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Regulatory and Technical Issues Concerning the Detection and Treatment of NDMA-Contaminated Groundwater at NASA WSTF

The National Aeronautics and Space Administration (NASA) White Sands Test Facility (WSTF) was established in 1963 primarily to provide rocket engine testing services for several NASA programs. The groundwater underlying the site has been contaminated as a result of historical operations. Groundwater contaminants include several volatile organic compounds (VOCs) and two semi-volatile compounds: N-nitrosodimethylamine (NDMA) and N-nitrodimethylamine (DMN). This paper discusses some of the technical, analytical, regulatory, and health risk issues associated with the contaminant plume. The plume has moved approximately 2.5 miles downgradient of the facility industrial boundary, with evidence of continued migration. As a result, NASA has proposed a pump and treat system using air strippers and ultraviolet (UV) oxidation to stabilize future movement of the contaminant plume. The system has been designed to treat 1,076 gallons (4,073 liters) per minute, with provisions for future expansion. The UV oxidation process was selected to treat NDMA-contaminated groundwater based on successes at other NDMA-contaminated sites. Bench- and pilot-scale testing of WSTF groundwater confirmed the ability of UV oxidation to destroy NDMA and generated sufficient data to design the proposed full-scale treatment system. NDMA is acutely toxic and is a probable human carcinogen. EPA-recommended health risk criteria for the residential consumption of NDMA/DMN-contaminated groundwater was used to determine that a 1.0 x 10(exp -6) excess cancer risk corresponds to 1.7 parts per trillion (ppt). EPA analytical methods are unable to detect NDMA and DMN in the low ppt range. EPA's current Appendix IX analytical method used to screen for NDMA, Method 8270, can detect NDMA only at levels that are orders of magnitude greater than the recommended health risk level. Additionally, EPA Method 607, the most sensitive EPA approved method, has a detection limit of 150 ppt. This corresponds to an excess cancer risk of 9.0 x 10(exp -5), which exceeds the State of New Mexico's water quality standard of a cancer risk less than 1 x 10(exp -5). The treatment system has been engineered to treat contaminated groundwater to levels significantly below the New Mexico standard. However, the inability of EPA-approved analytical methods to detect NDMA and DMN at low ppt levels, and to provide verification of compliance with the 1 x 10(exp -5) cancer risk, introduces a notable risk to the long-term operation of the system. WSTF has been working with Southwest Research Institute to develop a non-EPA analytical method that can achieve a reporting limit of 1 ppt, which corresponds to an excess cancer risk of 7.6 x 10(exp -7). WSTF is currently developing a proposal to obtain approval from the New Mexico Environment Department (NMED) of this non-EPA method.

Wiebe, D. T.↗

Components Refurbishment and Chemical Analysis Facility, SWMU #041 - Per- and Polyfluoroalkyl Substances Site Assessment Report Kennedy Space Center, Florida

This PFAS Site Assessment (SA) Report presents the activities and results associated with PFAS investigations at the Components Refurbishment and Chemical Analysis (CRCA) facility located at Kennedy Space Center (KSC), Florida. In 2022, CRCA was identified as an Area of Potential Concern because the facility stores several potential PFAS-containing chemicals. A groundwater sample collected from an onsite monitoring well detected PFOA and PFOS at concentrations greater than State of Florida provisional Groundwater Cleanup Target Levels (pGCTLs). PFAS SA activities were conducted between March 2022 and February 2024. During this timeframe, a total of 16 direct-push technology (DPT) locations and 82 discrete samples were collected from these locations, along with 90 monitoring well samples. The analytical data screening process focused on State of Florida pGCTLs and United States Environmental Protection Agency (USEPA) Regional Screening Level (RSLs) from November 2023 to evaluate the data. Analytical results identified PFOS, PFOA, and PFBA at concentrations exceeding their respective RSLs at each depth interval (shallow, intermediate, and deep). PFOS and PFOA had the largest footprint of RSL exceedances in each depth interval, but pGCTL exceedances were only observed at limited locations in the shallow and intermediate intervals. PFBA had the highest detections of any PFAS compound, with concentrations exceeding 180,000 nanograms per liter (ng/L), which is 100-times the RSL of 1,800 ng/L in the shallow and intermediate intervals and 10-times the RSL in the deep interval. The maximum PFBA detection was 841,000 ng/L at shallow monitoring well, MW0006. The PFAS SA also included samples collected from the onsite hydraulic containment system (HCS) which was installed to control and treat the onsite chlorinated volatile organic compound (CVOC) plume. Influent and effluent aqueous samples were collected monthly from the system. PFAS concentrations were relatively the same for both influent and effluent samples, indicating that while the HCS has been effective for CVOC treatment, it does not provide any additional treatment for PFAS compounds. Since the HCS has achieved its objectives, the system was shut down in December 2024. PFAS data gaps still exist, to include surface water and soil, which were not sampled during this SA. Soil sampling near the Chemical Process Area is recommended. Surface water and soil sampling at select stormwater outfalls is also recommended. Additionally, further groundwater sampling is recommended (DPT and monitoring well) in all depth intervals to delineate the extent of PFAS impacts at CRCA.

K Alex Murphy↗

Launch Complex 39B, SWMU 009, 2023 Performance Monitoring and Air Sparge Expansion Construction Completion Report, Kennedy Space Center, Florida

The 2023 Performance Monitoring and Construction Completion Report (PM-CCR) presents the findings, observations, and results for Air Sparging (AS) operations and expansion activities, as well as sitewide groundwater monitoring for Launch Complex 39B (LC39B), Solid Waste Management Unit (SWMU) 009, at Kennedy Space Center (KSC), Florida. The reporting period for activities covered under this PM-CCR is from January 1, 2023, to December 31, 2023. At LC39B, AS operations began in 2017 in the area west of the launch pad, in the liquid oxygen (LOX) tank area located northwest of the launch pad, and in an area outside of the perimeter fence to protect nearby Outstanding Florida Waters (OFW). The LC39B AS system was installed with 279 AS wells to depths ranging from 23 to 60 feet below land surface (bls), including the sump, correlating to top of screen depths ranging from 20 to 57 feet bls. In December 2022, a total of 22 AS wells were abandoned to support launch pad crane operations, and in November 2023, the system was expanded with five additional AS wells installed to 13 or 17 feet bls near the LOX tank. The remedial objective of the LC39B AS Interim Measure (IM) is to actively decrease concentrations of contaminants of concern (COCs) in groundwater, specifically trichloroethene (TCE), cis-1,2-Dichloroethene (cDCE), and vinyl chloride (VC), to less than their respective Natural Attenuation Default Concentrations (NADCs), so LC39B can transition into a Long-Term Monitoring (LTM) program. This PM-CCR presents the following information for LC39B: • AS system operations and maintenance (O&M) (Year 7 of operation) from January 2023 to December 2023, to include AS trailer relocation in March 2023 and subsequent replacement and re-start in June 2023. • Construction completion details for AS system expansion, which included installation of five new AS wells and one new monitoring well in November 2023. As part of expansion activities, soil samples were also collected for petroleum analysis; no exceedances were identified, and no further investigation for petroleum is warranted. • Performance monitoring results for groundwater sampling events conducted in May/June 2023 (30 wells) and November 2023 (31 wells) in the AS IM area and in the Low Concentration Plume (LCP) areas located north and east of the launch pad for volatile organic compound (VOC) analysis. • Sampling results for one monitoring well, LOX-IW0012S, which is sampled for aluminum on an annual basis (May/June 2023). This well was resampled in November 2023 for both total and dissolved aluminum. Due to a communication error with the laboratory, the May/June 2023 sample was analyzed for total aluminum only. • Groundwater sampling results for per- and polyfluoroalkyl substances (PFAS) collected from seven monitoring wells during the May/June 2023 event to further investigate the Former Sewage Treatment Plant #6 and Percolation Pond area, west of the launch pad. O&M and performance monitoring results show that the AS system at LC39B is operating as designed and meeting performance criteria. Overall runtime was 45 percent (%) during the reporting period (January to December), but the operational runtime was 78% during the timeframe when the system could run (June to December). The most significant downtime contributor was post-launch crane operations following the Artemis launch on November 16, 2022, which lasted until June 2023. During that timeframe, the AS trailer at LC39B was relocated to another KSC remediation site (Wilson Corners) and was subsequently replaced with the AS trailer from the Paint & Oil Locker (POL) remediation site at KSC to resume AS system operations. Performance monitoring results in the AS IM and LCP areas continue to show reduction in COC concentrations over time when compared to baseline levels. In 2023, only one monitoring well (MW0048) detected a COC exceeding its NADC (VC at 740 micrograms per liter [µg/L]), which marks the baseline result for this new well installed during system expansion. Across the rest of the site, VC concentrations have declined or remained stable during the 2023 sampling events. Excluding MW0048, the highest VC result in 2023 was during the May/June sampling event with a concentration of 63 µg/L at MW0032, which is located near MW0048 and the AS expansion area by the LOX tank. TCE was detected in select monitoring wells in the IM area in 2023, but only two locations exceeded the State of Florida Groundwater Cleanup Target Level (GCTL): MW0032 (21 µg/L in May/June 2023 and 9.1 µg/L in November 2023) and MW0036 (5.0 µg/L in November 2023). MW0036 is also located near the LOX tank, on the north side, where the AS system is still operational (Zone Z4). cDCE and trans-1,2-dichloroethene concentrations were less than laboratory method detection limits or their respective GCTLs in all wells sampled in 2023. Near the OFW located northwest of the launch complex, all COC concentrations were less than laboratory method detection limits from monitoring wells (MW0039, MW0040, and LOXTA0002S) sampled in 2023. Aluminum results from LOX-IW0012S, which has been sampled routinely since 2006, detected a total aluminum concentration of 3,900 µg/L during the May/June 2023 sampling event. Results from the November 2023 event detected 5,700 µg/L for total aluminum and 5,500 µg/L for dissolved aluminum. These concentrations slightly decreased from the previous year but remain relatively consistent with historical detections. Aluminum will continue to be sampled on an annual basis at this well as results still exceed the GCTL of 200 µg/L and the Upper Limit of the KSC Background Concentration of 280 µg/L. PFAS results detected nine different PFAS compounds (out of 32 analyzed) from seven wells sampled. Two PFAS compounds, perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), currently have FDEP Provisional GCTLs of 70 nanograms per liter (ng/L). All seven samples collected resulted in concentrations less than the FDEP Provisional GCTLs for both PFAS compounds; no exceedances were observed. PFOS and PFOA also have assigned United States Environmental Protection Agency (USEPA) Maximum Contaminant Levels (MCLs) of 4 nanograms per liter (ng/L). None of the PFOS results exceeded the USEPA MCLs. PFOA was detected in two samples above the USEPA MCL at concentrations of 5.8 ng/L (ECS-IW0009I) and 5.5 ng/L (ECS-IW0009S). Three other PFAS compounds, perfluorohexanesulfonic acid (PFHxS), perfluoro-n-nonanoic acid (PFNA), and hexafluoropropylene oxide dimer acid (GenX), currently have USEPA MCLs of 10 ng/L. PFHxS, PFNA, and GenX were not detected at concentrations greater than their respective USEPA MCLs in any of the seven wells. PFAS compounds without FDEP Provisional GCTLs or USEPA MCLs were screened against USEPA RSLs. No other detections exceeded their respective USEPA RSLs. Additional PFAS sampling will be conducted as part of a future PFAS Site Assessment. Based on O&M activities and performance monitoring, the following is recommended for LC39B: • Continue with Year 8 AS system operation within Zone Z4, which includes the AS expansion area. Zone Z3, which has been off since 2018, should remain off as no rebound has been observed. Zones Z1 and Z2, which were turned off at the end of 2022, will remain shut down as monitoring well results have consistently been below GCTLs or have low-level detections with stable or decreasing trends (Meeting Minute 2402-M10, Decision 2402-D30). • Continue with performance monitoring in 2024 with the same monitoring well network as 2023, except with the addition of MW0048 in both semi-annual events. Baseline concentrations for this well were collected during the November 2023 performance monitoring event. Semi-annual sampling should be planned for the May 2024 and November 2024 timeframes (Meeting Minute 2402-M10, Decision 2402-D31). • Continue sampling monitoring well, LOX-IW0012S, for aluminum (total and dissolved) on an annual basis in May 2024. It is also recommended to re-develop this well prior to the next sampling event (Meeting Minute 2402-M10, Decision 2402-D32). The above recommendations for LC39B were presented at the February 2024 KSCRT Meeting, with Team consensus reached on the path forward. The contents of this PM-CCR were also presented at this meeting.

Deborah M Wilson↗

Wilson Corners SWMU 001 2014 Annual Long Term Monitoring Report Kennedy Space Center, Florida

This document presents the findings of the 2014 Long Term Monitoring (LTM) that was completed at the Wilson Corners site, located at the National Aeronautics and Space Administration (NASA) John F. Kennedy Space Center (KSC), Florida. The goals of the 2014 annual LTM event were to evaluate the groundwater flow direction and gradient and to monitor the vertical and downgradient horizontal extent of the volatile organic compounds (VOCs) in groundwater at the site. The LTM activities consisted of an annual groundwater sampling event in December 2014, which included the collection of water levels from the LTM wells. During the annual groundwater sampling event, depth to groundwater was measured and VOC samples were collected using passive diffusion bags (PDBs) from 30 monitoring wells. In addition to the LTM sampling, additional assessment sampling was performed at the site using low-flow techniques based on previous LTM results and assessment activities. Assessment of monitoring well MW0052DD was performed by collecting VOC samples using low-flow techniques before and after purging 100 gallons from the well. Monitoring well MW0064 was sampled to supplement shallow VOC data north of Hot Spot 2 and east of Hot Spot 4. Monitoring well MW0089 was sampled due to its proximity to MW0090. MW0090 is screened in a deeper interval and had an unexpected detection of trichloroethene (TCE) during the 2013 LTM, which was corroborated during the March 2014 verification sampling. Monitoring well MW0130 was sampled to provide additional VOC data beneath the semi-confining clay layer in the Hot Spot 2 area.

Monitoring↗

Wilson Corners SWMU 001 2015 Annual Long Term Monitoring Report Kennedy Space Center, Florida

This document presents the findings of the 2015 Long Term Monitoring (LTM) that was completed at the Wilson Corners site, located at the National Aeronautics and Space Administration John F. Kennedy Space Center, Florida. The objectives of the 2015 LTM event were to evaluate the groundwater flow direction and gradient, to monitor the vertical and horizontal extent of the volatile organic compounds (VOCs; including the upgradient and sidegradient extents, which are monitored every five years), and to monitor select locations internal to the dissolved groundwater plume. The 2015 LTM event included several upgradient and sidegradient monitoring wells that are not sampled annually to verify the extent of VOCs in this portion of the site. The December 2015 LTM groundwater sampling event included, depth to groundwater measurements, 40 VOC samples collected using passive diffusion bags, and one VOC sample collected using low-flow techniques. Additionally, monitoring well MW0052DD was overdrilled and abandoned using rotasonic drilling techniques. The following conclusions can be made based on the 2015 LTM results: groundwater flow is generally to the west with northwest and southwest flow components from the water table to approximately 55 feet below land surface (ft BLS); peripheral monitoring wells generally delineate VOCs to groundwater cleanup target levels (GCTLs) except for monitoring wells MW0088, MW0090, MW0095, and NPSHMW0039, which had vinyl chloride (VC) concentrations near the GCTL and MW0062, which had trichloroethene (TCE), cis-1,2-dichloroethenen (cDCE), and VC concentrations above natural attenuation default concentrations (NADCs); VOCs in interior downgradient wells generally fluctuate within historic ranges except for monitoring wells in the north-northwest portion of the site, which have increasing VC concentrations indicating potential plume migration and expansion; Historically, the vertical extents of the VOCs were delineated by monitoring wells screened greater than 60 ft BLS (MW0083 through MW0086, and MW0078). The 2015 LTM results indicate that concentrations of daughter product cDCE is greater than the NADC in MW0078 and that cDCE and VC are greater than NADCs in MW0130. TCE was greater than the GCTL in monitoring well MW130 and not detected above method detection limits (9 micrograms per Liter) in monitoring well MW0078. No GCTL exceedances were identified in monitoring wells MW0083 or MW0086; the dissolved plume footprint appears generally stable, though not fully delineated by monitoring well data in the northeast portion of the site; and 2015 LTM results generally support the existing Conceptual Site Model. Geosyntec recommends modifying the LTM program, collecting a verification sample from monitoring well MW0062, and performing a direct push technology instigation in the northnortheastern portion of the site. A cluster of monitoring wells (MW0132 [2 to 12 ft BLS], MW0133 [15 to 25 ft BLS], and MW0134 [29 to 34 ft BLS]) is proposed to delineate impacts in the northnortheast portion of the site. Geosyntec recommends installation of a vertical extent well in the center of the site (Hot Spot 2 area) post-remediation implementation.

groundwater↗

Contractors Road Heavy Equipment Area (SWMU 055) 2021 Annual Groundwater Monitoring Report

This document presents a summary of activities completed at the Contractors Road Heavy Equipment (CRHE) Area, located at Kennedy Space Center (KSC), Florida, from January through December 2021. The activities conducted at the CRHE Area include: - Annual groundwater sampling activities associated with site-wide plume monitoring and Underground Injection Control (UIC) monitoring in the former bioremediation Interim Measures (IM) Hot Spot 1 (HS1) area; - Direct push technology (DPT) groundwater investigation; and - Semi-annual vapor intrusion (VI) evaluation activities. This facility is designated Solid Waste Management Unit (SWMU) Number 055 (SWMU 055) under KSC’s Resource Conservation and Recovery Act Corrective Action program. This report was prepared by HydroGeoLogic, Inc. (HGL) for the National Aeronautics and Space Administration (NASA) under contract number 80KSC019F0096. The annual groundwater sampling results demonstrated that the footprint where chlorinated volatile organic compounds (VOC) are present above their State of Florida groundwater cleanup target levels (GCTLs) is not expanding overall. One non-chlorinated VOC (1,4-dioxane) is found above its GCTL at isolated points within the chlorinated VOC plume. The DPT groundwater investigation is being used to delineate the horizontal and vertical boundaries where chlorinated VOCs are present at levels above natural attenuation default concentrations. That data supports an evaluation of potential additional remedial actions. The potential for VI into the CRHE Area Office (K6-1996H) is evaluated by collected sub-slab vapor samples from four locations twice a year (once in the wet season and once in the dry season). The results for 2021 were all below the Environmental Protection Agency's vapor intrusion screening levels (VISLs) for both commercial and residential settings. The path forward for the site is to continue annual monitoring for chlorinated VOCs and 1,4-dioxane until additional remedies are implemented or the site is transitioned to long-term monitoring.

Contractors Road Heavy Equipment↗

Launch Complex 34, SWMU Cc054 2021 DNAPL Source Zone Operations, Maintenance, and Monitoring, and Hot Spot 6 Air Sparge System Annual Performance Monitoring Report Cape Canaveral Space Force Station, Florida

This Annual Performance Monitoring Report (PMR) for the Dense Non-Aqueous Phase Liquid (DNAPL) Source Zone (DSZ) and Hot Spot 6 (HS 6) Air Sparge (AS) System presents the results of Year 12 operation of the hydraulic containment (HC) Interim Measure (IM), the results of performance monitoring direct-push technology (DPT) sampling and monitoring well sampling conducted in the DSZ, and the results of operations and performance sampling of the HS 6 AS IM at Launch Complex 34 (LC34), located at Cape Canaveral Space Force Station (CCSFS), Florida. Site-wide biennial LTM sampling was not conducted during this reporting period and is scheduled to be conducted in December 2022. The timeframe for activities documented in this PMR extends from April 1, 2021 to March 31, 2022. LC34 has been designated Solid Waste Management Unit CC054 under the Kennedy Space Center (KSC) Resource Conservation and Recovery Act Corrective Action Program. The objective of the HC IM at LC34 is to contain the DSZ and deep dissolved-phase trichloroethene (TCE) high concentration plume via operation of a hydraulic containment system (HCS). The pre-IM design 300 micrograms per liter (μg/L) TCE groundwater contour was used to establish the deep zone capture area for deep recovery wells, and the shallow zone capture area was defined by the DSZ. The system began operating in 2010, and in 2015, the system was expanded to provide HC for areas within the 300 μg/L TCE groundwater isocontours of HS 3 and 4. In 2018 and 2019, an investigation was conducted to re-characterize the DSZ, which included investigating TCE mass in Layer 7. This data was subsequently used to optimize the pumping rates of the HCS to more adequately capture residual contaminant mass. The operational period for Year 12 of the HCS was from April 1, 2021 to March 31, 2022. Operational runtime for the system was 94 percent during Year 12, with downtime events attributed to planned maintenance, system repairs, and power outages. As of March 31, 2022, a total of 285,712,801 gallons of groundwater containing 84,933 pounds of VOCs have been removed by the HCS. Influent concentrations of TCE have decreased since startup from approximately 280,000 µg/L (January 2010) to 12,000 µg/L (March 2022). During the reporting period, all effluent concentrations from the HCS (aqueous and vapor) were below regulatory reporting limits, indicating the system continues to operate as intended. Performance monitoring was conducted in December 2021 within the DSZ to evaluate TCE contamination. Groundwater samples were collected via DPT at nine locations, consistent with previous events in 2017, 2018, 2019, and 2020. Full vertical profile sampling was completed at each DPT from 8 to 98 ft bls, at 5 foot intervals. The DPT performance monitoring results are summarized in this PMR. The results revealed TCE remains at concentrations greater than 11,000 µg/L in the DSZ (1-percent solubility, indicative of DNAPL) at eight of the nine DPT locations at depths ranging from 8 to 98 ft bls. An overall increasing trend of TCE concentrations was observed in DPT samples during this reporting period, which may be due to several recovery wells that were turned off during the AS Pilot Study in the DSZ that operated from July 2021 to February 2022 (documented separately from this report). The maximum TCE concentration in 2021 was 15,400,000 µg/L in the 58 ft bls depth interval at DPT597 (previous maximum result in 2020 was 1,690,000 at 48 ft bls at DPT596). During the 2021 DPT event, the overall majority of TCE contamination was identified in the 58 ft bls interval (below Layer 4), where in the previous year the majority of mass was observed in Layer 4. This trend appears to indicate continued mass discharge from Layer 4 (fine-grained unit). In addition to DPT sampling, monitoring well samples were collected from deep wells in the DSZ area (Layers 7 and 8) to verify vertical delineation. All monitoring well results were non-detect or below cleanup levels, with exception of one well (IW0162, screened 105 to 115 ft bls, which is below the existing recovery well capture zone) where TCE was identified above cleanup target levels. The HS 6 AS system remained operational during the reporting period covered under this report. The HS 6 AS IM was initiated in 2018 with 160 AS wells, and expanded in 2019 with an additional 140 AS wells. Quarterly performance monitoring was reduced to semi-annual prior to this operational period. The results of the HS 6 system operation and semi-annual performance monitoring are summarized in this report. Semi-annual monitoring results collected in April and October 2021 show concentrations of contaminants of concern (cis-1,2-dichloroethene, trans-1,2- dichloroethene, and vinyl chloride) are generally decreasing and not impacting the surface water drainage canal, indicating the HS 6 IM is meeting objectives. Overall, the tasks associated with Year 12 operation of the HC IM and operation of the HS 6 AS IM were performed in accordance with the recommendations of the 2020 LC34 (Year 11) Operations, Maintenance, and Monitoring Report for DNAPL Source Zone, Site Wide LongTerm Monitoring, and Hot Spot 6 Air Sparging System PMR (NASA, 2021c). Evaluation of results from the HC IM and HS 6 IM show that these systems are operating as designed and meeting performance objectives.

trichloroethene↗