S02 - NDEP response 03_26_24 4-000560.pdf

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This document is a response letter from the Nevada Division of Environmental Protection (NDEP) regarding a Release Identification and Work Plan for Additional Environmental Site Assessment at the Ioannis A. Lougaris V.A. Medical Center in Reno, Nevada. The letter reviews a work plan submitted by UES on behalf of the U.S. Department of Veterans Affairs concerning a recently discovered underground storage tank (UST) with diesel oil-impacted soil. Analytical results showed total petroleum hydrocarbon levels above NDEP screening levels, reaching up to 1,578 mg/kg at 5.5 to 7.5 feet below ground surface.

The proposed work plan includes several key activities: inspecting the opened UST container, removing any remaining product, conducting oversight of UST removal by a Nevada-licensed tank handler, collecting and testing soil samples from the excavation area, assessing the extent of impacted soil through additional sampling, removing impacted soil until residential levels are met, and performing final soil sampling and analytical testing by a Nevada-certified laboratory. NDEP concurs with the submitted work plan and requests all report documents be submitted digitally, with a 100-megabyte attachment limit for emails.

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901 S. Stewart Street, Suite 4001 • Carson City, Nevada 89701 • p:775.687.4670 • f:775.687.5856 • ndep.nv.gov

Subject: NDEP Response: Release Identification and Work Plan for Additional Environmental Site Assessment

Facility: Ioannis A. Lougaris V.A. Medical Center 975 Kirman Ave Reno, Nevada

Spill Report No.: 24020501 Facility ID: 4000560

March 26, 2024

Travis Robinett U.S. Dept. of Veteran Affairs 975 Kirman Ave Reno, NV 89502

Dear Travis Robinett:

The Nevada Division of Environmental Protection (NDEP) has reviewed the Release Identification and Work Plan for Additional Environmental Site Assessment (Report) for the referenced facility (Site) dated March 22, 2024 and prepared by Anna Henry, Certified Environmental Manager (CEM) of UES on behalf of the U.S. Dept. of Veteran Affairs.

The report contains a proposed workplan for additional environmental site assessment for the referenced facility in preparation for future construction activities. The workplan also discusses remediation measures regarding diesel oil impacted soil of a recently discovered underground storage tank. Analytical results for the initial soil samples show total petroleum hydrocarbon levels above NDEP screening level for dieselrange and oilrange organics, up to 1,578 mg/kg (DRO) at approximately 5.5 to 7.5 feet below ground surface (bgs).

The report submitted by UES suggests additional assessment and remediation activities for this site. A summary of the workplan is described below:

Inspection of the opened UST container to identify any remaining product or substance within the tank In the event that product is found, treatment by pumping and rinsing of the UST will be conducted to remove any residual product to the point of clean tank conditions for excavation Oversite of removal/excavation of the UST to be conducted by a Nevadalicensed tank handler Soil sample collection and testing of the nearimpacted soil from both endpoints of the excavated area Assessing the extent of impacted soil through sampling and analytical testing of the surrounding soil Oversite of removal/excavation of all remaining impacted soil until satisfactory to residential levels for total petroleum hydrocarbons Confirmation of completed excavation activities with final soil sampling and analytical testing by a Nevadacertified laboratory Reporting with NDEP for review of site activities and analytical soil sample results for concurrence of contaminant levels

NDEP concurs with the submitted work plan from UES.

NDEP requests all report documents be submitted in digital portable document format (pdf) via email, by uploading to a file transfer protocol (ftp) site, or by a link to an online document site. Please be advised that NDEP has a 100 megabyte limit for email attachments.

If you have any questions or concerns regarding this letter, please contact the undersigned at 775687 9377 or d.peterson@ndep.nv.gov.

Sincerely, Dean Peterson Environmental Scientist Bureau of Corrective Actions, NDEP ec Anna Henry, 6995 Sierra Center Parkway, AHenry@teamues.com

Benjamin Moan, Professional Engineering Specialist, P.E., bmoan@ndep.nv.gov

Caitlin Jelle, McGinley & Associates, Inc, dba UES, 6995 Sierra Center Parkway, Reno, NV 89511, cjelle@teamues.com

Christian Kropf, Senior Hydrogeologist, Truckee Meadows Water Authority, ckropf@tmwa.com

Don Warner, Bureau of Corrective Actions, Petroleum Fund Staff, dwarner@ndep.nv.gov

Luke Franklin, Northern Nevada Public Health, lfranklin@nnph.org

Megan Slayden, Bureau of Corrective Actions, Petroleum Fund Supervisor, m.slayden@ndep.nv.gov

Michael Mazziotta, Remediation & LUST Supervisor, Las Vegas Office, mmazziotta@ndep.nv.gov

Phil Tousignant, City of Reno Environmental Control, tousignantp@reno.gov

Scott Smale, DoD and Remediation Branch Supervisor, ssmale@ndep.nv.gov

Wes Rubio, Northern Nevada Public Health, wrubio@nnph.org

Subject: NDEP Response: Release Identification and Work Plan for Additional Environmental Site Assessment

Facility: Ioannis A. Lougaris V.A. Medical Center 975 Kirman Ave Reno, Nevada

Spill Report No.: 24020501 Facility ID: 4000560

March 26, 2024

Travis Robinett U.S. Dept. of Veteran Affairs 975 Kirman Ave Reno, NV 89502

Dear Travis Robinett:

The Nevada Division of Environmental Protection (NDEP) has reviewed the Release Identification and Work Plan for Additional Environmental Site Assessment (Report) for the referenced facility (Site) dated March 22, 2024 and prepared by Anna Henry, Certified Environmental Manager (CEM) of UES on behalf of the U.S. Dept. of Veteran Affairs.

The report contains a proposed workplan for additional environmental site assessment for the referenced facility in preparation for future construction activities. The workplan also discusses remediation measures regarding diesel oil impacted soil of a recently discovered underground storage tank. Analytical results for the initial soil samples show total petroleum hydrocarbon levels above NDEP screening level for dieselrange and oilrange organics, up to 1,578 mg/kg (DRO) at approximately 5.5 to 7.5 feet below ground surface (bgs).

The report submitted by UES suggests additional assessment and remediation activities for this site. A summary of the workplan is described below:

Inspection of the opened UST container to identify any remaining product or substance within the tank In the event that product is found, treatment by pumping and rinsing of the UST will be conducted to remove any residual product to the point of clean tank conditions for excavation Oversite of removal/excavation of the UST to be conducted by a Nevadalicensed tank handler Soil sample collection and testing of the nearimpacted soil from both endpoints of the excavated area Assessing the extent of impacted soil through sampling and analytical testing of the surrounding soil Oversite of removal/excavation of all remaining impacted soil until satisfactory to residential levels for total petroleum hydrocarbons Confirmation of completed excavation activities with final soil sampling and analytical testing by a Nevadacertified laboratory Reporting with NDEP for review of site activities and analytical soil sample results for concurrence of contaminant levels

NDEP concurs with the submitted work plan from UES.

NDEP requests all report documents be submitted in digital portable document format (pdf) via email, by uploading to a file transfer protocol (ftp) site, or by a link to an online document site. Please be advised that NDEP has a 100 megabyte limit for email attachments.

If you have any questions or concerns regarding this letter, please contact the undersigned at 775687 9377 or d.peterson@ndep.nv.gov.

Sincerely, Dean Peterson Environmental Scientist Bureau of Corrective Actions, NDEP ec Anna Henry, 6995 Sierra Center Parkway, AHenry@teamues.com

Benjamin Moan, Professional Engineering Specialist, P.E., bmoan@ndep.nv.gov

Caitlin Jelle, McGinley & Associates, Inc, dba UES, 6995 Sierra Center Parkway, Reno, NV 89511, cjelle@teamues.com

Christian Kropf, Senior Hydrogeologist, Truckee Meadows Water Authority, ckropf@tmwa.com

Don Warner, Bureau of Corrective Actions, Petroleum Fund Staff, dwarner@ndep.nv.gov

Luke Franklin, Northern Nevada Public Health, lfranklin@nnph.org

Megan Slayden, Bureau of Corrective Actions, Petroleum Fund Supervisor, m.slayden@ndep.nv.gov

Michael Mazziotta, Remediation & LUST Supervisor, Las Vegas Office, mmazziotta@ndep.nv.gov

Phil Tousignant, City of Reno Environmental Control, tousignantp@reno.gov

Scott Smale, DoD and Remediation Branch Supervisor, ssmale@ndep.nv.gov

Wes Rubio, Northern Nevada Public Health, wrubio@nnph.org

U.S. Dept. of Veteran Affairs Ioannis A. Lougaris V.A. Medical Center Workplan and ESA response March 26, 2024 mailto:d.peterson@ndep.nv.gov

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