hazardous waste bureau - nasa · nmed comment: the following issues were noted during review of...

SUSANA MARTINEZ Governor

JOHN A. SANCHEZ Lieutenant Governor

State of New Mexico ENVIRONMENT DEPARTMENT

Hazardous Waste Bureau

2905 Rodeo Park Drive East, Building 1 Santa Fe, New Mexico 87505-6313

Phone (505) 476-6000 Fax (505) 476-6030 www.env.nm.gov

CERTIFIED MAIL - RETURN RECEIPT REQUESTED

August 14, 2018

Tim Davis Chief, Environmental Officer National Aeronautics and Space Administration White Sands Test Facility P.O. Box 20 Las Cruces, NM 88004-0020

Attention of: RE-1 7-121

RE: DISAPPROVAL 400 AREA CLOSURE INVESTIGATION REPORT NATIONAL AERONAUTICS AND SPACE ADMINISTRATION JOHNSON SPACE CENTER WHITE SANDS TEST FACILITY DONA ANA COUNTY, NEW MEXICO EPA ID #NM08800019434 HWB-NASA-17-018

Dear Mr. Davis:

BUTCH TONG~ TE Cabinet Secretary

J.C. BORREGO Deputy Secretary

The New Mexico Environment Department (NMED) has received the National Aeronautics and Space Administration Johnson Space Center White Sands Test Facility (Permittee) 400 Area Closure Investigation Report (Report), dated December 27, 2018. NMED has

reviewed the Report and hereby issues this Disapproval. The Permittee must address the following comments.

Mr. Davis August 14, 2018

GENERAL COMMENTS

1. Soil-to-Groundwater Pathway Screening Level Evaluation

NMED Comment: The primary contamination migration pathway at the 400 Area Closure is release of contaminants to the surface, followed by migration through the vadose zone, which subsequently resulted in groundwater contamination. Review of soil sample concentration data indicates various COCs (e.g., lead, arsenic, hexavalent chromium, tetrachlorodibenzofuran, and n-nitrosodimethylamine (NDMA)) have exceeded the corresponding NMED soil screening levels (SSLs) for dilution attenuation factor (DAF) 20 and require further evaluation. A complete screening level evaluation of the soil-togroundwater pathway must be included in the revised Report as a separate section.

2. Soil-Gas Laboratory Reports

NMED Comment: The following issues were noted during review of soil-gas analytical reports and data. The comments must be addressed in the revised report as follows:

a. The chain-of-custody information included in each soil-gas analytical report indicates that the final pressure of the soil-gas sample canisters was recorded as zero. Information provided in the corresponding sample analysis reports indicates that the final soil-gas sample canister pressures were positive values above zero. The initial and final soil-gas canister pressures must be listed on the chain of custody for all submitted samples or complete sampling field note information must be provided in the report, including the initial and final soil-gas sample canister pressure reading information and any additional sample collection information. The revised Report must include soil-gas sampling field notes with the required sample collection information as an additional appendix.

b. The soil-gas sample analysis data indicates that large sample dilutions were necessary during analyses of various collected samples due to elevated concentrations of Freon 11 and Freon 113, which exceeded sample analysis instrument upper calibration limits. In the case of soil-gas sample 400-KV-137 (Sample No. 1708070845), the provided Excel spreadsheet data indicates a sample aliquot dilution of 41,500 was necessary for the detection of Freon 11 and Freon 113 within the instrument calibration range. Although it is understood that the dilution was necessary for detection of the COCs within the sample analysis instrumentation calibration range, the large dilutions have resulted in sample analysis detection limits above NMED Vapor Intrusion Screening Levels (VISLs) for other COCs, as indicated by soil-gas sample analysis report information. The revised Report must address the effects of large sample dilutions on reported COC concentrations and sample analytical results reported below elevated laboratory detection limits for key COCs indicative of site contamination at White Sands Test Facility (WSTF) in all applicable Report sections.


3. Additional Figures Depicting COC Concentration Information

NMED Comment: The revised Report must include additional figures that spatially depict key concentration results for soil samples, groundwater samples, and soil-gas samples collected during the investigation as required by Permit Attachment 20, Section 20.3.13, Figures. COC concentrations in exceedance of applicable NMED screening levels, United States Environmental Protection Agency (USEPA) Regional Screening Levels (RSLs) or Maximum Contaminant Levels (MCL) must be highlighted for respective COCs on each figure for the provided sample result information. The figures must be referenced in all corresponding sections of the revised Report.

SPECIFIC COMMENTS

4. Section 2.2.1, 400 Area Test Stands, Page 5

NMED Comment: A September 25, 2017 Request/or Extension ofTimefor Submittal of 400 Area Investigation Report was submitted by WSTF and approved by NMED on October 18, 2017 to accommodate the need for additional time to complete groundwater and soil-gas sampling at 400 Area Closure monitoring wells. The submittal date extension was necessary due to ongoing propulsion testing conducted at the 400 Area throughout July and August 2017. Discuss ongoing propulsion testing at the 400 Area and any associated hazardous waste generation, containment, and disposal measures related to recent propulsion system testing in the revised Report.

5. Section 4.4, Performance or Acceptance Criteria, Page 15

Permittee Statement: "Project [ 400 Area Closure investigation] DQOs [Data Quality Objectives] are summarized as follows: If COC concentrations in vadose zone soils exceed the screening level as described in Permit Attachment 15 for direct exposure routes under the residential, industrial/occupational, and construction worker exposure scenarios, then move to the corrective measures evaluation phase. Otherwise, consider a "Corrective Action Complete."

NMED Comment: Revise the statement and any other affected Report sections to also account for groundwater encountered beyond the previously defined vadose zone investigation conditions established in the October 2011 400 Area Closure Investigation Work Plan and deemed necessary by NMED to fully characterize subsurface contamination. The 400 Area is a source for groundwater contamination at WSTF; therefore, the site must also meet the conditions of Permit Attachment 15, Section 15.1, Groundwater Cleanup Levels.

Soil-gas impacts in the subsurface, also must be evaluated in accordance with NMED's 2017 Risk Assessment Guidance for Site Investigations and Remediation (RA Guidance).

Mr. Davis August 14, 2018 Page4

Any proposed corrective action status determination for the 400 Area Closure will require additional contamination characterization, potential source zone corrective measures, and risk evaluation in accordance with the RA Guidance.

6. Section 7 .5, Groundwater Conditions, Page 30 through 31

Permittee Statement: "Figure 7 .5 [ 400 Area Potentiometric Surface Map] provides a potentiometric surface map of the 400 Area generated using groundwater elevations measured in new and existing groundwater monitoring wells."

NMED Comment: Include an additional table in the revised Report that provides pertinent groundwater information and potentiometric surface elevations utilized to develop Figure 7 .5 and support the information provided in Section 7.5.

7. Section 7 .5, Groundwater Conditions, Page 31

Permittee Statement: "The third observation is that there is a very large response (3 to 4 ft [feet]) in the elevation of the potentiometric surface to the precipitation. If all of the rain was able to infiltrate to groundwater the response would be approximately 5 Yi to 1. As some of the precipitation will run off or be captured by evapotranspiration, the ratio is even greater. It indicates that the bedrock aquifer has very little storativitiy."

NMED Comment: Clarify the statement and explain the provided ratio (5 Yi to 1) in the revised Report. As stated, it is unclear how the ratio or statement translates to an interpretation of bedrock aquifer storativity.

8. Section 9.3.5, Soil Chemical Analytical Results and Comparison to Regulatory Criteria, Page 37 and 38

Permittee Statement: "Where no NMED SSL was available for a hazardous constituent, the New Mexico Groundwater (NMGW) or MCL-based SSL, Dilution Attenuation Factor (DAF 20) was used."

NMED Comment: Permit Attachment 15, Section 15.2, Soil Cleanup Levels requires the use of USEP A RS Ls for comparison to detected soil concentrations in the absence of established NMED SS Ls. DAFs for evaluation of the soil-to-groundwater pathway must not be used for screening COC concentrations for evaluation of human health risk. Revise all affected sections of the Report to include the appropriate screening level evaluation and discussion of soil chemical analytical result data as required by the Permit for the residential, industrial/occupational, and construction worker exposure pathways.


9. Section 9.3.6, Soil Chemical Analytical Results Above NMED RSSL [Residential Soil Screening Levels] and CWSSLs [Construction Worker Soil Screening Levels], Page 38

Permittee Statement: "A total of three of the original COP Cs [constituents of potential concern] were detected in chemical soil samples at concentrations above NMED screening levels: arsenic (above RSSL); lead (above RSSL and CWSSL); and NDMA (above RSSL)."

NMED Comment: Use ofDAF 20 for lead (0.052 mg/kg) as the human receptor exposure screening level has resulted in the identification of the COC as a COPC for the residential and construction worker exposure pathway. RA Guidance, Section 2.0, Development of Pathway Specific Soil Screening Levels and Section 2.3.3, Alternative Evaluation for Lead provides the guidelines for the evaluation of lead in soil. Based on the RA Guidance and the Permit requirements, the appropriate human health screening levels for lead are the USEP A RSLs of 400 milligrams per kilogram (mg/kg) for the residential exposure scenario and 800 mg/kg for the industrial and construction worker exposure scenarios. Reevaluate the soil analytical data for lead and revise all affected sections of the Report accordingly.

10. Section 9.4.1, Groundwater Grab Samples, Page 38

Permittee Statement: "Groundwater was encountered during the installation of soil borings 400-SB-04, 400-SB-08, 400-SB-10, 400-SB-12, and 400-SB-14. Following removal of down hole drilling equipment from each boring, groundwater was allowed to recover sufficiently for sample collection. A decontaminated stainless steel bailer was lowered into the boring to collect groundwater samples for analysis of VOCs [volatile organic compounds] by method 8260, SVOCs [semivolatile organic compounds] by method 8270, and NDMA by EPA method 607."

NMED Comment: The Permittee's statement indicates that groundwater samples collected from soil borings 400-SB-04, 400-SB-08, 400-SB-10, 400-SB-12, and 400-SB-14 were collected prior to well development. Information provided in the Report indicates that dedicated sampling systems were installed in six of eight completed groundwater monitoring wells at the 400 Area Closure. Provide the rationale for sampling groundwater in the borings prior to well development and sampling system installation. Samples collected without proper well development or adequate purging may only be used for informational purposes. Only include groundwater sample data collected from developed monitoring wells in the Report. Revise the Report to include the required additional information.

11. Section 9.4.2, Groundwater Sampling at MSVGM Wells, Page 39

Permittee Statement: "Sampling equipment was not installed in 400-KV-142 due to its low recharge rate or in 400-L V-125 because the potentiometric surface had declined below the screened interval."

NMED Comment: The Permittee's statement indicates that groundwater was encountered in the boring ( 400-SB-O 1) for well 400-L V-125 and then dropped further than was anticipated during completion of the monitoring well. However, information provided in the January 9,


2017 400-SB-OI Diagram email communication between the Permittee and NMED indicated that groundwater was not encountered upon advancement of boring 400-SB-O 1 to total depth. The boring was subsequently completed as a groundwater monitoring well with the intent of sampling groundwater during any potential future recharge events. Based on observed field conditions, the well screen was set at a location most likely to intercept groundwater during a recharge event (screened interval: 125 to 140 feet below ground surface (bgs)). The completion information indicates that the borehole was advanced to 167 .5 feet bgs. Resolve the discrepancy and revise the Report accordingly.

12. Section 9.6.3.3, Metals, Page 41

NMED Comment: In order to maintain contaminant concentration unit continuity in the Report discussion and supporting data tables, the groundwater sample concentration units (milligrams per liter) for metals in Section 9.6.3.3 must be converted to concentration units (micrograms per liter) consistent with the units reported in Table 7.5, Groundwater Analytical Results Above WSTF Cleanup Screening Levels.

13. Section 9.7, Soil Vapor Sampling, Page 42

NMED Comment: Information provided in Section 9.7 indicated that soil-gas samples could not be collected from sampling ports 400-FV-131-130 (130 feet bgs) and 400-JV-150-145 (145 feet bgs). The inability to sample the soil-gas wells at the specified sample intervals was attributed to the groundwater table rising above the sampling port depth. Provide additional discussion in the revised section clarifying the aquifer conditions encountered at monitoring well 400-FV-131 and 400-JV-150 that resulted in the submergence of the soil-gas sampling ports after the wells were completed. Revise the Report accordingly.

14. Section 11.4.2, Metals, Page 47

Permittee Statement: "Lead occurs as a product of intrusive metamorphism within the area, and the "outer lead zone" includes the Bear Canyon area to the east (Seager 1981) that is the source of much of the alluvial fan deposits within the WSTF test areas.

NMED Comment: Provide additional information from the cited Seager 1981 reference document that better defines the "outer lead zone" and substantiates the given line of evidence for naturally occurring concentrations oflead and other metals in site soils. In addition, provide a copy of the referenced document forNMED's administrative record.

15. Section 11.4.2, Metals, Page 47

Permittee Statement: "Based on the available data, NASA concludes that concentrations of metals in soil beneath and adjacent to 400 Area Closures are consistent with local and regional background concentrations. Metals in the soils at the 400 Area Closure do not present a source of contamination to the groundwater."


NMED Comment: Concentrations of various metals (e.g., beryllium, chromium, and copper) have exceeded NASA WSTF September 2015 Soil Background Study upper tolerance limits (UTL) for Area No. 2 soils (representative of soils at the 400 Area). The 95 % UTLs for each established background concentration interval (shallow, middle, and deep) are the appropriate criteria for soil background concentration evaluation. Additionally, various metals have exceeded NMED DAF 20 SS Ls for protection of groundwater (e.g., lead, arsenic, and hexavalent chromium). Reevaluate the collected soil sample analytical results with respect to the appropriate background concentration criteria and NMED DAF values and revise the soil analytical result data interpretation accordingly in the revised Report.

16. Section 11.5, Interpretation of Soil Vapor Analytical Results, Table Reference Issue, Page 48

Permittee Statement: "Table 7.7 [Soil Vapor Analytical Results Above NMED VISLs and WSTF RBCs (risk-based concentrations)] provides a summary of the two primary soil vapor VOCs detected above the NMED VISLs (Freon 11 and Freon 113) with a comparison to calculated concentrations in equilibrium with the corresponding groundwater samples collected from the same MSVGM well."

NMED Comment: Table 7.7 has been referenced incorrectly in Section 11.5. Soil vapor to groundwater concentration information is provided Table 11.1 , Comparison of Vapor COCs to Their Groundwater Concentration. Revise the statement accordingly.

17. Section 11.5, Interpretation of Soil Vapor Analytical Results, Soil Vapor Intrusion, Page 48

Permittee Statement: "None of the COCs in the vapor phase were present in concentrations exceeding 1 percent of their residential RBCs. Detected VOCs at concentrations above NMED VIS Ls are from sampling zones toward the base of the well at depths of over 100 ft bgs in proximity to the local groundwater table. In addition, there are no occupied buildings in the 400 Area Closure, as the nearest regularly occupied buildings are several hundred feet south of the impoundments and adjacent arroyo; therefore, the vapor exposure pathway is considered incomplete. Given all these factors , the result of the preliminary assessment is that there is no potential for vapor intrusion for the 400 Area Closure."

NMED Comment: The 400 Area Closure is a source zone for WSTF groundwater contamination and potentially vapor intrusion. Additional soil-gas and groundwater sampling are required to substantiate the soil vapor exposure pathway conclusion presented in the Report. Evaluation of the collected data with respect to human health risk is also required to support the exposure pathway conclusion, but it is not currently required under the approved 400 Area Closure investigation scope of work. Revise the Report to address the need for additional groundwater and soil-gas sampling, data evaluation, and subsequent human health risk evaluation to support the vapor exposure pathway conclusion.


18. Section 12.0, Recommendations, Page 50

Permittee Statement: "NASA recommends no further investigation of the vadose zone beneath and adjacent to the 400 Area Closures at this time. A thorough evaluation of available soil and soil vapor analytical data should be conducted for the 300 Area and 400 Area utilizing the most recent NMED Risk Assessment Guidance to determine if the Corrective Measures Study (CSM) recommended in the 300 Area Closure Investigation Report is the best option for these areas."

NMED Comment: Based on the investigation results, additional groundwater and soil-gas sampling is required at the 400 Area Closure, which may result in supplemental investigation of the subsurface, including the vadose zone. Soil-gas concentrations for the COCs Freon 11, Freon 113, and chloroform were reported in exceedance ofNMED residential VISLs in samples collected at the 400 Area Closure as well as at up-gradient and down-gradient sampling locations within the vadose zone. The required additional soil-gas and groundwater sampling must be conducted in accordance with the current quarterly schedule for 400 Area Closure groundwater monitoring. Section 11.5 must be revised to include recommendations for submittal of a work plan for additional combined groundwater and soil-gas sampling at the 400 Area Closure for at least four sampling events on a quarterly reporting schedule. The collected data may then be utilized to develop a Corrective Measures Evaluation in accordance with Permit Attachment 20, Section 20.6, Corrective Measures Evaluation Report.

Additional evaluation of collected soil-gas concentration data previously collected at the 300 Area with current NMED and USEP A VISL site evaluation criteria and approved RBCs appears warranted. However, a soil-gas COC concentration gradient (concentrations increasing with depth) has been noted at WSTF operations areas (e.g., 200, 400, and 600 Areas) currently and previously subject to soil-gas sampling, which may be attributable to a combination of groundwater contamination off-gassing, COC density differences, and the influence of preferential migration pathways. Although the approved scope of work for the previously completed 300 Area Closure investigation was completed as proposed, the investigation did not result in complete subsurface characterization at the closure area. A complete characterization of subsurface vapor conditions above groundwater and corresponding groundwater concentration information is required to fully characterize subsurface conditions at the 300 Area Closure. The collected data could then be utilized for comparison to soil-gas and groundwater information collected at the 400 Area Closure and other WSTF operations areas. Any proposed corrective measures at the 300 Area Closure would likely also require supplemental investigation of the groundwater and the vadose zone where COC concentrations are the highest. Discuss the 300 Area Closure subsurface characterization data gaps, the potential for comparability of any groundwater and soil-gas data collected from the 300 and 400 Area investigations, and the need for additional subsurface characterization at the 300 Area in the revised Report.


19. Figure 11.1, 400 Area NDMA Concentrations, Page 68

NMED Comment: In order to maintain concentration unit consistency throughout the Report, the Figure 11 .1 groundwater isoconcentration map units (nanograms per liter) must be converted to be consistent with the concentration units (micrograms per liter) referenced in the discussion provided in Sections 9 and 11 and Table 7.5. Revise the Report accordingly.

20. Figure 11.2, Historical NDMA Trends for the 300 and 400 Areas, Page 69

NMED Comment: In order to maintain concentration unit consistency throughout the Report, the groundwater concentration units (parts per trillion) utilized in Figure 11.2 must be converted to match the concentration units (micrograms per liter) referenced in the discussion in Section 11.6.2.

21. Table 7.4, Soil Analytical Results Above NMED SSLs, Page 83 and 84

NMED Comment: The appropriate SS Ls for lead are the USEP A RS Ls of 400 mg/kg for the residential exposure scenario and the 800 mg/kg for construction worker and industrial exposure. Revise the table and Report accordingly.

22. Table 7.5, Groundwater Analytical Results Above WSTF Cleanup Screening Levels, Page 85 and 86

NMED Comment: The following discrepancies were noted for Table 7 .5 and must be resolved in the revised Report.

a. The appropriate NMED Tap Water screening level for further evaluation ofNDMA is · the more conservative cancer screening level 0.00491 µg/L.

b. The appropriate NMED Tap Water screening level for further evaluation of barium is 3,280 µg/L.

c. The appropriate NMED Tap Water screening level for further evaluation of chromium is the more conservative cancer screening level 5.70 µg/L.

d. The appropriate NMED Tap Water screening level for further evaluation of vanadium is 63 .1 µg/L.

e. Ensure that all screening levels utilized for the evaluation and elsewhere in the Report are listed as provided in Table A-1: NMED Soil Screening Levels of the RA Guidance.


23. Table 7.7, Soil Vapor Analytical Results Above NMED VISLs and WSTF RBCs, Page 89

NMED Comment: The listed WSTF Residential RBC for chloroform (210,000 micrograms per cubic meter (µg/m 3

)) for the 50 feet bgs interval listed on Table 7.7 is incorrect. The approved 2017 WSTF RBC for chloroform at 50 feet bgs is 2,600 µg/m 3. Revise the table and any affected Report sections accordingly.

24. Table 10.1, Summary of Deviations, Page 90 through 94

NMED Comment: Additional information is required for Table 10.1 for clarification of the provided work plan deviation information:

a. Provide a sequential reference number for each work plan deviation listing.

b. 400 Area IWP [Investigation Work Plan], Upgradient Borings, Page 90, Sixth Comment: Include information on the specific borings that were added to the subsurface monitoring network as MSVGM wells or multiport soil vapor monitoring wells at the 400 Area Closure.

c. 400 Area IWP, Soil Sampling Plan, Page 91, Second Comment: A deviation was noted with respect to the proposed sample collection at the lowest sample interval above the expected bedrock for each boring location. The statement documenting the deviation indicated "[i]n general, with the exception 400-SB-04, the lower sample was collected over the depth range from 75 to 90 feet." The comment and corresponding boring log indicate that the lowest samples from each boring with the exception of 400-SB-04 were collected between 20 and 30 feet above the cemented alluvium contact in most of the completed borings. Typically, a sample is collected in unconsolidated soils directly above any consolidated subsurface layers or bedrock during environmental investigations. Provide additional information regarding the rationale for determining the lowest sampling interval for each boring during the 400 Area Closure investigation and include all supporting field notes in an additional appendix in the revised Report.

25. Table 11.1, Comparison of Vapor COCs To Their Groundwater Concentrations, Page 95

NMED Comment: The following discrepancies were noted for the provided Table information and must be corrected in the revised Report.

a. The soil vapor concentration reported for Freon 11 (1 ,700,000 micrograms per cubic meter (µg/m 3)) for the sample collected at 400-KV-142 at 137 feet bgs is incorrect. Supporting Report information indicates that the correct corresponding concentration is 1,800,000 µg/m3. Revise the table and any affected Report sections accordingly.

b. The soil vapor concentration reported for Freon 113 ( 1,800,000 µg/m 3) for the sample


collected at 400-EV-131at130 feet bgs is incorrect. Supporting Report information indicates that the correct corresponding concentration is 1, 700,000 µglm 3. Revise the table and any affected Report sections accordingly.

c. The NMED tap water Freon 113 screening level listed in the table (54,987 µg!L) does not correspond to the 2017 NMED tap water screening level of 55,000 µg/L. Correct the table information or provide a reference for the listed screening level.

26. Table 11.2, NDMA Concentrations in Groundwater, Page 96

NMED Comment: In order to maintain concentration unit consistency throughout the Report, the groundwater concentration units (parts per trillion) utilized in Table 11.2 must be converted to the concentration units (micrograms per liter) referenced in groundwater concentration evaluation discussions provided in Sections 9 and 11 and in Table 7.5. Revise the Report accordingly.

27. Appendix A, Lithologic Logs

NMED Comment: The following comments must be addressed in the provided lithologic logs as well as any additional discrepancies noted during reevaluation, review, and revision of the provided lithologic log information:

a. Soil Boring Lithologic Log 400-SB-01: The soil sample identification number (1612190950-1135) for the 44 to 45-foot bgs sample interval does not appear to match the information provided in Table 7 .2, Sampling Summary for Chemical Analyses. The soil sample identification number given in Table 7.2 for the 44 to 45-foot bgs sample interval is 1612191130-1135. Correct the lithologic log in the revised Report.

b. Soil Boring Lithologic Log 400-SB-02: A transcription error was noted in the lithologic description for the 60-foot bgs sample interval. The soil sample matrix description indicates the sample contains limestone, mudstone, siltstone, granite, "quartzile" and lepidolite clast material. It is likely that "quartzile" is a typographical error. Correct the lithologic log in the revised Report.

The lithologic description for the 90-foot bgs sample interval contains the soil clast matrix descriptor "monozoite diorite". It is unclear if use of the soil matrix descriptor was intended to convey the dominant mineralogy of the diorite clasts identified in the sample, or the intended clast description term was monzodiorite. Clarify the information in the response to NMED's modifications. Correct the lithologic log in the revised Report.

c. Soil Boring Lithologic Log 400-SB-03: The noted sample interval (44 to 45 bgs) for collected sample number 1610111030-1041 does not match information provided in the Table 7.2., which indicates the sample was collected for the 40 to 45-foot bgs sample interval. Correct the lithologic log in the revised Report. A transcription error


was noted in the lithologic description ("imestone") for the 60-foot bgs sample interval. Correct the lithologic log in the revised Report.

The sample identification number (1619111415-1420) for the 80 to 81-foot bgs sample interval does not appear to match the sample identification number (1610111415-1420) provided in the Table 7.2. Correct the lithologic log in the revised Report.

d. Soil Boring Lithologic Log 400-SB-05: A transcription error was noted in the lithologic description ("linestone") for the 70-foot bgs sample interval. Correct the lithologic log in the revised Report.

e. Soil Boring Lithologic Log 400-SB-06: A transcription error was noted in the lithologic description ("cemented clases") for the 80-foot bgs sample interval. Correct the lithologic log in the revised Report.

f. Soil Boring Lithologic Log 400-SB-08: The transcription errors "coatings oon clasts" was noted and "mafic instrusives" were noted for the 10-foot bgs sample interval and must also be corrected in the revised Report.

The soil sample identification number (1611201415-1420) for the 41to42-foot bgs sample interval does not appear to match the sample identification information provided in Table 7.2 (1611201415-1426). Correct the lithologic log in the revised Report.

A transcription error was noted in the lithologic description ("distinctive from the samples taken at the shallows internals in this borehole") for the 60-foot bgs sample interval. Correct the lithologic log in the revised Report.

g. Soil Boring Lithologic Log 400-SB-09: The soil sample identification number (1611161000-1005) for the 52.5 to 53.5-foot bgs sample interval does not appear to match the information provided in Table 7.2 (1611161000-1011). As necessary, correct the lithologic log in the revised Report.

h. Soil Boring Lithologic Log 400-SB-10: A transcription error was noted in the lithologic description ("volcanic tephna") for the 0 to 10-foot bgs sample interval. It is assumed the intended soil matrix clast description is volcanic tephra. Correct the lithologic log in the revised Report.

An additional transcription error was noted in the lithologic description ("pherocrysts of felsies") for the 170-foot bgs sample interval. Correct the lithologic log in the revised Report.

1. Soil Boring Lithologic Log 400-SB-12: A transcription error was noted in the lithologic description ("incrase in crystalline clasts") for the 30-foot bgs sample interval. Correct the lithologic log in the revised Report.


A bedrock description was not provided in the lithologic log interval from 90 to 154.5 feet bgs. Provide a revised lithologic log with bedrock descriptions for the samples collected at each sample interval ·between 90 to 154.5 feet bgs in the revised Report.

J. Soil Boring Lithologic Log 400-SB-13: The soil sample identification number (16111811330-1335) for the 47.5 to 48.5-foot bgs sample interval does not appear to match the information provided in Table 7.2 (1611181330-1341). Correct the lithologic log in the revised Report.

k. Soil Boring Lithologic Log 400-SB-14: A transcription error was noted in the lithologic description ("mud stores") for the 60-foot bgs sample interval. Correct the lithologic log in the revised Report.

28. Appendix E, Well Completion Diagrams

NMED Comment: The following information provided in the Well Completion Diagrams must be revised accordingly:

a. The noted Portland Type I/II Cement well completion material information for the 86.5 to 105.3-foot interval was not included in the graphic representation of the 400-IV-123 well diagram. Correct the well completion diagram in the revised Report. As necessary, include a discussion in the revised Report that addresses any deviation from the well design for monitoring well 400-IV-123 that was submitted in the December 9, 2016 email communication sent by the Permittee to NMED titled Proposed MSVM Well Construction Diagram for Boring 400-SB-06.

b. Provide information on the dedicated groundwater sampling equipment installed in each groundwater monitoring well on each well completion diagram. As necessary, also include a note that indicates where dedicated sampling equipment was not installed in a monitoring well. Include a brief discussion of sampling equipment installation in each groundwater monitoring well as an additional section in the revised Report.

The Permittee must submit a revised Report that addresses the comments contained in this letter. In addition, the Permittee must include a response letter that identifies where NMED's comments were addressed. The Permittee must also submit an electronic redline-strikeout version of the revised Report showing where all changes were made to the Report. The revised Report must be submitted no later than November 30, 2018. The required work plan for additional groundwater and soil-gas sampling must be submitted no later than February 28, 2019.


If you have any questions regarding this letter, please contact Gabriel Acevedo at (505) 476-6043 .

s ·ncerely,

Hazardous Waste Bureau

cc: D. Cobrain, NMED HWB B. Wear, NMED HWB G. Acevedo, NMED HWB L. King, EPA Region 6 (6MM-RC) M. Zigmond, NASA WSTF A. Sanchez, NASA WSTF

File: NASA 201 8 and Reading, NASA-17-018

HWB 3391 New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East, Btdg.l Santa Fe, New Mexico 87505-6313 1111 I I II

7017 1450 0001 9650 9414

Timothy J. Da"is Chief, Environmental Office NASA/WSTF P.O. Box20 Las Cruces, New Mexico 88004-0020

Hasler 08115/2018 US POSTAGE

hazardous waste bureau - nasa · nmed comment: the following issues were noted during review of...

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