NM8800019434 · Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR iii...

National Aeronautics and Space Administration

White Sands Test Facility P.O. Box 20 Las Cruces, NM 88004-0020

Reply to Attn of: RE-20-033

Mr. Kevin Pierard, Bureau Chief New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East, Building I Santa Fe, NM 87505-6303

February 27, 2020

Subject: Groundwater Data Representativeness Phase I: Water FLUTe Well Evaluation Abbreviated Investigation Report

NASA submitted the Abbreviated Investigation Work Plan Groundwater Data Representativeness Phase I: Water FLUTe Well Evaluation on October 30, 2018. On May 13, 2019, NMED approved the work plan with modifications and directed NASA to submit a final investigation report no later than February 28, 2020. NASA revised the work plan according to NMED comments and submitted the Response to Approval with Modifications of Abbreviated Investigation Work Plan Groundwater Data Representativeness Phase I: Water FLUTe Well Evaluation on July 30, 2019.

Enclosed is the required Groundwater Data Representativeness Phase I: Water FLUTe Well Evaluation Abbreviated Investigation Report. This submittal includes a bound paper copy of the Abbreviated Investigation Report as Enclosure I, analytical data spreadsheets as Enclosure 2 on CD-ROM, analytical lab reports as Enclosure 3 on CD-ROM, and an electronic report in PDF on CD-ROM as Enclosure 4.

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 known violations. If you have any questions or comments concerning this submittal, please contact Mike Zigmond of my staff at 575-524-5484.

SinceT~ A:hy J. Davis

Chief, Environmental Office

Enclosure

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

Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation Abbreviated Investigation Report

February 2020

NM8800019434


Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation Abbreviated Investigation Report

February 2020

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. 1 am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

)1=\~t Timothy J. Davis Chief, Environmental Office


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

www.nasa.gov

Date

Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR iii

Table of Contents

Table of Contents ......................................................................................................................................... iii List of Figures and Tables ............................................................................................................................. v

List of Acronyms ......................................................................................................................................... vi 1.0 Background ....................................................................................................................................... 1

2.0 Location ............................................................................................................................................ 2

3.0 Investigation Activities ..................................................................................................................... 2

3.1 Constituents of Concern ................................................................................................................ 2

3.1.1 Analytical Methods ............................................................................................................... 2

3.1.2 Groundwater Quality Control Samples ................................................................................. 3

3.2 Field Activities .............................................................................................................................. 3

3.2.1 Initial Water FLUTe Sampling ............................................................................................. 3

3.2.2 Water FLUTe System Removal and Sampling ..................................................................... 4

3.2.3 Camera Log of WW-4 ........................................................................................................... 4

3.2.4 Monitoring Well Sampling ................................................................................................... 4

3.3 Performance or Acceptance Criteria ............................................................................................. 5

3.4 Investigation-Derived Waste Management ................................................................................... 6

3.5 Investigation Deviations ............................................................................................................... 7

4.0 Investigation Results and Interpretation............................................................................................ 8

4.1 Initial FLUTe and Liner Sample Results ...................................................................................... 8

4.2 WW-4 First Screened Interval (Zone 1)........................................................................................ 8

4.2.1 Zone 1 NDMA Results by Low-Level Method .................................................................... 8

4.2.2 Zone 1 SVOC Results by SW-846 Method 8270D and 8270-SIM ...................................... 9

4.2.3 Zone 1 VOC Results by SW-846 Method 8260 .................................................................... 9

4.3 WW-4 Second Screened Interval (Zone 2) ................................................................................... 9

4.3.1 Zone 2 NDMA Results by Low-Level Method .................................................................... 9

4.3.2 Zone 2 SVOC Results by SW-846 Method 8270D and 8270-SIM .................................... 10

4.3.3 Zone 2 VOC Results by SW-846 Method 8260 .................................................................. 10

4.4 WW-4 Third Screened Interval (Zone 3) .................................................................................... 10

4.4.1 Zone 3 NDMA Results by Low-Level Method .................................................................. 10



4.5 WW-4 Fourth Screened Interval (Zone 4) .................................................................................. 11

4.5.1 Zone 4 NDMA Results by Low-Level Method .................................................................. 11



4.6 Purging and Sampling Results Summary .................................................................................... 11

Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR iv

4.6.1 NDMA Summary ................................................................................................................ 11

4.6.2 SVOC Summary ................................................................................................................. 12

4.6.3 VOC Summary .................................................................................................................... 12

4.7 Potential for Interference with Low-Level NDMA Analysis...................................................... 12

5.0 Uncertainties ................................................................................................................................... 12

6.0 Conclusions ..................................................................................................................................... 13

7.0 Recommendations ........................................................................................................................... 14

8.0 References ....................................................................................................................................... 14

Figures ........................................................................................................................................................ 16

Tables .......................................................................................................................................................... 32

Appendix A Field Logbooks ..................................................................................................................... A-1

Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR v

List of Figures and Tables

Figure 2.1 Monitoring Well WW-4 Well Location Map ...................................................................... 17 Figure 3.1 WW-4 Water FLUTe Installation Diagram ........................................................................ 18 Figure 4.1 Historical WW-4 FLUTe NDMA Concentrations: All Zones ............................................ 19 Figure 4.2 Historical WW-4 FLUTe SVOC and TICConcentrations: Zone 1 ..................................... 20 Figure 4.3 Historical WW-4 FLUTe SVOC and TIC Concentrations: Zone 2 .................................... 21 Figure 4.4 Historical WW-4 FLUTe SVOC and TIC Concentrations: Zone 3 .................................... 22 Figure 4.5 Historical WW-4 FLUTe SVOC and TIC Concentrations: Zone 4 .................................... 23 Figure 4.6 WW-4 Phase I NDMA Low-Level Concentrations: Zone 1 ............................................... 24 Figure 4.7 WW-4 Phase I VOC, SVOC, and TIC Concentrations: Zone 1 ......................................... 25 Figure 4.8 WW-4 Phase I NDMA Low-Level Concentrations: Zone 2 ............................................... 26 Figure 4.9 WW-4 Phase I SVOC and TIC Concentrations: Zone 2 ..................................................... 27 Figure 4.10 WW-4 Phase I NDMA Low-Level Concentrations: Zone 3 ............................................... 28 Figure 4.11 WW-4 Phase I SVOC and TIC Concentrations: Zone 3 ..................................................... 29 Figure 4.12 WW-4 Phase I NDMA Low-Level Concentrations: Zone 4 ............................................... 30 Figure 4.13 WW-4 Phase I SVOC and TIC Concentrations: Zone 4 ..................................................... 31

Table 3.1 Phase I Investigation Sample Inventory ............................................................................. 33 Table 3.2 Well WW-4 Calculated Purge Volumes ............................................................................. 35 Table 4.1 Phase I Investigation FLUTe and Liner Sample Results .................................................... 37 Table 4.2 Phase I Investigation NDMA Sample Results .................................................................... 38 Table 4.3 Phase I Investigation SVOC Sample Results ..................................................................... 39 Table 4.4 FLUTe vs. Fifth Purge Concentration of Certain SVOC TICs .......................................... 40 Table 4.5 Fourth and Fifth Purge Sample NDMA Concentration vs. SVOC TIC Concentrations .... 41

Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR vi

List of Acronyms

µg Microgram µm Micrometer AIWP Abbreviated Investigation Work Plan bgs Below Ground Surface BLM Bureau of Land Management CAS Chemical Abstract Service CFR Code of Federal Regulations COPC Constituent of Potential Concern DP Discharge Permit EPA Environmental Protection Agency FLUTe Flexible Liner Underground Technologies, LLC Freon 113 1,1,2-Trichloro-1,2,2-trifluoroethane ft Feet GC/MS Gas Chromatography-Mass Spectrometry GMP Groundwater Monitoring Plan HWB Hazardous Waste Bureau ID Inner Diameter IDW Investigation-Derived Waste in. Inch JDMB Jornada del Muerto Basin L Liter mg Milligram MPITS Mid-plume Interception Treatment System NASA National Aeronautics and Space Administration NBBS N-butyl-benzenesulfonamide ND Not Detected NDMA N-nitrosodimethylamine NDMA-LL N-nitrosodimethylamine Low-Level ng/L Nanogram per liter NMAC New Mexico Administrative Code NMED New Mexico Environment Department NTU Nephelometric Turbidity Unit OD Outer Diameter PCE Tetrachloroethene PPE Personal Protective Equipment QA Quality Assurance QC Quality Control RCRA Resource Conservation and Recovery Act SDL Sample Detection Limit SIM Selective Ion Monitoring SVOC Semi-volatile Organic Compound TCE Trichloroethene TDS Total Dissolved Solids TIC Tentatively Identified Compound TSDF Treatment, Storage, and Disposal Facility VOC Volatile Organic Compound WSTF White Sands Test Facility YJD Yellow Jacket Drilling

NASA White Sands Test Facility

Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR 1

1.0 Background

In 2013, the National Aeronautics and Space Administration (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 Flexible Liner Underground Technologies (FLUTe™) 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 semi-volatile organic compounds (SVOCs), including low concentrations of N-nitrosodimethylamine (NDMA), 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 to approximately 5 to 8 gallons per zone 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.

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 NDMA 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, 2017b). 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 SVOCs in samples from Water FLUTe sampling systems, including NDMA and several tentatively identified compounds (TICs) 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. In the April 25, 2018 Request for Extension of Time for NASA WSTF Monitoring Well Groundwater Data Representativeness Work Plan (NASA, 2018a), 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 (SIM) 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 SVOCs, 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 SVOCs, leading NASA to conclude that the contamination may be originating with the sampling system. In efforts to verify this, NASA submitted Abbreviated Investigation Work Plan for Groundwater Data Representativeness, Phase 1: FLUTe Well on December 21, 2018 (NASA, 2018c). On May 13, 2019,

1 Westbay is a registered trademark of Nova Metrix Ground Monitoring (Canada) Ltd.



NMED approved the abbreviated investigation work plan with modifications (AIWP; NMED, 2019). NASA submitted the revised AIWP with modifications on July 30, 2019 (NASA, 2019). NASA conducted the first phase of an evaluation of groundwater data representativeness in 2019, which comprised an evaluation of Water FLUTe monitoring well WW-4 to determine if the sampling system is the source of SVOCs, including NDMA and 1,4-dioxane.

2.0 Location

Groundwater monitoring well WW-4 is located approximately three miles west of the WSTF test areas near the western site boundary within the Jornada del Muerto Basin (JDMB). Well WW-4 was originally placed in its location to provide additional groundwater analytical information to assist with delineation of the WSTF trichloroethene (TCE) 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 feet (ft) west of the leading edge of the conceptualized groundwater contaminant plume and east of the WSTF water supply wells (Figure 2.1). The well provides horizontal and vertical definition within the local aquifer as part of the WSTF monitoring network and acts as a sentinel well downgradient of the contaminant plume.

3.0 Investigation Activities

The first phase of the data representativeness evaluation consisted of collection and analysis of groundwater samples from well WW-4, following removal of the Water FLUTe sampling system. This first phase consisted of: collection of initial groundwater samples from the Water FLUTe system; collection of water samples inside the FLUTe liner and removal of the Water FLUTe system; isolation of the four screened intervals in well WW-4 and purging and sampling of groundwater from each screened interval; and comparing data from samples collected during purging to available data from previous sampling events performed using the Water FLUTe sampling systems.

3.1 Constituents of Concern

Based on the available analytical data from groundwater monitoring well WW-4, NASA identified NDMA and 1,4-dioxane as the primary constituents of concern for this investigation. Several additional SVOC TICs in groundwater samples by SW-846 Method 8270D are of interest to NASA. These compounds are 2,5-dimethyl-1,4-dioxane, N-butyl-benzenesulfonamide (NBBS), and N,N-dimethyl-formamide. Finally, several volatile organic compounds (VOCs) are present in the WSTF groundwater contaminant plume, and while these constituents were not expected to be present in groundwater at the WW-4 location, NASA collected samples for VOC analysis to obtain data consistent with the ongoing groundwater assessment program. NASA measured groundwater indicator parameters such as temperature, turbidity, pH, and conductivity prior to collection of each set of samples.

3.1.1 Analytical Methods

NASA collected and analyzed groundwater samples for the constituents of potential concern (COPCs) using the analytical methods and 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 SIM

• SVOCs – SW-846 Method 8270D

• VOCs – SW-846 Method 8260C

3.1.2 Groundwater Quality Control Samples

NASA collected groundwater samples and analyzed them as described in preceding sections of this plan and the NMED-approved WSTF Groundwater Monitoring Plan (GMP; NASA, 2018b). Quality control samples were collected to ensure quality and representativeness of field data generated during the investigation. Field quality control samples were collected as follows:

• A set of VOC and low-level NDMA trip blanks were collected using deionized filtered water 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 were collected using deionized filtered water run through the wellhead manifold and flow meter, after all pumping equipment was decontaminated and the pump and drop pipe positioned down-borehole.

• A set of field blanks for all analytical methods were collected at the beginning of purging at each screened interval in well WW-4.

• Field duplicate samples were collected for all analytical methods to ensure that at least three duplicate samples were collected for analyses at each screened interval in well WW-4.

• One VOC and low-level NDMA matrix spike/matrix spike duplicate sample was collected at each screened interval in well WW-4.

Laboratory quality control samples were analyzed as required by the accredited contracted laboratory’s Quality Manual or Standard Operating Procedures.

3.2 Field Activities

NASA performed investigation fieldwork at well WW-4 between June 18 and August 13, 2019. The following sections describe the field activities conducted during this phase of the investigation. Field activities are documented in logbooks, provided in Appendix A.

3.2.1 Initial Water FLUTe Sampling

Prior to removal the Water FLUTe System from WW-4, groundwater samples were collected on June 18 to June 20, 2019, from the four sampling zones in the well’s Water FLUTe sampling system using the established sampling process in accordance with the Phase I AIWP (NASA, 2019). NASA collected initial groundwater samples in accordance with the GMP (NASA, 2018b). 1,4-dioxane by SW-846 Method 8270D SIM analysis was not included for the initial FLUTe sampling and is noted as a deviation from the approved work plan (Section 3.5).

In addition to the groundwater sampling identified in the work plan, NASA performed two sampling events on July 16, 2019, before the liner was removed (Section 3.5). NASA completed one sampling event on the morning of July 16, 2019, according the established FLUTe sampling procedures consistent with the GMP (NASA, 2018b). NASA collected a second set of samples in the afternoon to provide groundwater samples representative of longer FLUTe zone purge times. NASA conducted these two events to observe the effect of an additional purge of the Water FLUTe system vs. the analytical results



from routine sampling. Table 3.1 shows the sequence of sampling events and analyses that were taken as part of this investigation. The analytical results are discussed in Section 4.0.

3.2.2 Water FLUTe System Removal and Sampling

On July 17, 2019, the FLUTe liner was removed and water from the inside was sampled a single time (Liner Sample; Table 3.1) in accordance with the NMED-approved Phase I AIWP (NASA, 2019).

FLUTe, LLC, was contracted to assist with the removal of the Water FLUTe liner from well WW-4 to maintain liner integrity and ensure proper reel storage. Two nitrogen pumps were used to purge the liner water: a built-in liner pump and a second pump were installed to assist and expedite the purging process. Samples of FLUTe liner purge water were collected between the ninth and twelfth gallon of purging, using the built-in liner pump. The samples were analyzed by the analytical methods listed in Section 3.1.1. The results are discussed in Section 4.0.

After approximately 200 gallons were purged from the liner, FLUTe, LLC, pulled the liner incrementally (6 to 60 ft pulls) and continued purging water as necessary to evacuate the liner for removal. The liner was fully intact, recovered from the well, and rolled up onto a reel. FLUTe transported the liner to their facility for secure storage. Approximately 225 gallons were purged from the FLUTe liner sampling system.

3.2.3 Camera Log of WW-4

NASA field personnel performed a downhole camera log of the conventional monitoring well casing on July 25, 2019 to verify its integrity prior to groundwater purging. The static water level was noted at 400.1 ft. All four screens were clean and in good condition. Minor staining or possible biological growth was noted on the third and fourth screens. The total depth reached by the camera was 952.3 ft below ground surface (bgs), within the lower screen due to the 6/9 sand that was added on November 10, 2015 to provide a base for the FLUTe system during its initial installation.

3.2.4 Monitoring Well Sampling

Following removal of the Water FLUTe sampling system and the camera log, each of the four screened intervals in well WW-4 (Figure 3.1) were sampled for the COPCs described in Section 3.1.

NASA subcontracted Yellow Jacket Drilling (YJD) to support the groundwater sampling described in the approved AIWP. YJD mobilized a Pulstar P12000 pump rig to the WW-4 location on August 11, 2019 and assembled the downhole system to isolate and purge each screened interval. On August 12 and 13, 2019, the screened intervals were successively isolated using a double packer system (straddle packer with 26.95 ft of separation) with a submersible pump between the packers. The upper three screened intervals were purged and sampled on August 12, and the fourth interval was purged and sampled on August 13, 2019.

The wellhead assembly, drop pipe, packers, and the pump were decontaminated at WSTF’s Building 637 decontamination pad and mobilized to the WW-4 well site. YJD used a Grundfos 16S30-24, 4-inch (in.) outer diameter (OD) pump with packers set above and below to seal off the individual well screens during pumping. The pump was installed on 1.5-in. inner diameter (ID) steel drop pipe. The static water level was measured at 402.22 ft bgs. The pump was set at 431.88 ft bgs for the first screened interval, just below the bottom of the upper screen. The wellhead manifold included a 1-in. ID Carlon 1000 SSM flow meter and sample collection port. YJD purged this screened interval and samples were taken. The pump



was then progressively lowered to each screened interval (600.83 ft, 869.5 ft, and 954.95 ft bgs respectively) for successive purging and sampling.

Per the AIWP (NASA, 2019), NASA performed COPC sampling at multiple purge volume intervals to determine the trend of COPCs as groundwater is progressively drawn from further distances from the well casing. At the given rates of flow into the pump between the packers, sampling was typically rapid (1 1/2 hours for five sample events per screened interval, see Table 3.1) to acquire volumes of water representative of the following in-well and near-well features:

• Initial groundwater samples were collected from the drop pipe. These samples represent the groundwater inside the drop pipe and well casing and are reflected in Table 3.1 as “0-Purge” under Purge Sequence Number.

• Purge volume one represents the groundwater in the well casing and the sand pack in the annular space and is reflected in Table 3.1 as “1-Purge” under Purge Sequence Number.

• Purge volume two represents the groundwater just outside the sand-packed borehole and is reflected in Table 3.1 as “2-Purge” under Purge Sequence Number.

• Purge volumes three through five represent groundwater within the aquifer and are reflected in Table 3.1 as “3-Purge, 4-Purge, and 5-Purge” under Purge Sequence Number.

Assumed purge volumes listed in the approved AIWP were approximated using a nominal 12.25-in. open borehole (NASA, 2019). The required purge volumes were recalculated according to the volume of drop pipe used to purge each screened interval, a 5-in. nominal well casing, and the annular space between the casing and the borehole wall at 25 percent porosity. Table 3.2 shows the calculated purge volumes and sample schedule for each screened interval. There were nominally 70 gallons removed during each purge interval, a deviation as noted in Section 3.5. A total of 329, 421, 393, and 378 gallons were removed from the top to bottom screened intervals, respectively. Samples were taken according to the purge volumes listed in Table 3.2 and sent to off-site contracted laboratories for the analytical methods described in Section 3.1.1. The results are discussed in Section 4.0.

3.3 Performance or Acceptance Criteria

The purpose of this investigation was to determine if the detections of constituents of concern at the four sampling screens in well WW-4 are representative of groundwater at that location or the result of contamination introduced by the Water FLUTe sampling system. The Phase I investigation was conducted to comply with NMED direction to evaluate groundwater sampling data representativeness (NMED, 2016a, 2017).

Quality control samples were collected using deionized filtered water that met or exceeded the qualifications for ASTM International Type 1 water. Equipment blank samples were collected using deionized filtered water that was run through the wellhead manifold and flow meter. Analytical data from equipment blanks were evaluated to ensure cross contamination did not occur. Field blank samples were collected using deionized filtered water in conjunction with groundwater samples during fieldwork. Analytical data from field blanks were evaluated to ensure field contamination did not negatively affect sample data quality. Analytical data from trip blank samples were evaluated to ensure possible contamination from the shipping process did not negatively affect sample data quality. The number and type of quality control samples for this investigation are indicated in Table 3.1.

NDMA low-level (NDMA-LL) and VOC samples showed analytical detections in several of these trip blank samples. The VOC detections in blanks did not contain any of the WSTF plume constituents. NDMA was detected in one equipment blank (0.75 ng/L), four field blanks (2.1 ng/L, 3.1 ng/L, 10 ng/L,



and 43 ng/L), and three trip blanks (0.53 ng/L, 0.9 ng/L, and 1.7 ng/L). NASA assigned the applicable data qualifiers (flags) (EB, FB, TB and QD) to the associated analytical results. There were no SVOC detections in the equipment and field blanks, and trip blanks for SVOC were not collected according to the AIWP (2019).

QC data must be considered when analyzing the validity of the NDMA data. There were detections of NDMA above the 1.1 ng/L cleanup level in the field blanks at all four sampling intervals in well WW-4. These detections may have consequently affected the outcome of this investigation. The presence of NDMA contamination in field blanks collected during this investigation is sufficient to call into question all NDMA detections equal to or less than the field blank detections. No absolute presence or absence determinations can be made for NDMA.

3.4 Investigation-Derived Waste Management

Waste management and disposal were conducted in accordance with the Investigation-Derived Waste Management and Disposal section of the Abbreviated Work Plan for Groundwater Data Representativeness, Phase I: FLUTe Well Evaluation (NASA, 2019). Well WW-4 is located beyond the known boundary of the WSTF groundwater contaminant plume and, as expected, WSTF volatile organic compound contaminants of concern were not observed in the investigation sample results. Investigation Derived Waste (IDW) generated during this evaluation included IDW debris (e.g., disposable personal protective equipment [PPE], wipes) and aqueous IDW, which included water extracted from inside the FLUTe liner, groundwater produced during investigation activities, and decontamination rinsate.

NASA initially managed all IDW as non-hazardous waste in accordance work plan. It is normal practice for WSTF sampling technicians to dispose of debris generated during sampling activities in hazardous waste containers, regardless if the point of generation of the waste is within the WSTF groundwater contaminant plume. In accordance with this procedure, IDW debris generated during this investigation was placed in a hazardous waste container in a Resource Conservation and Recovery Act (RCRA) Central Accumulation Area. The container was managed in accordance with 20.4.1.300 New Mexico Administrative Code (NMAC) and 40 CFR 262.17 (2017). The IDW debris container was shipped to a permitted RCRA treatment, storage, and disposal facility (TSDF) for proper treatment and disposal before the 90-day accumulation time limit expired.

Aqueous IDW generated during the investigation consisted of water removed from inside the FLUTe liner, purge water produced from the formation during the investigation, and decontamination rinsate. The aqueous IDW was initially managed as non-hazardous waste in accordance with the work plan requirements and 20.9 NMAC Solid Waste Regulations. Waste characterization samples were collected from the three aqueous IDW containers used for this project. The samples were analyzed using the current revision of EPA SW-846 methods for VOCs (SW-846 Method 8260), SVOCs (SW-846 Method 8270), N-Nitrosodimethylamine (NDMA; Modified Method 607), 1,4-dioxane (SW-846 Method 8270 SIM), and total metals (SW-846 Methods 6010, 6020, and 7470). Analytical results for the aqueous IDW waste characterization samples are provided in the laboratory reports in Enclosure 2.

1,1,2-Trichloro-1,2,2-trifluoroethane (Freon 113), TCE, and NDMA were detected in samples collected from waste container number 1451. Freon 113 (0.39J µg/L) and TCE (0.25J µg/L) results were flagged with the "J" data qualifier, which indicated that the result was an estimated value that is less than the quantitative limit but greater than or equal to the detection limit. Because there were no detections of Freon 113 or TCE in the investigation results, NASA believes the Freon 113 and TCE observed in samples collected from container 1451 reflect contamination from RCRA empty container residue. The aqueous IDW containers were RCRA empty in accordance with 40 CFR 261.7 before being used in this



investigation, and the residual was not subject to RCRA regulation [40 CFFR 261.7(a)(1)]. NDMA was the only contaminant detected in the second aqueous IDW container (container number 8452).

Final waste characterization was performed after receiving the analytical results. Waste generator knowledge was used with the results to determine the waste in containers 1451 and 8452 did not exhibit any characteristics of hazardous waste (40 CFR 261 Subpart C) or meet the hazardous waste listing definitions identified in 40 CFR 261 Subpart D. TCE and Freon 113 present in the waste in container 1451 was determined to originate from RCRA empty container residue. The residue itself was not RCRA regulated and the waste after accumulation was found not to exhibit any characteristics of hazardous waste or meet the listing definition of hazardous waste. Recognizing the presence of Freon 113, TCE, and NDMA in this waste, NASA transported both containers to the Mid-plume Interception and Treatment System (MPITS) where the waste was combined with hazardous IDW from other well purging activities and remediation waste from the MPITS extraction wells. Once combined, this waste was treated at the MPTIS and discharged in accordance with Discharge Permit (DP)-1255 (NMED, 2017a).

Analytical results for samples collected from the third container (number 1452) indicated the presence of NDMA, Freon 113, and 1,4-dioxane. Freon 113 was only detected in the sample duplicate at a concentration of 0.22J μg/L. The result was flagged with the “J” data qualifier, indicating that the result was an estimated value that is less than the quantitative limit but greater than or equal to the detection limit. No Freon 113 was present in the primary sample above the method detection limit. 1,4-dioxane concentration was reported as 0.55 µg/L in both the primary and duplicate samples taken from container. Final waste characterization was performed on this waste after receiving the analytical results. Using generator knowledge and the analytical results, it was determined the waste did not exhibit any characteristics of hazardous waste or meet the listing definition of hazardous waste. The Freon 113 present in the duplicate sample was attributed to contamination from RCRA empty container residue. There were no detections of Freon 113 in the groundwater investigation results. The MPITS was not designed to treat 1,4-dioxane, and the discharge of 1,4-dioxane is not permitted by DP-1255 (NMED, 2017a). In lieu of on-site treatment at the MPITS or discharge to the WSTF sewer system, the waste from container 1452 was shipped off-site to a RCRA TSDF for storage prior to treatment and disposal in a RCRA permitted landfill.

3.5 Investigation Deviations

NASA implemented several deviations from the approved AIWP (NASA, 2018b).

• NASA conducted two additional sample events prior to FLUTe removal on July 16, 2019. These were to observe the effects of extended purging of the FLUTe system on concentrations of COCs or TICs.

• Initial FLUTe samples were collected in accordance with the standard GMP requirements, which used SW-846 Method 8260C for 1,4-dioxane analysis; not SW-846 Method 8270D with SIM.

• A set of equipment blanks for all analytical methods were collected using deionized filtered water run through the wellhead manifold and flow meter, after the pump and drop pipe positioned down-borehole instead of the collected from the pump prior to placing it in the borehole.

• The approved AIWP estimated each purge volume assuming a nominal 12.25-in. open borehole (NASA, 2019) and 160 gallons per purge cycle. The required purge volumes were recalculated according to the volume of drop pipe used to purge each screened interval, a 5-in. nominal well casing, and the annular space between the casing and the borehole wall at 25 percent porosity. The revised purge volume per purge cycle was approximately 70 gallons.



4.0 Investigation Results and Interpretation

Analytical results from the groundwater samples collected at WW-4 are provided in Enclosure 2. The laboratory analytical reports are provided in Enclosure 3. Detections for COPCs are summarized in the following sections.

Historical FLUTe concentrations from COPCs are shown on five separate scatter plots. One scatter plot shows historical NDMA concentrations versus investigation concentrations (Figure 4.1). The other four scatter plots show historical SVOC concentrations versus investigation concentrations (Figure 4.2 to Figure 4.5). Historical Westbay data was excluded due to NMED’s position that “Westbay wells do not produce representative samples of ambient groundwater” and direction to convert the WW-4 Westbay sampling system (NMED, 2011b).

4.1 Initial FLUTe and Liner Sample Results

NASA collected three sets of groundwater samples prior to removal of the Water FLUTe system. The samples collected between June 18 through 20, 2019 and the July 16, 2019 morning samples were collected according to the established Water FLUTe sampling system process. The July 16, 2019 afternoon samples were collected in the same manner; however, additional water was purged from each interval as a result of the morning samples that were collected. This was to observe whether extended purging of the FLUTe system would affect concentrations of COPCs or TICs.

A comparison provided in Table 4.1 of the appearance of COPC over all three sample events shows uniform concentrations of NDMA in the screened intervals, a constant presence of NBBS in the screened intervals, and inconsistent occurrences of 2,5-dimethyl-1,4-dioxane and N,N-dimethyl-formamide. WW-4 is beyond the WSTF plume and VOCs related to the plume are consistently non-detect in all four sampling intervals.

NASA collected one set of water samples from water contained inside the FLUTe liner, which never came in contact with the groundwater. The purged water from inside the FLUTe liner was sampled and analyzed by methods discussed in Section 3.1.1. Table 4.1 provides a comparison of FLUTe groundwater samples and the FLUTe liner water samples. TICs are elevated inside the liner compared to the FLUTe groundwater samples. NDMA and VOCs do not appear in the liner samples. The data indicates that NBBS, 2,5-dimethyl-1,4-dioxane, and N,N-dimethyl-formamide concentrations are derived from the FLUTe liner.

4.2 WW-4 First Screened Interval (Zone 1)

The first screened interval in groundwater monitoring well WW-4 extends from 419 ft to 429 ft bgs. Figure 4.6 and Figure 4.7 show detections of NDMA and SVOCs respectively.

4.2.1 Zone 1 NDMA Results by Low-Level Method

NDMA was detected in Zone 1 after the FLUTe liner was removed. Detections ranged from 0.44 ng/L to 44 ng/L (Figure 4.6). Many of the values are flagged with multiple data qualifiers (Table 4.2). Overall NDMA had a downward trend and was below the 1.1 ng/L cleanup level by the fifth purge cycle.

The FLUTe initial samples showed 0.94 µg/L on June 18, 2019 and ND at detection limits of 0.22 ng/L from both July 17, 2019 sampling events (Figure 4.6). Subsequent samples from this zone primarily have single-digit ng/L NDMA detections throughout the purge cycle, with the exception of the 0-Purge sample (44 ng/L). The trend through sampling is slightly downward and generally in the single-digit ng/L range after the first purge. The lowest concentrations recorded is on the 5-Purge sample (0.95 ng/L; Table 4.2).



Where sample duplicates were taken, the greater of the two concentrations, sample or its duplicate are shown on the plots. Further extraction of groundwater beyond the gallons pumped in this interval would be beneficial for determining the long-term trend, and whether NDMA would remain at the single digit ng/L range or reduce to non-detect.

Field blank detections for August 2019 samples must be considered when evaluating data for the screened intervals sampled on those days (Section 5.0).

Since installation of the Water FLUTe sampling system in WW-4 in December 2015, NDMA concentrations in samples collected from all of the sampling intervals in well WW-4 are generally below 10 ng/L (Figure 4.1). Historical detections in the first sampling interval range from ND to 7.7 ng/L. With the exception of the 0-Purge result (44 ng/L), NDMA concentrations in samples collected from Zone 1 are consistent with historical concentrations.

4.2.2 Zone 1 SVOC Results by SW-846 Method 8270D and 8270-SIM

During this investigation 1,4-dioxane was consistently detected in Zone 1 after the FLUTe liner was removed (Figure 4.7). Where sample duplicates were taken, the greater of the two concentrations, sample or its duplicate are shown on the plots. Detections ranged from 0.035 µg/L to 0.12 µg/L (Table 4.3). NBBS was detected in in Zone 1. This TIC was detected prior to removal of the FLUTe liner (120 µg/L and 100 µg/L) and again after the fifth purge cycle (6.3 µg/L and Dup-6.4 µg/L) (Figure 4.7). No other TICs of interest were detected in Zone 1 during this investigation.

4.2.3 Zone 1 VOC Results by SW-846 Method 8260

Volatile WSTF plume constituents were analyzed by SW-846 Method 8260C. Only one constituent, chloroform (1.9 µg/L), was detected after the third purge cycle. No other constituents were detected in Zone 1. Chloroform is a WSTF volatile constituent of concern that has sporadic low-level detections across the site.

4.3 WW-4 Second Screened Interval (Zone 2)

The second screened interval in groundwater monitoring well WW-4 extends from 589 ft to 599 ft bgs. Figure 4.8 and Figure 4.9 show detections of NDMA and SVOCs respectively.


NDMA was detected in Zone 2 after the FLUTe liner was removed. Detections ranged from 1.5 ng/L to 2.9 ng/L (Figure 4.8). Many of the values are flagged with multiple data qualifiers (Table 4.2). Overall NDMA had a slightly increasing trend throughout the five purge cycles.

The FLUTe initial samples showed 0.94 µg/L on June 18, 2019 and ND at detection limits of 0.22 ng/L from both July 16, 2019 sampling events. All subsequent samples from this zone have single-digit ng/L NDMA detections throughout the purge cycle. The lowest concentrations were recorded on the 2-Purge and 3-Purge samples (1.5-1.6 µg/L), but increased to 4.1 ng/L by the 5-Purge sample.

Since installation of the Water FLUTe sampling system in WW-4 in December 2015, NDMA concentrations in samples collected from all of the sampling intervals in well WW-4 were generally below 10 ng/L (Figure 4.1). Historical detections in the second screened interval range from ND to 7 ng/L. NDMA concentrations in samples collected from Zone 2 during this investigation are consistent with historical values.




For this investigation 1,4-dioxane was consistently detected in Zone 2 after the FLUTe liner was removed. Detections ranged from 0.030 µg/L to 0.056 µg/L (Figure 4.9; Table 4.3).

NBBS was detected prior to removal of the FLUTe liner (34 µg/L and 30 µg/L). There are no detections after the liner was removed (Figure 4.9; Table 4.3). No other TICs of interest appeared in Zone 2 during this investigation.


Volatile WSTF plume constituents were not detected in Zone 2.

4.4 WW-4 Third Screened Interval (Zone 3)

The third screened interval in groundwater monitoring well WW-4 extends from 848 ft to 858 ft bgs. Figure 4.10 and Figure 4.11 show detections of NDMA and SVOCs, respectively.


NDMA was detected in Zone 3 after the FLUTe liner was removed (Figure 4.10). Detections ranged from 0.36 ng/L to 6.1 ng/L and many of the values are flagged with multiple data qualifiers (Table 4.2). Overall NDMA had a consistent downward trend and was non-detect by the fifth purge cycle.

The FLUTe initial samples were ND at detection limits of 0.22 ng/L to 0.23 ng/L from both July 17, 2019 sampling events. All subsequent samples from this zone have single-digit ng/L NDMA detections throughout the purge cycle. For this zone, the lowest concentrations were recorded during the 5-Purge samples as non-detect (Table 4.2). Further extraction of ground water beyond the gallons pumped in this interval would be beneficial for determining whether NDMA would remain non-detect.

The field blank (August) concentrations must be considered when analyzing data (see Section 5.0) The presence of NDMA contamination in field blanks collected during this investigation is sufficient to call into question the NDMA detections equal to or less than the field blank detections.

Since installation of the Water FLUTe sampling system in WW-4 in December 2015, NDMA concentrations in samples collected from all of the sampling intervals in well WW-4 are generally below 10 ng/L (Figure 4.1). Historical detections in the third sampling interval range from ND to 4.5 ng/L. NDMA concentrations in samples collected from Zone 3 during this investigation are consistent with historical values.


One TIC of interest, NBBS, was detected prior to removal of the FLUTe Liner (74 µg/L and 42 µg/L). There are no detections after the liner was removed (Figure 4.11). No other TICs of interest were detected in Zone 3 during this investigation.





4.5 WW-4 Fourth Screened Interval (Zone 4)

The lowermost, or fourth, screened interval in groundwater monitoring well WW-4 extends from 948 ft to 958 ft bgs. Figure 4.12 and Figure 4.13 show detections of NDMA and SVOCs, respectively.


NDMA was detected in Zone 4 before and after the FLUTe system was removed (Figure 4.12). Detections ranged from 0.93 ng/L to 13 ng/L and many of the values are flagged with multiple data qualifiers (Table 4.2). Overall NDMA has a slightly increasing trend throughout the five purge cycles. The detections varied throughout the five purge cycles.

The field blank sample for Zone 4 was taken on August 13, 2019 and its sample concentration for low-level NDMA was 43 ng/L. Unlike the three shallower intervals purged, concentrations of NDMA tend to be greatest in this interval, and no decline in concentration through the purge cycles is evident.

Since installation of the Water FLUTe sampling system in WW-4 in December 2015, NDMA concentrations in samples collected from all of the sampling intervals in well WW-4 are generally below 10 ng/L (Figure 4.1). Historical detections in the fourth sampling interval range from ND to 35 ng/L. NDMA concentrations in samples collected from Zone 4 during this investigation, while higher than those in overlying sampling intervals, are consistent with historical values.


Two TICs of interest, NBBS and 2,5-dimethyl-1,4-dioxane, were detected prior to removal of the FLUTe liner (4 µg/L and 38 µg/L). There were no detections after the liner was removed (Figure 4.13). No other TICs of interest appeared in Zone 4 during this investigation.



4.6 Purging and Sampling Results Summary

4.6.1 NDMA Summary

All of the zones isolated and purged in well WW-4 appear to have single-digit nanogram per liter concentrations of NDMA at the end of the purge events.

Pumping volumes correlated with an increasing radius from which stagnant water from the FLUTe, presumed to contain COPCs, was replaced by formation water. Limiting assumptions are that flow is radial, no flow enters the packer zone from the sand pack above and below the isolated interval, a 25% estimated porosity of the pack, and that the diameter of the borehole wall within the isolated interval does not vary. A limitation of the experimental design is that equal incremental volumes of water removed from the well are derived from successive exponentially thinning cylindrical “shells” of formation that contains water. Assuming a right circular cylinder, the maximum radius from which water was drawn from the formation was 1.3, 1.5, 1.6, and 1.5 ft, respectively. This assumes a 25 percent porosity in the formation. Given the radius, on the order of 1.5 ft, from which water was drawn within each interval, further observations from purging and sampling using any future system will be beneficial, as water will be brought into the well from a progressively further radius.



4.6.2 SVOC Summary

Concentrations of 1,4-dioxane in Zones 1 and 2 remained relatively constant during purging performed for this investigation. SVOC TICs were generally not present in successive purges of groundwater samples and, whenever identified in any of the zones, were largely absent by the end of purging each zone.

Table 4.4 illustrates the most notable example of how the TICs responded to purging. NBBS showed significant concentrations in groundwater samples collected from the Water FLUTe system before the liner was removed. By the end of purging at all four screened intervals, NBBS was detected only in Zone 1 at 6.4 µg/L.

Four scatter plots, provided in Figure 4.2 to Figure 4.5, show the historical trends of SVOC TICs in FLUTe groundwater samples for each zone of well WW-4. Concentrations of 1,4-dioxane reduced one to two orders of magnitude from historical samples that were collected in June 2018. The June 2018 samples were the only instance, prior to the Phase I investigation, when groundwater samples were analyzed by SW-846 Method 8270D SIM.

4.6.3 VOC Summary

VOCs were analyzed by SW-846 Method 8260C and were not detected in samples collected during this investigation with one exception. Chloroform (1.9 µg/L) was detected after the third purge cycle of Zone 1. No other constituents were detected in Zone 1. There are no VOCs related to WSTF COPCs at well WW-4.

4.7 Potential for Interference with Low-Level NDMA Analysis

Although the primary objective of this investigation was to determine if detections of SVOCs in well WW-4 using the Water FLUTe sampling are representative of groundwater at that location, NASA also indicated in the approved AIWP (NASA, 2019), that some TICs may interfere with the analysis of NDMA by the low-level method. As stated in the work plan, NASA has observed concentrations of several SVOC TICs in groundwater samples collected at Water FLUTe wells. Analytical laboratory library searches of TICs from the SVOC analyses has frequently indicated the presence of NBBS, 1,4-dioxane, and 2,5-dimethyl-1,4-dioxane. NASA uses SW-846 8720D SIM to quantify concentration of 1,4-dioxane in groundwater samples.

NDMA concentrations in groundwater samples collected during this investigation were still present by the end of purging. On the other hand, SVOCs and SVOC TICs, if present, diminished. Other than 1,4-dioxane in Zones 1 and 2, SVOC TICs were largely absent by the end of purging each zone. Table 4.5 is a comparison of NDMA vs. concentrations of SVOC TICs for the final two (4- and 5-Purge) samples in each zone. NDMA was present in mostly single-digit concentrations throughout the purging of each zone. All NDMA detections had associated data qualifiers. As such, it is inconclusive from this investigation whether the presence of SVOC TICs or detectable concentrations for 1,4-dioxane caused detectable concentrations of NDMA.

5.0 Uncertainties

NDMA concentrations in groundwater samples collected during this investigation of well WW-4 may be subject to uncertainty when considering detections of NDMA in the accompanying quality control samples. Table 4.2 provides the NDMA and quality control concentrations.



The table shows that there was NDMA contamination in field blanks collected during this investigation sufficient to call into question NDMA detections at concentrations equal to or less than the field blank concentrations. At greater concentrations than the field blank, it is also noted that sample and duplicate sample NDMA concentrations for the zones are in general agreement and close to concentrations observed either in field or trip blanks. Some of the greatest NDMA concentrations were observed in Zone 4, where the NDMA field blank concentration was also greatest among field blank sample concentrations in this investigation.

Low-level NDMA concentrations historically observed in WSTF groundwater samples have often been associated with FB, TB, and EB qualifiers. The observed concentrations are consistent with those measured historically in groundwater using the Water FLUTe sampling system. The source of NDMA may be from environmental phenomena that have likewise affected the QC samples. With that caveat and from the standpoint of whether the FLUTe samples are representative of groundwater, they are as representative as samples taken from other sampling systems including the straddle packer and submersible pump purging used for this investigation.

6.0 Conclusions

This FLUTe data representativeness evaluation compared a time series of sampling event concentrations from well WW-4 following removal of the FLUTe liner to historical concentrations of groundwater from FLUTe system sampling, as well to COPC sample concentrations of the water used to submerge the liner but which has not historically been in contact with groundwater. The evaluation shows the following:

• There were a number of SVOC TICs of interest inside the FLUTe liner. Many were absent after removal of the FLUTe sampling system and concentrations were further reduced with purging of each screened interval. Based on the evaluation of SVOC TICs presented in this report, NASA concludes that groundwater samples collected from the Water FLUTe system are not representative of WSTF groundwater. Two TICs of interest, NBBS and 2,5-dimethyl-1,4-dioxane, were detected prior to FLUTe liner removal. NBBS was detected twice in Zone 1 (sample and duplicate) after the fifth purge cycle. No other TICs of interest were detected.

• The presence of 1,4-dioxane in the FLUTe liner, historical samples, and the purge samples will likely cause future detections of 1,4-dioxane in samples taken with the FLUTe system.

• NDMA concentrations through the purging event in the four screened intervals were consistent with historical concentrations in groundwater samples collected from the Water FLUTe system. Based on the evaluation of NDMA detections presented in this report, NASA concludes that NDMA concentrations in groundwater samples collected from the Water FLUTe system may be representative of groundwater at that location. However, the uncentainty introduced by routine detections of NDMA in field quality control samples leads NASA to also conclude that further evaluation of NDMA at low levels is required at WSTF.

• The same uncentainty introduced by routine detections of NDMA in field quality control samples makes it inconclusive from this investigation whether the presence of SVOC TICs or detectable concentrations for 1,4-dioxane caused detectable concentrations of NDMA.

• Given the radius, on the order of 1.5 ft, from which water was drawn within each interval, further observations from purging and sampling using any future system will be beneficial, as water will be brought from a progressively further radius into the well.

The purpose of this investigation was to determine if the detections of constituents of concern 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. NASA concludes that the detections of



SVOCs using the FLUTe system in well WW-4 is not representative of the groundwater at that location, and that the detections of NDMA may be coming from a non-groundwater source.

7.0 Recommendations

Based on the regulatory criteria and decision rule provided in the NMED-approved abbreviated work plan (NASA, 2019), the results of the Phase I investigation summarized in Section 4.0 and the conclusions drawn from those results summarized in Section 6.0, NASA recommends reinstalling the FLUTe system in WW-4, though SVOC TICs will be a concern. Before reinstallation, NASA recommends further purging. After reinstallation, SVOC TICs should be monitored by SW 846 Method 8270 SIM. NASA recommends weighing alternatives to the FLUTe system for a permanent purgeable sampling system in this well. The selected alternative will be part of a well reconfiguration plan for Westbay wells due December 31, 2020 to the NMED.

8.0 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.

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.

NASA Johnson Space Center White Sands Test Facility. (2018c, December 21). Abbreviated Investigation Work Plan for Groundwater Data Representativeness, Phase 1: FLUTe Well Evaluation. Las Cruces, NM.

NASA Johnson Space Center White Sands Test Facility. (2019, July 30). Response to Approval with Modifications of Abbreviated Investigation Work Plan Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation. 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 Ground Water Quality Bureau. (2017a, July 14). Discharge Permit Renewal and Modification, DP-1255, NASA White Sands Testing Facility. Santa Fe, NM.

NMED Hazardous Waste Bureau. (2017b, October 4). Approval with Modifications Detections of NDMA (N-Nitrosodimethylamine) and TCE (Trichloroethylene) In WSTF Groundwater Monitoring Wells 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.

NMED Hazardous Waste Bureau. (2019, May 13). Approval with Modifications Abbreviated Investigation Work Plan Groundwater Data Representativeness Phase 1: Water Flute Well Evaluation. Santa Fe, NM.

Standards Applicable to Generators of Hazardous Waste, 40 C.F.R. § 262 (2017). Retrieved from http://www.gpo.gov

http://www.gpo.gov/



Figures



Figure 2.1 Monitoring Well WW-4 Well Location Map

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NDMA CleanupLevel (1.1 ng/L)TCE Cleanup Level(4.9 ug/L)

Western BoundryFault Zone

WSTF Boundary ²February 20201 in = 1,042 ft0 1,250 2,500

Feet



Figure 3.1 WW-4 Water FLUTe Installation Diagram

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402.22’

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’

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989’ Total Depth PVC Casing

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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



Figure 4.1 Historical WW-4 FLUTe NDMA Concentrations: All Zones

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y = 0.0039x - 164.18

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Figure 4.1 Historical WW-4 NDMA Low-Level Concentrations (ng/L): All Zones

Zone 2 - Non-Detect

Indicates Phase I Sample

Zone 3 NDMA

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Zone 4 NDMA

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Samples collected after FLUTe removal.



Figure 4.2 Historical WW-4 FLUTe SVOC and TICConcentrations: Zone 1

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Figure 4.2 Historical WW-4 SVOC and TIC Concentrations (ug/L): Zone 1

1,4-Dioxane - Phase I Investigation

NBBS

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1,4-Dioxane

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Figure 4.3 Historical WW-4 FLUTe SVOC and TIC Concentrations: Zone 2

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Figure 4.6 WW-4 Phase I NDMA Low-Level Concentrations: Zone 1

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Figure 4.6 Phase I NDMA Low-Level Concentrations (ng/L): Zone 1

NDMA Trend (NDMA)

June 2019FLUTe

July 2019 FLUTe AM

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Figure 4.7 WW-4 Phase I VOC, SVOC, and TIC Concentrations: Zone 1

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Figure 4.7 Phase I VOC, SVOC, and TIC Concentrations (ug/L): Zone 1

Chloroform - Non-Detect

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Trend (1,4-Dioxane)

1,4-Dioxane - Non-Detect

Trend (NBBS)

SW-846 Method 8260 ND = <13

June 2019FLUTe

July 2019 FLUTe AM Chloroform


July 2019FLUTe PM

0-Purge 1-Purge 2-Purge 3-Purge 4-Purge 5-Purge




(SEE NEXT PAGE)

1.51.6

2.4

2.9

4.14.4

1

y = 0.3365x + 1.6438

0.1

1

10


NDMA NDMA - Non-Detect Trend (NDMA)

June 2019FLUTe

July 2019

FLUTe AMJuly 2019FLUTe PM




Figure 4.9 WW-4 Phase I SVOC and TIC Concentrations: Zone 2

(SEE NEXT PAGE)

7.1

3034

39

0.030.034

0.051 0.051 0.0530.056y = 0.0044x + 0.0305

y = -4.5x + 29.833

0.01

0.1

1

10

100

Figure 4.9 Phase I SVOC and TIC Concentrations (ug/L): Zone 2

1,4-Dioxane - Non-Detect 2,5-Dimethyl-1,4-Dioxane NBBS Trend (1,4-Dioxane ) Trend (NBBS)

SW-846 Method 8260 ND = <13

June 2019FLUTe

July 2019 FLUTe AM

1,4-Dioxane - Detection

July 2019FLUTe PM





(SEE NEXT PAGE)

2.3

6.1

3.1

1.41.3

y = -0.7886x + 5.1267

0.1

1

10


NDMA NDMA - Non-Detect Trend (NDMA)

June 2019FLUTe

July 2019






(SEE NEXT PAGE)

4242

74y = 16x + 68.667

1

10

100


NBBS Trend (NBBS)

June 2019FLUTe

July 2019






(SEE NEXT PAGE)

1.6

2.2

2.8

4.4

6.1

11 1113

y = 1.205x + 3.8014

0.1

1

10

100


N-Nitrosodimethylamine - Detection N-Nitrosodimethylamine - Non-Detect Linear (N-Nitrosodimethylamine - Detection)

June 2019FLUTe

July 2019 FLUTe AM

July 2019FLUTe PM





(SEE NEXT PAGE)

3838y = 38

0.01

0.1

1

10

100


1,4-Dioxane NBBS Trend (NBBS)

June 2019FLUTe

July 2019

FLUTe AMJuly 2019

FLUTe PM


0-Purge 1-Purge 2-Purge


3-Purge 4-Purge 5-Purge

SW-846 Method 8260 ND = <13



Tables



Table 3.1 Phase I Investigation Sample Inventory

Depth Category of Sample

Date of Sample

Purge Sequence Number

Time of Day Initial Field Para-

meters

VOC VOC

Dupli-cate

LL-NDMA

LL-NDMA Dupli-

cate

SVOC VOC

Dupli-cate

SVOC Selective Ion Monitoring


Duplicate

final Field Para-

meters

Equipment Blank Field Blank Trip Blank

From To

419 FLUTe - initial 06/18/19 FLUTe 9:10 9:45 x x x x x VOC, LL-NDMA VOC, LL-

NDMA

419 FLUTe - initial 07/16/19 FLUTe 10:40 12:14 x x x x x VOC, LL-NDMA

419 FLUTe - initial

07/16/19 FLUTe 16:06 17:48 x x

x

x

x

423 Purge Day 08/12/19 Blanks 8:00 9:13 VOC, LL-NDMA,

SVOC, SVOC SIM

VOC, LL-NDMA, SVOC, SVOC SIM

VOC, LL-NDMA

0-Purge 9:15 9:20 x x

x

x

x

1-Purge 9:32 9:40 x x x x x x x x x

2-Purge 9:50 9:54 x x

x

x

x

3-Purge 10:15 10:23 x x x x x x x x x

4-Purge 10:30 10:36 x x x x

x

x

5-Purge 10:49 10:57 x x x x x x x x x



589 FLUTe - initial

07/16/19 FLUTe 16:16 17:50 x x x x

x

x

594 Purge Day 08/12/19 Blanks 11:30 12:33 VOC, LL-NDMA, SVOC, SVOC SIM

VOC, LL-NDMA

0-Purge 12:45 12:49 x x

x

x

x

1-Purge 13:12 13:16 x x

x

x

x

2-Purge 13:27 13:37 x x x x x x x x x

3-Purge 14:00 14:04 x x

x

x

x

4-Purge 14:05 14:13 x x x x x x x x x

5-Purge 14:25 14:34 x x x x x x x x x

848 FLUTe - initial 06/20/19 FLUTe 8:35 9:20 x x x x x VOC, LL-NDMA VOC, LL-

NDMA

848 FLUTe - initial 07/16/19 FLUTe 10:51 12:03 x x x x x x VOC, LL-NDMA

FLUTe -

initial 07/16/19 FLUTe 16:30 18:00 x x

x

x

x


VOC, LL-NDMA

0-Purge 15:52 15:58 x x

x

x

x

1-Purge 16:00 16:18 x x

x

x

x

2-Purge 16:23 16:35 x x x x x x x x x



Depth Category ofSample

Date of Sample

Purge Sequence Number

Time of Day Initial Field Para-

meters

VOC VOC

Dupli-cate

LL-NDMA

LL-NDMA Dupli-

cate

SVOC VOC

Dupli-cate



Duplicate

final Field Para-

meters

Equipment Blank Field Blank Trip Blank

From To 3-Purge 16:40 16:45 x x x x x 4-Purge 16:50 17:02 x x x x x x x x x 5-Purge 17:08 17:25 x x x x x x x x x



948 FLUTe - initial

07/16/19 FLUTe 16:45 17:41 x x x x x


VOC, LL-NDMA

1-Purge 8:10 8:14 x x x x x

2-Purge 8:27 8:36 x x x x x x x x x 3-Purge 8:40 8:44 x x x x x 4-Purge 8:50 8:55 x x x x x x x x x 5-Purge 9:10 9:20 x x x x x x x x x

Liner 07/17/19 Liner x x x x x 07/17/19 Liner 07/17/19 Liner 07/17/19 Liner 07/17/19 Liner

N/A



Table 3.2 Well WW-4 Calculated Purge Volumes

Sample No.

Top Packer

Bottom Packer

Length of Zone Feature Dia.

(in.) Dia. (ft)

Cross-Sectional

Area (ft2)

Porosity Volume(ft3)

Volume (gal)

Cumulative Volume to

Purge (gal)

Comment

Zone 1 (Upper) 0-Purge Collected

sample directly from drop pipe WW-4-423 1-Purge 407.4 434.4 27 Borehole (1) 13.5 1.125 0.994 0.25 6.7 50.2 68.4

2-Purge 407.4 434.4 27 Outer PVC 5 0.417 0.136 0.25 0.9 6.9 136.8 3-Purge 407.4 434.4 27 Difference 5.86.4 43.3 205.2 4-Purge 407.4 434.4 27 Inner PVC 5 0.417 0.136 1.00 3.7 27.5 273.6 5-Purge 407.4 434.4 27 Drop pipe 1.5 0.125 0.012 1.00 0.3 2.5 342.0

Difference 3.4 25.1 (1) Avg. caliper through interval is 13.5" Total volume, each purge 9.1 68.4

Zone 2 0-Purge

Collected sample directly from drop pipe WW-4-594 1-Purge 576.4 603.3 27 Borehole (1) 13.5 1.125 0.994 0.25 6.7 50.2 68.4

2-Purge 576.4 603.3 27 Outer PVC 5 0.417 0.136 0.25 0.9 6.9 136.8 3-Purge 576.4 603.3 27 Difference 5.8 43.3 205.2 4-Purge 576.4 603.3 27 Inner PVC 5 0.417 0.136 1.00 3.7 27.5 273.6 5-Purge 576.4 603.3 27 Drop pipe 1.5 0.125 0.012 1.00 0.3 2.5 342.0

Difference 3.4 25.1 (1) Avg. caliper through interval is 13.5" Total volume, each purge 9.1 68.4

Zone 3 0-Purge Collected sample directly from drop pipe

WW-4-853 1-Purge 844.0 871.0 27 Borehole (1) 13 1.083 0.922 0.25 6.0 46.5 64.7 2-Purge 844.0 871.0 27 Outer PVC 5 0.417 0.136 0.25 0.9 6.9 129.4 3-Purge 844.0 871.0 27 Difference 5.1 39.7 194.1 4-Purge 844.0 871.0 27 Inner PVC 5 0.417 0.136 1.00 3.5 27.5 258.8 5-Purge 844.0 871.0 27 Drop pipe 1.5 0.125 0.012 1.00 0.3 2.5 323.5

Difference 3.2 25.1 (1) Avg. caliper through interval is 13" Total volume, each purge 8.3 64.7



Sample No.

Top Packer

Bottom Packer

Length of Zone Feature Dia.

(in.) Dia. (ft)

Cross-Sectional

Area (ft2)

Porosity Volume(ft3)

Volume (gal)

Cumulative Volume to

Purge (gal)

Comment

Zone 4 (Lower) 0-Purge

Collected sample directly from drop pipe

WW-4-953 1-Purge 930.5 957.5 27 Borehole (1) 12.25 1.021 0.818 0.25 5.5 41.3 59.5 2-Purge 930.5 957.5 27 Outer PVC 5 0.417 0.136 0.25 0.9 6.9 119.0 3-Purge 930.5 957.5 27 Difference 4.6 34.4 178.5 4-Purge 930.5 957.5 27 Inner PVC 5 0.417 0.136 1.00 3.7 27.5 238.0 5-Purge 930.5 957.5 27 Drop pipe 1.5 0.125 0.012 1.00 0.3 2.5 297.5

Difference 3.4 25.1 (1) Avg. calliper through interval is 12", use 12.25" Total volume, each purge 8.0 59.5

Note: 1 Purge volumes assume 25% saturation (available groundwater) of the filter pack in the annulus. Purge volumes are not based on open hole volumes.



Table 4.1 Phase I Investigation FLUTe and Liner Sample Results

Constituents of concern June 18-20, 2019 July 16, 2019

Morning July 16, 2019

Afternoon July 17, 2019 Liner Purge

Water Zone 1

Zone 2

Zone 3

Zone 4

Zone 1

Zone 2

Zone 3

Zone 4

Zone 1

Zone 2

Zone 3

Zone 4

NDMA (ng/L) 0.94 1 ND 2.8 ND ND ND 2.2 FB ND ND ND ND ND

1,4-dioxane (µg/L) ND* ND* ND* ND* ND* ND* ND* ND* ND* ND* ND* ND* 99 TIC*

NBBS (µg/L) 260 TIC

39 TIC

42 TIC

38 TIC

120 TIC

34 TIC

74 TIC

— 100 TIC

30 TIC

42 TIC

38 TIC

38 TIC

2,5-dimethyl-1,4-dioxane (µg/L)

7.1 TIC

— — — — — — 4 TIC — — — — 90 TIC

N,N-dimethyl-formamide (µg/L)

— — — — — — — 8.2 TIC

— — — — 1,700 TIC

WSTF Plume VOC Constituents (µg/L) ND ND ND ND ND ND ND ND ND ND ND ND ND

Notes FB The analyte was detected in the field blank. TIC The analyte was tentatively identified by a GC/MS library search and the amount reported is an estimated value. * 1,4-dioxane was analyzed by SW-846 Method 8260C which has a higher detection limit (13 µg/L) than SW-846 Method 8270D with selective

ion monitoring (0.027 µg/L). — Indicates no appearance of the specific TIC.



Table 4.2 Phase I Investigation NDMA Sample Results

Zone Purge Number Sample (ng/L)

Duplicate Sample (ng/L)

Quality Control (ng/L)

FB EB TB MS

1

0-Purge 44 —

< 0.22 0.75 EB < 0.22 —

1-Purge 4.4 EB 4.7 EB 2-Purge 2.3 EB — 3-Purge 2.6 EB QD 0.44 J EB QD 4-Purge 2.2 EB —

5-Purge 0.95 EB 0.97 EB

2

0-Purge 2.9 —

< 0.22 — 0.53 TB —

1-Purge 2.4 TB — 2-Purge 1.5 TB < 0.22 3-Purge 1.6 TB — 4-Purge 3.7 TB 4.4 TB 5-Purge 2.5 TB QD 4.1 TB QD

3

0-Purge 2.3 TB FB —

2.1 FB TB — 1.7 TB FB —


2-Purge 3.1 TB FB QD 1.4 TB FB QD

3-Purge 1.4 TB FB — 4-Purge 1.3 TB FB 0.36 J TB FB 5-Purge < 0.23 < 0.22

4


43 FB — 0.9 TB FB 3.9 TB FB


2-Purge 11 FB QD 1.3 TB FB QD

3-Purge 13 FB

4-Purge 5.3 TB FB 6.1 TB FB

5-Purge 11 FB QD 0.93 TB FB QD

QA Flags EB The analyte was detected in the equipment blank. FB The analyte was detected in the field blank. J The result is an estimated value less than the quantitation limit, but greater than or equal to the detection limit. MS Matrix Spike QD The relative percent difference for a field duplicate was outside standard limits. TB The analyte was detected in the trip blank.



Table 4.3 Phase I Investigation SVOC Sample Results

Zone Purge Number

1,4-dioxane NBBS1

Sample (µg/L)

Duplicate Sample (µg/L)

Quality Control (µg/L) Sample

(µg/L)

Duplicate Sample (µg/L) FB EB

1

0-purge 0.091 —

< 0.027 < 0.027

— — 1-purge 0.067 0.064 — — 2-purge 0.061 — — — 3-purge 0.036 J 0.035 J — — 4-purge 0.12 — — — 5-Purge 0.059 0.06 6.3 TIC 6.4 TIC

2

0-purge 0.034 J —

< 0.027 —

— — 1-purge 0.03 J — — — 2-purge 0.054 0.056 — — 3-purge 0.051 — — — 4-purge 0.051 0.044 — — 5-Purge 0.053 < 0.027 — —

3

0-purge < 0.027 —

< 0.027 —

— — 1-purge < 0.027 — — — 2-purge < 0.027 < 0.027 — — 3-purge < 0.027 — — — 4-purge < 0.027 < 0.027 — — 5-Purge < 0.027 < 0.027 — —

4

0-purge < 0.027 —

< 0.028 —

— — 1-purge < 0.027 — — — 2-purge < 0.027 < 0.027 — — 3-purge < 0.027 — — — 4-purge < 0.027 < 0.027 — — 5-Purge < 0.027 < 0.027 — —

Notes 1 No compounds were tentatively identified in the associated quality control samples. J The result is an estimated value less than the quantitation limit, but greater than or equal to the detection

limit. TIC The analyte was tentatively identified by a GC/MS library search and the amount reported is an estimated

value.



Table 4.4 FLUTe vs. Fifth Purge Concentration of Certain SVOC TICs

Zone

NBBS FLUTe Sample Concentration,

07/16/2019 (µg/L)1

NBBS 5- Purge Concentration

(µg/L)1

1,4-dioxane FLUTe Sample Concentration,

07/16/2019 (µg/L)3

1,4-dioxane 5- Purge

Concentration (µg/L)4

Zone 1 120 6.42 ND (13) 0.06 Zone 2 34 - ND (13) 0.053 Zone 3 74 - ND (13) ND (0.027) Zone 4 38 - ND (13) ND (0.027)

Notes: 1 Compound is a TIC by SW-846 Method 8270D. A blank (-) entry means this TIC was not detected. 2 Compound is a TIC by SW-846 Method 8270D. Greater concentration of sample and duplicate result. A

detection limit is not provided. 3 SVOC SIM analysis was not performed on initial FLUTe samples. July 16, 2019 results are reported from SW-

846 Method 8260C, VOC. 4 By SVOC SIM. ND indicates that the analyte was not detected above the noted detection limit.



Table 4.5 Fourth and Fifth Purge Sample NDMA Concentration vs. SVOC TIC Concentrations

NDMA

Concentration (ng/L)

NBBS1 (µg/L)

1,4-dioxane2 (µg/L)

2,5-dimethyl-1,4-dioxane1 (µg/L)

Fourth Purge Zone 1 2.2 EB - 0.12 - Zone 2 4.4 TB - 0.051 - Zone 3 1.3 TB FB - ND (0.027)2 - Zone 4 6.1 TB FB - ND (0.027)2 -

Fifth Purge Zone 1 0.97 EB 6.43 0.06 - Zone 2 4.1 TB QD - 0.053 - Zone 3 ND (0.22)2 - ND (0.027)2 - Zone 4 11FB QD - ND (0.027)2 -

Notes: 1 Compound is a TIC by SW-846 Method 8270D. A blank (-) entry means this TIC was not found. 2 By SVOC SIM. 3 ND = non-detect at noted detection limit. 4 No detection limit is given for a TIC by Method 8270.


Groundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation AIR A-1

Appendix A Field Logbooks

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