Streamlined Approach for Environmental Restoration Plan, Corrective Action Unit 473, Nevada Test Site

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STREAMLINED APPROACH FOR ENVIRONMENTAL RESTORATION PLAN, CORRECTIVE ACTION UNIT 473, NEVADA TEST SITE

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STREAMLINED APPROACH FOR ENVIRONMENTAL RESTORATION PLAN, CORRECTIVE ACTION UNIT 473, NEVADA TEST SITE Defense Special Weapons Agency

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STREAMLINED APPROACH FOR ENVIRONMENTAL RESTORATION PLAN FOR CORRECTIVE ACTION UNIT 473: NEVADA TEST SITE Approved by: Q. Date: Chief, Nevada Test Site Environmental Programs Defense Special Weapons Agency

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Table of Contents CAU 473 SAFER Plan Page i of iv List of Figures ............................................................................................................................... iii List of Acronyms and Abbreviations............................................................................................. iv 1.2 Closure Objectives for CAU 473 ....................................................................................2 2.0 Corrective Action Unit Description........................................................................................ 5 2.2.2 Corrective Action Site Descriptions...................................................................... 7 2.3 Recommendations for Closure........................................................................................ 7 6.0 Site-Specific Health and Safety Plans ...................................................................................13 7.0 Reports and Records Availability...........................................................................................14

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CAU 473 SAFER Plan Page ii of iv Table of Contents (Continued) Appendix B - Field Instructions for Collection of Soil Samples At Corrective Action Site 16-25-01, CAU 473 Oil Spill, Nevada Test Site ...........................B-l

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CAU 473 SAFER Plan Page iii of iv List of Figures Number Title Page 1- 1 Decision Diagram for Corrective Action Unit 473, Correc ve Action Sites ..............4 2- 1 General Location Map, Area 16 - Tunnel Portal Corrective Action Sites, Nevada Test Site ......................................................................................................... 6 2-2 Site-Specific Location Map Area 16 - Tunnel Portal Corrective Action Sites, Nevada Test Site ......................................................................................................... 8

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CAU 473 SAFER Plan Page iv of iv List of Acronyms and Abbreviations Corrective Action Investigation U.S. Department of Defense U.S. Department of Energy Defense Nuclear Agency Defense Special Weapons Agency Federal Facility Agreement and Consent Order Nevada Administrative Code Nevada Division of Environmental Protection Nevada Test Site Parts per million Streamlined Approach for Environmental Restoration Site-Specific Health and Safety Plan Total petroleum hydrocarbon

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CAU 473 SAFER Plan This Streamlined Approach for Environmental Restoration (SAFER) Plan was prepared for the Defense Special Weapons Agency (DSWA). The recommendations and corrective actions prescribed within this plan apply to the removal and disposal, if applicable, of an inactive electrical transformer, the transformer pad, and the remnants of an oil spill on the Nevada Test Site (NTS) for which DSWA is responsible. The DSWA is a multiservice branch of the This SAFER Plan is consistent with the requirements of the Federal Facility Agreement and Consent Order (1996) agreed to by the U.S. Department of Energy, the Nevada Division of Environmental Protection, and the DoD. David A. Bedsun, Chief, Nevada Test Site Environmental Programs, Defense Special Weapons Agency, is the NTS point of contact.

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CAU 473 SAFER Plan This plan describes the current status and past activities that have taken place at the Corrective Action Sites (CASs) that comprise Corrective Action Unit (CAU) 473. It provides a systematic process for closure following prescribed guidelines leading to a Nevada Division of Environmental Protection (NDEP)-issued Notice of Completion for CAU 473. This plan was prepared under the Streamlined Approach for Environmental Restoration (SAFER) concept, as described in Section 1.4 of Appendix VI of the Federal Facility Agreement and Consent Order (FFACO, 1996). The SAFER process was followed for CAU 473 because the existing information about each CAS was adequate to either support a recommendation of closure with no further action or to propose an appropriate corrective action to achieve site closure. The Corrective Action Investigation (CAI) of CAU 473 consisted of a thorough review of archival documents and process knowledge about each CAS and an on-site inspection. The information obtained was sufficient to make informed decisions regarding the closure of each CAS and eliminated the need for a field investigation involving collection and analysis of environmental samples. This document incorporates the essential elements of a Corrective Action Investigation Plan which includes the results of the investigation (Section 2.0), a Corrective Action Decision Document (Section 2.3), and a Correction Action Plan (Section 3.0). This SAFER Plan allows work to proceed from the CAI to the implementation of corrective actions. Following completion of the corrective actions, a Closure Report documenting closure activities will be submitted to NDEP. Closure of CAU 473 will be achieved when it has been documented that each CAS has been closed in compliance with the governing environmental regulations described in Section 1.1. Corrective Action Unit 473 includes a site which contains an inactive transformer and transformer pad, and oil-stained soil, that have been identified as CASs under the FFACO (1996). The Defense Nuclear Agency (DNA) (predecessor to the Defense Special Weapons Agency [DSWA]) used the transformer and pad (CAS 16-14-01) to support weapons effects tests in the U16a-Tunnel at the Nevada Test Site (NTS). The oil spill (CAS 16-25-01) likely occurred as a result of oil blow-off from compressors that were located on the pad above the U16a-Tunnel

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CAU 473 SAFER Plan Remediation of oil-stained areas is regulated under Nevada Administrative Code (NAC) 459.9921-459.999, which stipulates that sites with total petroleum hydrocarbon (TPH) concentrations exceeding 100 milligrams per liter (100 parts per million [ppm]) be reported to the NDEP and remediated (NAC, 1996). The Voluntary Corrective Actions (VCAs) that are proposed to be performed at the stained soil site in CAU 473 are designed to comply with this 1.2 Closure Objectives for CAU 473 Historical information and process knowledge concerning the transformer indicate that it is a “dry-type” transformer which cannot contain polychlorinated biphenyls (PCBs) (IT, 1990). For this reason, the transformer in CAS 16-14-01 (described in detail in Section 2.0) does not contain radioactive or federally regulated hazardous materials. To enhance the existing process knowledge of CAS 16-14-01, an electrician will inspect the transformer during removal to Area 12. The transformer will be stored at the P-Tunnel storage yard for use on a future DSWA project. Documentation concerning the transformer will be included in the Closure Report for CAU 473. The pad will be allowed to remain in place. The objective for closure of CAS 16-25-01 is to remove and properly dispose of the soil impacted from the oil spill. Process knowledge of historical operations concerning the oil spill indicates that it occurred as a result of oil blow-off coming from compressors that were located on the pad above the U16a-Tunnel portal (Pritchett, 1997). Because a CAI involving sample collection and analysis will not be conducted. Data Quality Objectives and Quality Assurance objectives are not required. However, once the impacted soil has been excavated, confirmation samples will be collected in order to confirm no soil exceeding the TPH concentration of Should removal of contaminated soil become impossible due to equipment limitations, or health and safety constraints, data from the confirmation samples will be used to ascertain the TPH concentration of the remaining contaminated soils. If the NDEP-established action level of

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CAU 473 SAFER Plan 100 milligrams per kilogram for TPH is exceeded, the area will be assessed for alternate closure methodology based on following factors outlined in NAC 445A.227 (2) (a,Jc) (NAC, 1996): “(a) The depth of the ground water; (b) The distance to irrigation or drinking water wells; (c) The type of soil; (d) The annual precipitation; (e) The type of regulated substance released; (f) The extent of contamination; (g) The present and potential land use; (h) The preferred routes of migration; (i) The location of structures or impediments; (j) The potential for a hazard related to fire, vapor or explosion; and (k) Any other factor that is specific to a site as determined by the division.” The results of this assessment, if required, will be documented in the closure report for CAU 473. Should closure in place occur based on the alternate closure methodology assessment, land use restrictions may be required. Such restrictions may include, but not be limited to, signage identifying the site, administrative controls, or fencing. Figure 1-1 illustrates the decision process for evaluation of each CAS to ensure that the sites are properly closed.

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CAU 473 SAFER Plan Page 4 of IS removal of site corrective action site Document and recommend with no further action office for guidance Implement corrective action Submit for closure upon completion of site remediation/ resulted in closure of the site in accordance with Decision Diagram for Corrective Action Unit 473, Corrective Action Sites

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CAU 473 SAFER Plan 2.0 Corrective Action Unit Description Corrective Action Unit 4,73 includes a site which contains an inactive transformer and transformer pad, an oil spill, and construction waste within close proximity of the U16a-Tunnel portal located in Area 16 in the central portion of the NTS in Nye County, Nevada (Figure 2-1). Area 16 is approximately 75 miles northwest of Las Vegas. The tunnel was used by DNA and the U.S. Atomic Energy Commission from 1961 to 1971 for underground nuclear tests. The tunnel was not used again until 1995 when DSWA began conducting underground highThe CAI of CAU 473 consisted of a thorough review of existing archival documents and process knowledge regarding the CASs. This information has been compiled through review of existing documentation and interviews conducted during the preparation of this plan. All records and documents used for the preparation of this SAFER Plan are referenced in Section 8.0 and are available for review in Central Files at the IT Corporation, Las Vegas office. The results of the CAI are summarized in Section 2.2.2. The approach followed in this plan is based on the assumptions listed below. If, at any time during the closure investigation or closure activities, information is developed that invalidates any assumption, this plan may be amended. Any amendments will be provided to NDEP for approval. Assumptions made and followed in this SAFER Plan include the following: • The transformer in CAS 16-14-01 is a “dry-type” transformer which cannot contain • No staining or spills of radioactive or federally regulated hazardous materials are present on the transformer pad in CAS 16-14-01. • The soil stain identified in CAS 16-25-01 was due to blow-off of compressor oil. It is not a radioactive or federally regulated hazardous material.

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General Location Map, Area 16 - Tunnel Portal Corrective Action Sites, Nevada Test Site

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CAU 473 SAFER Plan 2.2.2 Corrective Action Site Descriptions Pertinent historical information and the current status of each CAS are summarized below. Refer to Figure 2-2 for the location of each CAS on the U16a-Tunnel portal. The transformer and pad (CAS 16-14-01} were used to support weapons effects tests in the U16a-Tunnel at the NTS. The transformer described in this site is situated on a transformer pad at the U16a-Tunnel portal, approximately 200 feet north of the tunnel entrance. The pad is behind a fenced enclosure. The transformer is marked “Inactive.” Manufacturer labels or other markings do not indicate PCB materials or contamination (Pritchett, 1997). There is no evidence of leaks from the transformer. The transformer will be removed to Area 12, P-Tunnel storage yard. Electricians confirmed, prior to its removal, that it is a dry transformer. Documentation of this will be contained in the Closure Report for CAU 473. The oil spill (CAS 16-25-01) likely occurred as a result of oil blow-off from compressors that were located above the U16a-Tunnel portal. The pad may be approached via an access road at the north end of the portal. The visible-stained soil will be removed by scraping by either manual or mechanical methods. The removed soil will be transported to the petroleum waste landfill at the NTS. Confirmation samples will be taken to ensure all contaminated soils (above 100 ppm TPH) have been removed. Once these VCAs have been performed, the CAS will be closed in accordance with the applicable state regulations (NAC, 1996). 2.3 Recommendations for Closure The information obtained during review of archival documents and reference material was sufficient to make informed decisions regarding the closure of each CAS (IT, 1990). In summary, the transformer will be removed; the transformer pad will remain in place; the stained soil will be removed and properly disposed of; and closure of CAU 473 will be obtained.

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CAU 473 SAFER Plan Not To Scale Site-Specific Location Map Area 16 - Tunnel Portal Corrective Action Sites, Nevada Test Site

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CAU 473 SAFER Plan 3.0 Corrective Action Plan On the basis of archival information summarized in Section 2.2.2 (IT, 1990), only one of the CASs in CAU 473 will require corrective actions to achieve site closure. The corrective actions will consist of removal and disposal of the soil impacted by the blow-off of compressor oil. • Prior to its removal, the boundaries of the impacted soil will be delineated and identified by temporary markings such as stakes, flagging, etc. • The impacted soil will be scraped either manually or by mechanical means. The removal of the soil will continue until soil staining is no longer visible. • The soil will be transported to an appropriately permitted hydrocarbon waste management facility on the NTS. • Confirmation samples will be obtained by means specified in Appendix B. The NDEP will be notified of the scheduled start date of field activities at least five working days prior to the start of field work. The expected schedule of completion dates (in working days) is • Day 1: Delineate site boundaries; mobilize equipment; and commence soil removal and containerization (CAS 16-25-01). • Days 2-10: Complete soil removal and containerization, take confirmation samples, and transport soil to an appropriately permitted hydrocarbon waste management facility on the NTS.

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Factors beyond the control of DSWA, such as inclement weather, may delay field activities. If such delays occur, NDEP will be verbally notified. CAU 473 SAFER Plan Upon completion of soil removal/disposal activities, a Closure Report will be prepared and submitted to NDEP as discussed in Section 4.0.

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CAU 473 SAFER Plan Reports during field activities and after completion of the SAFER process will be provided to NDEP by DSWA. DSWA will verbally inform NDEP of any substantial changes in scope or schedule as quickly as possible. If it is determined that this plan requires significant amendments, NDEP will then be notified, the plan amended, and NDEP’s concurrence solicited. When closure is achieved, DSWA will provide a written closure report to NDEP documenting that closure was completed in accordance with this SAFER Plan. The Closure Report will describe corrective measures taken for each CAS and request a Notice of Completion from

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CAU 473 SAFER Plan All waste generated through the performance of field activities from each of the sites will be managed in accordance with existing federal and State of Nevada regulations, waste minimization and pollution prevention objectives, and waste management programs. Field activities prescribed by this SAFER Plan will consist of removing hydrocarbon-impacted soil from the site as described in Section 3.0 and sampling the excavation to determine the levels of TPH remaining in soil. Generation of radioactive and/or federally regulated hazardous wastes is not expected. The only additional waste type expected to be generated will likely be sanitary Disposable sampling equipment and gloves from sampling activities will be managed in accordance with all applicable requirements. If additional waste streams are determined to be present, they will be managed in accordance with all applicable regulations and requirements.

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6.0 Site-Specific Health and Safety Plans CAU 473 SAFER Plan The health and safety protocols for the field activities related to the implementation of this SAFER …