+ All Categories
Home > Documents > National Aeronautics and Space Administration · also observed detections of 1,4-dioxane in several...

National Aeronautics and Space Administration · also observed detections of 1,4-dioxane in several...

Date post: 19-Mar-2020
Category:
Upload: others
View: 8 times
Download: 0 times
Share this document with a friend
18
National Aeronautics and Space Administration Lyndon B. Johnson Space Center White Sands Test Facility P.O. Box 20 Las Cruces, NM 88004-0020 Reply to Attn of: RE-18-180 Mr. John E. Kieling, Chief December 21, 2018 New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505 Subject: Abbreviated Investigation Work Plan for Groundwater Data Representativeness, Phase 1: FLUTe Well Evaluation In the October 4, 2017 Approval with Modifications Detections of NDMA and TCE in WSTF Groundwater Monitoring Wells BLM-30, PL-5, PL-6, PL-7, PL-8, PL-10, St-5, and WW-3, NMED directed NASA to submit a work plan for evaluating the representativeness of monitoring well sampling data by April 30, 2018. While developing the required work plan in early 2018, NASA continued to collect comprehensive groundwater samples and evaluate chemical analytical data. NASA observed detections of 1,4-dioxane in several Water FLUTe wells by SW-846 Method 8260C. Preliminary data indicated that 1,4-dioxane contamination may be present in Water FLUTe systems. On April 25, 2018, NASA recommended immediate 1,4-dioxane sampling at several wells with Water FLUTe systems with subsequent analysis using SW-846 Method 8270D with selective ion monitoring to more effectively quantify concentrations of 1,4-dioxane in Water FLUTe wells. NASA also requested additional time in which to prepare and submit the required work plan for · evaluating data representativeness. NMED approved the request on May 15, 2018 and extended the due date for submittal of the groundwater data representativeness evaluation work plan to December 31, 2018. Enclosed is the required groundwater data representativeness evaluation work plan. This submittal includes a paper copy of the Abbreviated Investigation Work Plan as Enclosure 1 and a CD-ROM with the work plan in PDF as Enclosure 2. I certify under penalty of law that this document and all .attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
Transcript

National Aeronautics and Space Administration

Lyndon B. Johnson Space Center White Sands Test Facility P.O. Box 20 Las Cruces, NM 88004-0020

Reply to Attn of: RE-18-180

Mr. John E. Kieling, Chief

December 21, 2018

New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

Subject: Abbreviated Investigation Work Plan for Groundwater Data Representativeness, Phase 1: FLUTe Well Evaluation

In the October 4, 2017 Approval with Modifications Detections of NDMA and TCE in WSTF Groundwater Monitoring Wells BLM-30, PL-5, PL-6, PL-7, PL-8, PL-10, St-5, and WW-3, NMED directed NASA to submit a work plan for evaluating the representativeness of monitoring well sampling data by April 30, 2018. While developing the required work plan in early 2018, NASA continued to collect comprehensive groundwater samples and evaluate chemical analytical data. NASA observed detections of 1,4-dioxane in several Water FLUTe wells by SW-846 Method 8260C. Preliminary data indicated that 1,4-dioxane contamination may be present in Water FLUTe systems. On April 25, 2018, NASA recommended immediate 1,4-dioxane sampling at several wells with Water FLUTe systems with subsequent analysis using SW-846 Method 8270D with selective ion monitoring to more effectively quantify concentrations of 1,4-dioxane in Water FLUTe wells. NASA also requested additional time in which to prepare and submit the required work plan for

· evaluating data representativeness. NMED approved the request on May 15, 2018 and extended the due date for submittal of the groundwater data representativeness evaluation work plan to December 31, 2018.

Enclosed is the required groundwater data representativeness evaluation work plan. This submittal includes a paper copy of the Abbreviated Investigation Work Plan as Enclosure 1 and a CD-ROM with the work plan in PDF as Enclosure 2.

I certify under penalty of law that this document and all .attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

RE-18-180

If you Ii.ave any questions or comments concerning this submittal, please contact Mike Zigmond at 575-524-5484.

~\tr Timothy J. Davis Chief, Environmental Office

2 Enclosures

cc: Mr. Gabriel Acevedo Hazardous Waste Bureau New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

2

National Aeronautics and Space Administration

Abbreviated Investigation Work Plan

Groundwater Data Representativeness

Phase 1: Water FLUTe Well Evaluation

December 2018

NM8800019434

Abbreviated Investigation Work Plan Groundwater Data Representativeness

Phase 1: Water FLUTe Well Evaluation

December 2018

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best ofmy knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

~J.Davis Chief, NASA Envirnnmental Office

National Aeronautics and Space Administration

Johnson Space Center White Sands Test Facility 12600 NASA Road Las Cruces, NM 88012 www.nasa.gov/ centers/wstf

www.nasa.gov

Date

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 3

Abbreviated Investigation Work Plan for

Groundwater Data Representativeness

Phase 1: Water FLUTe Well Evaluation

Issue and

Regulatory

Background

In 2013, NASA began a campaign to replace Westbay®1 multiport sampling

systems in several monitoring wells with sampling systems capable of being

purged. To date, NASA has identified and installed two purgeable sampling

systems believed to be capable of providing high quality, representative

groundwater samples: dual-zone dedicated bladder pump systems and Water

FLUTe™ (Flexible Liner Underground Technologies) multilevel groundwater

monitoring systems. NASA has collected groundwater samples from each

reconfigured monitoring well since installation, typically on a quarterly

schedule. NASA evaluates groundwater chemical analytical data on an

ongoing basis and has observed inconsistencies in data from samples collected

from Westbay systems and samples collected from the replacement Water

FLUTe systems. Of primary consideration are initial and ongoing detections of

several SVOC (semi-volatile organic compounds), including low

concentrations of NDMA (N-nitrosodimethylamine), as well as more recent

detections of 1,4-dioxane. Although Water FLUTe wells are purged prior to

sample collection, purge volume is somewhat limited by the small diameter

purge/sample tubing and time required to perform purging. As a result, the

potential exists for groundwater samples collected with the Water FLUTe

system to be impacted by components of the system that are in close and long-

term contact with groundwater.

Several NASA submittals and related NMED (New Mexico Environment

Department) responses (discussed below) include various requirements related

to Westbay sampling system replacement and groundwater data

representativeness. In order to address these issues, NASA recommends a

phased work approach.

On November 19, 2010, NASA submitted the NASA WSTF Westbay Well

Evaluation Work Plan (NASA, 2010) that described work necessary to

evaluate the representativeness of chemical analytical results from

groundwater samples collected at WSTF monitoring wells equipped with

Westbay sampling systems. The NMED HWB (Hazardous Waste Bureau)

approved the work plan on January 14, 2011 (NMED, 2011a) and NASA

subsequently performed fieldwork in accordance with the work plan and

reported the results of the evaluation to NMED on October 20, 2011 (NASA,

2011). NMED approved the investigation report with modifications on

December 16, 2011 (NMED, 2011b) and required NASA to convert eight

existing Westbay monitoring wells to wells containing purgeable sampling

systems. NASA submitted the required Westbay Well Conversion Work Plan

on November 1, 2012 (NASA, 2012) and NMED approved the work plan on

January 16, 2013 (NMED, 2013). NASA completed the conversions of the

first two wells in December 2013 and submitted the Well Completion Report

for the Conversion of Westbay Wells WW-2 and JP-3 on December 16, 2013

(NASA, 2013). The Westbay sampling systems in these wells were replaced

with dedicated dual-zone low-flow bladder pump systems. NASA

1 Westbay is a registered trademark of Nova Metrix, LLC.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 4

subsequently replaced the Westbay sampling systems in monitoring wells

BLM-32, WW-4, and WW-5 (NASA, 2016) and wells JER-1, JER-2, ST-6,

and ST-7 (NASA, 2017a) with Water FLUTe sampling systems. In 2016 and

early 2017, NASA drilled and installed new groundwater monitoring well PL-

11 (NASA, 2017b) and equipped the well with a Water FLUTe sampling

system.

On March 29, 2016, NMED approved NASA’s January 27, 2016 NASA WSTF

Periodic Monitoring Report – Fourth Quarter 2015 with a comment

expressing uncertainty about the source of detections of in groundwater

monitoring wells BLM-30, PL-6, PL-7, PL-8, PL-10, ST-5, and WW-3 during

2015 (NMED, 2016a). In response, NASA provided an evaluation of NDMA

results from the identified wells and requested an extension of time for

submittal of the NMED-required reconfiguration work plan for the wells

(NASA, 2017c). On October 4, 2017, NMED approved NASA’s submittal

with modifications (NMED, 2017). NMED Modification 1 required NASA to

evaluate monitoring well sampling data. While developing the required data

representativeness work plan, NASA continued to collect comprehensive

groundwater samples and evaluate chemical analytical data. NASA continued

to observe detections of SVOC in samples from Water FLUTe sampling

systems, including NDMA and several tentatively identified compounds that

may interfere with the analysis of WSTF groundwater contaminants. NASA

also observed detections of 1,4-dioxane in several Water FLUTe wells by SW-

846 Method 8260C. Preliminary data indicated that 1,4-dioxane contamination

may be present in Water FLUTe systems, as sampling performed at the

groundwater remediation systems indicates that 1,4-dioxane is not a WSTF

groundwater contaminant. In the April 25, 2018 Request for Extension of Time

for NASA WSTF Monitoring Well Groundwater Data Representativeness Work

Plan (NASA, 2018), NASA recommended immediate 1,4-dioxane sampling at

several wells with Water FLUTe systems with subsequent analysis using SW-

846 Method 8270D with selective ion monitoring to more effectively quantify

concentrations of 1,4-dioxane in Water FLUTe wells. NASA also requested

additional time in which to prepare and submit the required work plan for

evaluating data representativeness. NMED approved the request on May 15,

2018, pointing out that “…additional data will be used to confirm recently

reported 1,4-dioxane concentrations in several groundwater monitoring wells

equipped with Water FLUTe sampling systems and provide additional

information for system evaluation” (NMED, 2018).

During 2018, NASA continued to collect samples for the analysis of SVOC,

including NDMA and 1,4-dioxane, from several Water FLUTe wells.

Chemical analytical data indicate a correlation between the Water FLUTe

sampling system and detections of 1,4-dioxane and several tentatively

identified SVOC, leading NASA to conclude that the contamination may be

originating with the sampling system. To verify this, NASA proposes that the

first phase of an evaluation of groundwater data representativeness be

comprised of an evaluation of a Water FLUTe monitoring well to determine if

the sampling system is the source of SVOC, including NDMA and 1,4-

dioxane.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 5

Primary Purpose The purpose of this AIWP (Abbreviated Investigation Work Plan) is to

describe the first phase of an evaluation of the representativeness of

groundwater chemical analytical data from WSTF groundwater monitoring

wells as required by NMED (2017). In order to evaluate the representativeness

of groundwater data from samples collected at a Water FLUTe well, NASA

will compare data from several recent sampling events at Water FLUTe well

WW-4 (Figure 1) to data from samples collected from the monitoring well

after the Water FLUTe system is removed. The primary objective is to

determine if the detections of SVOC at the four sampling zones in well WW-4

(Figure 2) are representative of groundwater at that location or the result of

contamination introduced by the Water FLUTe sampling system.

Conceptual Model Monitoring well WW-4 is located approximately three miles west of the

WSTF test areas near the western site boundary within the JDMB (Jornada del

Muerto Basin). Well WW-4 was originally placed in its location to provide

additional groundwater analytical information to assist with delineation of the

WSTF TCE (trichloroethene) plume, the location of (then) proposed extraction

well PFE-7, and to provide a groundwater monitoring point between

contaminated monitoring well ST-6 and the NASA supply wells. Well WW-4

has historically served as a key component of WSTF’s sentinel well group, the

distal tier of groundwater monitoring wells located between the WSTF Plume

Front Area to the east and the NASA supply wells to the west. Well WW-4 is

located approximately 1,500 ft (feet) west of the leading edge of the

conceptualized groundwater contaminant plume and east of the WSTF water

supply wells (Figure 1). The well provides horizontal and vertical definition

within the local aquifer as part of the WSTF monitoring network and acts as a

sentinel downgradient of the contaminant plume.

Surficial soils within the JDMB in the vicinity of well WW-4 include stony

loams and sandy loams associated with alluvial fans, arroyos, and gentle slopes

that range from zero to 15% that dip west toward the basin axis. Runoff ranges

from slow to rapid, and permeability is slow to moderately rapid. The DR

(Dona Ana-Reagan) Association predominates within the area (USDA SCS,

1980). The Dona Ana Series consists of deep, well-drained soils that formed in

mixed alluvium on fans and piedmonts. The Reagan Series consists of well-

drained alluvial soils that formed on basin floors. Calcium carbonate

concentrations typically range from 15 to 40%.

Within the subsurface, the well WW-4 lithologic log indicates alluvium of the

Late Pliocene to Quaternary Santa Fe Group extends from ground surface to a

depth of 580 ft bgs (below ground surface). The alluvium typically comprises a

poorly to moderately cemented silty sandy gravel, with clasts ranging from

pebbles to cobbles in size composed primarily of Paleozoic sedimentary rocks

with some Tertiary volcanic rocks. Relatively thin caliche horizons, clay lenses

and carbonate-cemented zones from a few inches to several feet in thickness

occur sporadically. At depth from 580 ft bgs to the total depth of the WW-4

borehole at 1,020 ft bgs, volcanic-rich Alluvium of Late Pliocene age is

reported. Volcanic-rich alluvium similarly comprises a poorly to moderately

cemented silty sandy gravel with pebble to cobble-sized clasts. Individual

clasts are composed predominantly of Tertiary volcanic rocks. The lithologic

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 6

boundary in alluvium is best defined by a slight shift (increase) in the borehole

geophysical gamma log at 580 ft bgs.

The depth to groundwater in the vicinity of well WW-4 was approximately

375 ft bgs when the well was first installed in 2001, and this piezometric level

had declined to approximately 390 ft bgs by 2015. Because well WW-4 is

located outside and to the west of the groundwater divide corresponding to

drawdown of the water table created through pumping of the WSTF Plume

Front extraction wells, the 15 ft decline in water level within WW-4 is

attributable to regional declines within the JDMB observed over the same time

period. The local aquifer is classified as unconfined. Historical water level data

from the Westbay multiport well previously installed at the well WW-4

location indicate the presence of a single alluvial hydrostratigraphic unit and a

slightly downward vertical gradient.

Investigation

Approach

The first phase of the required data representativeness evaluation is the

collection and analysis of groundwater samples from well WW-4 that have not

been impacted by the current Water FLUTe sampling system, and comparison

of those data to historical data from sampling performed through the Water

FLUTe system. This first phase consists of three primary steps: collection of

initial groundwater samples from the Water FLUTe system; removal of the

Water FLUTe system; isolation of the four screened intervals in well WW-4

and purging and sampling of groundwater from each zone; and comparison of

data from samples collected during purging to available data from previous

sampling events performed using the Water FLUTe and Westbay sampling

systems.

Initial Water FLUTe Sampling

In the month prior to removal of the Water FLUTe system from well WW-4,

NASA will collect groundwater samples for analysis of the compounds of

interest from each of the four sample zones in the well’s Water FLUTe

sampling system using the established sampling process. Analytical data from

these samples will finalize the dataset representing the Water FLUTe system in

this well. The final dataset will serve as a baseline to which subsequent data

will be compared.

Water FLUTe System Removal

After the groundwater sampling has been completed, NASA will retrieve the

Water FLUTe system from well WW-4 using the tether support or recovery

line while pumping water from the previously everted flexible liner. NASA

will sample this water, which has resided within the liner since installation in

late 2015, for the compounds of interest for this evaluation. The liner and

tubing bundle will be rolled onto an appropriately sized reel provided by a

qualified off-site contractor or acquired by NASA for use during this test. The

reel will be packaged to maintain the integrity of the sampling system in the

event of potential reuse. Following removal of the Water FLUTe system,

NASA will perform a camera log of the conventional monitoring well casing

to verify its integrity prior to groundwater purging.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 7

Groundwater Purging and Sampling

Following removal of the Water FLUTe sampling system, each of the four

screened intervals in well WW-4 (Figure 2) will be sampled for the target

analytes. NASA expects to contract the services of an off-site contractor to

support groundwater purging operations. Using equipment provided by the

contractor, each screened interval will be isolated from others in the well

casing to prevent vertical mixing within the casing. A submersible pump

provided by the contractor will be placed within or immediately adjacent to

each isolated screened interval. The configuration of screen isolation and

purging equipment will be determined during the competitive procurement

process for the required off-site contractor services. Downhole equipment

provided by the off-site contractor will be decontaminated using a high

temperature pressure washer prior to deployment in well WW-4.

When the screened interval is isolated, the purge pump will be activated to

initiate groundwater extraction from the targeted well screen. The contractor

will operate the purge pump until a volume approximately equal to the volume

of the pump drop pipe has been purged. NASA will then collect a set of

groundwater samples for measurement of indicator parameters and analysis for

the compounds of interest. These samples are expected to represent the

groundwater in the annular space outside of the conventional well casing,

which may have been impacted by the Water FLUTe system. NASA will

continue purging each screened interval and will periodically measure

indicator parameters and collect groundwater samples. It is expected that field

measurements and sampling will be performed following the removal of one,

two, three, four, and five borehole volumes from the well, in addition to the

volume removed from the drop pipe. Assuming a nominal 12.25-inch borehole

and 26-ft interval between annular seals as shown in Figure 2, the volume of

26 ft of open borehole is approximately 160 gallons, thus sampling will be

performed following the removal of 160, 320, 480, 640, and 800 gallons from

each screen in well WW-4, in addition to the volume removed from the drop

pipe following pump startup. NASA will collect and manage groundwater

samples in accordance with the GMP (Groundwater Monitoring Plan; NASA,

2018b).

Chemical Analytical Data Comparison

NASA will submit groundwater samples to an accredited off-site laboratory

for analysis and review analytical data as described in the GMP (NASA,

2018b). Depending on the chemical analytical results from groundwater

samples collected during this test, qualitative or quantitative data evaluation

may be required. If the compounds of interest are not regularly detected in

samples collected during groundwater purging, a quantitative evaluation is not

possible. Data will be objectively evaluated on a qualitative basis to support

conclusions and recommendations. If the compounds of interest are detected in

samples collected throughout the purging process, a quantitative evaluation of

the data will be possible. NASA will directly compare analytical data from the

samples collected during this test to those available from samples collected

through the Water FLUTe sampling system prior to the test. A statistical

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 8

evaluation of the two data populations may also be performed if there are

adequate detections to support such an evaluation.

Compounds of

Interest and

Analytical Methods

Compounds of Interest

Based on the available analytical data from groundwater monitoring well WW-

4, NASA identifies NDMA and 1,4-dioxane as the primary compounds of

interest for this investigation. In addition, several additional SVOC have been

tentatively identified in groundwater samples using SW-846 Method 8270D

and are of interest to NASA. Finally, several VOC (volatile organic

compounds) are present in the WSTF groundwater contaminant plume, and

while these constituents are not expected to be present in groundwater at the

WW-4 location, NASA will collect samples for VOC analysis to obtain data

consistent with the ongoing groundwater assessment program. NASA will

measure groundwater indicator parameters such as temperature, turbidity, pH,

and conductivity prior to the collection of each set of samples.

Analytical Methods

Groundwater samples will be measured or analyzed for the target compounds

using the analytical methods or equipment indicated below:

Groundwater indicator parameters – field instruments

NDMA – Approved low-level analytical method (Southwest Research

Institute TAP 01-0403-015)

1,4-Dioxane – SW-846 Method 8270D with selective ion monitoring

SVOC – SW-846 Method 8270D

VOC – SW-846 Method 8260C

Groundwater Quality Control Samples

Groundwater samples will be collected, managed, and analyzed as described in

preceding sections of this plan and the GMP (NASA, 2018b). Quality control

samples will be collected to ensure quality data are generated during the

investigation. Field quality control samples will be collected as follows:

A set of VOC and low-level NDMA trip blanks will be collected prior

to proceeding to the well for purging at each screened interval in well

WW-4.

A set of equipment blanks for all analytical methods will be collected

from the non-dedicated purge pump prior to its installation in well

WW-4.

A set of field blanks for all analytical methods will be collected at the

beginning of purging at each screened interval in well WW-4.

Adequate field duplicate samples will be collected for all analytical

methods to ensure that at least eight samples are collected for these

analyses at each screened interval in well WW-4.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 9

One VOC and low-level NDMA matrix spike/matrix spike duplicate

sample will be collected at each screened interval in well WW-4.

Laboratory quality control samples will also be analyzed as required by the

accredited contracted laboratory’s Quality Manual or Standard Operating

Procedures.

Regulatory Criteria

and Decision Rule

The purpose of this investigation is to determine if the detections of

compounds of interest at the four sampling zones in well WW-4 are

representative of groundwater at that location or the result of contamination

introduced by the Water FLUTe sampling system. This work plan is provided

to comply with NMED direction to evaluate groundwater sampling data

representativeness (NMED, 2016a, 2017).

If the compounds of interest are not regularly detected in samples collected

during groundwater purging, and a qualitative evaluation indicates that

groundwater samples collected from the Water FLUTe system are not

representative of the groundwater at the WW-4 location, NASA will evaluate

the impacts of non-representative detections and determine if an alternate

sampling system is required at this location. NASA may propose further

evaluation of additional Water FLUTe wells at locations beyond the

conceptualized groundwater contaminant plume.

If the compounds of interest are detected in samples collected throughout the

purging process, and the quantitative evaluation indicates that groundwater

samples collected from the Water FLUTE system are representative of

groundwater at the WW-4 location, NASA will reinstall the Water FLUTe

system and propose additional investigation to further delineate the nature and

extent of groundwater contamination in the area.

Based on the decisions made using groundwater data from this test, additional

investigation phases may be required.

Investigation-

Derived Waste

Management and

Disposal

Attachment 20 of the Permit (Section 20.2.13) requires a discussion of IDW

(Investigation-Derived Waste) management for the project (NMED, 2016b).

All IDW will be managed and disposed of in accordance with NASA waste

management procedures that incorporate appropriate federal and state

regulations. The types of IDW expected during the investigation include water

from within the FLUTe liner, groundwater produced during purging and

sampling operations, disposal PPE (personal protective equipment) and debris,

and water and soap solutions used to decontaminate reusable equipment.

Constituents derived directly from the WSTF contaminant plume are not

expected to be encountered during this investigation. Well WW-4 is located

beyond the known boundary of the WSTF groundwater contaminant plume.

Water inside the FLUTe liner was obtained from the WSTF potable water

system and was added during FLUTe system installation. Water within the

FLUTe liner has not been exposed to the borehole, conventional well

components, or groundwater.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 10

NASA will manage water generated from the inside of the FLUTe liner,

groundwater generated from development activities, decontamination water,

and disposable PPE and debris generated during the investigation as non-

hazardous waste. The IDW will be properly containerized and samples will be

collected from IDW water. The samples will be analyzed for NDMA, 1,4-

dioxane, and WSTF plume constituents in accordance with the EPA methods

identified in this work plan.

Final waste characterization will be performed upon receipt of analytical data

for samples collected from the IDW water. If analytical results confirm that the

IDW is non-hazardous, the IDW water will be disposed of in the WSTF

sanitary sewer or by other appropriate disposal method. IDW debris will be

disposed of at a permitted non-hazardous landfill. In the unlikely event WSTF

listed waste constituents are detected, the IDW water will be properly managed

as hazardous waste, in accordance with the requirements of 20.4.1.300 NMAC

and 40 CFR 262.17 (2017). This waste would be treated and disposed of at the

Mid-plume Interception and Treatment System. Debris and disposable PPE

would be managed as hazardous waste in the central accumulation area in

accordance with the requirements of 20.4.1.300 NMAC and 40 CFR 262.17

(2017), as described in the GMP (NASA, 2018b). This waste would then be

properly treated and disposed of at a Resource Conservation and Recovery Act

treatment, storage, and disposal facility (EPA, 1998).

Schedule NMED approval of this AIWP is required prior to initiation of the evaluation.

Following NMED approval of the AIWP, NASA will initiate final planning

and procurement activities required to coordinate fieldwork. NASA expects

project planning to require approximately three months, after which fieldwork

will be performed in approximately one month. Following the completion of

fieldwork, data review, and data compilation, preparation of the final

evaluation report is estimated to require approximately four months. NASA

anticipates submittal of the final evaluation report to NMED within seven

months of NMED approval of this plan.

References Adoption of 40 CFR Part 262, Environmental Improvement Board, 20.4.1.300

NMAC (12-1-18).

EPA (Environmental Protection Agency). (1998, October). Management of

Remediation Waste Under RCRA. Washington, DC.

NASA Johnson Space Center White Sands Test Facility, (2010, November

19). Westbay Well Evaluation Work Plan. Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility, (2011, October 20).

NASA WSTF Westbay Well Evaluation Investigation Report. Las

Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2012, November 1).

Westbay Well Conversion Work Plan. Las Cruces, NM.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 11

NASA Johnson Space Center White Sands Test Facility. (2013, December 16).

Well Completion Reports for the Conversion of Westbay Wells WW-2

and JP-3. Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2016, March 30).

Well Configuration Reports for Wells BLM-32, WW-4 and WW-5.

Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2017a, March 22).

Well Reconfiguration Report for Westbay Wells JER-1, JER-2, ST-6,

and ST-7. Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2017b, September

28). Response to Disapproval - Well Completion Report for PL-11

Monitoring Well. Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2017c, March 30).

Detections of NDMA and TCE in WSTF Groundwater Monitoring

Wells BLM-30, PL-5, PL-6, PL-7, PL-8, PL-10, ST-5, and WW-3. Las

Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2018a, April 25).

Request for Extension of Time for NASA WSTF Monitoring Well

Groundwater Data Representativeness Work Plan. Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2018b, April 24).

NASA WSTF Groundwater Monitoring Plan Update for 2018. Las

Cruces, NM.

NMED Hazardous Waste Bureau. (2011a, January 14). Notice of Approval

with Modifications - Investigation Work Plan for Evaluating the

Representativeness of Groundwater Samples Collected from Westbay

Wells. Santa Fe, NM.

NMED Hazardous Waste Bureau. (2011b, December 16). Approval with

Modifications Investigation Report for Evaluating the

Representativeness of Groundwater Samples Collected from Westbay

Wells. Santa Fe, NM.

NMED Hazardous Waste Bureau. (2013, January 16). Approval Westbay Well

Conversion Work Plan. Santa Fe, NM.

NMED Hazardous Waste Bureau. (2016a, March 29). Approval NASA WSTF

Periodic Monitoring Report Fourth Quarter 2015. Santa Fe, NM.

NMED Hazardous Waste Bureau. (2016b, November 10). Administrative

Completeness and Fee Assessment Transmittal of Class 1 Permit

Modification Without Prior Approval. Santa Fe, NM.

NMED Hazardous Waste Bureau. (2017, October 4). Approval with

Modifications Detections of NDMA (N-Nitrosodimethylamine) and

TCE (Trichloroethylene) In WSTF Groundwater Monitoring Wells

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 12

BLM-30, PL-5, PL-6, PL-7, PL-8, PL-10, ST-5, and WW-3. Santa Fe,

NM.

NMED Hazardous Waste Bureau. (2018, May 15). Approval Request for

Extension of Time for NASA WSTF Monitoring Well Groundwater

Data Representativeness Work Plan. Santa Fe, NM.

Standards Applicable to Generators of Hazardous Waste, 40 C.F.R. § 262

(2017). Retrieved from http://www.gpo.gov

USDA SCS (United States Department of Agriculture Soil Classification

Survey. (1980). Soil Classification Survey. Washington, DC.

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 13

Figure 1 WSTF Monitoring Well WW-4 Location

(SEE NEXT PAGE)

!(!(

!(

!(#*

!(

!(#*

!(

!(

!(

!(!(

!(

!(

!(!(!(!(

!(!(!( !(

!(!(!(

!(!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

!(

Well WW-4

WELL J

WELL K

WELL M

Monitoring Well WW-4 Location Map!( Multiport

!( Conventional Well

!( Extraction Well

!( Injection Well

#* Piezometer

!( Exploration Well

!( Production Well

NDMA Cleanup

Level (1.1 ng/L)

TCE Cleanup Level

(4.9 ug/L)

Western Boundry

Fault ZoneWSTF Boundary ²

December 2018

1 in = 1,042 ft0 1,250 2,500

Feet

AIWP Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation 14

Figure 2 Monitoring Well WW-4 Completion Diagram

(SEE NEXT PAGE)

396.92’

WW-4 WATER FLUTe INSTALLATION DIAGRAMBrass Cap: 4,443.19’ (AMSL)Borehole Diameter: 17 ½” 0-117’; 12 ¼” 117’-1,020’Surface Casing: Nominal 14” (13 ½” Inside Diameter

[ID]) Carbon Steel to 117’Casing and Screen: Nominal 5” (4 ¾” ID) Schedule (SCH)

80 PVC

Santa Fe Alluvium

Nominal 14” (13 ½” ID) Carbon Steel Surface Casing

Nominal 5” (4 ¾” ID) SCH 80 PVC CasingNominal 5” (4 ¾” ID) SCH 80 PVC 0.020-Slot Screen

Water FLUTe Liner (Polyurethane Coated Nylon Fabric)

Bentonite and 10/20 Sand Mix

Seal: 3/8” Bentonite Chips (~5’ thick)

30/70 Fine Sand (~3’ thick)

10/20 Coarse Sand (~20’ thick)

6/9 Coarse Sand

Slough

Sampling Port

Groundwater ElevationIn Open Borehole

Well Apron Construction:3’ x 3’ x 4” sloped concrete pad, barrier posts, and locking steel well cap surrounding casing.

Not to ScaleAll measurements in ft-bgs

unless otherwise notedCoordinates are NM State Plan (NAD 83 in ft)

Water FLUTe Sampling Zones:419’-429’589’-599’848’-858’948’-958’

Type II Portland Cement with 5% BentoniteGround Surface = 0’

419’

429’

589’

599’

948’

+

17 ½” Borehole

+

Santa Fe GroupAlluvium

958’ Total Depth FLUTe Liner and 6/9 Sand

Sample Zone 1 (10’)

Sample Zone 2 (10’)

Sample Zone 4 (10’)

848’

858’Sample Zone 3 (10’)

989’ Total Depth PVC Casing

201’

Coordinates: 554,772.88’ N; 1,512,065.14’ E Original Development Start Date: 04/18/01 Original Development End Date: 04/25/01 Redevelopment Start Date: 09/29/15 Redevelopment End Date: 10/02/15 FLUTe Well Installation Date: 11/09/15

PVC Casing Stick-up: ~1’

12 ¼” Borehole

117’

1,020’ Total Depth Borehole1,014’ Slough


Recommended