Safer Work Plan for Caus 452, 454, 456, and 464 Closure of Historical Ust Release Sites Nevada Test Site 0) REVISION:0 August 1997

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SAFER Work Plan Closure of Historical UST Release Sites Nevada Test Site Controlled Copy No.: trFACD-S Approved for public release; further distribution is authorized U.S. Department of Energy Nevada Operations Office j

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Available to the public from: National Technical Information Service 5285 Port Royal Road Available electronically at http://www.doe.gov/bridge. Available to the 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, or favoring by the U.S. Government or any agency thereof or its contractors or

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CONTROLLED COPY RECEIPT RECORD CONTROLLED COPY NUMBER: FFACO-5 NAME: Southern Nevada Public Reading Room ORGANIZATION: DOE SAFER Work Plan For Corrective Action Units 452,454,456, and 464: Closure of Hostorical UST Release Sites Nevada Test Site The document listed above has been received. Note: To be signed by addressee only and returned within ten days to: Dana L. Wruble, Bechtel Nevada, M/S NLV080, PO Box 98521, Las Vegas, Nevada 89193-8521.

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Department of Energy Nevada Operations Office Southern Nevada Public Reading Room Northern Nevada Public Reading Room Nevada State Library and Archives SUBMITTAL OF THE FINAL SAFER WORK PLAN FOR CAUS 452, 454, 456, AND 464 CLOSURE OF HISTORICAL UST RELEASE SITES, NEVADA TEST SITE, AUGUST 1997 The Federal Facility Agreement and Consent Order (FFACO) requires that the enclosed document is available to the public through the FFACO Public Reading Rooms. The following copies have been provided for submittal into the FFACO Public Reading Room collection in accordance with the DOE/NV Distribution Process for FFACO Documents. Southern Nevada Public Reading Room: 1 controlled copy Northern Nevada Public Reading Room: 1 uncontrolled copy Please direct comments and questions to Clayton W. Barrow, of my staff, at (702) 295-7960. ERDJAW Environmental Restoration Division

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SAFER WORK PLAN FOR CLOSURE OF HISTORICAL UST RELEASE SITES NEVADA TEST SITE Prepared for the Nevada Operations Office Under Contract No. DE-AC08-96NV11718

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SAFER WORK PLAN FOR CLOSURE OF HISTORICAL UST RELEASE SITES NEVADA TEST SITE vada Environmental Restoration Project

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UST Release Sites TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS ..........................;...................................................... vi 1.3 SAFER PLAN CONTENTS........................................................................................ 4 1.4 SAFER PLAN ASSUMPTIONS ..........................................:.................................. 5 1.5 APPROACH FOR CLEAN CLOSURE...................................................................... 5 1.6 APPROACH FOR SITE CHARACTERIZATION AND CLOSURE........................6 1.7 APPROACH FOR SITE EVALUATION .................................................................. 6 2.0 SITE LOCATION AND DESCRIPTION ................................ ,........................................... 7 2.1 CAU 452, AREA 25 RELEASE SITES ................................................ ....................7 2.1 1 UST 25-3101-1 (NDEMNo. H940825C, Release CAS No. 25-25-09) ... 7 2.1.2 UST 25-3102-3 (NDEM No. H940314E, Release CAS No. 25-25-14) ... 7 2.1.3 UST 25-3152-1 (NDEMNo. H941020E, Release CAS No. 25-25-15) ... 8 2.2 CAU 454, AREA 12 RELEASE SITES...................................................................... 8 2.2.2 UST 12-B-3 (NDEMNo. 960722-02, Release CAS No. 12-25-09).......... 9 2.3 CAU 456, AREA 23 RELEASE SITE........................................................................ 9 2.3.1 UST 23-111-1 (NDEM No. Not Assigned, UST/Release 2.4 CAU 464, AREAS 2 AND 9 RELEASE SITES ...................................................... 10 3.0 SCOPE OF WORK............................................................................................................... 12 3.1.1 Tortoise Habitat and Endangered Species Investigation.............. ............12 3.1.2 National Environmental Protection Act Documentation............................ 12 3.13 Health and Safety Plan................................................................................ 12

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TABLE OF CONTENTS (continued) 3.2 CONSTITUENTS OF CONCERN............................................................................ 13 3.3.1 Sample Collection and Handling............ ....................................................13

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UST Release Sites TABLE OF CONTENTS (continued) Figure 1 - Site Location Map CAUs 452,454,456, and 464 ....................................................... 2 Figure 4 - UST Release Site 9-300-1 - Site Layout...................................................................... 19 Figure 5 - UST Release Site 2-300-1 - Proposed Borehole Locations ........................................21 Figure 6 - US Release Sites 25-3101-1 and 25-3102-3 - Site Layout and Figure 9 - UST Release Site 23-111-1 - Site Layout.................................................................... 28 Table 1 - Hydrocarbon Release Sites Identified for Closure.........................................................3 Table 2 - Summary of Closure Approach, Methodology, and Sample Requirements................ 14

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ACRONYMS AND ABBREVIATIONS below ground surface Corrective Action Site Corrective Action Unit Combustible Gas Analyzer U.S. Environmental Protection Agency Environmental Safety, Security, and Health Federal Facility Agreement and Consent Order milligrams per kilogram milligrams per liter Nevada Administrative Code Nevada Division of Environmental Management Nevada Division of Environmental Protection UST Release Sites

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Section: Acc. & Abb. UST Release Sites ACRONYMS AND ABBREVIATIONS (continued) PID Photoionization Detector ppm parts per million Rad Safe Radiological Safety RCRA Resource Conservation and Recovery Act SAFER Streamlined Approach for Environmental Restoration TCLP Toxicity Characteristic Leaching Procedure TPH. Total Petroleum Hydrocarbon UST Underground Storage Tank VOC Volatile Organic Compound

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UST Release Sites This plan addresses characterization and closure of nine underground storage tank (UST) petroleum hydrocarbon release sites. The sites are located at the Nevada Test Site (NTS) in Areas 2, 9,12,23, and 25 (Figure 1). The sites are identified in the Federal Facility Agreement and Consent Order (FFACO) in Appendix II (currently proposed to be moved into Appendix III) and are assigned as Corrective Action Units (CAUs) 452,454,456, and 464. Each tank and associated hydrocarbon release has been assigned a Corrective Action Site (CAS) Number (Table 1). Closure of the associated USTs have been accepted by the Nevada Division of Environmental Protection (NDEP). Releases associated with the tanks have not been closed, therefore, this Streamlined Approach for Environmental Restoration (SAFER) Work Plan only addresses closure of the spills associated with each tank. The USTs associated with the release sites and addressed by this plan were closed between 1990 and 1996 by the U.S. Department of Energy, Nevada Operations Office (DOE/NV). One UST was closed in place (23-111-1) while the remaining eight were closed by removal. Hydrocarbon releases were identified at each of the sites based upon laboratory analytical data from samples collected below the tank bottoms. Hydrocarbon concentrations exceeded the Nevada Administrative Code (NAC) Action Level of 100 milligrams per kilogram (mg/kg) (NAC 459.9973, 1995). Each release was reported to the NDEP and the Nevada Division of Emergency Management (NDEM) within 24 hours of identification. NDEM numbers were assigned to each site except for 23-111-1. The release at this site was identified prior to the time period when NDEM assigned tracking numbers. Tank locations are shown on Figure 1 and identified in Table 1. The objective of this plan is to provide a method for implementing characterization and closure of historical UST hydrocarbon release sites. This plan is prepared under the SAFER concept. The SAFER concept recognizes that technical decisions may be made based on incomplete but sufficient information and the experience of the decision maker. Any uncertainties are addressed by documented assumptions that are verified by sampling and analysis, data evaluation, and on site observations as planned activities progress, and by contingency plans as necessary. If, at any time during the site closure, new information is developed that indicates that the closure method or underlying assumptions should be revised, the decision makers will redirect the closure activities to more appropriately protect human health and the environment.

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UST Release Sites TABLE 1 - HYDROCARBON RELEASE SITES IDENTIFIED FOR CLOSURE 452 25-3101-1 25-02-13 25-25-09 H940825C Area 25 Control Point Facility July 20, 1994 544 Diesel 25-3102-3 25-02-18 25-25-14 H940314E Area 25 Control Point Facility March 9, 1994 620 Diesel/Oil 25-3152-1 25-02-19 25-25-15 H941020E Area 25 Former Rad Safe 454 12-B-l 12-02-07 12-25-08 H950524F Area 12 “B” Tunnel March 1, 1995 570 Diesel 12-B-3 12-02-06 12-25-09 960722-02 Area 12 “B” Tunnel May 6, 1996 310 Waste Oil 456 23-111-1 23-02-03 23-02-03 Not Assigned Area 23 ESS&H Building September 6, 1990 191 Heating Oil 464 2-300-1 02-02-03 02-02-03 960603-771 Area 2 300 Bunker April 30, 1996 9,600 Diesel 9-300-1 09-02-01 09-02-01 960701-849 Area 9 300 Bunker May 2, 1996 3,300 Diesel 1 Corrective Action Unit Number identified in the FFACO. 2 Underground Storage Tank Identification Number. 3 Corrective Action Site Number assigned to the UST within the FFACO. 4 Corrective Action Site Number assigned to the hydrocarbon release within the FFACO. UST Sites 23-111-1, 2-300-1, and 9-300-1 were assigned the same CAS Numbers for both the UST and associated release. 5 Nevada Division of Environmental Management Number assigned at time of release identification. 6 Date which tank was closed by removal or closed in place. 7 Concentration detected at maximum sample depth reported in milligrams per kilogram.

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UST Release Sites Closure for each site will be completed by: • Excavation of impacted soils for clean closure (12-B-1,12-COMM-1, and 9-300-1). • Delineation of the hydrocarbon impacted soils for potential administrative closure • Site evaluation without excavation or drilling (12-B-3 and 23-111-1). 1.3 SAFER PLAN CONTENTS This SAFER Plan has been developed in a manner to support the proposed characterization and closure of nine UST petroleum hydrocarbon release sites. The format of the plan is as follows: • Introduction, background, and closure approach (Section 1.0). • CAU site location and description (Section 2.0). • Waste management and disposal (Section 4.0). • Schedule of closure activities (Section 5.0). This plan was developed using information and guidance provided from the following • Nevada Environmental Restoration Project. Project Management Plan. Revision 0, DOE, • Nevada Env' onmental Restoration Project. Health and Safety Plan. Revision 2, DOE, • Nevada Environmental Restoration Project. Industrial Sites. Quality Assurance Project Plan. Nevada Test Site. Revision 1, DOE, 1996.

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UST Release Sites 1.4 SAFER PLAN ASSUMPTIONS The closure approach is based on the following assumptions: • Each site is impacted by petroleum hydrocarbons only. Samples will not be analyzed for Resource Conservation and Recovery Act (RCRA) constituents since they were not identified in previous soil samples collected below the tank bottoms or by process Clean Closure bv Excavation • At sites to be excavated for clean closure (12-B-l, 12-COMM-l, and 9-300-1) hydrocarbon concentrations greater than 100 mg/kg do not extend 3 meters (m) (10 feet [ft]) below the former tank bottom. • A maximum of two excavation and sampling events will be conducted at each clean closure site. If after two events, the verification sample results indicate the presence of hydrocarbons above the regulatory limit of 100 mg/kg, the remediation plan for that site will be re Administrative Closure by Site Characterization fDrillingt • At sites requiring drilling (25-3101-1,25-3102-3,25-3152-1 and 2-300-1), the extent of the hydrocarbon release does not extend beyond 30 m (100 ft) below ground surface (bgs) and has not impacted the groundwater. • Information collected from the proposed soil boreholes will be sufficient to support closure 1.5 APPROACH FOR CLEAN CLOSURE Clean closure will be completed at former tank sites 12-B-l, 12-COMM-l, and 9-300-1 by excavation and sampling to verify that the soil is below the petroleum hydrocarbon Action Level of 100 mg/kg (NAC 459.9973,1995). Petroleum impacted soils will be excavated using a backhoe or front end loader. These sites have been identified for clean closure based upon site observations at the time of tank removal, equipment accessibility, and the low total petroleum hydrocarbon (TPH) soil concentrations identified subsequent to tank removal.

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UST Release Sites 1.6 APPROACH FOR SITE CHARACTERIZATION AND CLOSURE Site characterization and closure will be completed at former tank sites 25-3101-1,25-3102-3, 25-3152-1, and 2-300-1. The approach for completing additional site characterization and closure will be to define the lateral and vertical extent of the hydrocarbon impacted soil using drilling equipment. Drilling is preferred at these sites based on the findings of previous remedial excavation efforts. Additional site characterization is anticipated to provide sufficient data to complete an “A through K” evaluation to support an administrative closure. 1.7 APPROACH FOR SITE EVALUATION Former tank sites 12-B-3 and 23-111-1 require additional site evaluation. The 12-B-3 site evaluation consists of collecting additional soil samples to confirm that hydrocarbons identified are from past site activities and are not from a release from UST 12-B-3. The 23-111-1 site evaluation consists of collecting air samples from two passive venting wells to determine if hydrocarbons are still present. The passive venting wells were installed during the tank closure activities to enhance bioremediation at the site. It is anticipated that the findings of the evaluation will provide sufficient information to support an administrative (A through K)

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Section: Site Location UST Release Sites 2.0 SITE LOCATION AND DESCRIPTION 2.1 CAU 452, AREA 25 RELEASE SITES Activities at sites 25-3101-1,25-3102-3, and 25-3152-1 consist of collecting soil samples in an effort to characterize the lateral and vertical extent of the hydrocarbon plume. Characterization will be completed using hollow-stem auger or air rotary drilling equipment. It is anticipated that drilling will not extend greater than 30 m (100 ft) bgs. Clean closure will not be attempted at these sites based upon the assumed extent of the subsurface impacted area and proximity to buildings and/or subsurface utilities. Figures are provided in Section 3.0. Data collected from the characterization will be used to complete an “A through K” evaluation for each site. It is anticipated that the analysis along with the concentrations and limits defined in the site characterization will support administrative closures of these sites. 2.1.1 UST 25-3101-1 (NPEM No. H940825C, Release CAS No. 25-25-09) UST 25-3101-1 was located on the south side of Building 25-3101 within the Area 25 Control Point Facility. The tank had an approximate capacity of 15,000 liters (L) (4,000 gallons [gal]) and was used for storing diesel fuel. One soil sample collected below the east tank bottom, at the time of tank removal on July 20,1994, had a TPH concentration of 2,400 mg/kg at a depth of approximately 3 m (9.5 ft) bgs. Analytical results from subsequent soil sampling on October 24, 1994, had a TPH concentration of 544 mg/kg at a depth of approximately 4 m (12.5 ft) bgs. Additional excavation was not completed in this area due to the following site limitations: • The tank excavation is bordered by a concrete loading dock to the north (within 0.9 m [3 ft]). • A 0.3 m (1 ft) diameter utility (water) line was identified within the southern sidewall of the excavation. The utility line is buried at an approximate depth of 1.5 m (5 ft) bgs. 2.1.2 UST 25-3102-3 (NDEM No. H940314E, Release CAS No. 25-25-14) UST 25-3102-3 was located on the southwest comer of Building 25-3102 within the Area 25 Control Point Facility. The tank had an approximate capacity of 2,100 L (560 gal) and was used for storing waste oil. Analysis of the tank contents identified, waste oil, polychlorinated biphenyls (PCBs), and barium. The tank contents were characterized as hazardous and subsequently removed and treated following appropriate State and Federal Regulations. The tank was removed on March 9,1994 and triple rinsed prior to disposal.

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Section: Site Location UST Release Sites Soil samples collected below the north and south tank bottom from approximately 3 m (10 ft) and barium were not detected in the soil samples collected below the tank bottom. Additional excavation was completed on May 1,1995. Samples collected from a depth of approximately 4 m (12 ft) bgs from the north and south end had hydrocarbon concentrations of 170 mg/kg and 620 mg/kg, respectively. Further remedial activities were not completed at the site due to the following limitations: • The tank excavation is bordered by Building 25-3102 to the north. • The site is on a sloped embankment limiting backhoe accessibility. • A five centimeter (2 inch) utility line is located diagonally across the south end of the …