Natural Resource Damage Assessment Plan: White Sands Test .
Natural Resource Damage Assessment Plan:White Sands Test FacilityDoña Ana County, New MexicoNew Mexico Office of Natural Resources TrusteeAlbuquerque, New MexicoDRAFTNovember, 2016
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016(This page intentionally left blank to facilitate double-sided printing)
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016TABLE OF CONTENTSEX EC UT IV E S UM MA RYCHA P T ER 1 IN TR O D UCT I O N A N D B A CKG R OU N D I N F OR MATI O N1.1 Purpose 21.2 Trustee Authority 21.3 Potentially Responsible Parties 31.4 Site Description and History 31.5 Overview of Natural Resource Damage Assessment Process 41.6 Assessment Activities at the Site 71.7 Public Participation 111.8 Organization of the Natural Resource Damage Assessment PlanCHA PT ER 2 NATU R A L R E S O UR CE S A N D R E S O UR CE S ERV I CE S2.1 Description of the Study Area 122.2 Description and Definition of Natural Resources2.3 Natural Resource Services 1613CHA P T ER 3 A P P R OA C H F OR I N J URY D ET ER MI NATI O N3.1 Injury Assessment Approach 203.2 Hazardous Substances 203.3 Pathways 213.4 Confirmation of Exposure 243.5 Injury Determination 243.6 Remediation-Related Impacts 273.7 Summary of Injury Determination28CHA P T ER 4 IN J URY Q UA NT I FIC ATI O N4.1 Injury Quantification4.2 Baseline 3429CHA P T ER 5 DA M A G E S D ET ERM I NATI O N5.1 Approach to Damages Determination 375.2 Restoration and Compensation Determination Plan3911
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016CHA P T ER 6 P R O P O SE D A S S E S SM E N T A CT IV ITI E S6.1 Introduction 406.2 Summary of Proposed Assessment Activities6.3 Ecological Assessment Activities 426.4 Groundwater Assessment Activities 446.5 All Resources Assessment Activities 4640CHA P T ER 7 QUA LI TY A S S UR A NC E A N D MA NA G EM E N T7.1 Introduction 487.2 Sharing Data, Split Samples, and Analytical Results7.3 Quality Assurance 487.4 Project Management 507.5 Data Generation and Acquisition 517.6 Assessment and Oversight 527.7 Data Validation and Usability 52RE F ER E NC E S 5 348
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016LIST OF EXHIBITSiiiExhibit ES-1Proposed Assessment ActivitiesExhibit 1-1Phases of the Natural Resource Damage AssessmentExhibit 1-2White Sands Test Facility (WSTF) Site MapExhibit 2-1Groundwater ServicesExhibit 3-1Summary of Current and Past Operations and Sources of ReleasesExhibit 4-1Injury Quantification Methodology in the context of Habitat EquivalencyAnalysis 31Exhibit 6-1Proposed Assessment ActivitiesExhibit 7-1Personnel Plan50610194122
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016LIST OF ACRO NYMS AND ABB REVI ATIO NSCERCLAComprehensive Environmental Response, Compensation, and LiabilityAct of 1980CFRCode of Federal RegulationsDOIUnited States Department of the InteriorEPAUnited States Environmental Protection AgencyFWPCAFederal Water Pollution Control Act of 1972 or Clean Water ActFWSUnited States Fish and Wildlife ServiceHEAHabitat Equivalency AnalysisHWMUsHazardous Waste Management UnitsMPITSmid-plume interception and treatment systemNASANational Aeronautics and Space AdministrationNDMAn-nitrosodimethylamineNMACNew Mexico Administrative CodeNMEDNew Mexico Environment DepartmentNRDANatural Resource Damage AssessmentPCEtetrachloroethenePFTSplume front treatment systemPIPrincipal InvestigatorPlanNatural Resource Damage Assessment PlanQAquality assuranceQAPQuality Assurance PlanQCquality controlRCDPRestoration and Compensation Determination PlanRCRAResource Conservation Recovery ActREAResource Equivalency AnalysisTCEtrichloroethene
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016TDStotal dissolved solidsUSCUnited States CodeVOCsvolatile organic compoundsWQCCWater Quality Control CommissionWSTFWhite Sands Test Facilityv
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016EXECUTIVE SUMMARYThe National Aeronautics and Space Administration (NASA) White Sands Test Facility(WSTF, “the Site”) is located near Las Cruces, New Mexico. WSTF was established in1962 to support the NASA Apollo Space Program. Activities at WSTF includepropulsion testing for rocket systems, laboratories for testing the quality of space flightmaterials, and other technical support activities (NASA 2013a, Corbett 2013). Siteoperations have resulted in the release of hazardous substances, particularly from tanksand impoundments used to store waste materials. Hazardous substances have come to belocated in groundwater and soils and may have adversely impacted other naturalresources.Under Federal law, Federal, state, and Tribal governments are authorized to act astrustees of natural resources on behalf of the public (e.g., Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 [CERLCA], 42 USC § 9607 (f); seealso 43 Code of Federal Regulations [CFR] Part 11). In this role, trustees plan andimplement actions to restore, replace, or acquire the equivalent of injured naturalresources and lost natural resource services as a result of the release of hazardoussubstances to the environment. Specifically, trustees conduct a natural resource damageassessment (NRDA) to assess and recover damages from the parties responsible for therelease(s). All damages recovered as a result of a NRDA under CERCLA must be used toundertake actions to restore, replace, or acquire the equivalent of the resources that wereinjured and the services those resources would have provided in their baseline (i.e., butfor hazardous release) condition.To meet its responsibilities, the New Mexico Office of Natural Resources Trustee(ONRT, the “Trustee”) is conducting a NRDA for WSTF. The NRDA process startedwith the development and release of the Preassessment Screen Determination Report inMarch 2016 (ONRT 2016). This document serves as the Natural Resource DamageAssessment Plan (the Plan) for the Site. The purpose of this Plan is to describe theapproach that the Trustee will take in determining and quantifying injury to naturalresources affected by the release of Site-related hazardous substances, as well asdetermining damages required for compensation of those injuries. This process willensure that the NRDA is conducted in a systematic manner and at a reasonable cost. ThisPlan will be released to the public for review and comment, and after public commentsare received and addressed as necessary, a final Plan will be released.The Trustee has completed a preliminary review of available data as part of theassessment planning process, and anticipates beginning the assessment with a more indepth review and evaluation of available data, followed by the implementation of specificassessment activities. The Trustee’s planned assessment activities are summarized ini
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016Exhibit ES-1 below and in Chapter 6. This Plan and the proposed assessment activitiesrepresent the Trustee’s current understanding of the analyses that may be necessary toidentify and quantify injuries to natural resources and the services they provide on andaround WSTF, and to identify and scale restoration. Inclusion of an activity within thisPlan does not guarantee that it will be undertaken, and efforts not included within thisPlan may be deemed necessary at a later date. This Plan does not limit in any way theextent and nature of analyses that maybe undertaken in the course of the assessment.Rather, it provides a framework within which the Trustee will begin to implement theassessment. As these efforts progress and additional information is generated, the Trusteemay modify this Plan, and may provide amendments to this Plan, or portions of this Plan,for public review and comment.ii
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016EXHIBIT ES-1PROPOSED ASSESSMENT ACTIVITIESCATEGORY /RESOURCEECOLOGICALASSESSMENT ACTIVITYSUMMARY OF ASSESSMENT ACTIVITYCompilation and Review ofExisting WSTF EcologicalDataCompile available data related to ecological resources(e.g., soils, biota) and contaminant exposure andbegin to review data to identify information relevantfor the ecological assessment.Identification of EcologicalContaminants of Concernand Adverse EffectsThresholdsBased on the review of existing information, identify asuite of contaminants of concern and summarizeavailable information on the ecotoxicological impactsof these contaminants of concern. Identify adverseeffects thresholds from the literature and/orpromulgated standards for use in identifying andquantifying ecological injuries.Compile available information on remedial actionsIdentification andcompleted and planned at WSTF. Determine theQuantification of Ecologicalpotential ecological adverse impacts, and benefits,Impacts due to Remedyresulting from the remedial actions.Analyze resource-use specific information compiledQuantification of Ecologicalduring previous efforts to quantify lost ecologicalInjuries and Service Lossesservices.Determination andMonetization of EcologicalDamagesIdentify and scale restoration projects needed tocompensate for ecological injuries and associated lostservices.Compile and review groundwater data containedCompilation and Review ofwithin available WSTF databases and reports, andExisting WSTF Groundwateridentify information relevant for groundwaterDataassessment purposes.Quantification of theVolume of ContaminatedGroundwaterGROUNDWATERALL RESOURCESQuantify injured groundwater volume and timedimensions using existing information and informationobtained as a result of activities listed in this Plan.Describe the services provided by groundwater in andaround WSTF under baseline conditions and how theseAssessment of Groundwater services have been impacted by the release ofService Losseshazardous contaminants, in order to determine theservice losses attributable to hazardous substancecontamination.Determination andMonetization ofGroundwater DamagesIdentify and scale restoration projects needed tocompensate for groundwater injuries and associatedlost services.Development of aRestoration andCompensationDetermination Plan (RCDP)Compile information and results from the ecologicaland groundwater assessment activities to develop anRCDP, summarizing restoration alternatives and theTrustee’s preferred alternative.iii
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016CHAPTER 1 INTRODUCTIO N AND BACKGROUND INFORM ATIONThe National Aeronautics and Space Administration (NASA) White Sands Test Facility(WSTF, “the Site”) is located near Las Cruces, New Mexico. WSTF has supported testingof space flight equipment for over 50 years. WSTF was built primarily to supportNASA’s Apollo Space Program, and past activities included developing and testingspacecraft propulsion systems. The Site currently includes propulsion testing facilities forrocket systems; materials and components laboratories for testing the quality of spaceflight materials; and technical services offices that provide expertise for developingground support equipment (NASA 2013a, Corbett 2013).Operations conducted at the Site have resulted in the release of hazardous substances tothe environment. Under Federal law, Federal, state, and Tribal governments areauthorized to act as trustees of natural resources on behalf of the public (e.g.,Comprehensive Environmental Response, Compensation, and Liability Act of 1980[CERLCA], 42 USC § 9607 (f); see also 43 Code of Federal Regulations [CFR] Part 11).In this role, trustees plan and implement actions to restore, replace, or acquire theequivalent of injured natural resources and lost natural resource services as a result of therelease of hazardous substances to the environment. Specifically, trustees conduct anatural resource damage assessment (NRDA) to assess and recover damages from theparties responsible for the release, and use those damages to implement restorationactions. Damages may include the cost of primary restoration actions to restore theinjured resources and the services provided by those resources to their baseline condition(i.e., the condition that would have existed but for the release), as well as the cost ofcompensatory restoration actions to compensate for interim losses pending restoration (73Fed. Reg. 57,260). All damages recovered as a result of a damage assessment underCERCLA must be used to undertake actions to restore, replace, or acquire the equivalentof the resources that were injured and the services those resources would have providedin their baseline (i.e., but for hazardous release) condition.To meet its responsibilities, the New Mexico Office of Natural Resources Trustee(ONRT, the “Trustee”) is conducting a NRDA for WSTF. The NRDA process startedwith the development and release of the Preassessment Screen Determination Report inMarch 2016 (ONRT 2016). This document serves as the Natural Resource DamageAssessment Plan (the Plan) for the Site. This Plan was prepared in accordance with theUnited States Department of the Interior (DOI) NRDA regulations in the CFR at Title 43Part 11. This Chapter presents background information and discusses the NRDA processand current status of the WSTF NRDA.1
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 20161.1 PURPOSEThe purpose of this Plan is to describe the approach that the Trustee will take indetermining and quantifying injury to natural resources affected by the release of Siterelated hazardous substances, as well as determining damages required for compensationof those injuries. This process will ensure that the NRDA is conducted in a systematicmanner and at a reasonable cost, as required by the DOI NRDA regulations (43 CFR Part11), and in accordance with other applicable Federal and state laws.The Plan allows for coordination between the Trustee and the public, including a publiccomment period for this Plan, with the goal of creating a comprehensive damageassessment plan based on information currently available to the Trustee. The Trusteeintends for this Plan to serve as a living document, subject to change as the NRDAprogresses. If this Plan is amended as additional data are collected or information isuncovered during the assessment, the Trustee may release subsequent drafts of thisdocument, in whole or in part, for public comment.1.2 TRUSTEE AUTHORITYThe CERCLA as amended, at Title 42 of the United States Code (USC) § 9601, et seq.,the Oil Pollution Act of 1990, 33 USC § 2701, et seq., and the Federal Water PollutionControl Act of 1972 (FWPCA; also known as the Clean Water Act), as amended, 33 USC§ 1251, et seq., authorize the Federal Government, states, and Tribal governments torecover damages for injuries to natural resources and their supporting ecosystems,belonging to, managed by, appertaining to, or otherwise controlled by them:“In the case of an injury to, destruction of, or loss of natural resources undersubparagraph (C) of subsection (a) of this section liability shall be to the UnitedStates Government and to any State for natural resources within the State orbelonging to, managed by, controlled by, or appertaining to such Provided,however, that no liability to the United States or State or Indian tribe shall beimposed under subparagraph (C) of subsection (a) of this section, where the partysought to be charged has demonstrated that the damages to natural resourcescomplained of were specifically identified as an irreversible and irretrievablecommitment of natural resources in an environmental impact statement, or othercomparable environment analysis, and the decision to grant a permit or licenseauthorizes such commitment of natural resources, and the facility or project wasotherwise operating within the terms of its permit or license ” (42 USC § 9607(f)(1))In New Mexico, the Natural Resources Trustee is designated under the Natural ResourcesTrustee Act (New Mexico Statutes Annotated [NMSA] 1978, §§ 75-7-1 to -5) to actpursuant to these federal authorities. Specifically:“The natural resources trustee shall act on behalf of the public as trustee of naturalresources within the state or belonging to, managed by, controlled by or appertainingto the state, including protecting and representing the state's interest under2
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016applicable federal laws regarding injury to, destruction of or loss of naturalresources in the state.” (NMSA 1978, § 75-7-2A)Under CERCLA, a natural resource is defined in relevant part as “land, fish, wildlife,biota, air, water, ground water, drinking water supplies, and other such resourcesbelonging to, managed by, held in trust by, appertaining to, or otherwise controlled by theUnited States any State or local government, any foreign government, [or] any Indiantribe.” (42 USC § 9601 (16), 43 CFR § 11.14(z))Based on a review of available information, the natural resource most clearly affected byreleases from the Site is groundwater. In New Mexico, all underground waters are publicwaters and belong to the public of the State of New Mexico (NMSA 1978, § 72-12-18).“The public waters of [New Mexico] are owned by the state as trustee for thepeople and it is authorized to institute suits to protect the public watersagainst unlawful use, or to bring any other action whether authorized by anyparticular statute, if required by its pecuniary interests or for the general publicwelfare.” State ex rel. Reynolds v. Mears, 1974-NMSC-070, 86 N.M. 510, 515(internal citations omitted).The Trustee is therefore authorized to assert trusteeship over groundwater. There mayalso be terrestrial resource injuries at the Site, including contamination of soil resourcesand potential impacts to wildlife.1 . 3 P O T E N T I A L LY R E S P O N S I B L E PA RT I E SThe Trustee has identified NASA and the Department of Defense as the potentiallyresponsible parties, as defined under CERCLA. From 1963 through the present, WSTFhas been owned and operated by NASA. At this time there are no other identified sourcesfor the hazardous substances at the Site.1 . 4 S I T E D E S C R I P T I O N A N D H I S TO RYThe facility, established to support the NASA Apollo Space Program in the early 1960s,is located in southern New Mexico (Exhibit 1-1). The area, approximately 18 milesnortheast of Las Cruces, was chosen for the Johnson Space Center Propulsion SystemsDevelopment Facility in 1962 because of its isolated location and topography.Construction of the facilities began in 1963, and in 1965 the name was changed to WhiteSands Test Facility. At the peak of the Apollo era in the mid-1960s, WSTF employedover 1,700 people. Work during that time involved developing, qualifying, refurbishing,and testing spacecraft propulsion systems, subsystems, and ground support equipment;investigating flight hardware anomalies; testing materials and components; andperforming hazard and failure analyses (NASA 2013a). The tanks and impoundmentsstoring waste materials in support of these activities have caused releases of hazardoussubstances to the environment. By 1970, WSTF was facing closure. However, due to itsunique test facilities, existing buffer zones, and other advantages, hazard tests for the3
Natural Resource Damage Assessment Plan for the White Sands Test FacilityNovember, 2016Space Shuttle Program began at the facility. WSTF currently employs 750 people (NASA2013a, Corbett 2013).Ongoing operations at the Site include serving as a field test facility under NASA’sLyndon B. Johnson Space Center, which provides testing services to NASA for theUnited States space programs and support to the Department of Defense, Department ofEnergy, pr
1.5 Overview of Natural Resource Damage Assessment Process . 4 . 1.6 Assessment Activities at the Site . 7. 1.7 Public Participation . 11 . 1.8 Organization of the Natural Resource Damage Assessment Plan . 11 . NATURAL RESOURCES AND RESOURCE SERVICES . 2.1 Description of the Study Area . 12. 2.2 Description and Definition of Natural Resources . 13
The Essential Guide to Cargo Damage 3 Table of Contents Preface 4 Chapter 1 – Introduction 6 Chapter 2 –Types of damages 8 2.1 – Physical Damage 10 2.2 – Reasons for Physical Damage 11 2.3 – Wet Damage 16 2.4 – Reasons for Wet Damage 17 2.5 – Contamination Damage 19 2.6 – Reasons for Contamination Damage 20 2.7 – Reefer related Damage 21
Elbow Drop 6 Grapple Upper, Head Damage Elbow Drop 11 Grapple Side, Chest Damage Side, Chest Damage Knee Slam Grapple Lower, Leg Damage Mo V eC oNTR LS D TAILS Head Scissors Elbow Grapple Upper, Head Damage Armcrusher Grapple Side, Arm Damage Leg Stomps Grapple Lower, Leg Damage Lower, Leg Damage Mo Ve CoNTR oLS DeTAILS
Natural Resource Damage Assessment & Restoration Handbook (Public) BLM Manual Rel. 1-1712 05/27/2008 3 Baseline Condition. The condition or conditions of a natural resource that would have existed at the assessment area had the discharge of oil or release of hazardous substance under investigation not occurred. The baseline condition is
Preliminary damage assessment – A mechanism used to determine the impact and magnitude of damage and the resulting unmet needs of individuals, businesses, the public sector, and communities as a whole. There are two types of PDAs: initial damage assessments and joint preliminary damage assessments. Initial damage assessment – The effort by .
communities as a whole. There are two types of PDAs: initial damage assessments and joint preliminary damage assessments. Initial damage assessment - The effort by local authorities to collect data related to the extent of damage within a jurisdiction. Joint preliminary damage assessment - The coordinated effort by local, state, and federal
contents 2 3 executive summary 5 women, poverty and natural resource management 5 poverty 7 land tenure 9 education 10 health 17 engage women, drive change 17 empowering women to manage natural resources 21 engaging women in natural resource management is good for women 23 engaging women in natural resource management is good for
Resource 2. Sample Independent Evaluator Agreement Template Resource 3. Measurement Guidance Resource 4. Logic Model Resources and Template Resource 5. Local Evaluation Planning Guide: Diving Deeper Resource 6. Process Evaluation Plan Template Resource 7. Outcome Evaluation Plan Template Resource 8. Washington 21st CCLC Improvement Plan Template
Part 2, Design – High Strength Steels was combined with Part 1, Design in 1993. Part 5, Special Types of Construction was combined with Part 1, Design in 2008. Part 10, Bearing Design, and Part 11, Bearing Construction, were combined into a new Part 5, Bearing Design and Construction in 2013.
