Corrective Action Plan for Cau No. 339: Area 12 Fleet Operations Steam Cleaning Discharge Area Nevada Test Site - Revision: 0, May 1997

Page 1

Corrective Action Plan for CAU No. 339: Area 12 Fleet Operations Steam Cleaning Discharge Area Nevada Test Site Controlled copy No.: uncontrolled U.S. Department of Energy Nevada Operations Office J

Page 2

U.S. Department of Energy 100 N. City Parkway, Suite 1750 Southern Nevada Public Reading Facility c/o Nuclear Testing Archive Northern Nevada Public Reading Facility c/o Nevada State Library and Archives SUBMITTAL OF FINAL DOCUMENTS TO THE PUBLIC READING FACILITIES The Federal Facility Agreement and Consent Order (FFACO) requires that the enclosed list of documents are available to the public through the FFACO Public Reading Facilities. The following copies are being provided for submittal into the FFACO Public Reading Facility collection in accordance with the FFACO Agreement. This electronic submittal will be the final submittal for these documents. DOCUMENT NUMBER AND TITLE DOCUMENT DATE DOE/NV—879-Rev 1: Corrective Action Decision Document for Corrective Action Unit 165: Area 25 and 26 Dry Well and Washdown Areas, Nevada Test Site, Nevada, Revision 1, August 2004 DOE/NV—982: Corrective Action Plan for Corrective Action Unit 165: Area 25 and 26 Dry Well and Washdown Areas, Nevada Test Site, Nevada, DOE/NV—11718-106 Corrective Action Plan for CAU No. 339: Area 12 Fleet Operations Steam Cleaning Discharge Area, Nevada Test Site, Nevada, Revision 0, May 1997

Page 3

Multiple Addressees -2- March 31, 2022 Please contact Carol Dinsman at (702)724-0832 if further information on this matter is needed. Deputy Program Manager, Operations EMO:14711.CD EM Nevada Program Navarro Document Production (electronic copy to OSTI) Christine Andres, NDEP Nikita Lingenfelter, NDEP Mary Murphy, NDEP Gail Tackett, NDEP Navarro Central Files Carol Dinsman, EM Tiffany Gamero, EM Bill Wilborn, EM FFACO Group, EM

Page 4

This report has been reproduced from the best available copy. DOE and DOE contractors can obtain copies of this report from the Office of Scientific and Technical Information, P.O. Box 62, Oak Ridge, TN 37831, (423) 576-8401. This report is publicly available from the National Technical Information Service, U. S. Department of Commerce, 5285 Port Royal Road, Springfield, VA, 22161, (703) 487-4650. This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsi bility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Refer ence herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recom mendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

Page 5

CORRECTIVE ACTION PLAN FOR CAU 339: AREA 12 FLEET OPERATIONS STEAM CLEANING DISCHARGE AREA NEVADA TEST SITE Prepared for the Nevada Operations Office Under Contract No. DE-AC08-96NV11718 Controlled Copy No.: UNCONTROLLED

Page 6

CORRECTIVE ACTION PLAN FOR CAU 339: AREA 12 FLEET OPERATIONS STEAM CLEANING DISCHARGE AREA NEVADA TEST SITE Industrial Sites Subproject Stephen A. Mellington, Project Manager Nevada Environmental Restoration Project

Page 7

TABLE OF CONTENTS Area 12 Fleet Ops ACRONYMS AND ABBREVIATIONS............................................................................................ iii 1.3 Corrective Action Plan Contents ..........................................................;................................7 2.0 CORRECTIVE ACTION EVALUATION................................................................................... 8 2.1 Evaluation of VOC Constituents ..............................................................................................8 2.3 Volatile Organic Compound Source Investigation..................... .'...................................... 10 3.0 DETAILED STATEMENT OF WORK .... '.........................................................................12 3.1 Approved Alternative Implementation........................................ 12 3.1.1 Excavating the Hydrocarbon Impacted Soils..................... 12 3.1.2 Fencing and Posting the Area of Hydrocarbon Impact............................................... 14 3.1.3 Removing the Sandbag Barrier and Plugging the Effluent Discharge Line...........14 3.1.4 Biennial Post-Closure Monitoring of the Hydrocarbon Impacted Area................... 14

Page 8

Area 12 Fleet Ops TABLE OF CONTENTS (continued) APPENDIX - Document Review Sheet FIGURE 1 - SITE LOCATION MAP .................................................................................................2 FIGURE 2 - SITE VICINITY MAP..................................................................................................... 3 FIGURE 3 - CAU 339 SITE BOUNDARY............................................... ......................................... 6 FIGURE 4 - PROPOSED EXCAVATION AND FENCE BOUNDARY..................................... 13 FIGURE 5 - PROPOSED POST-CLOSURE SAMPLE LOCATIONS..................................... 19 TABLE 1 - AREA 12 DISCHARGE AREA MAXIMUM HYDROCARBON AND VOC TABLE 2 - REGULATORY ACTION LEVELS FOR VOCS IDENTIFIED IN THE DISCHARGE AREA............. ............................................ 10 TABLE 3 - POST-CLOSURE MONITORING SAMPLES............................................................. 20

Page 9

ACRONYMS AND ABBREVIATIONS bgs below ground surface CADD Corrective Action Decision Document CAP Corrective Action Plan CAS Corrective Action Site CAU Corrective Action Unit CEA Comparative Enumeration Assay CFR Code of Federal Regulations COC Constituent(s) of Concern DOE U.S. Department of Energy EPA U.S. Environmental Protection Agency FFACO Federal Facility Agreement and Consent Order IRIS Integrated Risk Information System LCB Legislative Council Bureau LDR Land Disposal Restrictions mg/kg milligrams per kilogram NAC Nevada Administrative Code Section: Acr & Abb. ' Area 12 Fleet Ops

Page 10

Section: Acr & Abb. Area 12 Fleet Ops ACRONYMS AND ABBREVIATIONS (continued) NDEP Nevada Division of Environmental Protection NTS Nevada Test Site PRO Preliminary Remediation Goals RCRA Resource Conservation and Recovery Act RPD Relative Percent Difference TCLP Toxicity Characteristic Leaching Procedure TPH Total Petroleum Hydrocarbon VOC volatile organic compound

Page 11

Area 12 Fleet Ops The Area 12 Fleet Operations site is located in the southeast portion of the Area 12 Camp at the Nevada Test Site (NTS) (Figure 1). The former Area 12 Fleet Operations Building 12-16 was constructed in approximately 1965 and functioned as a maintenance facility for light- and heavyduty vehicles up to January 1993. Services performed at the Fleet Operations site included steam cleaning, tire service, and preventative maintenance on vehicles and special purpose A sand/oil interceptor, which segregated the materials generated from the steam cleaning activities, is located at the southeast side of the Fleet Operations Building. The separator effluent discharge line is located approximately 104 meters (340 feet) east of the sand\oil interceptor. The effluent discharge line is presently surrounded by a sandbag barrier. Physical boundaries of the discharge area include the Rainier Mesa Road to the south, a helicopter pad to the east, a natural erosional channel (arroyo) to the north, and a former parking area to the west. The discharge area is separated from a down gradient arroyo by a soil berm to the east. A site vicinity map is provided as Figure 2. Surface flow from the discharge pipe and other Fleet Maintenance activities appears to follow the natural topography which slopes predominantly to the east and northeast. Approximate Nevada coordinates for the site are N 890,000 and E 650,000 (from NTS Road and Facility Map, Holmes and Narver, 1986 update). This site is identified in the Federal Facility Agreement and Consent Order (FFACO) as Corrective Action Site (CAS) Number 12-19-01 and is the only CAS assigned to Corrective Action Unit (CAU) 339. The purpose of this Corrective Action Plan (CAP) is to provide the method for implementing the corrective action alternative as provided in the Corrective Action Decision Document (CADD) (DOE, 1996a). Detailed information of the site history and results of previous characterizations can be found in the Work Plan (REECo, 1992a), the Preliminary Investigation Report (DOE, 1996b), and the Phase 2 Characterization Report (DOE, 1996a). Previous characterization investigations were completed as a condition of the Temporary Water Pollution Control Permit issued by the Nevada Division of Environmental Protection (NDEP) on July 14,1992 (NDEP, This document includes the closure activities and the Post-Closure Monitoring Plan of only the release area east of the effluent discharge. Building 12-16, the former vehicle dispatch parking area, the sand/oil interceptor, and helicopter pad are not considered part of this closure as they are considered serviceable infrastructure.

Page 14

Area 12 Fleet Ops The scope of this report is to prepare a CAP based upon the selected remedial alternative for closure of the Area 12, Building 12-16 Fleet Operations steam cleaning discharge area. The effluent discharge area has been impacted by volatile organic compounds (VOCs) and total petroleum hydrocarbons (TPH) as oil. The maximum hydrocarbon and VOC concentrations detected in the Preliminary and Phase II Site Characterization Investigations are summarized in Sample collection areas from the Preliminary' and Phase II Site Characterization Investigations are shown on Figure 3. Figure 3 also depicts the approximate extent of soil impact (identified by discolored soil) which constitutes the CAU 339 boundary. Based on the findings of the previous investigations, the selected remedial alternative, as presented in the CADD report, was to: * Complete excavation of the VOC impacted soil. * Remove the sandbag barrier surrounding the effluent line and use the resulting soils for area grading and backfill. * Plug the effluent discharge line. * Fence and post the area of hydrocarbon impact. Based on a re-evaluation of the source of the VOCs identified on-site and Environmental Protection Agency (EPA) regulations recently adopted by NDEP, the selected remedial alternative for closure of the discharge area has been modified to consist of the following: • Leave VOC impacted soil in place, as supported by the Integrated Risk Information System • Excavate hydrocarbon impacted soils in the areas of visibly stressed vegetation and where a hardened crust of hydrocarbon waste has formed. • Fence and post the area of hydrocarbon impact. • Remove the sandbag barrier surrounding the effluent line and use the resulting soils for area grading and backfill. • Plug the effluent discharge line. * Complete biennial post-closure monitoring of the hydrocarbon-impacted area identified as

Page 15

Area 12 Fleet Ops TABLE 1 - AREA 12 DISCHARGE AREA MAXIMUM HYDROCARBON AND VOC Methyl Ethyl Ketone 0.550 1 The Sample Areas consist of one or more sample locations from the Phase 1 and Phase 2 Site Investigations 2 TPH as oil was the only hydrocarbon identified above laboratory detection limits within the discharge area. 3 VOCs listed represent the maximum concentrations detected including those analytes reported as being identified in the laboratory method or trip blanks. ND: Not detected above the laboratory detection limits. B: Analyte was identified in the blank as well as the sample. mg/kg: milligrams per kilogram

Page 16

Discolored Surface Soil Area & CAU 339 Boundary^SAMPLE AREA 3> Sandbagged Area With Discharge Pipe Rainier Mesa Road CAU 339 SITE BOUNDARY

Page 17

Area 12 Fleet Ops 1.3 CORRECTIVE ACTION PLAN CONTENTS This CAP has been developed in a manner to support the proposed closure of the discharge effluent area. The format of the CAP is as follows: • Site description and history (Section 1.0). •• Summary of previous activities (Section 1.1). • Evaluation of the proposed corrective action (Section 2.0). •* Closure strategy for the CAU (Section 3.0). •• Waste management and disposal (Section 3.2). •* Schedule of closure activities (Section 4.0). •* Post-Closure Sample and Monitoring Plan for the hydrocarbon impacted area This plan was developed using information and guidance provided from the following • Corrective Action Decision Document-Area 12 Fleet Operations Steam Cleaning Discharge Area Nevada Test Site Corrective Action Unit 339. DOE, 1996a. • Preliminary Investigation-Area 12 Fleet Operations Steam Cleaning Discharge Area Nevada Test Site. DOE, 1996b. • Nevada Environmental Restoration Project. Project Management Plan. Revision 0, DOE, • Nevada Environmental Restoration Project. Health and Safety Plan. Revision 2, DOE, • Nevada Environmental Restoration Project. Project Management Plan. Revision 0, DOE, • Nevada Environmental Restoration Project. Industrial Sites. Quality Assurance Project Plan. Nevada Test Site. Revision 1, DOE, 1996.

Page 18

2.0 CORRECTIVE ACTION EVALUATION Section: Coir. Act. Eval. Area 12 Fleet Ops The NDEP provided comments on the CADD in a Memorandum dated February 7, 1997 (NDEP, 1997). The comments addressed the proposed corrective action in reference to the hydrocarbonimpacted soils and VOC-impacted soils. The selected alternative proposed in the CADD was to leave the hydrocarbon soils in place (based on an A through K risk-based analysis) and remove the VOC-impacted soils (DOE, 1997). Although the VOC concentrations in the soil were veiy low (a maximum of 1.2 milligrams per kilogram [mg/kg] for acetone), they were identified as being Resource Conservation and Recoveiy (RCRA) “F Listed” wastes based upon the use of solvents in past Fleet Operation steam cleaning activities. In the memorandum, NDEP did not accept the assumption made in the CADD that the VOCs identified in the Preliminary and Phase II Site Characterizations were “F Listed” wastes. This determination was made based on the followings conclusions: •• VOC-impacted areas do not coincide with the pattern of TPH-impacted areas. *• VOCs are only identified up gradient of the soil berm and not in the arroyo. •• Lack of definitive process knowledge that the VOCs identified were used in the Fleet Operation steam cleaning process. •• The likelihood that other discharges occurred in the vicinity separate from the Fleet Operations discharge (former storage areas, helicopter pad, etc.). In addition, recently adopted Legislative Council Bureau (LCB) regulations were identified as being applicable to identifying closure standards for the site (LCB, 1996, Section 2.2). The A through K risk-based analysis of the hydrocarbon-impacted soil was determined insufficient to support leaving the soils in place without corrective action. NDEP recommended that heavily impacted areas, identified by lack of vegetation growth and soil staining, be excavated (NDEP, 1997). The remaining impacted areas will be left in place and sampled biennially (every two years) to monitor the natural degradation of the hydrocarbon-impacted 2.1 EVALUATION OF VOC CONSTITUENTS Since the NDEP does not consider the VOCs to be RCRA “F Listed” wastes, an evaluation of their hazardous characteristics is warranted. The characteristics of corrosivity (40CFR 261.22) and reactivity (40CFR 261.23) are not considered applicable to the site by definition. Even though ignitability was not analyzed in the previous samples collected, the very low

Page 19

concentrations of VOCs in the soil (a maximum of 1.2 mg/kg for acetone), under standard temperature and pressure, would not support ignition. The only VOC exhibiting the toxicity characteristic was methyl ethyl ketone (MEK). The maximum concentration detected (0.550 mg/kg total VOC analysis) is significantly below the Toxicity Characteristic Leaching Procedure (TCLP) Action Level of200 mg/1. In evaluating the concentrations of VOCs in relation to the Nonwastewater Treatment Standards (40CFR 268.40) for Land Disposal Restrictions (LDRs), they are found to be below the listed LDRs. Therefore, the VOC constituents exhibit neither a listed nor a characteristic waste (NDEP, 1997). Section: Corr. Act. Eval. Area 12 Fleet Ops 2.2 REGULATORY ACTION LEVELS The Nevada Administrative Code (NAC) Action Level for petroleum hydrocarbons is 100 mg/kg (NAC 459.9973). Soils within the discharge area exceed the NAC Action Level, however, all impacted soils will not be removed as part of the closure activity. This is supported by the • The A through K Risk-Based Analysis for the site. • Limited vertical migration of the hydrocarbon release. • Minimal environmental impact. The natural in-situ degradation of the hydrocarbon-impacted soils will be monitored in a PostClosure Monitoring Program (Section 5.0). Since hazardous waste regulations are not applicable to the VOCs present, the uncodified corrective action regulations found in LCB File R119-96 may be applied. The appropriate levels used must be based on the protection of public health and safety and the environment. The appropriate levels are determined using the Integrated Risk Information System (IRIS) (LCB File Section 26d). The IRIS Action Levels are summarized in Table 2. The IRIS levels represent those listed for residential use since they provide …