space administration lyndon b. johnson space center white

National Aeronautics and Space Administration

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

April 19, 2021

Reply to Attn of: RE-21-058

Mr. Kevin Pierard, Bureau Chief New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505 Subject: NASA White Sands Test Facility (WSTF) Monthly Environmental Activity Report

for March 2021 Enclosed is the NASA White Sands Test Facility (WSTF) Monthly Environmental Activity Report for March 2021. This reporting format includes an Executive Summary that provides important events/observations as Enclosure 1, a paper copy of the 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 knowing violations. If you have any questions or comments concerning this submittal, please contact Amanda Skarsgard at 575-571-9668.

Timothy J. Davis Chief, Environmental Office

3 Enclosures

TIMOTHYDAVIS

Digitally signed by TIMOTHY DAVIS Date: 2021.04.19 07:58:32 -06'00'

RE-21-058 2 cc: Mr. Gabriel Acevedo Hazardous Waste Bureau New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505

Enclosure 1

Executive Summary The following summarizes important information associated with NASA White Sands Test Facility (WSTF) environmental program activities in March 2021:

NASA completed a shipment of universal waste in March 2021.

NASA sampled 45 of 45 groundwater monitoring wells scheduled for March 2021 and scheduled 40 groundwater monitoring wells for sampling in April 2021.

NASA operated the Plume Front Treatment System on 31 of 31 days in March 2021 and treated 74.5 acre-feet of contaminated groundwater.

NASA operated the Mid-plume Interception and Treatment System on 31 of 31 days in March 2021 and treated 1.39 acre-feet of contaminated groundwater and 49,513 gallons of investigation-derived waste.

NASA received NMED’s disapproval of three documents associated with the 300/400 Area HWMU investigations and one related to the 500 Area Fuel Storage investigation and began addressing NMED comments.

NASA continued planning the work required to address NMED comments on the disapproved investigation report for the 200 Area Hazardous Waste Transmission Lines (SWMU 10).

NASA continued addressing NMED comments on the disapproved investigation report for septic tanks (SMWUs 21-27).

Fieldwork for the 700 Area Landfill (SWMU 49) investigation, site-wide geophysics investigation, and groundwater treatment system well evaluation is on hold pending return to on-site work.

NASA performed fieldwork in accordance with the NMED-approved minimum site assessment work plan at the SMWU 52 diesel release.

NASA continued extraction of perched groundwater at monitoring well 600-G-138. NASA also continued project planning for the additional 600 Area perched groundwater investigation.

NASA extracted groundwater from five wells as part of the Targeted Mobile Remediation Process Pilot Test initiated in August 2019.

NASA began project planning for the replacement of well BLM-30 and continued developing a work plan for abandonment of monitoring well BLM-28.

NASA submitted three documents to the NMED Hazardous Waste Bureau in March 2021.

There were no reportable non-compliance issues in March 2021.

Monthly Environmental Activity Report

March 2021

Report Deadline: April 15, 2021


NASA Johnson Space Center White Sands Test Facility Monthly Environmental Activity Report

March 2021

NM8800019434

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.

______________________________________________

Timothy J. Davis

Date 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

TIMOTHY DAVIS Digitally signed by TIMOTHY DAVIS Date: 2021.04.19 07:59:02 -06'00'

NASA White Sands Test Facility

Monthly Environmental Activity Report – March 2021 3

Executive Summary

The following summarizes important information associated with NASA White Sands Test Facility (WSTF) environmental program activities in March 2021:

NASA completed a shipment of universal waste in March 2021.

NASA sampled 45 of 45 groundwater monitoring wells scheduled for March 2021 and scheduled 40 groundwater monitoring wells for sampling in April 2021.

NASA operated the Plume Front Treatment System on 31 of 31 days in March 2021 and treated 74.5 acre-feet of contaminated groundwater.

NASA operated the Mid-plume Interception and Treatment System on 31 of 31 days in March 2021 and treated 1.39 acre-feet of contaminated groundwater and 49,513 gallons of investigation-derived waste.

NASA received NMED’s disapproval of three documents associated with the 300/400 Area HWMU investigations and one related to the 500 Area Fuel Storage investigation and began addressing NMED comments.

NASA continued planning the work required to address NMED comments on the disapproved investigation report for the 200 Area Hazardous Waste Transmission Lines (SWMU 10).

NASA continued addressing NMED comments on the disapproved investigation report for septic tanks (SMWUs 21-27).

Fieldwork for the 700 Area Landfill (SWMU 49) investigation, site-wide geophysics investigation, and groundwater treatment system well evaluation is on hold pending return to on-site work.

NASA performed fieldwork in accordance with the NMED-approved minimum site assessment work plan at the SMWU 52 diesel release.

NASA continued extraction of perched groundwater at monitoring well 600-G-138. NASA also continued project planning for the additional 600 Area perched groundwater investigation.

NASA extracted groundwater from five wells as part of the Targeted Mobile Remediation Process Pilot Test initiated in August 2019.

NASA began project planning for the replacement of well BLM-30 and continued developing a work plan for abandonment of monitoring well BLM-28.

NASA submitted three documents to the NMED Hazardous Waste Bureau in March 2021.

There were no reportable non-compliance issues in March 2021.



1.0 Waste Management Activities

1.1 NASA completed the following waste shipment in March 2021.

Date Shipped To Type of Waste

No. of Containers

Amount of Waste

Disposition

3/31/21 Big Green Box, Anaheim,

CA Universal (Batteries)

1 14 kg Recycle

1.2 NMED is reviewing the Response to Approval with Modifications Closure Certification Report for the NASA WSTF FTU (Fuel Treatment Unit) (August 31, 2020).

2.0 Environmental Monitoring

2.1 NASA performed sampling at 45 of 45 groundwater monitoring wells or zones scheduled for sampling in March 2021, in accordance with the Groundwater Monitoring Plan (GMP). This includes well NASA 3, which was not sampled as scheduled in February 2021 because the water level was insufficient for sampling, and two wells that were rescheduled from April 2021 to March 2021 to accommodate TMRP sampling. Previous deviations from the planned sampling schedule are described below and have been reported to NMED in previous monthly reports:

Well PL-3-453 (scheduled for sampling in December 2020), wells 400-C-118 and 400-IV-123(scheduled for sampling in November 2020), and well 300-C-128 (scheduled for sampling inAugust 2020) cannot be sampled because the water levels are insufficient for sampling. NASAmonitors the water levels in these wells and will sample the wells if the water levels recoverenough to allow for the collection of representative samples.

NASA postponed monitoring at groundwater wells ST-1-541 and ST-1-630, scheduled forsampling in November 2020, because the wells are currently in use as extraction locations forthe ongoing Targeted Mobile Remediation Process Pilot Test and are not equipped withgroundwater sampling equipment. NASA plans to continue groundwater extraction andmonitoring at these wells and will collect routine groundwater samples when the wells revert tomonitoring status.

Well NASA 9, scheduled for sampling in October 2020, cannot be sampled because access tothe screened interval was prevented by the intrusion of roots into the well casing and screen.NASA is evaluating potential future use of this monitoring well.

Well 200-LV-150, scheduled for sampling in November 2019, failed to recharge adequately tocollect representative groundwater samples. NASA determined that future sampling is notpossible using a method with purging. NASA has successfully sampled the well using a no-purge method for engineering purposes and proposed future sampling with this technique in the2020 GMP. On January 25, 2021, NMED approved the GMP with modifications indicating no-purge technology is not acceptable for any groundwater monitoring at WSTF. Furtherevaluation, and potential replacement, of the well is required.

Well BLM-28-515, scheduled for sampling in July 2019, cannot be sampled because ofsampling system issues described in previous monthly reports. NASA plans to plug andabandon this well (Section 3.17) and removed it from the 2020 GMP.

The Water FLUTe sampling system was removed from well WW-4 to support the collection ofgroundwater samples in accordance with the Abbreviated Investigation Work PlanGroundwater Data Representativeness Phase 1: Water FLUTe Well Evaluation (July 30, 2019;



revised). Routine groundwater sampling required by the Groundwater Monitoring Plan is not possible at this time.

2.2 NASA performed other regulatory groundwater sampling requirements as scheduled and as allowed by operational status. NASA did not sample wells PFE-1 and PFE-2 because they were not operational due to equipment failure. NASA will initiate efforts to resolve these equipment issues in April 2021.

2.3 NASA developed the April 2021 groundwater sampling schedule and plans to sample 40 groundwater monitoring wells or zones based on GMP requirements.

3.0 Corrective Actions/Investigations

3.1 Plume Front Treatment System Operations

Days Operated

Average Flow Rate

(gpm)

Volume Extracted/

Treated (acre-feet)

Volume Injected

(acre-feet)

Volume Discharged to

Grade (acre-feet)

Volume Discharged to Modu-Tank (acre-feet)

31 of 31 538 74.5 73.7 0.44 0.10

Shutdown Date

Restart Date

Shutdown Status

Discussion

2/27/21 3/1/21 Unplanned The system shut down automatically because of a UV wiperfault.

3/16/21 3/16/21 Unplanned The system shut down automatically because of a disruptionin the off-site electrical power supply.

3/20/21 3/20/21 Unplanned The system shut down automatically because of acommunication loss.

3.2 Mid-plume Interception and Treatment System Operations

Days Operated

Average Flow Rate

(gpm)

Volume Extracted and

Treated (acre-feet)

Volume of Groundwater Discharged to

Infiltration Basin (acre-feet)

Volume of IDW Treated and

Discharged to the Infiltration Basin

(gallons)

31 of 31 9.8 1.39 1.55 49,513



Shutdown Date

Restart Date

Shutdown Status

Discussion

3/11/21 3/11/21 Unplanned They system shut down automatically because of a transmissivity lamp failure.

3/26/21 3/27/21 Unplanned The system shut down automatically because of a communication loss.

3.3 200 Area Investigation

NMED is reviewing the NMED Disapproval Response for 200 Area and 600 Area Vapor Intrusion Assessment Report (January 30, 2020).

3.4 400 Area

On March 15, 2021, NMED disapproved the 400 Area Supplemental Groundwater and Soil Vapor Monitoring Plan (5/28/19). NMED directed NASA to address three comments and submit a revised monitoring plan no later than July 30, 2021.

On March 19, 2021, NMED disapproved the 400 Area Closure Investigation Report (12/30/19; revised). NMED directed NASA to address 17 comments and submit a revised report no later than July 30, 2021.

On March 19, 2021, NMED disapproved the 300 Area Supplemental Abbreviated Drilling Work Plan (5/30/19). NMED directed NASA to address four comments and submit a revised work plan no later than July 30, 2021.

3.5 600 Area Perched Groundwater Extraction Pilot Test and Investigation

In March 2021, NASA extracted approximately 180 gallons of perched groundwater from monitoring well 600-G-138 in accordance with NMED’s March 1, 2013 Approval Time Extension for Implementation of the Perched Groundwater Extraction Pilot Test at the 600 Area. Extracted groundwater was containerized for treatment at the MPITS and discharge in accordance with DP-1255.

NASA continued project planning for the perched groundwater investigation in accordance with NMED’s December 22, 2020 approval with modifications of the Synopsis of the Findings of the 600 Area Closure Geophysical Seismic Refraction Tomography and Reflection Surveys with Revised Soil Boring Locations Submitted for NMED Approval. The perched groundwater investigation report is due to NMED no later than December 31, 2021.

3.6 SWMUs 2, 8, and 34 and AOC 51 (Wastewater Lagoons)

NMED is reviewing the NASA White Sands Test Facility (WSTF) 200 Area Wastewater Lagoons Closure (SWMU 8) Investigation Report (November 25, 2019), the NASA White Sands Test Facility (WSTF) 600 Area Wastewater Lagoons Closure (SWMU 34) Investigation Report (November 26, 2019), the NASA White Sands Test Facility (WSTF) 100 Area Wastewater Lagoons Closure (SWMU 2) Investigation Report (August 3, 2020), and the NASA White Sands Test Facility (WSTF) STGT Wastewater Lagoons Closure (AOC 51) Investigation Report (October 13, 2020).

3.7 SWMU 10 (200 Area Hazardous Waste Transmission Lines)

NASA continued revising the NASA WSTF 200 Area HWTL (SWMU 10) Investigation Report (July 30, 2019) and planning additional fieldwork to address 16 NMED comments from the



November 16, 2020 disapproval. A revised report is due to NMED no later than August 30, 2021.

3.8 SWMU 16 (600 Area BLM Off-site Soil Pile)

NMED is reviewing the Response to Fourth Disapproval of NASA WSTF SWMU 16 (600 Area BLM Off-Site Soil Pile) Investigation Report (December 18, 2019).

3.9 SWMUs 21-27 (Septic Tanks)

NASA continued preparing the response to NMED’s disapproval of the revised NASA WSTF Septic Tanks (SWMUs 21-27) Investigation Report. NMED directed NASA to address six comments and submit a revised investigation report no later than May 30, 2021.

3.10 SWMUs 29-31 (Small Arms Firing Ranges)

NMED is reviewing the Response to Second Disapproval Small Arms Firing Ranges (SWMUs 29-31) Remedy Completion Report and Risk Assessment Report (August 3, 2020).

3.11 SWMU 33 (Test Stand 302 Cooling Water Pond)

NMED is reviewing the revised SWMU 33 Historical Investigation Summary and Investigation Work Plan (August 17, 2020).

3.12 SWMU 47 (500 Area Fuel Storage)

On March 19, 2021, NMED disapproved the Response to Disapproval of 500 Area Fuel Storage Area (SWMU 47) Investigation Work Plan (November 21, 2019). NMED directed NASA to address five comments and submit a revised work plan no later than July 30, 2021.

3.13 SWMU 49 (700 Area Landfill)

The additional fieldwork necessary to support the investigation required by the SWMU 49 (700 Area Landfill) Phase I Investigation Work Plan (August 8, 2019; revised) has been planned, but is on hold pending return to on-site work.

Because of work restrictions resulting from NASA’s response to the COVID-19 pandemic, NASA submitted the Second Request for Extension of Time for Submittal of the SWMU 49 (700 Area Landfill) Phase I Investigation Report on February 3, 2021. NMED approved the request on March 15, 2021, extending the due date of the investigation report to April 29, 2022.

3.14 SWMU 50 (TDRSS Diesel Release)

NMED is reviewing the Response to Disapproval of First Tracking Data Relay Satellite System (TDRSS) Diesel Release (SWMU 50) Investigation Report and Risk Screen Evaluation Report (November 9, 2020).

3.15 SWMU 52 (Second TDRSS UST)

Between March 23 and March 26, 2021, NASA installed five soil borings in accordance with the NMED Petroleum Storage Tank Bureau (PSTB)-approved Minimum Site Assessment Work Plan (February 4, 2021). Rotosonic drilling equipment was used to install the borings to a minimum of 50 ft below ground surface (bgs) and a maximum of 85 ft bgs and to collect 29 primary soil samples for vapor analysis. Soil cores were analyzed for Volatile Organic Compound (VOC) vapor at 5 ft intervals during drilling. Vapor concentration exceeding 100 PPM VOC was detected in two of the five borings. The five open boreholes were properly plugged following sampling in accordance with the approved plan.



NASA containerized excess soil from drilling and sampling activities in intermediate bulk containers and is managing the waste as petroleum contaminated soil in accordance with New Mexico Special Waste rules. This investigation derived waste soil will be will be properly disposed of after waste characterization analytical results are received and evaluated.

3.16 Newly Identified SWMU near 500 Area

NMED is reviewing the 500 Area Newly Identified SMWU Release Assessment Report (June 22, 2020).

3.17 Monitoring Well Installation and Decommissioning

NMED is reviewing the Well Completion Report for BLM-42 and the Well Completion Report for PL-12 (May 4, 2020).

3.18 Westbay Monitoring Well Reconfiguration

NASA initiated planning for monitoring well work described in the NMED-approved Work Plan for Abandonment of NASA WSTF Well BLM-30 and Replacement with Monitoring Well BLM-43 (February 3, 2021; revised). Fieldwork is on hold pending return to on-site work.

NASA continued evaluating NMED’s response to the Well Reconfiguration Report for Well BLM-28 and Notice of Intent to Plug and Abandon (May 4, 2020). NMED directed NASA to submit a work plan for abandonment of well BLM-28 no later than April 30, 2021 and a subsequent work plan for well replacement, or notification that the well will not be replaced, no later than January 31, 2022.

NASA continued developing a work plan for the reconfiguration of several Westbay monitoring wells. The work plan in due to NMED no later than April 30, 2021.

3.19 Targeted Mobile Remediation Process (TMRP)

During March 2021, NASA continued TMRP fieldwork in accordance with the Targeted Mobile Remediation Process Pilot Test Work Plan (April 26, 2019; updated). NASA extracted 47,750 gallons of contaminated groundwater in March 2021. NASA evaluated well performance data to identify wells that will be targeted for additional groundwater extraction as the program progresses.

NASA continued the second episode of groundwater extraction at well MPE-3 through March 2021. NASA extracted 11,970 gallons from this well, for a total of 121,400 gallons since beginning extraction on July 9, 2020. NASA expects to continue groundwater extraction at well MPE-3 in April 2021.

NASA continued the second episode of groundwater extraction at well ST-1-541 through March 2021, removing an additional 13,500 gallons from the well. NASA has extracted a total of 123,100 gallons from the well since beginning extraction on June 24, 2020. NASA expects to continue groundwater extraction at well ST-1-541 in April 2021.

NASA continued the second episode of groundwater extraction at well ST-1-630 through March 2021, removing an additional 17,900 gallons of groundwater from the well. NASA has extracted a total of 125,538 gallons from the well since beginning extraction on August 3, 2020. NASA expects to continue groundwater extraction at this well in April 2021.

NASA completed the second episode of groundwater extraction at well BLM-14-327 on March 1, 2021. NASA extracted an additional 2,200 gallons of groundwater from the well, for a total of 88,205 gallons since beginning extraction from this well on September 9, 2020.



NASA initiated a second episode of groundwater extraction at well 400-A-151 on March 30,2021, and extracted 180 gallons. NASA expects to continue groundwater extraction at this wellinto April 2021.

NASA transported extracted groundwater to the MPITS for treatment and discharge inaccordance with the approved work plan and DP-1255.

On February 16, 2021, NASA field personnel observed water leaking from the tanker trailerused to contain groundwater extracted from monitoring well ST-1-541 as part of the TMRPpilot test. Approximately 900 gallons of contaminated groundwater was released directly to soil,and approximately 0.5 cubic yards of absorbent and surface soil were removed during theimmediate corrective action activities that NASA performed that day. NASA submitted oralnotification of this spill through the NMED Environmental Notification Reporting website and viaemail to the Hazardous Waste Bureau on February 17, 2021. NASA informed the NMED GroundWater Quality and Hazardous Waste Bureaus of the spill in writing on February 19, 2021. Furtherinformation regarding the spill and planned corrective action was provided in the required 15-daynotification, which was submitted to NMED on March 2, 2021.

NMED is reviewing the Targeted Mobile Remediation Process Interim Status Report – ProjectYear 2 (August 17, 2020).

3.20 Groundwater Data Representativeness Evaluation

NMED is reviewing the Groundwater Data Representativeness Phase 1: Water FLUTe WellEvaluation Abbreviated Investigation Report (February 27, 2020).

3.21 Dye Tracer Test Investigation

NMED is reviewing the Report on Tracer Testing in the 200/600 Areas and Mid-plumeConstriction Area (August 31, 2020).

4.0 Non-compliance Issues

The NASA Hazardous Waste Permit requires that other non-compliance conditions be reported to NMED. There were no instances of other non-compliance conditions 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, and 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 Documents Submitted

5.1 Documents submitted to the Hazardous Waste Bureau in March 2021

NASA submitted the Response to Approval with Modifications for NASA WSTF GroundwaterMonitoring Plan Update for 2020 on March 16, 2021.

NASA submitted the Response to Approval with Modifications of NASA WSTF PeriodicMonitoring Report – Fourth Quarter 2019 on March 30, 2021.

NASA submitted the Response to Approval with Modifications of NASA WSTF PeriodicMonitoring Report – First Quarter 2020 on March 30, 2021.



5.2 Pertinent documents submitted to other NMED bureaus in March 2021

NASA submitted the NASA WSTF Fifteen-Day Corrective Action Report to the Ground Water Quality Bureau on March 2, 2021.

NASA submitted the Opacity/Visible Emission Observation Report (A) to the NMED Air Quality Bureau on March 11, 2021.

NASA submitted the MACT Report – Opacity/Visible Emissions Test Results (ZZZZ) to the NMED Air Quality Bureau on March 11, 2021.

NASA submitted the NASA WSTF 700 Area Landfill Detection Monitoring Results for 2020 Second Semi-Annual Sampling Event to the Solid Waste Bureau on March 15, 2021.

NASA submitted the NASA WSTF Seven-Day Written Release Notification to the Ground Water Quality Bureau on March 18, 2021.

NASA submitted the NASA JSC WSTF – FF First Quarter 2021 Disinfectant Residual Monitoring Report to the Drinking Water Bureau on March 25, 2021.

NASA submitted the NASA WSTF Discharge Permit DP-697 Quarterly Analytical Results – First Quarter 2021 to the NMED Ground Water Pollution Prevention Section on March 30, 2021.

NASA submitted the NASA WSTF Universal Air Permit Application for Significant Permit Revision Air Quality Permit Number 0629-M4 to the Air Quality Bureau on March 30, 2021.

NASA certified the NMED Air Permit Emissions Inventory Report (AEIR) for the Air Quality Bureau on March 30, 2021.

5.3 Status of documents previously submitted to the NMED Hazardous Waste Bureau for which activity was recorded in March 2021

NASA submitted the NASA White Sands Test Facility (WSTF) SWMU 49 (700 Area Landfill) Phase I Investigation Work Plan (IWP) and Historical Information Summary (HIS) on December 28, 2017. NASA received NMED’s February 7, 2018 fee assessment for review of the plan and submitted the $10,000 review fee to NMED on March 5, 2018. NMED disapproved the plan on November 29, 2018 and directed NASA to address eight NMED comments and submit a revised plan no later than May 31, 2019. NASA submitted the Response to NMED Disapproval SWMU 49 (700 Area Landfill) Phase I Investigation Work Plan and Historical Information Summary on March 28, 2019. NMED approved the plan with modifications on June 6, 2019 and directed NASA to address four additional NMED comments and submit a revised plan no later than August 30, 2019. NASA submitted the Response to NMED Approval with Modifications SWMU 49 (700 Area Landfill) Phase I Investigation Work Plan and Historical Information Summary on August 8, 2019. NASA submitted the Request for Extension of Time for Submittal of the SWMU 49 (700 Area Landfill) Phase I Investigation Report on May 4, 2020. NMED approved the request on July 1, 2020, extending the due date for submittal of the investigation report to March 31, 2021. NASA submitted the Second Request for Extension of Time for Submittal of the SWMU 49 (700 Area Landfill) Phase I Investigation Report on February 3, 2021. NMED approved the request on March 15, 2021, extending the due date of the investigation report to April 29, 2022.

NASA submitted the NASA WSTF 400 Area Closure Investigation Report on December 27, 2017. NASA received NMED’s February 7, 2018 fee assessment for review of the report and submitted the $7,500 review fee to NMED on April 17, 2018. NMED disapproved the report on August 14, 2018 and provided 28 comments that required NASA response. NMED directed



NASA to submit a revised report by November 30, 2018, and a work plan for additional groundwater and soil vapor sampling by February 28, 2019. NASA submitted the NASA WSTF 400 Area Closure Investigation Report – NMED Disapproval Response on November 29, 2018. The submittal included the revised investigation report recommendations for additional groundwater and soil vapor sampling as required by NMED. NASA submitted the Request for Extension of Time for 400 Area Soil Vapor and Groundwater Monitoring Plan on April 25, 2019. NMED approved the request on May 2, 2019, extending the submittal date for the monitoring plan to May 31, 2019. NASA submitted the 400 Area Supplemental Groundwater and Soil Vapor Monitoring Plan on May 28, 2019. NASA also submitted the 300 Area Supplemental Abbreviated Drilling Work Plan on May 29, 2019. NASA received NMED’s July 3, 2019 fee assessments for review of the monitoring plan and drilling work plan on July 9, 2019. NASA provided the $1,000 fee for review of the drilling work plan on August 13, 2019. NASA received NMED’s September 16, 2019 Disapproval 400 Area Closure Investigation Report, which directed NASA to address 14 NMED comments and submit a revised report no later than December 31, 2019. NASA submitted the Fee Assessment for 400 Area Supplemental Groundwater and Soil Vapor Monitoring Plan on October 7, 2019. NASA submitted the NASA WSTF 400 Area Closure Investigation Report – NMED Second Disapproval Response on December 30, 2019. NMED disapproved the 400 Area Supplemental Groundwater and Soil Vapor Monitoring Plan, the 400 Area Closure Investigation Report, and the 300 Area Supplemental Abbreviated Drilling Work Plan, on March 15, 2021, March 19, 2021, and March 19, 2021, respectively. NMED directed NASA to address comments on each of the submittals and submit the revised report and plans no later than July 30, 2021.

NASA submitted the NASA WSTF Periodic Monitoring Report – Fourth Quarter 2019 on January 30, 2020. NASA received NMED’s February 21, 2020 fee assessment for review of the report on March 3, 2020 and provided the $2,000 review fee on March 17, 2020. NMED approved the report with modifications on February 19, 2021 and directed NASA to address two comments and submit a revised report no later than April 16, 2021. NASA revised the report to address the comments and submitted the Response to Approval with Modifications of NASA WSTF Periodic Monitoring Report – Fourth Quarter 2019 on March 30, 2021.

NASA submitted the NASA WSTF Periodic Monitoring Report – First Quarter 2020 on May 26, 2020. NASA received NMED’s July 9, 2020 fee assessment for review of the report on July 22, 2020 and provided the $5,000 fee for review of the report on August 17, 2020. NMED approved the report with modifications on January 25, 2021. NMED directed NASA to address two comments and submit a revised report no later than March 26, 2021. NASA revised the report to address the comments and submitted the Response to Approval with Modifications of NASA WSTF Periodic Monitoring Report – First Quarter 2020 on March 30, 2021.

NASA submitted the NASA WSTF Groundwater Monitoring Plan Update for 2020 on May 26, 2020. NASA received NMED’s July 9, 2020 fee assessment for review of the plan on July 22, 2020 and provided the $10,000 fee for review of the plan on August 17, 2020. NMED approved the plan with modifications on January 25, 2021. NMED directed NASA to address three comments and submit a revised plan no later than March 19, 2021. NASA revised the plan to address the three comments and submitted the Response to Approval with Modifications for NASA WSTF Groundwater Monitoring Plan Update for 2020 on March 16, 2021.