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-14-04 2
Mr. John
E.
Kieling,
Chief
New Mexico Environment Department
Hazardous Waste Bureau
2905 Rodeo Park Drive East, Building 1
Santa Fe,
NM
87505
April 9, 2014
Subject: WSTF Monthly Environmental Activity Report for March 2014
Enclosed is the WSTF Monthly Environmental Activity Report for March 2014. This
reporting format includes an Executive Summary that provides important events/observations
as Enclosure 1, a paper copy
ofthe
report as Enclosure 2, and a CD-ROM with the report in
PDF as Enclosure
3.
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 Tim Davis
.
A52tQ~
~4--
Radel Bunker-Farrah
Chief, Environmental Office
3 Enclosures
cc:
Mr. Dan Comeau
Hazardous Waste Bureau
New
Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe,
NM
87505
Mr. Baird Swanson (*CD only)
Ground Water Quality Bureau
New
Mexico Environment Department
5500 San Antonio Drive
NE
Albuquerque,
NM
87109
Executive Summary
The following summarizes important information associated with NASA White Sands Test
Facility (WSTF) environmental program activities in March 2014:
• NASA completed two shipments
of
hazardous waste in March 2014.
• NASA completed
43
of
43
groundwater sampling events and all required groundwater
remediation system sampling scheduled for March 2014.
• The Plume Front Treatment System operated on 30
of31
days in March 2014 at an average
flow rate
of
851
gallons per minute. The PFTS extracted and treated approximately 94.7
acre-feet
of
groundwater.
• The Mid-plume Interception and Treatment System operated on
31
of
31
days in March
2014 and treated approximately 2.2 acre-feet
of
groundwater and approximately 0.02 acre-
feet
of
investigation-derived waste.
• NASA evaluated data from sampling performed at the JP4/5 remote test site and initiated
development
of
the investigation report.
• NASA continued preparations for the investigation and removal
of
several WSTF septic
tanks. A report summarizing the results
of
sampling performed at SWMU 22 was submitted
toNMED.
• NASA continued project planning for the wastewater lagoon investigation, the upcoming
200 Area Phase II investigation fieldwork, and a groundwater dye tracer test.
• NASA submitted several documents to NMED in March 2014, including a request for an
extension
of
time for beginning the lagoon investigation, analytical data for sludge samples
collected from SWMU 22, the annual waste report for a permitted treatment unit, and the
Soil Background Study Investigation Report.
• During March 2014, NASA continued a project to upgrade the sanitary sewer at WSTF and
connect to the City
of
Las Cruces sewer system.
• There were no reportable non-compliance issues in March 2014.
Enclosure 1
National Aeronautics and
Space Administration
Monthly Environmental Activity Report
March 2014
Submitted April 14, 2014
NM8800019434
NASA Johnson Space Center White Sands Test Facility
12600 NASA Road Las Cruces, New Mexico 88012
NASA
Johnson
Space
Center
White
Sands
Test
Facility
Monthly
Environmental
Activity
Report
March
2014
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.
Chief, Environmental Office
NASA White Sands Test Facility
Executive Summary
The following summarizes important information associated with NASA White Sands Test Facility
(WSTF) environmental program activities in March 2014:
• NASA completed two shipments of hazardous waste in March 2014.
• NASA completed 43 of 43 groundwater sampling events and all required groundwater remediati
on
system sampling scheduled for March 2014.
• The Plume Front Treatment System operated on 30 of 31 days in March 2014 at an average flow rate
of 851 gallons per minute. The PFTS extracted and treated approximately 94.7 acre-feet of
groundwater
.
• T
he Mid-plume Interception and Treatment System operated on 31 of 31 days in March 2014 a
nd
tr
eated approximately 2.2 acre-feet of groundwater and approximately 0.02 acre-feet of
investigation-derived waste.
•
NASA evaluated data from sampling performed at the JP4/5 remote test site and initiated
development of the investigation report.
• NASA continued preparations for the investigation and removal of several WSTF septic tanks. A
report summarizing the results of sampling performed at SWMU 22 was submitted to NMED.
• NASA continued project planning for the wastewater lagoon investigation, the upcoming 200 Area
Phase II investigation fieldwork, and a groundwater dye tracer test.
•
NASA submitted several documents to NMED in March 2014,
including a request for an extension
of time for beginning the lagoon investigation, analytical data for sludge samples collected from
SWMU 22, the annual waste report for a permitted treatment unit, and the Soil Background Study
Investigation Report.
• During March 2014, NASA continued a project to upgrade the sanitary sewer at WSTF and connect
to the City of Las Cruces sewer system.
• There were no reportable non-compliance issues in March 2014.
Monthly Environmental Activity Report – March 2014 3
NASA White Sands Test Facility
1.0 Waste Management Activities
1.1 NASA completed a shipment of hazardous waste to Veolia in Burley, Idaho on March 20, 2014.
The shipment consisted of one intermediate bulk container with 2,640 pounds (1,200 kg) of
hazardous waste.
1.2 NASA completed a shipment of hazardous waste to Veolia in Henderson, Colorado on March 20,
2014. The shipment consisted of 14 containers with 1,573 pounds (715 kg) of hazardous waste.
2.0 Environmental Monitoring
2.1 In March 2014, NASA performed sampling at all 43 of the groundwater monitoring wells
scheduled for sampling in March 2014.
2.2 Sampling of groundwater remediation system influent, effluent, and operational extraction wells
was performed in accordance with applicable permits and approved plans.
3.0 Corrective Actions
3.1 Plume Front Treatment System
• PFTS Operation – The PFTS operated on 30 of 31 days in March 2014 at an average flow rate
of 851 gallons per minute. The system extracted and treated approximately 94.7 acre-feet of
groundwater, most of which was injected to the aquifer following treatment. Approximately
25,000 gallons of groundwater were discharged to the on-site Modu-tanks during routine PFTS
startup operations. Approximately 1.13 acre-feet were discharged to grade at the PFI well
s
dur
ing backwashing and startup activities.
• PFTS Shutdowns, Repairs, and Modifications – There were two planned shutdowns of the
PFTS in March 2014. On March 6, 2014 the system was shut down to replace the variable
frequency drive (VFD) units on both air strippers. The system was restarted on March 7, 2014.
The system was shut down on March 11, 2014 to fine tune the air stripper VFDs. The system
was restarted later that day. There were also two unplanned PFTS shutdowns in March 2014.
On March 15, 2014 the PFTS shut down automatically because of an electrical power outage.
The system was restarted on March 17, 2014. On March 18, 2014 the PFTS shut down
automatically when a severe dust storm clogged the air filters at the air stripper intake.
Following the storm, the filters were replaced and the system was restarted within four hours.
3.2 Mid-plume Interception and Treatment System
• MPITS Operation – The MPITS operated on 31 of 31 days in March 2014 and treated
approximately 2.2 acre-feet of groundwater and approximately 0.02 acre-feet of IDW. All
t
reated groundwater was discharged to the infiltration basin.
• MPITS Shutdowns, Repairs, and Modifications – There was one unplanned shutdown of the
MPITS on March 15, 2014 because of an electrical power outage. The system was restarted on
March 16, 2014. On March 20, 2014 the MPITS was shut down for approximately one hour t
o
u
pgrade system software. The MPE wellheads are being modified to facilitate sampling
required for the upcoming groundwater dye tracer test.
3.3 JP4 and JP5 Investigation
• NASA completed evaluation of the analytical data from samples collected during th
e
in
vestigation and has initiated development of the final investigation report
.
3.4
200 Area Investigation
• NASA continued project planning activities for upcoming Phase II investigation fieldwork.
Monthly Environmental Activity Report – March 2014 4
NASA White Sands Test Facility
3.5 600 Area Investigation
• NASA continued extracting perched groundwater from monitoring well 600-G-138 in March
2014 in accordance with NMED’s March 1, 2013 Approval Time Extension for Implementati
on
o
f the Perched Groundwater Extraction Pilot Test at the 600 Area. Approximately 294 gallons
of perched groundwater was removed from 600-G-138 in March 2014.
3.6 Wastewater Lagoon Investigation and Closure
• NASA continues to plan for the investigation and closure of the WSTF wastewater lagoons i
n
acco
rdance with the NMED-approved Wastewater Lagoon Areas Closure Investigation Work
Plan. NASA was to start the investigation by April 30, 2014 or notify NMED by April 1, 2014
.
On
March 31, 2014 NASA submitted a letter requesting a revised project start date of July 31
,
2014. T
he extension is required to complete the Sanitary Sewer Pipeline Project which wil
l
co
nnect WSTF to the City of Las Cruces sewage treatment facilities.
• NASA completed surveying the lagoons to establish sample collection locations in preparation
for lagoon wastewater and sludge sampling after discharge to the lagoons is terminated.
3.7 Septic Tank Investigation and Removal
• NASA submitted a report to NMED on March 4, 2014 that summarized the analytical data from
samples collected at the SWMU 22 septic tank. The report also discussed evidence that
indicated the SWMU 22 septic tank had been leaking, and introduced the possibility that the
tank had no leach field. Proposed deviations to the SWMU 22 soil investigation were presented
to address these issues.
• NASA resampled the sewage sludge in the SWMU 22 septic tank for cyanide on March 17,
2014. It was determined during this sampling event that the tank does have an effluent pipe.
Exploratory fieldwork is planned to determine if this effluent line drains to a leach field.
3.8 Groundwater Dye Tracer Test
• NASA continued planning for a groundwater dye tracer test, which will be conducted in the
WSTF 200/600 Areas and in the Mid-plume Constriction Area (MPCA). NASA’s May 10,
2012
Work Plan for Tracer Testing in the 200/600 Areas and Mid-plume Constriction Area
,
a
pproved by the NMED Hazardous Waste Bureau on July 20, 2012, provides specific
information regarding the planned test. Though originally scheduled for as early as August
2012, the dye tracer test was postponed to allow sufficient time for the completion of work at
the Mid-plume Interception and Treatment System. Consistent operational conditions have
been achieved in the MPCA and MPE wellheads are being modified to allow for the collecti
on
of dye tracer samples. They dye tracer test was recently expanded to include additional
sampling locations in the 200 and 600 Areas and the MPCA. NASA anticipates that fieldwork
will begin in June 2014
.
3.9
Soil Background Study
• The recently submitted final investigation report for the soil background study remains under
NMED review.
4.0 Non-compliance Issues
• The NASA Hazardous Waste Permit requires that other non-compliance conditions be reported to
N
MED. There were no instances of other non-compliance during this reporting period that require
notification under the Permit. The criteria for non-compliance reporting in this report (as defined by
40 CFR 270.30(l)(10) and EPA interpretations at RCRA Faxbacks 13142 and 13686) would be any
non-compliance with permit conditions that is not classified as minor recordkeeping, reporting, a
nd
Monthly Environmental Activity Report – March 2014 5
NASA White Sands Test Facility
similar oversights that were corrected once discovered. Additionally, there were no issues meeting the
previously defined criteria (minor items immediately corrected) that were part of a repeating pattern
of non-compliance.
5.0 Miscellaneous
5.1 Sanitary Sewer Upgrade
During March 2014, NASA continued the project to upgrade the sanitary sewer system at WSTF
and connect to the City of Las Cruces (CLC) sewer system. The sewer upgrade includes a
combination of both gravity and force main in addition to four lift stations. NASA will continue to
keep NMED informed about the status of the sewer project, and its potential impacts on other
WSTF projects. Construction progress to date includes the following:
• NASA continues to negotiate the Transfer Agreement with the City of Las Cruces. The Servi
ce
A
greement was signed and approved by the City of Las Cruces on October 29, 2013. The
Transfer Agreement addresses NASA’s transfer of ownership of Line A and the Holman Lift
St
ation (HLS) to the City. NASA met with BLM and CLC on February 13, 2014 to discuss the
transfer agreement documents. Based on this meeting, NASA drafted a letter per BLM request
to explain NASA's right-of-way and the City's requirement to maintain, access, and operate the
HLS and the Holman Road 6-inch force main sewer line.
• Construction of Line A along Holman Road is substantially complete. A final hydrostatic leak
test and acceptance procedure with NASA and the City of Las Cruces was completed.
• Construction continues on the HLS. The lift station pumps have been installed. Connection of
piping and electrical power is in progress. Installation of controls and instrumentation is in
progress. Water service inside the HLS is complete. Grouting and sealant coating of the wet
well is complete.
•
Line B (from Holman Road to the WSTF 100 Area) is substantially complete. Manholes have
been installed. Grouting and sealant coating of the inside of the manholes
is complete, and
setting and pouring of the manhole rings is complete. A final low pressure air leak test and
cleaning of the line were completed.
• L
ine C (the force main from the Second TDRSS Ground Terminal (STGT) to the WSTF
400
A
rea) is substantially complete. A boring under the STGT access road, and installation of pip
e
casi
ng under the road, is complete. Installation of Lift Station #1 is in progress. A fina
l
h
ydrostatic leak test of the line was completed.
• Line D (the force main from the 400 Area to the 200 Area) is substantially complete. A fina
l
h
ydrostatic leak test was completed.
• Line E (from the 800 Area to the 300 Area) is complete. Installation of connecting manholes
,
g
routing, application of sealant coating, and setting of rings is in progress. A final low pressur
e
air leak test and acceptance procedure with NASA will be performed prior to activating the
system.
• Line E (from the 100 Area to the 200 Area) is substantially complete. Grouting, application of
sealant coating, and setting of rings is in progress. A final low pressure air leak test and
acceptance procedure with NASA will be performed prior to activating the system.
• Line F (400 Area) is substantially complete. A final low pressure air leak test was completed.
•
Lines G and H (from several buildings in the 100 Area to Line B) are substantially
complete,
and completion of several manholes is also complete. Grouting and sealant coating of the inside
of the manholes is complete. A final low pressure air leak test of the line was completed.
Monthly Environmental Activity Report – March 2014 6
NASA White Sands Test Facility
• Line I (from Lift Station #3 to Line E) is substantially complete. Lift Station #3 has been
ins
talled, and backfilling and installation of control panels is complete. A final hydrostatic leak
test was completed. Backfilling and compaction around the lift station is in progress.
• Line J (from the Hypervelocity facility to Lift Station #3) is substantially complete. A final lo
w
p
ressure air leak test was completed.
• Line K (from Lift Station #3 to the 800 Area) is substantially complete. A final low pressure air
leak test was completed.
•
Line L (from various 400 Area buildings toward Lift Station #2) is substantially complete. A
boring under Road L, and installation of pipe casing under the road, is complete. Installation of
the 8-inch gravity line in the pipe casing is complete.
Installation of connecting manholes,
grouting, application of sealant coating, and setting of rings is complete. Lift Station #2 has
been installed, and backfilling and installation of control panels is complete. A final low
pressure air leak test of the line was completed. Application of the sealant coating is also
complete.
6.0 Documents Submitted
6.1 Documents submitted in March 2014
• NASA submitted the Fee Assessment for Periodic Monitoring Report – 2013 Comprehensive
R
eport on March 4, 2014.
• NASA submitted the Summary of SWMU 22 Sewage Sludge Analytical Results and Propose
d
SWMU 22 Soil Investigation Methodology Deviations on March 4, 2014.
• NASA submitted the 2013 Annual Waste Summary Report for Waste Placed into the Permitted
T
reatment Unit at the NASA White Sands Test Facility (WSTF) on March 5, 2014.
• NASA submitted the Soil Background Study Investigation Report on March 27, 2014.
• NASA submitted the Request for Additional Extension of Time for Implementation of Lago
on
In
vestigation Work Plan on March 31, 2014.
6.2 Status of documents submitted in previous months
• NASA submitted the IWP for Evaluating Anomalous Detections of NDMA in Monitoring Wells
JER-1 and JER-2 on November 7, 2013. NASA received NMED’s November 21, 2013 fee
assessment for review of the plan and submitted the $10,000 review fee on December 19, 2013.
NMED review is pending.
• NASA submitted the Periodic Monitoring Report (PMR) – 2013 Comprehensive Report
on
J
anuary 30, 2014. NASA received NMED’s February 11, 2014 fee assessment for review of the
report and submitted the $2,000 review fee on March 4, 2014.
• NASA submitted the Well Completion Reports for the Conversion of Westbay Wells WW-2 and
JP-3
on December 16, 2013. NASA received NMED’s January 14, 2014 fee assessment for
review of the reports and submitted the $1,000 review fee on February 21, 2014. NMED is
reviewing the reports and has provided initial feedback to NASA.
• NASA submitted the Request for Revised Westbay Well Conversion Schedule on February 2
4,
2014.
NMED approved the request on March 7, 2014.
Monthly Environmental Activity Report – March 2014 7
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