Closure Plan for Cau No. 93: Area 6 Steam Cleaning Effluent Ponds Nevada Test Site - Revision: 0 April 1997

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for CAU No. 93: Area 6 Steam Cleaning Nevada Test Site Controlled copy No.: UNC0NTRQLLEP U.S. Department of Energy Nevada Operations Office A

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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 Department of Commerce, National Technical Information Service, 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.

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Portions of this document may be illegible in electronic image products. Images are produced from the best available original

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CLOSURE PLAN FOR CAU 93: AREA 6 STEAM CLEANING EFFLUENT PONDS NEVADA TEST SITE Prepared for U. S. Department of Energy Nevada Operations Office Under Contract No. DE-AC08-96NV11718 Controlled Copy No.: UNCONTROLLED aWrrWBUTTON OF this DOCUMENT IS UNUMHID

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SITE CLOSURE PLAN FOR CAU 93 AREA 6 STEAM CLEANING EFFLUENT PONDS NEVADA TEST SITE Industrial Sites Subproject Stephen A. Mellington, Project Manager Nevada Environmental Restoration Project

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TABLE OF CONTENTS LIST OF FIGURES................................................................................................................ iv LIST OF TABLES ...................................................................................................,.................. v LIST OF ACRONYMS AND ABBREVIATIONS ................................................................. vi 1.3 CLOSURE PLAN OUTLINE.............................................................. 7 2.0 CLOSURE STATEMENT OF WORK........................!.....................................................9 2.1.1 Past Regulatory Issues............................................................................. 9 , 2.1.2 Steam Cleaning Effluent Ponds Models .............................................. 9 2.1.2.1 North Steam Cleaning Effluent Pond Model.................................9 2.1.2.2 South Steam Cleaning Effluent Pond Model.......................... ... 10 2.1.3 Characterization Investigation Summary...................... ......................... 10 2.1.3.1 North Steam Cleaning Effluent Pond Characterization 2.1.3.2 South Steam Cleaning Effluent Pond Characterization 2.1.4 North Steam Cleaning Effluent Pond Pipe Line Summary.................... 13 2.2.1 Layout Pad Grease Trap Closure Strategy.................... ..........................13 2.2.2 Test Pad Closure Strategy ................................... 14 2.2.3 Building 6-623 Steam Cleaning Pad Closure Strategy .......................... 15 2.2.4 Building 6-623 Grease Trap Closure Strategy..........................................16 2.2.5 North Steam Cleaning Effluent Pond Spill H91091 ID Closure 2.2:6 North Steam Cleaning Effluent Pond Influent Pipe Closure Strategy ... 18 2.2.7 North Steam Cleaning Effluent Pond Closure Strategy........ ...................20 2.2.8 Building 6-800 Steam Cleaning Pad Closure Strategy ........................... 21

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TABLE OF CONTENTS (Continued) 2.2.9 Building 6-800 Separator Closure Strategy .................... ................22 2.2.10 Building 6-800 Separator Spill H920625B Closure Strategy ................ 23 2.2.11 Building 6-621 Sump Closure Strategy.................................................. 23 2.2.12 South Steam Cleaning Effluent Pond Influent Pipe Closure Strategy ... 24 2.2.13 South Steam Cleaning Effluent Pond Closure Strategy ...........................25 2.3.1 Waste Stream Descriptions ............................. 27 2.3.2 Waste Management Strategy............................................................ 27 2.3.3 Waste Management Regulatory Framework............................................27 2.3.4 Waste Characterization Requirements ............ 30 3.0 CLOSURE VERIFICATION SAMPLING........ ................................................................32 3.1 LAYOUT PAD GREASE TRAP VERIFICATION SAMPLING ......................32 3.2 TEST PAD VERIFICATION SAMPLING......................................................... 32 3.3 BUILDING 6-623 STEAM CLEANING PAD VERIFICATION 3.4 BUILDING 6-623 GREASE TRAP VERIFICATION SAMPLING..................35 3.6 NORTH STEAM CLEANING EFFLUENT POND VERIFICATION 3.7 BUILDING 6-800 STEAM CLEANING PAD VERIFICATION 3.8 BUILDING 6-800 SEPARATOR VERIFICATION SAMPLING...................... 37 3.10 SOUTH STEAM CLEANING EFFLUENT POND INFLUENT PIPE 3.11 SOUTH STEAM CLEANING EFFLUENT POND VERIFICATION

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CAP - CAU No. 93 TABLE OF CONTENTS (Continued) 5.2 FIELD WORK CLOSURE SCHEDULE ........................ 43 APPENDIX A (SUMMARY OF PAST AREA 6 SCEP UNIT INVESTIGATIONS) LIST OF FIGURES..................................................... A-i LIST OF TABLES................................................................................... A-ii 2.0 PAST REGULATORY ISSUES........................................................................ A-2 2.1 SPILL NOTIFICATION REPORT NUMBER 91-18, NDEM CASE 2.2 SPILL NOTIFICATION REPORT NUMBER 92-42, NDEM CASE 2.3 JULY 29,1994 FINDING OF ALLEGED VIOLATION.................. A-4 3.0 PRELIMINARY STEAM CLEANING EFFLUENT POND 3.1 SOUTHSCEP JULY 29,1994 FOAV SAMPLING EVENT .......... A-5 3.2 NORTH SCEP SEPTEMBER, 1994 SAMPLING EVENT.............. A-5 3.3 NORTH & SOUTH SCEP SEPTEMBER, 1995 SAMPLING 4.0 SEPARATOR AND PIPELINE INVESTIGATIONS .................................... A-ll 5.1 STEAM CLEANING EFFLUENT PONDS MODEL .................... A-14 5.2 NORTH STEAM CLEANING EFFLUENT POND MODEL........ A-14 5.3 SOUTH STEAM CLEANING EFFLUENT POND MODEL ........ A-14 6.0 CHARACTERIZATION INVESTIGATION SUMMARY............................ A-18 6.1 NORTH STEAM CLEANING EFFLUENT POND .......................... A-18 6.2 SOUTH STEAM CLEANING EFFLUENT POND SUMMARY .. A-18 APPENDIX C (NDEP DRAFT CLOSURE PLAN COMMENT RESPONSE)

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FIGURE 2 - CAU 93 VICINITY MAP........................................................................................3 FIGURE 3 - SOUTH SCEP MODEL.................. ..................................................................... 11 FIGURE 5 - AREA 6 SCEP CLOSURE PROJECT SCHEDULE............................................ 44 FIGURE 6 - AREA 6 SCEP CLOSURE ACTIVITY SCHEDULE ..................................46 LIST OF FIGURES

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LIST OF TABLES TABLE 1 - SOUTH SCEP AND NDEM SPILL RELEASE H91091 ID SAMPLING TABLE 2 - MANAGEMENT OF REMEDIATION DERIVED WASTE ................ .. 28 TABLE 3 - ANALYTICAL PARAMETERS FOR WASTE CHARACTERIZATION .......... 31 TABLE 4 - AREA 6 SCEP CAU 93 VERIFICATION SAMPLING PARAMETERS............ 33

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CAP - CAU No. 93 Section: ACR. & ABBR. LIST OF ACRONYMS AND ABBREVIATIONS American Society for Testing and Materials Corrective Action Unit Code of Federal Regulations Combustible Gas Analyzer Constituents of Concern United States Department of Energy Data Quality Objectives Environmental Compliance Office Defense Special Weapons Agency Environmental Restoration Division Federal Facility Agreement and Consent Order Finding of Alleged Violation Investigation Derived Wastes

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Section: ACR. & ABBR. LIST OF ACRONYMS AND ABBREVIATIONS (Continued) Lower Explosive Limit Large Quantity Generator Management & Operations Contractor Nevada Administrative Code Nevada Division of Emergency Management Nevada Division of Environmental Protection Nevada Test Site Personal Protective Equipment parts per million Resource Conservation and Recovery Act

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CAP - CAU No. 93 Section: ACR. & ABBR. LIST OF ACRONYMS AND ABBREVIATIONS (Continued) REECo Reynolds Electric & Engineering Company SCEP Steam Cleaning Effluent Pond(s) SVOC Semi-Volatile Organic Compounds TCLP Toxicity Characteristic Leaching Procedure TPH Total Petroleum Hydrocarbons TSDF Treatment, Storage and Disposal Facility VOC Volatile Organic Compounds WMP Waste Management Project

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The Steam Cleaning Effluent Ponds (SCEP) waste unit is located in Area 6 at the Nevada Test Site (NTS) (Figure 1). The United States Department of Energy (DOE), Nevada Operations Office operates the NTS and has entered into a trilateral agreement with die State of Nevada and the Defense Special Weapons Agency (DSWA). The trilateral agreement, which is entitled the Federal Facilities Agreement and Consent Order (FFACO), provides a framework for identifying, characterizing, remediating, and closing environmental sites on the NTS and associated bombing ranges. Area 6 is in the southern part of Yucca Flat, and the locations of the various portions of the unit is found in Figure 2. The SCEP waste unit is identified in the FFACO as Corrective Action Unit (CAU) 93. The unit consists of: • Two steam cleaning effluent ponds. • Layout Pad and associated grease trap. • Building 6-623 steam cleaning pad. • Building 6-623 grease trap. • Building 6-800 Steam Cleaning Pad. • The concrete asbestos piping connecting these components to both SCEPs. The SCEPs are evaporation basins formerly used for the disposal of untreated liquid effluent discharged from steam cleaning activities associated with Buildings 6-623 and 6-800. The North SCEP was constructed in 1975 and became operational during the same year. It is rectangular (19.8 m [65 ft] wide, 27.5 m [90 ft] long, and 2.4 m [8.0 ft] deep) and surrounded by a wire fence. Rinsate water from the steam cleaning pad next to Building 6-623 (the Area 6 Machine and Welding Shop), Test Pad, and Layout Pad were piped to the North SCEP (Figure 2).

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Approxiaiate unit boundary ^ Steam Oeanisg Effluent Pond Existing sewer line (to be removed) Existing sewer line Existing underground utility Existing building / number Nevada Division of Emergency Management STEAM CLEANING PAD TOPOGRAPHY. HEAVY DUTY REPAIR FACILITY BY REYNOLDS ELECTRICAL & ENGINEERING CO., INC. CAU 93 VICINITY MAP

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The South SCEP was constructed in 1969 and became operational in 1970. It is irregular in [12 ft] deep) and is surrounded by a gravel berm. The rinsate water from the steam cleaning pad adjacent to Building 6-800 (the Heavy Duty Machine Shop) and the Building 6-621 (Welding Shop) Sump was piped to the South SCEP (DOE, 1996). The piping, steam cleaning pads, separator, sump, and grease traps associated with the CAU were added to the SCEP system to meet the changing operational mission of the Fleet Operations Yard (DOE, 1996). Discharges to both SCEPs were discontinued in November 1992 when closed-loop, recirculating steam cleaning systems were installed. The piping from the steam cleaning pads to the separator or grease traps were subsequently plugged with cement. Suspected Resource Conservation and Recovery Act (RCRA) regulated hazardous waste or hazardous waste constituents released into the SCEPs were degreasing solvents associated with equipment decontamination activities (methylene chloride and 1,1,1-trichloroethane) and petroleum hydrocarbon constituents (toluene, xylenes, and lead). No releases of RCRAregulated hazardous waste or hazardous waste constituents have been discharged to either SCEP since 1988 (DOE, 1996). Prior to 1988, the volume of water discharged into the SCEPs was dependent on the amount of nuclear testing conducted each year. A detailed discussion of the unit activities can be found in the Resource Conservation and Recovery Act. Industrial Site Environmental Restoration Site Characterization Plan. Area 6 Steam Cleaning Effluent Ponds The Area 6 SCEP was identified as an historic RCRA site in a permit issued by the Nevada Division of Environmental Protection (NDEP) Hazardous Waste Management Permit Number NEV HW009 (NDEP, 1995). This permit specifies that the unit will be closed under Title 40 Code of Federal Regulations (CFR) 265.228 (Closure and Post-Closure Care). This regulation allows the unit to be closed two ways: • Remove or decontaminate all waste residues, contaminated containment (liners, etc.), contaminated subsoils, and structures and equipment contaminated with waste and leachate, and manage them as hazardous waste (i.e., clean closure), or • Close the impoundments and provide post-closure care for a landfill under Subpart G and Title 40 CFR 265.310. In addition to the regulatory requirements of Title 40 CFR 265.228, the Nevada Administration Code (NAC) 459.9973 requirements regarding the closure of hydrocarbon sites also applies and have been included in this

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To determine which closure method was appropriate, the DOE characterized the unit during the spring of 1996. Sufficient information is available to support clean closure of this unit based upon data collected during this field sampling event and other pre-characterization sampling Clean closure is the recommended closure strategy for the majority of the components within this CAU. Four components of the unit (Building 6-621 Sump, Test Pad Grease Trap, Building 6-623 Steam Cleaning Pad, and North SCEP pipeline) are recommended to be closed in place. This closure plan provides the strategy and backup information necessary to support the clean closure of each of the individual components within CAU 93. Analytical data generated during the characterization field work and earlier sampling events indicates the majority of CAU 93 soil and infrastructure is non-hazardous (i.e., impacted primarily with petroleum hydrocarbons). The following activities will be conducted during the closure of this unit: • Surface soil samples will be collected from soil to the north, south, and east of the North SCEP. The analytical results from these samples will be used to develop a plan to close out the Nevada Division of Emergency Management (NDEM) spill release number • The top one meter (3.3 ft) of soil from the North SCEP will be excavated and disposed of within the Area 6 Hydrocarbon Landfill. Samples will be collected to verify that the soil remaining within the North SCEP has a TPH concentration below the NAC Action Level • The North SCEP will be backfilled with clean fill material following standard • A soil sample will be collected 0.6 m (2.0 ft) under each end of the Layout Pad Grease Trap. If the analytical results from these, samples indicate that the grease trap has leaked, the grease trap and all associated impacted soil will be excavated and properly disposed. • The piping from the Test Pad will be exposed and two analytical samples will be collected from areas that exhibit visually or instrument impacted soil. If no obviously impacted soil is detected, the samples will be collected from around piping joints or seals. • The piping from the Building 6-623 Steam Cleaning Pad will be exposed and two analytical samples will be collected from areas that exhibit visually or instrument

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CAP - CAU No. 93 impacted soil. If no obviously impacted soil is detected, the samples will be collected from around piping joints or seals. The in-line grease trap located west of Building 6-623 will be excavated and the grease trap removed. Four soil samples will be collected from under the grease trap to evaluate if the grease trap has leaked RCRA-constituents or petroleum hydrocarbons into the surrounding soil. Final disposal options for the grease trap and associated soil will be determined after review of the analytical results. Surface and near-surface soil samples will be collected from the South SCEP berm to further identify the extent of RCRA listed impacted soil and thereby minimize the volume of RCRA waste. All of the RCRA and petroleum hydrocarbon impacted soil (Zone 2) will be removed from the South SCEP and placed into roll-off containers. This material will be managed as hazardous waste. Confirmatory samples will be collected to verify whether all of the RCRA hazardous constituents have been excavated from the South SCEP. Any remaining petroleum hydrocarbon soil will be excavated from the South SCEP and disposed of within the Area 6 Hydrocarbon Landfill. Samples will be collected to verify that the soil remaining within the South SCEP has a Total Petroleum Hydrocarbon (TPH) concentration below the NAC Action Level of 100 milligrams per kilogram (mg/kg). The South SCEP will be backfilled with clean fill material following standard The piping from the Building 6-800 Steam Cleaning Pad will be exposed and two analytical samples will be collected from areas that exhibit visually or instrument impacted soil. If obviously impacted soil is not detected, the samples will be collected from around piping joints or seals. The separator associated with the Building 6-800 Steam Cleaning Pad will be excavated and the separator removed. A soil sample will be collected under each end of the separator to verify that the separator did not leak and impact the surrounding soil. Disposal of the separator will depend on the analytical results from these samples. Additional soil (if analytical results indicates TPH concentrations exceed the NAC Action Level of 100 mg/kg) will be removed from the site of NDEM spill release number impacted soils were initially removed in 1992. Samples indicated that the TPH

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concentrations exceeded the NAC Action Level of 100 mg/kg (maximum 3,490 mg/kg). The soils excavated during the remedial activities will be disposed of in the Area 6 The Building 6-621 Sump will be closed in place by filling it with cement. The asbestos …