Exhibit_D_Appendix_D-5_SWPPP.pdf

Storm Water Pollution Prevention Plan

TA-21 DP Site Aggregate Area Demolition and Disposal Cleanup

Project

N3B

Los Alamos National Laboratory a requirement of the NPDES General Permit for Storm Water Discharges from Construction Activities

Prepared by: N3B Environmental Remediation Project Field Execution

Date:

TA‐21 DP Site Aggregate Area D&D Cleanup iii

TABLE OF CONTENTS

PREFACE .............................................................................................................................................. V

CERTIFICATION STATEMENT ............................................................................................................... VII

1.0 OPERATORS

1.1 Storm Water Team

2.0 CONSTRUCTION ACTIVITIES AND CONTROLS

2.1 Site History, Nature of Construction Activities

2.2 Design Requirements

2.3 Control Measure Considerations

2.4 Stabilization Measures

3.0 POLLUTION PREVENTION

3.1 Potential Pollutants

3.2 Non–Storm Water Discharges

3.3 Dewatering

3.4 Receiving Waters

3.5 Buffers

3.6 Spill Prevention, Response, and Reporting

4. PROCEDURES AND REQUIREMENTS

4.1 Inspections

4.2 Maintenance/Corrective Actions

4.3 Corrective Action Reporting

4.4 SWPPP Modifications

4.5 Training

4.6 Record Keeping

4.7 Compliance with Other Federal Requirements

5.0 REFERENCES

TA-21 DP Site Aggregate Area D&D Cleanup iv

Appendix A Sequence of Events for Soil Disturbance Tracking Table

Appendix B SWPPP Modification Records Tracking Table

Appendix C Site Map

Appendix D Spill Tracking Form

Appendix E Permit Regulations, NOI, Delegation of Authority letter, EPA acknowledgement

Appendix F Los Alamos National Laboratory Storm Water BMP Manual

Appendix G SWPPP Training Documentation

Appendix H SWPPP Inspection Reports and Corrective Action Reports

Appendix I Blank Inspection/Corrective Action Forms

Appendix J Inspector Qualifications v

PREFACE

The United States Environmental Protection Agency (EPA) has issued a final 2017 National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) that covers discharges of storm water from qualifying construction sites. Authorization to discharge storm water is allowed under the 2017 CGP for construction projects disturbing more than one (1) acre or part of a larger common plan of development that collectively disturbs more than one (1) acre. EPA Region 6 has issued NMR100000 for CGP coverage to discharges in New Mexico.

Requirements imposed by the 2017 CGP which are applicable to this project include the following:

Preparation of a site-specific storm water pollution prevention plan (SWPPP), Completion of a critical habitat and threatened/endangered species study, Submittal of a notice of intent (NOI) via EPA’s Electronic Notice of Intent (eNOI) website (https://www.epa.gov/npdes/storm water-discharges-construction-activities#ereporting), Installation and maintenance of erosion and storm water controls, Performance and documentation of inspections during construction and site stabilization, Maintenance of the SWPPP with up-to-date documentation as necessary, and

Submittal of a notice of termination (NOT) following project completion and final stabilization of disturbed areas.

This SWPPP has been prepared by Newport News Nuclear BWXT – Los Alamos, LLC (N3B) in accordance with good engineering practices and the provisions of the Clean Water Act (33 United States Code [USC] § §1251 et seq., as amended by the Water Quality Act of 1987, Public Law [PL] 100-4), and the regulations established by EPA for NPDES General Permits for Storm Water Discharges from Construction Activities to cover sitewide demolition and disposal (D&D) and related site cleanup activities at Technical Area 21 (TA-21), DP Site Aggregate Area at Los Alamos National Laboratory (LANL or the Laboratory) (see site map provided in Appendix C). This plan describes the general nature and sequencing of construction activities associated with the sitewide D&D and cleanup and identifies the best management practices (BMPs) to minimize the potential for erosion and storm water pollution. Task-specific details will be added to this SWPPP as the project progresses, subcontractors are selected, and implementation details emerge.

N3B is the operator for this project with operational control over construction plans and specifications and also with the day-to-day operational control over the activities necessary to maintain compliance with the 2017 CGP. As the operator, N3B is responsible for submitting the requisite NOI for this discharge to EPA Region 6 and for the proper implementation of the SWPPP. All subcontractors performing work on this project will be responsible for complying with the provisions of the 2017 CGP and the SWPPP as those requirements relate to their scope of work. Inspections will be performed and documented by N3B. N3B will additionally prepare revisions to the site map and SWPPP, as necessary, to cover all operations related to the sitewide D&D activities at TA-21. Subcontractors are not required to develop and implement a separate SWPPP, nor are subcontractors responsible for submitting NOIs for project discharges under the 2017 CGP.

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1.0 OPERATORS

The “operator” of a storm water discharge associated with construction activity is the individual or party responsible for applying to the EPA for NPDES CGP coverage. The EPA defines an “operator” to be anyone who meets either of the following two criteria:

1. Has operational control over construction plans and specifications, including the ability to make modifications to those plans and specifications, or

2. Has day-to-day operational control of project activities.

With respect to the TA-21 DP Site Aggregate Area D&D Cleanup project, which is the subject of this SWPPP, the entity with day-to-day operational control over the construction plans and specifications including the ability to make modifications to those plans and specifications and with control of project activities and control over implementation of this SWPPP is

Newport New Nuclear BWXT – Los Alamos, LLC Los Alamos, NM 87545 Contact: Frazer Lockhart

Subcontractors with responsibility for implementation of D&D cleanup activities will vary based on specific task and scope. This SWPPP will be updated to reflect each subcontractor with work scope relevant to TA-21 D&D activities and/or responsibilities relevant to this SWPPP or the 2017 CGP for this work.

N3B is responsible for the implementation of this SWPPP. Subcontractors must be familiar with the conditions and requirements of the 2017 CGP as well as the specific provisions of this SWPPP. Project plans and specifications, including the installation and maintenance of BMPs, must be in accordance with all requirements of this SWPPP and the 2017 CGP. All BMPs and SWPPP-related requirements will remain in place until either (1) final stabilization is complete and a NOT has been submitted, or (2) or another operator’s NOI submission is submitted in accordance with Appendix I Section I.12.3 (Transfers) of the 2017 CGP addressing changes to operational control.

1.1 Storm Water Team

A storm water team composed of N3B and subcontractor employees will be assembled for each phase of work on this project. This team will be updated as necessary to reflect active work on the site. Individuals included on this team will be responsible for overseeing the development of and appropriate changes to this SWPPP as well as compliance with the requirements of the 2017 CGP. Each member of the storm water team will have ready access to either an electronic or paper copy of applicable portions of the 2017 CGP and this SWPPP. SWPPP preparer qualifications are included in Appendix J of the 2017 CGP.

Storm Water Team Participants

Organization Individual Title Contact Responsibilities

N3B Environmental Remediation (ER)

William M. O’Neill

Backup:

Grayson Vogel

Inspector 505-379-1413

505-369-9515

NOI/NOT, inspections, SWPPP modifications, identifying corrective actions

N3B R&SI Frazer Lockhart Program Manager 505-257-8049 Certifying SWPPP, implementing SWPPP and corrective actions, and signing inspections

N3B Larry Salazar Shift Operations Manager

505-309-1353 Implementing SWPPP and corrective actions

N3B Saul Alanis Subcontract Technical Representative

505-859-0726 Implementing SWPPP and corrective actions

Subcontractor – to be determined (TBD)

Subcontractor - TBD

Subcontractor - TBD

Subcontractor (2) - TBD

Subcontractor (2) - TBD

Subcontractor(2) – TBD

Subcontractor(2) – TBD

SWPPP Preparer:

Name Title Company Contact

William M. O’Neill Environmental Professional IV N3B 505-379-1413

Christian Maupin Regulatory & Stakeholder Interface N3B 505-695-4281

Jennifer von Rohr Regulatory & Stakeholder Interface N3B 505-695-4365

2.0 CONSTRUCTION ACTIVITIES AND CONTROLS

As discussed above, this SWPPP has been prepared to broadly define the measures which will be implemented to minimize the discharge of pollutants in storm water during the sitewide D&D/cleanup activities at TA-21. Currently this plan lacks specificity with regard to individual work tasks and site features, as these details have yet to be defined. This SWPPP will be updated as necessary to incorporate additional details as individual work tasks are defined and awarded to subcontractors for implementation. As currently written, this section provides an overview of the anticipated work scope and progression of construction/D&D activities; minimum requirements for the design, installation and maintenance of storm water controls; and pollution prevention practices for this project. The site map in Appendix C shows locations of controls, areas of earth disturbance, and other site features as required by the 2017 CGP. N3B will verify appropriate implementation of controls as needed and as required in this SWPPP and the 2017 CGP.

2.1 Site History, Nature of Construction Activities

Site Location and History

TA-21 is adjacent to the northern Laboratory boundary, on DP Mesa in the area east-southeast of the Los Alamos townsite. TA-21 encompasses approximately 312 acres extending from the mesa top to adjacent stream channels to the north (DP Canyon) and south (Los Alamos Canyon).

During World War II, the Laboratory was established for the research, development, and testing of the first deliverable nuclear weapon. In 1945, the operations for establishing the chemical and metallurgical properties of the nuclear material necessary to achieve and sustain the nuclear fission reaction were transferred to newly built facilities at TA-21. TA-21 included five material disposal areas (MDAs): A, B, T, U, and V. DP West operations began in September 1945, primarily to produce metal and alloys of plutonium from nitrate solution feedstock provided by other production facilities. This procedure involved several acid dissolution and chemical precipitation steps to separate the plutonium and other valuable actinides from the feedstock. A major research objective at DP West was the development of new purification techniques that would increase the efficiency of the separation processes (Christensen and Maraman 1969). Details of the purification techniques are discussed in the operable unit work plan for TA-21 (LANL 1991). Other operations performed at DP West included nuclear fuel reprocessing. In 1977, transfer of work to the new plutonium facility at TA-55 began and much of the DP West complex was vacated. DP East operations also began in September 1945. These facilities were used to process polonium and actinium and to produce initiators (a nuclear weapon component). In 1964, building 21-209 was built to house research into high-temperature and actinide chemistry. Building 21-155 housed the Tritium Systems Test Assembly (TSTA) for developing and demonstrating effective technology for handling and processing deuterium and tritium fuels used in fusion reactors.

As depicted in the site map provided in Appendix C, TA-21 is bisected by several east-to west-roadways, which provide access to a variety of out-of-service buildings, utilities, equipment, and debris. Site access is limited by one entrance located on DP Road near the western end of the mesa. Operations on the TA-21 site are limited to D&D and site cleanup functions.

General Description of Construction Activities

This SWPPP covers the sitewide D&D and cleanup activities at TA-21, including the following broad tasks:

Miscellaneous site cleanup, including debris removal, Installation and maintenance of storm water pollution prevention controls, Road maintenance and repair, including paving, grading, and asphalt patching, Installation and maintenance of work signage, Fence installation/repair, Decontamination of equipment, debris and materials, Equipment service/repair, demolition, Radiological and nonradiological waste removal, Waste loading and packaging for final disposition, Building and utility demolition and removal, and

Soil sampling and excavation.

Activities covered by this SWPPP will be developed and initiated in phases, with details pertaining to how each task is completed to be determined by each subcontractor responsible for implementation. In general, however, during each phase of demolition, excavation, and soil disturbance, area BMPs will be placed around the site of disturbance and will remain in place until each disturbed area is stabilized with 4 in. of compacted base course.

Site work is anticipated to begin in November 2018. The initial phases of work (Phase I and 2 Base and Optional Scope) are likely to include the following activities:

Phase 1

Loading of existing concrete piles at MDA-B into N3B-provided bins for off-site disposal, Loading of a concrete crusher into N3B-provided bins for off-site disposal, Loading of miscellaneous metal, equipment, debris, CONNEX, and high-efficiency particulate air (HEPA) units currently stockpiled on and near DP West slabs into N3B-provided bins for off-site disposal, Relocation of existing Super Sack equipment, MDA-B anchor blocks and unused Jersey barriers to an on-site laydown area (locations to be determined by consultation with subcontractors), Installation of perimeter fencing and completion of necessary repairs to existing perimeter fence and MDA-U fence, Application of a fixative to interior mobile enclosure surfaces, Decontamination of excavation equipment currently on-site, Removal of utility and light poles and associated wiring for off-site disposal, and

Minor road repairs.

Phase 2

D&D of building TA-21-257, Radiological Waste Treatment Facility, Removal of six underground tanks (tank numbers 110, 111, 112, 113, 288, and 289), and

Removal of approximately 5300 linear ft of underground radiological waste line.

Construction Support Activities

Implementation of the TA-21 D&D/cleanup work will require support in the form of controlling site access;

conducting entrance/exit vehicle inspections; escorting visitors; fueling operations; vehicle washing;

application of water for dust control; and staging of materials, equipment, and wastes. Details pertaining to the implementation of these activities, including site maps, will be developed as appropriate with each task.

Proposed Schedule

Ground-disturbing work associated with this project is anticipated to begin in November 2018. The following table will be kept up to date to reflect the current state of activities associated with the project. This table will be updated as work is initiated, completed, modified, or paused on-site.

Additional details may be provided in an attached project schedule.

Schedule Date Activity Actual Date

November__,2018 Phase I work scope

Site work is expected to be conducted year round during normal business days and hours, Monday through Friday between 7:00 a.m. and 5:00 p.m.

2.2 Design Requirements

Throughout the implementation of this project, a variety of BMPs including good housekeeping and scheduling, procedures, and physical structures and controls will collectively be used to control storm water runoff, promote sediment and erosion control, and minimize potential surface water pollutants from the TA-21 D&D/cleanup project.

In accordance with Section 401 of the Clean Water Act, the New Mexico Environment Department (NMED) has issued a State Certification that the 2017 CGP is consistent with state law and complies with the state Water Quality Standards. As specified in Section 9.4.1.c. of the 2017 CGP, in order to comply with the State Certification, this SWPPP must include site-specific interim and permanent BMPs and/or other controls that are designed to prevent an increase in sediment yield and flow velocity from preconstruction, predevelopment conditions. Any storm water run-on to the site must be factored into the design of these controls. If permanent drainage features are designed to divert water around the site, these features must also meet the State Certification requirements. These requirements apply to storm water discharges both during construction and after construction operations have been completed.

Work scope–specific and site-specific BMPs will be developed for each phase of work, based on the approach proposed by the subcontractor selected to perform that work. These BMPs will be specified by the subcontractor in accordance with 2017 CGP requirements and the design details and specifications applicable to this project provided in Appendix F. The following table summarizes physical BMPs that are commonly used on LANL projects.

BMP Application/Use Pros/Cons Comment

Silt fence, S-Fence Drainage area < 1 acre used for sediment retention, sheet flow control and wind erosion control

Decreases runoff velocity, low cost, easy installation/longevity issues, not suitable for concentrated flow

Effective as a perimeter control to intercept sheet flow and detain sediment

Temporary gravel bag check dams

Check dams in small swales Will reduce velocity of concentrated storm water and erosion/temporary

Easily installed

Gravel bags, wattles/coil logs

Drainage area < 1 acre used for sediment control and to reduce runoff velocity

Can be used on impervious surfaces, easily moved for access, easy to maintain or replace/typically last for 1–2 years

Can be effective as a perimeter control if overlapped and placed correctly

Turf reinforcement mats (TRMs), erosion-control blankets

Used for erosion control and soil stabilization on slopes and in swales

Can be used to promote permanent vegetation growth/not recommended for steep slopes

TRMs are non-degradable, permanent erosion control features, whereas erosion-control blankets are produced of organic, biodegradable material such as straw, coconut fiber, etc.

Detention ponds Excavated depressions or reinforced natural low areas used for sedimentation and to reduce runoff velocity

Can provide erosion control and sediment retention/require space and can be difficult and costly to install

Ponds are sized to slow storm water runoff to predevelopment values.

Topsoil preservation Measures will be taken to preserve existing topsoil in all instances.

Will promote reseeding Topsoil will be used over fill slopes with base course to promote seeding. TRM will be applied over topsoil.

Mulch Used for erosion and dust control

Easy application with low cost/temporary stabilization measure

When used in conjunction with seeding, mulch will speed establishment of vegetation, maintain moisture, and minimize erosion.

Riprap Used for erosion control and to reduce flow velocity

Effective for stabilizing construction slopes, fill areas, and concentrated flow/costly, difficult to remove accumulated sediment

Long-term, permanent control

2.3 Control Measure Considerations

Point-Source Excavation/Ground Disturbance Controls and Stabilization

Any point-source excavations or areas of ground disturbance, such as those for removal of power and light poles, will require the use of downgradient erosion controls such as gravel bags until the point can be properly stabilized. Point-source stabilization will require backfill with 4 in. of compacted base course before BMP removal.

Areas of concrete pad removal involving less than 25 ft2will use downgradient BMPs such as wire-backed silt fence and/or gravel bags to prevent migration of sediments towards the surrounding canyons. Such controls will be placed downgradient from the area of disturbance in a semi-circular pattern. All temporary controls will be removed once disturbed areas are stabilized with a minimum of 4 in. of compacted base course.

Areas of concrete removal in excess of 25 ft2 will require full-perimeter sediment controls such as wire-backed silt fence or S-Fence, as appropriate. In some cases, the use of ground-penetrating BMPs may not be appropriate. When this condition exists, N3B will discuss appropriate alternatives with the subcontractor.

All building demolition will require full-perimeter controls such as wire-backed silt fence or S-Fence. Gravel bags may be used at point-source runoff points and for drain/culvert protection.

The MDA-B concrete pile demolition and waste management will be completed within the existing berm pond area. The subcontractor for this work will be responsible for maintaining berm integrity and repairs should it be damaged during operations. Areas that may be impacted by equipment demolition will require downgradient sediment controls until operations are complete.

Following completion of site disturbance, final grades will match existing contours.

Soil and Debris Stockpile Controls

Soil and debris stockpile staging locations will be protected with appropriate perimeter sediment controls such as berms, gravel bags, and wattles.

Stockpiles, which contain sediment or soil, will be appropriately stabilized with the use of tarps or other methods (such as hydromulching) when inactive/unused for 14 or more days.

Waste Management Controls

Construction and domestic wastes will be contained within appropriately sized containers that are closed or covered (i.e., with lids or tarps) when not in use and at the end of each workday. Any waste material that overflows or escapes a container will be cleaned up immediately upon identification.

All materials delivered to or removed from the site will be will be transported in a manner which prevents discharge or spillage during transport.

Pollution Prevention Controls

Portable lavatories will be maintained and secured in accordance with manufacturer recommendations to prevent from tipping over in windy conditions or being knocked over;

lavatory waste will be treated off-site. Lavatories will be placed on level areas.

All vehicles and equipment will be inspected daily for leaks and, if found, drip pans will be used until fixed. Leaks will be fixed as soon as practicable and leaking vehicles and equipment will be removed from service and repaired. Any leaks discovered shall be recorded in Appendix D and reported to N3B’s R&SI group. Spills of all products will be cleaned up and managed per N3B’s Minor Spill Response Reporting Procedure (procedure number is pending) and state and federal regulations.

Fueling operations will be completed such that head space is maintained within fuel tanks to allow for fuel expansion. Secondary containment structures or other similarly effective means of preventing the discharge of spilled or leaked chemicals will be used. Fueling operations will be limited to defined areas equipped with appropriate spill control measures. All fueling operations will be identified on the site map provided in Appendix C.

Dust Control

Dust generation on site will be minimized with the application of potable water as necessary.

Water used to suppress dust generation will be applied at a rate to avoid discharge of water from the site.

2.4 Stabilization Measures

Stabilization of disturbed areas will be initiated immediately upon temporary or permanent cessation of construction activities within a defined project area, regardless of acreage. Application of stabilization measures will be completed within 7 days from initiation.

Stabilization will consist of the installation of base course, riprap, TRM, and/or revegetation/reseeding.

Existing base course areas will be returned to base course. Vegetated berms, shoulders, or any slopes or vehicle pull-off areas that are disturbed outside of the road, if applicable, will be stabilized via reseeding utilizing Flexterra Flexible Growth Medium (FGM) hydromulch in accordance with N3B Construction Specification 32 9219 – Seeding and Manufacturer Specifications. Approved TRM or riprap will be installed as necessary on steep slopes, in areas of concentrated flow, or as an alternative to hydromulching.

Once final stabilization is achieved, temporary sediment controls (i.e., gravel bags/S-Fence/wattles) will be removed. Final stabilization is defined as either of the following conditions:

1. Uniform, perennial vegetation (e.g., evenly distributed, without large bare areas) has been established, or for arid or semi-arid areas, 70 percent or more of the cover that is provided by vegetation native to local undisturbed areas has been established.

2. Permanent nonvegetative stabilization measures (e.g., riprap, gravel, gabions, and geotextiles) have been implemented to provide effective cover for exposed portions of the site.

N3B will make determinations of whether final stabilization has been achieved.

3.0 POLLUTION PREVENTION

3.1 Potential Pollutants

Potential pollutants that could have an effect on the quality of storm water discharges from this project include the following:

Construction equipment (i.e. graders, excavators, backhoes, trucks, compressors, generators, etc.), Sediment from exposed areas, excavations, and material or spoils stockpiles, Construction materials (metal, concrete, utility piping, pipe-cutting debris, base course, asphalt, soil and chemicals etc.), Vehicle fluids and fluids from construction equipment leaks (i.e., hydraulic fluid, motor oil, gasoline, diesel fuel, and lubricants), Construction trash, Concrete washouts, and

Portable lavatories

All equipment and materials used during the project will be stored upslope of the site’s structural controls.

Additional appropriate controls including secondary containment, drip pans, and berms and covers will be established based on-site conditions and the type of equipment/materials used.

This section will be updated as necessary to incorporate new potential pollutants brought on the site and to specify the controls, storage practices, and spill prevention and response measures used for those materials.

3.2 Non–Storm Water Discharges

Certain non–storm water discharges are allowed under the 2017 CGP provided they are not routed to disturbed areas of the site (unless used to control dust and irrigate vegetation in stabilized areas) or to a watercourse.

Anticipated non–storm water discharges associated with this project include the following:

Water used to control dust

The application of water to control dust will be implemented in a conservative manner to prevent runoff from the immediate area of application. If necessary, appropriate controls such as rock-check structures and gravel bags will be installed to ensure erosion is minimized and any sediment is contained.

Although the encounter of groundwater is not anticipated in conjunction with the planned work covered by this SWPPP, discharges of groundwater are prohibited unless managed according to NMED conditions and notifications, 20 New Mexico Administrative Code 6.2.1203 (20.6.2.1203). Contact N3B R&SI personnel before discharging any groundwater at TA-21.

3.3 Dewatering

If storm water accumulates in any trenches or excavations and dewatering is necessary, the discharge of pollutants will be minimized. Discharges of accumulated water are prohibited unless managed by appropriate controls:

Controls such as a sediment basin, sediment trap, dewatering tank, weir tank, or filtration system designed to remove sediment will be used.

To the extent feasible, vegetated, upland areas of the site will be used to infiltrate dewatering water. Discharges to watercourses are prohibited.

At points where dewatering water is discharged, velocity dissipation requirements per Part 2.2.11 of the 2017 CGP will be implemented to prevent erosion.

3.4 Receiving Waters

Receiving waters of TA-21 surface water runoff include Los Alamos (LA) Canyon to the south and DP Canyon to the north. Both receiving waters are listed by NMED in the 2018–2020 State of New Mexico Clean Water Act 303(d)/304(b) integrated list as impaired due to aluminum, copper, polychlorinated biphenyls, and gross alpha; LA Canyon is additionally listed as impaired due to cyanide, radium, and mercury. Neither receiving water is listed as Tier 2 Waters; nor have total maximum daily loads (TMDLs) been completed for either reach.

3.5 Buffers

In accordance with Section 2.2.1 of the 2017 CGP, as no water of the United States is located within 50 ft of the project boundary, maintenance of a natural buffer and/or equivalent erosion and sediment controls is not required.

3.6 Spill Prevention, Response, and Reporting

In accordance with Section 1.3.5 of the 2017 CGP, discharges of toxic or hazardous substances from a spill or other release are prohibited. To control unanticipated releases during site operations, spill prevention and control measures have been incorporated into all aspects of this project. Spill prevention measures include the following:

Vehicles and equipment will be inspected regularly for leaks. Any items found to be leaking will be removed from service and repaired. Drip pans or other means of controlling incidental drips will be used under staged equipment and vehicles as necessary.

Spill kits appropriate for the potential pollutants stored/used on the site will be staged on-site to respond to any spills or leaks.

Fueling operations, if conducted on-site, will be conducted in a manner that accounts for tank or container expansion.

Potential pollutants staged on-site, including chemicals, cleaners, stockpiled soils and debris, fuels, etc. will be stored within an area equipped with secondary containment.

Portable lavatories will be placed on level ground and secured in accordance with manufacturer recommendations.

The site operations manager is responsible for ensuring all site personnel are aware of the procedures for responding to spills and the location of all spill kits.

Discharges of minor spills or releases, which can be safely cleaned up by the person who discovered or caused the spill without special equipment beyond what is readily available in a spill kit, will be reported in accordance with N3B’s Minor Spill Response Reporting Procedure (procedure number is pending).

Los Alamos National Security, LLC (LANS) Emergency Operations Support Center (EOSC) is the organization responsible for emergency management at the Laboratory. All uncontrolled spills or releases must be reported to the TA-54 Operations Center by calling 505-257-8400. In the event of a non-minor spill, the TA-54 Operations Center will contact the EOSC, which will determine appropriate cleanup procedures and notify the affected individuals or organization. If fire or explosion hazards are present, or if the potential for such exists, the situation must be reported by dialing 911 or by activating a fire pull-box.

In accordance with N3B requirements, internal spill reporting will be completed in the event of any release. Spill reports will be completed by the N3B R&SI organization. Federal and state reporting is the responsibility of R&SI. A determination of reporting requirements will be made by R&SI and, if applicable, the EOPC, in accordance with Laboratory and United States Department of Energy (DOE) policies and federal and state regulatory reporting requirements. All spills will be recorded in the Spill Tracking Form provided in Appendix D of this SWPPP.

Based on anticipated fuel needs for this project, a Spill Prevention Control and Countermeasure Plan (SPCC) is not likely to be required for this site. In the event that fuel and oil storage needs exceed 1320 gal., an SPCC will be prepared and this SWPPP will be modified to reference that plan.

4. PROCEDURES AND REQUIREMENTS

4.1 Inspections

Site inspections will be conducted at least once every seven (7) calendar days, and within 24 hr following a storm event equal to or greater than 0.25 in. of precipitation.

The following Inspections will be routinely performed:

Inspection Type Example Inspection Frequency

Disturbed areas All disturbed areas that have not yet been stabilized

Every 7 days and within 24 hr of a qualifying storm event (0.25 in.) or the occurrence of runoff from snowmelt sufficient to cause a discharge

Storm water controls BMPs installed to comply with the 2017 CGP Every 7 days and within 24 hr of a qualifying storm event (0.25 in.) or the occurrence of runoff from snowmelt sufficient to cause a discharge

Material storage areas Waste, borrow, and equipment storage and maintenance areas, including potential pollutant storage areas and fuel storage areas

Every 7 days and within 24 hr of a qualifying storm event (0.25 in.) or the occurrence of runoff from snowmelt sufficient to cause a discharge

Storm water drainages All areas where storm water typically flows on or from the site, including drainage ways designed to divert, convey, and/or treat storm water

Every 7 days and within 24 hr of a qualifying storm event (0.25 in.) or the occurrence of runoff from snowmelt sufficient to cause a discharge

Site discharge points All points of discharge from the site Every 7 days and within 24 hr of a qualifying storm event (0.25 in.) or the occurrence of runoff from snowmelt sufficient to cause a discharge

Stabilized areas Areas where stabilization measures have been initiated

Every 7 days and within 24 hr of a qualifying storm event (0.25 in.) or the occurrence of runoff from snowmelt sufficient to cause a discharge

Precipitation Following qualifying precipitation events involving 0.25 in. or greater

Within 24 hr of a qualifying precipitation event

Notes:

Inspections will not be conducted outside of normal working hours or during unsafe conditions.

Precipitation rates for determining qualifying events will be collected from the LANL rain gage RG038; the TA-53 rain gage will be used as a backup data source.

Frequency of nonprecipitation inspections may be reduced in accordance with Section 4.4 of the 2017 CGP if the site has been stabilized or during seasonal arid periods.

Inspections will be documented on the inspection form provided in Appendix I of this SWPPP. Completed inspection forms will be retained in the SWPPP under Appendix H. Each inspection report shall be certified in accordance with Appendix I, Part I.11 of the 2017 CGP. Inspections will be conducted until final stabilization of the site is achieved. Documentation of inspector training will be maintained in Appendix J of this SWPPP.

Following submittal of a NOI to EPA Region 6, the site will be posted with information to indicate 2017 CGP permit coverage. Posted information will include the NPDES tracking number assigned to the NOI, site contacts, and other required information. Copies of the SWPPP will be retained on-site with easy accessibility.

4.2 Maintenance/Corrective Actions

Storm water controls will remain in effective, operational condition throughout permit coverage. Controls will be inspected as required, and corrective actions will be taken as necessary. As issues requiring corrective actions are identified, they will be documented on inspection forms and corrective action forms.

Repairs or modifications to BMPs will be initiated according to the following schedule:

If the problem does not require significant repair or replacement, or if it can be corrected through routine maintenance, corrections will be initiated immediately and completed by the close of the next work day.

Where there is evidence of accumulated sediment adjacent to drop inlet protection measures, the deposited sediment will be removed by the end of the same work day.

When installation of a new erosion or sediment control feature or significant repair is needed, installation or repair will be completed within 7 calendar days from the time of the identification of needed corrective action when feasible. If this schedule is not feasible, the reason for the delay and the anticipated schedule for completion will be documented. Where these actions result in changes to any of the storm water controls or procedures documented in this SWPPP, the SWPPP will be modified accordingly within 7 calendar days of completing the work.

4.3 Corrective Action Reporting

In compliance with Section 5.4 of the 2017 CGP, a corrective action report will be completed for each corrective action. A blank corrective action report form is attached to this SWPPP in Appendix I.

Completed corrective action reports will be maintained in Appendix H. Corrective actions will be taken and documented for the following conditions:

A storm water control needs repair or replacement (beyond routine maintenance required under Part 2.1.4 of the 2017 CGP), A storm water control necessary to comply with the requirements of the 2017 CGP was never installed or was installed incorrectly, Site discharges are causing an exceedance of applicable water quality standards, A prohibited discharge has occurred, and/or

Required routine maintenance has not been performed.

Upon identification of any condition requiring corrective action, appropriate immediate action will be taken to address the situation, including cleaning up any contaminated surfaces. Conditions requiring significant repair or replacement of a BMP will be addressed in accordance with the maintenance schedule referenced above. Within 24 hr of identification, a corrective action report will be completed which documents the specific condition and the date and time it was identified. Within 24 hr of completing the corrective action, the specific actions taken will be documented and the SWPPP will be updated as necessary. All corrective action reports will be signed and certified in accordance with Appendix I, Part I.11 of the 2017 CGP and maintained for easy access.

4.4 SWPPP Modifications

This SWPP, including site maps, will be modified within 7 calendar days under the following conditions:

New subcontractors become active in construction activities on the site or changes, including those for required corrective actions, are made to the construction plans, storm water control measures, pollution prevention measures, or other activities at the site that are not accurately reflected in the SWPPP.

Operational control of any area of the site is transferred since 2017 CGP coverage was initiated.

Inspections or investigations by site staff, or by state or federal officials determine that SWPPP modifications are necessary for compliance with the 2017 CGP.

EPA determines it is necessary to impose additional requirements on site discharges. In this case, a copy of any correspondence describing imposed requirements and a description of the storm water control measures used to meet the imposed requirements will be included in the

SWPPP.

Revisions to applicable federal or state requirements affect the storm water control measures implemented at the site.

A record of SWPPP modifications including a summary of the changes, authorization, dates, and notifications to other operators will be maintained using the SWPPP Modification Records Tracking Table provided in Appendix B.

4.5 Training

The following personnel at a minimum must receive training to understand the requirements of the 2017 CGP and their specific responsibilities with respect to the requirements:

Personnel who are responsible for the design, installation, maintenance, and/or repair of storm water controls (including pollution prevention measures)

Personnel responsible for the application and storage of treatment chemicals (if applicable)

Personnel who are responsible for conducting inspections as required in Part 4 of the 2017 CGP

Personnel who are responsible for taking corrective actions as required in Part 5 of the 2017

CGP.

Project personnel must be trained to understand the following if required in the scope of their job duties:

The location of all storm water controls on the site required by the 2017 CGP, and how they are to be maintained

The proper procedures to follow with respect to the 2017 CGP’s pollution prevention requirements

When and how to conduct inspections, record applicable findings, and take corrective actions.

Records of training will be maintained in Appendix G.

4.6 Record Keeping

A copy of the SWPPP will be maintained on-site for the use of all operators and those identified in the SWPPP as having on-site responsibilities, EPA, regulatory compliance representatives, and state and federal agencies until the project is closed under the conditions of the 2017 CGP. The SWPPP will contain required signatures, a copy of 2017 CGP language, all reports required by 2017 CGP coverage, a copy of the complete NOI (once posted on EPA’s website), and any other applicable documentation.

Items that will be maintained and attached to the SWPPP include the following:

Sequence of Events for Soil Disturbance (Appendix A)

SWPPP Modification Records Tracking Table (Appendix B)

Site Maps (Appendix C)

Spill Tracking Form (Appendix D)

Permit Regulations, NOI, Delegation of Authority Letter, EPA Acknowledgement (Appendix E)

Los Alamos National Laboratory Storm Water BMP Manual (Appendix F)

SWPPP Training Documentation (Appendix G)

SWPPP Inspection Reports and Corrective Action Reports (Appendix H)

Blank Inspection/Corrective Action Forms (Appendix I)

Inspector Qualifications (Appendix J).

Copies of the SWPPP, inspection records, spill reports, all reports required by NPDES permit coverage, and data used to complete the NOI will be retained by the permittees for a period of at least three

(3) years from the date of final stabilization. N3B will also retain records in accordance with N3B records management policies.

4.7 Compliance with Other Federal Requirements

This section contains summary information related to other federal requirements which may be applicable to this project.

TMDLs

Several tributaries to the Rio Grande in the vicinity of the project, including receiving waters, LA Canyon, and DP Canyon are listed on the State of New Mexico Clean Water Act 303(d) list for assessed river/stream reaches requiring TMDLs. TMDLs pertaining to sediment have yet to be established for these waters.

Historical Properties and Cultural Resources

Section 106 of the National Historic Preservation Act (36 Code of Federal Regulations [CFR] Part 800) requires federal agencies to take into account the effects of their undertaking on cultural properties. There is one archaeological site (LA 4710), an 11-room pueblo structure, within the project site at TA-21. The site was excavated from November 1963 to March 1964 and was determined to be not eligible for inclusion in the National Register of Historic Places by the New Mexico State Historic Preservation Officer. If cultural materials (artifacts, features, architecture, or inadvertent discoveries) are encountered from project ground-disturbing activities, activities will be paused and the subcontractor technical representative contacted.

Cultural resources are flagged off for avoidance by project activities, and N3B cultural resources staff will be contacted in the event of inadvertent discoveries.

Clean Water Act 404/401 Permit Requirements

NMED has issued State Certification for the NPDES General Permit for Storm Water Discharges from Construction Activities (CGP) NMR100000. No additional requirements apply to comply with Section 401 of the Clean Water Act.

No work is anticipated under this SWPPP that would require the discharge of dredge or fill materials to waters of the United States. Consequently, there is no Clean Water Act Section 404 permit requirement applicable to this project.

Energy Independence and Security Act

Section 438 of the Energy Independence and Security Act requires newly developed or redeveloped projects at federal facilities with a footprint greater than 5000 ft2 to maintain or restore, to the maximum extent technically feasible, the predevelopment hydrology of the area which includes storm water rate, duration, and volume. This is to be accomplished through low-impact development methods designed to

Infiltrate and recharge storm water into the ground

Promote evapotranspiration through vegetation

Where possible, these practices will be incorporated the project design.

Threatened and Endangered Species

All of TA-21 is within the Los Alamos Canyon Mexican Spotted Owl area of environmental interest.

However, since the area is currently developed, contains little wildlife habitat, and is not occupied by threatened and endangered species, there will be no habitat loss as a result of project activities. If the site becomes occupied in future breeding seasons, the project may affect, but is not likely to adversely affect, the Mexican Spotted Owl. This scenario would require all reasonable and prudent alternatives described in Appendix B of the “Biological Assessment of Federally Listed Species at LANL."

Surveys for threatened and endangered species are conducted annually at LANL.

National Environmental Protection Act Review

A National Environmental Protection Act determination is required of all projects. TA-21 closure impacts were analyzed in the 2008 “Final Site-Wide Environmental Impact Statement for Continued Operation of Los Alamos National Laboratory, Los Alamos, New Mexico” (SWEIS) (DOE 2008). DOE’s decision to implement additional elements of the Expanded Operations Alternative considered under the SWEIS, including the remediation and closure of TA-21 DP Site with an emphasis on decommissioning, decontamination, and demolition of the TA-21 buildings and environmental remediation of MDAs, is summarized in the National Nuclear Security Administration’s “Record of Decision: Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory, Los Alamos, New Mexico” (DOE 2009).

All land conveyance activities are also covered; upon final determination portions of TA-21 will be conveyed to Los Alamos County during the period of 2018 through 2022.

5.0 REFERENCES

Christensen, E.L., and W.J. Maraman, April 1969. “Plutonium Processing at the Los Alamos Scientific

Laboratory,” Los Alamos Scientific Laboratory report LA-3542, Los Alamos, New Mexico.

DOE 2008. “Final Site-Wide Environmental Impact Statement for Continued Operation of Los Alamos

National Laboratory, Los Alamos, New Mexico,” DOE EIS-0380 (May 2008).

DOE 2009. “Record of Decision: Site-Wide Environmental Impact Statement for the Continued Operation of Los Alamos National Laboratory, Los Alamos, New Mexico” (July 2009).

LANL (Los Alamos National Laboratory), May 1991. “TA-21 Operable Unit RFI Work Plan for

Environmental Restoration,” Vol. II (Chapters 14 to 16), Los Alamos National Laboratory document LA-UR-91-962, Los Alamos, New Mexico.

Appendix A

Sequence of Events for Soil Disturbance Tracking Table

A‐1

Sequence of Events for Soil Disturbance

Activity Description Actual Dates of

Disturbance Activity Status

A‐2

Appendix B

SWPPP Modification Records-Tracking Table

B‐1

SWPPP Modification Records-Tracking Table

No.

Description of the Amendment (show date condition identified)

Date of Amendment

Amendment Prepared and Authorized by

(Name[s] and Title)

Other Operators Notified:

(name & date notified)

B‐2

Appendix C

Site Map

C‐1

C‐2

Appendix D

Spill Tracking Form

D‐1

Spill Tracking Form

Date Spill

Location Material(s)

Spilled Quantity Spilled

Corrective Action Taken Plans to Prevent Recurrence

Appendix E

Permit Regulations, NOI, Delegation of Authority Letter, EPA Acknowledgement

(Place Documents Here Once NOI Complete) http://www.epa.gov/npdes/pubs/cgp2012_finalpermit.pdf

Appendix F

Los Alamos National Laboratory Storm Water BMP Manual

Los Alamos National Laboratory

LAUR-

Revision 0: March 2011

Storm Water BMP Manual

Prepared by:

ENV-RCRA

LANL Storm Water BMP Manual

Blank pages in document are for duplex printing purposes.

TABLE OF CONTENTS

i

Table of Contents…………………………………………………………………………………………………..i

Acronyms……………………………………………………………………………………………………………ii

1. General Guidance

1.1. Introduction (how to use this guidance document)…………………………………….1

1.2. Best Management Practice Use Matrix……………………………………..…………..3

1.3. LANL Considerations…………………………………………………………………

1.4. References……………………………………………………………………………

2. Good Housekeeping and Scheduling Practices

2.1. Good Housekeeping…………………………………………………………………...….9

2.2. Scheduling Practices………………………………………………………………….…13

3. Sediment Control

3.1. Silt Fence and S-Fence……………………………………………………………….…17

3.2. Fiber Rolls ……………………………………………………………………………

3.3. Triangular Silt Dike……………………………………………………………………….27

3.4. Construction Entrance/Exit …………………………………………………………

3.5. Brush Barrier……………………………………………………………………………...39

3.6. Storm Drain Inlet Protection…………………………………………………………….43

4. Runon/Runoff Control

4.1. Berms and Channels…………………………………………………..……………

4.2. Check Dams………………………………………………………………………………57

4.3. Waterbars and Runouts………………………………………………………………

4.4. Terracing…………………………………………………………………………………..65

4.5. Surface Roughening……………………………………………………………………..71

4.6. Sediment Traps…....…....…....…....…....…....…....…....…....…....…....…....…

4.7. Storm Water Detention Basins………………………..……..…………………………81

5. Erosion Controls

5.1. Revegetation……………………………………………………………………………...87

5.2. Temporary Stabilization………………………………………………………………

5.3. Rolled Erosion Control Products (RECP)…………………………………………

5.4. Dust Suppression………………………………………………………………………...99

5.5. Gabions………………………………………………………………………………….101

5.6. Riprap……………………………………………………………………………………105

5.7. Permanent Capping……………………………………………………………………109

ACRONYMS

ii

AOC Area of Concern BFM Bonded Fiber Matrix BMP Best Management Practice CGRP Cerro Grande Rehabilitation Project DOE Department of Energy ECB Erosion Control Blanket EM&R Emergency Management & Response ENV-RCRA LANL Water Quality Group EPA Environmental Protection Agency FGM Flexterra or other Flexible Growth Medium HDPE High Density Polyethylene IECA International Erosion Control Association LANL Los Alamos National Laboratory MgCl Magnesium…