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Corrective Action Decision Document for Corrective Action Unit 340: Pesticide Release Sites, Nevada Test Site, Nevada Controlled Copy No.: Approved for public release; further dissemination unlimited. U.S. Department of Energy
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Available to the public from - U.S. Department of Commerce National Technical Information Service 5285 Port Royal Road Available electronically at http://www. doe, qov/bridee. Available to U.S. Department of Energy and its contractors in paper from - U.S. Department of Energy Office of Scientific and Technical Information Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, orfavoring by the United States Government or any agency thereofor its contractors or
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CORRECTIVE ACTION DECISION DOCUMENT FOR CORRECTIVE ACTION UNIT 340: PESTICIDE RELEASE SITES, NEVADA TEST SITE, NEVADA DOE Nevada Operations Office Las Vegas, Nevada Controlled Copy No.: 6 Approved for public release; further dissemination unlimited.
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CORRECTIVE ACTION DECISION DOCUMENT FOR CORRECTIVE ACTION UNIT 340: PESTICIDE RELEASE SITES, NEVADA TEST SITE, NEVADA Janet Appenzeller-Wing, Project Manager Industrial Sites Subproject Nevada Environmental Restoration Project
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Table of Contents Page i of vii List of Figures............................................................................................................................................. *v List of Tables.............................................................................................................................................. v List of Acronyms and Abbreviations......................................................................................................vi 2.0 Corrective Action Investigation Summary................................................................................. 6 2.3 Need for Corrective Action.............................................................................................. 9 3.1 Corrective Action Objectives........................................................................................ 12 3.1.1 Contaminants of Concern............................................................................... 12 3.2.2 Remedy Selection Decision Factors..............................................................15 3.3 Development of Corrective Action Alternatives....................................................... 16 3.3.1 Alternative 1 - No Further Action................................................................ 19 3.3.2 Alternative 2 - Clean Closure by Excavationand Disposal....................... 19 3.3.3 Alternative 3 - Closure in Place by Protective Cover.................................20 3.4 Evaluation and Comparison of Alternatives................................................................ 20 Appendix A - Corrective Action Investigation Report for CAU 340: Pesticide Release Sites, Nevada Test Site, Nevada A.2.0 Field Investigation and Sampling Activities.......................................................................... A-3
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Table of Contents (Continued) Page ii of vii A.2.4.4 Additional Soil Sampling Conducted Near the Q800 and Skid Huts Sites..................................................................................... A-10 A.3.1 Total Volatile Organic Compound Analytical Results.........................................A-15 A.3.2 Total Semi volatile Organic Compound Analytical Results................................A-22 A.4.6 Tier I and Tier II Data Evaluations......................................................................... A-42
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Page iv of vii List of Figures Number Title Page 1- 1 Nevada Test Site.................................................................................................................... 2 1 -2 General Location of the Area 23 and Area 15 Pesticide Release Sites............................. 3 2- 1 Approximate Lateral Extent of Contamination at the Area 23 Pesticide Release Sites, Nevada Test Site......................................................... 10 A.2-1 Quonset Hut 800 Investigation Area and Soil Sample Locations, Nevada Test Site, Pesticide Release Sites...................................................................... A-8 A.2-2 Area 23 Skid Huts Investigation Area and Soil Sample Locations, Nevada Test Site, Pesticide Release Sites...................................................................... A-9 A.2-3 Area 15 Quonset Hut 15-11 Investigation Area and Soil Sample Locations, Nevada Test Site, Pesticide Release Sites.................................................................... A-l 1 A.2-4 Area 23 Location of Additional Soil Samples Between the Q800 and Skid Huts Sites, Pesticide Release Sites, Nevada Test Site........................................ A-12
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Page v of vii List of Tables Number Title Page 3-1 Detailed Evaluation of Alternatives...................................................................................... 21 3-2 Comparative Evaluation of Alternatives..............................................................................24 A.3-1 Samples Collected During the CAU 340 Pesticide Release Site A.3-2 Laboratory Analytical Methods Used for Samples Collected at the CAU 340 Pesticide Release Sites, Nevada Test Site................................................... A-22 A.3-3 Soil Sample Results for Total Volatile Organic Compounds Detected Above Minimum Reporting Limits, Pesticide Release Sites, Nevada Test Site ................A-23 A.3-4 Soil Sample Results for Total Petroleum Hydrocarbons Detected Above Minimum Reporting Limits, Pesticide Release Sites, Nevada Test Site..................A-24 A.3-5 Summary of Total RCRA Metals Results Detected Above Minimum Reporting Limits, CAU 340 Pesticide Release Sites, Nevada Test Site..................A-25 A.3-6 Summary of TCLP Metals Results Detected Above Minimum Detectable Concentrations, CAU 340 Pesticide Release Sites, Nevada Test Site...................... A-29 A.3-7 Summary of Total Pesticides Results Detected Above Minimum Reporting Limits, CAU 340 Pesticide Release Sites, Nevada Test Site..................A-32 A.3-8 Summary of TCLP Pesticides Results Detected Above Minimum Reporting Limits, CAU 340 Pesticide Release Sites, Nevada Test Site......................................A-37 A.3-9 Summary of Total Herbicides Results Detected Above Minimum Reporting Limits, CAU 340 Pesticide Release Sites, Nevada Test Site..................A-39
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Page vi of vii List of Acronyms and Abbreviations Below ground surface Corrective Action Decision Document Corrective Action Investigation Plan Corrective Action Site Corrective Action Unit Contract Laboratory Program Contaminant(s) of potential concern U.S. Department of Energy, Nevada Operations Office U.S. Environmental Protection Agency Federal Facility Agreement and Consent Order Inductively coupled plasma
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Page vii of vii List of Acronyms and Abbreviations (Continued) NAC Nevada Administrative Code NDEP Nevada Division of Environmental Protection NIST National Institute for Standards and Technology NTS Nevada Test Site PAL Preliminary action level(s) PRG Preliminary Remediation Goals QA Quality Assurance QAPP Quality Assurance Project Plan RCRA Resource Conservation and Recovery Act RPD Relative percent difference SDG Sample delivery group SVOC Semivolatile organic compound(s) TCLP Toxicity Characteristic Leaching Procedure TPH Total petroleum hydrocarbons VOC Volatile organic compound(s)
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This Corrective Action Decision Document has been prepared for Corrective Action Unit 340, the NTS Pesticide Release Sites, in accordance with the Federal Facility Agreement and Consent Order of 1996 (FFACO, 1996). Corrective Action Unit 340 is located at the Nevada Test Site, Nevada, and is comprised of the following Corrective Action Sites: • 23-21-01, Area 23 Quonset Hut 800 Pesticide Release Ditch • 23-18-03, Area 23 Skid Huts Pesticide Storage • 15-18-02, Area 15 Quonset Hut 15-11 Pesticide Storage The purpose of this Corrective Action Decision Document is to identify and provide a rationale for the selection of a recommended corrective action alternative for each Corrective Action Site. The scope of this Corrective Action Decision Document consists of the following tasks: • Develop corrective action objectives. • Identify corrective action alternative screening criteria. • Develop corrective action alternatives. • Perform detailed and comparative evaluations of the corrective action alternatives in relation to the corrective action objectives and screening criteria.• • Recommend and justify a preferred corrective action alternative for each Corrective Action A corrective action investigation was performed in 1998 as set forth in the Corrective Action Investigation Plan for Corrective Action Unit 340: Pesticide Release Sites, Nevada Test Site, Nye County, Nevada (DOE/NV, 1998). Pesticide (primarily Chlordane) contamination exceeding preliminary action levels was discovered in the upper 0.6 meters (2 feet) of soil at the two Corrective Action Sites located in Area 23. Similar contamination was also discovered in the upper 0.3 meters (1 foot) of soil in sections of the disturbed area between these two Corrective Action Sites (Table ES-1). The disturbed area was not originally identified as part of the corrective action investigation. Unknown hydrocarbons were detected at concentrations exceeding 100 milligrams per kilogram and were associated with elevated pesticide concentrations at both the Quonset Hut 800 and Skid Huts sites. Grading operations at the Quonset Hut 800 and Skid Huts sites are believed to be
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responsible for spreading the contaminants from the Corrective Action Sites to the surrounding area. Due to the proximity and similarity of the disturbed area to the Area 23 Corrective Action Sites, the disturbed area will be addressed in this Corrective Action Decision Document along with the original three Corrective Action Sites. No corrective action is necessary at Area 15 Quonset Hut 15-11 because no contaminants of concern were identified at this Corrective Action Site. Details regarding the investigation can be found in Appendix A of this document. The results of the investigation indicated that contamination is present at locations shown in Figure 2-1. Locations of Contaminants of Concern Corrective Action Site No Contaminants of 23-21-01, Area 23 Quonset Hut 800 Pesticide 23-18-03, Area 23 Skid Huts Pesticide Storage X 15-18-02, Area 15 Quonset Hut 15-11 Pesticide Drainage ditch adjacent (northeast) of the Quonset Area immediately adjacent (north, west, south) to the Skid Huts site X Flood control channel adjacent to the Skid Huts site X Outfall area immediately south of Quonset Hut 800 Based on the potential exposure pathways, the following corrective action objectives have been identified for Corrective Action Unit 340:• • Prevent or mitigate exposure to surface and near-surface soil containing pesticides at concentrations greater than the contaminant specific preliminary action levels identified in the Corrective Action Investigation Planfor Corrective Action Unit 340: Pesticide Release Sites, Nevada Test Site, Nye County. Nevada (DOE/NV, 1998).
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• Prevent spread of contaminants of concern beyond the corrective action sites. • Prevent adverse impacts to groundwater quality. Based on the review of existing data, future use, and current operations at the Nevada Test Site, the following alternatives were developed for consideration at the Pesticide Release Sites: • Alternative 1 - No Further Action • Alternative 2 - Clean Closure by Excavation and Disposal • Alternative 3 - Closure in Place by Protective Cover The corrective action alternatives were evaluated based on four general corrective action standards and five remedy selection decision factors. Based on the results of this evaluation, the preferred alternative for Corrective Action Unit 340 is Alternative 2, Clean Closure by Excavation and The preferred corrective action alternative was evaluated on technical merit, focusing on performance, reliability, feasibility, and safety. The alternative was judged to meet all requirements for the technical components evaluated. The alternative meets all applicable state and federal regulations for closure of the site and will eliminate potential future exposure pathways to the contaminated soils at the Pesticide Release Sites. During corrective action implementation, this alternative will present a potential threat to site workers who come in contact with the contaminated soil. However, procedures will be developed and implemented to ensure worker health and safety.
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This Corrective Action Decision Document (CADD) has been prepared for Corrective Action Unit (CAU) 340, Pesticide Release Sites, in accordance with the Federal Facility Agreement and Consent Order (FFACO) of 1996 that was agreed to by the U.S. Department of Energy, Nevada Operations Office (DOE/NV); the Nevada Division of Environmental Protection (NDEP); and the U.S. Department of Defense (FFACO, 1996). The CADD provides or references the specific information necessary to recommend corrective actions for the Corrective Action Sites (CASs) within CAU 340, which include the following: • 23-21 -01; Area 23 Quonset Hut 800 Pesticide Release Ditch (Q800) • 23-18-03; Area 23 Skid Huts Pesticide Storage (Skid Huts) • 15-18-02; Area 15 Quonset Hut 15-11 Pesticide Storage (Q15-11) Investigation activities identified an area of concern not included in the original CAS investigation areas. This area is defined by the disturbed soil located between the Q800 and Skid Huts sites. This area is addressed in this CADD along with the CASs mentioned above. Corrective Action Unit 340 is located at the Nevada Test Site (NTS) in Nevada. The NTS is approximately 105 kilometers (km) (65 miles [mi]) northwest of Las Vegas, Nevada (Figure 1-1 and This CADD identifies and provides a rationale for the selection of a recommended corrective action alternative for each CAS within the CAU. The need for evaluation of corrective action alternatives is based on process knowledge and the results of investigative activities conducted in accordance with the Corrective Action Investigation Plan for Corrective Action Unit 340: Pesticide Release Sites, Nevada Test Site, Nye County, Nevada (CAIP) (DOE/NV, 1998).
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Nevada Test Site Boundan General Location of the Area 23 and Area 15 Pesticide Release Sites
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The scope of this CADD consists of the following: • Develop corrective action objectives. • Identify corrective action alternative screening criteria. • Develop corrective action alternatives. • Perform detailed and comparative evaluations of corrective action alternatives in relation to corrective action objectives and screening criteria. • Recommend and justify a preferred corrective action alternative for each CAS within the CAU and the disturbed area between the Q800 and Skid Huts sites. This CADD is divided into the following sections: Section 1.0 - Introduction: summarizes the purpose, scope, and contents of this CADD. Section 2.0 - Corrective Action Investigation Summary: summarizes the investigation field activities, the results of the investigation, and the need for corrective action. Section 3.0 - Evaluation of Alternatives: documents steps taken to determine a preferred corrective Section 4.0 - Recommended Alternative: presents the preferred corrective action alternative and the rationale for its selection based on the corrective action objectives and alternative screening criteria. Section 5.0 - References: provides a list of all referenced documents. Appendix A: Corrective Action Investigation Reportfor CA U 340: Pesticide Release Sites, Nevada Test Site, Nevada. Appendix B: Cost estimates.
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work was performed in accordance with the following documents: Industrial Sites Quality Assurance Project Plan (DOE/NV, 1996) Project Management Plan (DOE/NV, 1994)
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2.0 Corrective Action investigation Summary The following sections describe and summarize the results of the investigation activities conducted at CAU 340. For detailed investigation results, please refer to Appendix A. From March 23,1998 through April 10, 1998, corrective action investigation activities were performed as set forth in the CAIP (DOE/NV, 1998). The purpose of the investigation was to: • Identify the presence and nature of contaminants of potential concern (COPCs) at the CAU. • Determine the vertical and lateral extent of COPCs. • Provide sufficient information and sample analytical data from which corrective action alternatives may be developed and evaluated in this CADD for the CAU. • Obtain sufficient sample analytical data for management of investigation-derived waste The investigation activities were conducted in two stages. The activities for each stage are • Collected 23 surface/near-surface soil samples from 23 locations at Q800 using hand tools. These samples were collected from 0 to 0.3 meters (m) (0 to 1 feet [ft]) and submitted for • Collected 18 surface and near-surface soil samples from 13 locations at Skid Huts using hand tools. These samples were collected at depths ranging from 0 to 0.6 m (0 to 2 ft) and submitted for laboratory analysis. • Removed the plywood flooring from the Q15-11 quonset hut. Four plywood samples were collected for waste characterization purposes only and analyzed off site for leachable • Collected eight surface/near-surface soil samples from seven locations at Q15-11 using hand tools. These samples were collected from 0 to 0.3 m (0 to 1 ft) and submitted for laboratory
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• Field-screened soil samples for volatile organic compounds (VOCs), total petroleum • Analyzed soil samples for total VOCs; total semivolatile organic compounds (SVOCs); total and leachable Resource Conservation and Recovery Act (RCRA) metals; total and leachable waste oil); TPH as gasoline; and radioactive isotopes by gamma spectroscopy (approximately 10 percent of the samples submitted were analyzed by gamma spectroscopy). • Evaluated soil sample analytical results from Stage I to guide soil sampling conducted in • At Q800, collected 49 surface and near-surface soil samples from 13 locations at depths ranging from 0.3 to 1.2 m (1.0 to 4.0 ft) using the direct-push method. Twenty-two of these samples were analyzed. The remaining 27 samples were archived and not analyzed because adequate samples had been obtained from similar horizons during Stage I sampling. • At Skid Huts, collected 10 surface and near-surface soil samples from three locations at depths ranging from 0 to 1.2 m (0 to 4.0 ft) using the direct-push method. Six of these samples were analyzed. The remaining four samples were not analyzed because sufficient samples were collected at similar horizons during the Stage I sampling. • No activities were conducted at Q15-11 in Stage II. • Soil samples submitted to an off-site laboratory were analyzed for total …
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