon gate. It is anticipated that analysis and disposal of IDW will be completed within approximately 30 days of generation of the waste. To facilitate disposal, IDW will be analyzed in accordance with specific requirements of the waste disposal facility to include, at a minimum: Purgeable and extractable petroleum hydrocarbons using Environmental Protection Agency

(EPA) Method 8015B; Volatile organic compounds using EPA Method 8260B; and Metals using EPA Method 6010B.

5 Work Plan

Specific Comment Section 6.0

Note the IDW will include soil, annular well materials, and well casing in addition to water.

The fourth bullet of Section 6.0 has been revised as follows: Off-Site Waste Transport of material (i.e., water, soil and annular well materials, as

appropriate) generated from well decommissioning. There is a possibility water will be treated through the WATS.

!

!!

!

!

!

!

!

!

!?

!?

!?

!?

!?

!

!H

!<!H

!<

!<

HANGAR 1

SEVERYNS AVENUE

CUMMINS AVENUE

NORTH AKRON ROAD

W29-2

EA1-3 PZA1-3APZA1-3D

PZA1-3BPZA1-3C

W9SC-7

W9-31

W9SC-2W9SC-1 W9SC-18 W9SC-5

W9SC-4

W29-4

W29-3

W29-6

W9SC-9W9SC-10

W61-1

W9SC-19

G:\arc\projects\Moffett\September 2010\SAP_Site_28_Sept10.mxd

0 25 50 75 100Scale in Feet

DRAWING NO.

DRAWN BY: MWCHECKED BY: MQDATE: SEPTEMBER 2010

FIGURE 1UPPER A AQUIFERWELL LOCATIONS

GROUNDWATER WELL DECOMMISSIONINGFORMER NAS MOFFETT FIELD, MOFFETT FIELD, CA

±Legend!H Wells decommissioned!< Wells proposed for decommissioning! Wells to be gauged!? Wells to be gauged & sampled

RoadBuilding

Location Name Sample Name Sample Matrix Sample Date Analyte Name Analyte Value Result Units Final QualifierW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,1,1-TRICHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,1,2,2-TETRACHLOROETHANE 13 UG_L U

W61-1 W61-01A1_20011029 Ground water 10/29/20011,1,2-TRICHLORO-1,2,2-TRICHFLUOROETHANE 13 UG_L U

W61-1 W61-01A1_20011029 Ground water 10/29/2001 1,1,2-TRICHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,1-DICHLOROETHANE 14 UG_LW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,1-DICHLOROETHENE 21 UG_LW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,2-DICHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,2-DICHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,2-DICHLOROPROPANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,3-DICHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 1,4-DICHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 2-CHLOROETHYL VINYL ETHER 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 BENZENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 BROMODICHLOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 BROMOFORM 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 BROMOMETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 CARBON TETRACHLORIDE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 CHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 CHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 CHLOROFORM 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 CHLOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 CIS-1,2-DICHLOROETHENE 370 UG_LW61-1 W61-01A1_20011029 Ground water 10/29/2001 CIS-1,3-DICHLOROPROPENE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 DIBROMOCHLOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 DICHLORODIFLUOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 ETHYLBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 JET FUEL JP-8 0.05 MG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 METHYLENE CHLORIDE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 TETRACHLOROETHENE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 TOLUENE 7.5 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 TPH-DIESEL RANGE C12-C24 0.05 MG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 TPH-OIL RANGE 0.05 MG_L U

W61-1 W61-01A1_20011029 Ground water 10/29/2001TPH-TOTAL UNKNOWN GASOLINE RANGE ORGANICS 0.05 MG_L U

W61-1 W61-01A1_20011029 Ground water 10/29/2001 TRANS-1,2-DICHLOROETHENE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 TRANS-1,3-DICHLOROPROPENE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 TRICHLOROETHENE 2200 UG_LW61-1 W61-01A1_20011029 Ground water 10/29/2001 TRICHLOROFLUOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 VINYL CHLORIDE 13 UG_L UW61-1 W61-01A1_20011029 Ground water 10/29/2001 XYLENES, TOTAL 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,1,1-TRICHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,1,2,2-TETRACHLOROETHANE 13 UG_L U

W61-1 W61-01A1_20011029_FD Ground water 10/29/20011,1,2-TRICHLORO-1,2,2-TRICHFLUOROETHANE 13 UG_L U

W61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,1,2-TRICHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,1-DICHLOROETHANE 15 UG_LW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,1-DICHLOROETHENE 21 UG_L

Location Name Sample Name Sample Matrix Sample Date Analyte Name Analyte Value Result Units Final QualifierW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,2-DICHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,2-DICHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,2-DICHLOROPROPANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,3-DICHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 1,4-DICHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 2-CHLOROETHYL VINYL ETHER 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 BENZENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 BROMODICHLOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 BROMOFORM 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 BROMOMETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CARBON TETRACHLORIDE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CHLOROBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CHLOROETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CHLOROFORM 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CHLOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CIS-1,2-DICHLOROETHENE 380 UG_LW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 CIS-1,3-DICHLOROPROPENE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 DIBROMOCHLOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 DICHLORODIFLUOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 ETHYLBENZENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 JET FUEL JP-8 0.05 MG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 METHYLENE CHLORIDE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TETRACHLOROETHENE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TOLUENE 7.5 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TPH-DIESEL RANGE C12-C24 0.05 MG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TPH-OIL RANGE 0.05 MG_L U

W61-1 W61-01A1_20011029_FD Ground water 10/29/2001TPH-TOTAL UNKNOWN GASOLINE RANGE ORGANICS 0.05 MG_L U

W61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TRANS-1,2-DICHLOROETHENE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TRANS-1,3-DICHLOROPROPENE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TRICHLOROETHENE 2000 UG_LW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 TRICHLOROFLUOROMETHANE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 VINYL CHLORIDE 13 UG_L UW61-1 W61-01A1_20011029_FD Ground water 10/29/2001 XYLENES, TOTAL 13 UG_L U

Nearby Wells Proximity (ft) Aquifer Current Status Proposed Future StatusW9SC-1 Adjacent upper A gauged & sampled gauged & sampledW9SC-2 Adjacent upper A gauged gauged

W9SC-18 30 upper A gauged gaugedW9SC-4 35 upper A gauged gaugedW9SC-5 35 upper A gauged gaugedW9-31 55 upper A gauged & sampled gauged & sampled

Nearby Wells Proximity (ft) Aquifer Current Status Proposed Future StatusW9SC-1 30 upper A gauged & sampled gauged & sampledW9SC-2 30 upper A gauged gauged

W9SC-18 40 upper A gauged gaugedW9SC-4 55 upper A gauged gaugedW9SC-5 55 upper A gauged gaugedW9-31 65 upper A gauged & sampled gauged & sampled

Nearby Wells Proximity (ft) Aquifer Current Status Proposed Future StatusW9SC-7 40 upper A gauged & sampled gaugedPZA1-3C 80 upper A gauged gaugedPZA1-3D 80 upper A gauged gaugedPZA1-3B 90 upper A gauged gaugedPZA1-3A 100 upper A gauged gaugedW9-31 100 upper A gauged & sampled gauged & sampledEA1-3 100 upper A gauged & sampled gauged & sampledW29-2 125 upper A gauged & sampled gauged & sampled

Nearby Wells Proximity (ft) Aquifer Current Status Proposed Future StatusW9SC-7 40 upper A gauged & sampled gaugedPZA1-3C 80 upper A gauged gaugedPZA1-3D 80 upper A gauged gaugedPZA1-3B 90 upper A gauged gaugedPZA1-3A 100 upper A gauged gaugedW9-31 100 upper A gauged & sampled gauged & sampledEA1-3 100 upper A gauged & sampled gauged & sampledW29-2 125 upper A gauged & sampled gauged & sampled

Nearby Wells Proximity (ft) Aquifer Current Status Proposed Future StatusPZA1-3C 80 upper A gauged gaugedPZA1-3B 100 upper A gauged gaugedPZA1-3D 120 upper A gauged gaugedPZA1-3A 120 upper A gauged gaugedW9-31 120 upper A gauged & sampled gauged & sampled

W61-1 (upper A aquifer well)

W9SC-19 (upper A aquifer well; not located - possibly decommissioned or paved over)

W9SC-9 (upper A aquifer well; not located - possibly decommissioned or paved over)

W9SC-10 (upper A aquifer well; decommissioned due to interference with base operations)

W29-6 (upper A aquifer well; decommissioned during tank removal in 1994)

EA1-3 120 upper A gauged & sampled gauged & sampledW29-4 140 upper A gauged & sampled gauged & sampled

Date post:	18-Feb-2018
Category:	Documents
Upload:	trinhque
View:	222 times
Download:	3 times

FINAL WORK PLAN FOR GROUNDWATER MONITORING WELL...

Documents