Exhibit_D_Appendix_D-6_WCSF.pdf

Characterization and Management of Environmental Programs Waste

Document No: ER-DIR-SOP-10021 Revision: 2

Effective date 6/26/18

Waste Characterization Strategy Form Project Title: TA-21 D&D and Cleanup Campaign, and MDA A & T Remedy

Campaign

Solid Waste Management Unit or 41 Various TA-21 SWMUs & AOCs Area of Concern #

Activity Type: Demolition and Remediation

Project Manager: Duane Parsons

Waste Management Coordinator: Jeff Lee

Waste Generator: Ron Desotel

Completed by: Jeff Lee

Date: 8/15/2018

The SUBCONTRACTOR and or SELF-PERFORMERS shall implement the requirements under this CONTRACTOR-prepared Waste Characterization Strategy Form (WCSF).

Description of Activity:

The objective of this activity is the site demolition, remediation, and restoration of Technical Area 21

(TA-21).

Site preparation - This activity includes establishment of site access control, vegetation control, immediately before performing survey, site characterization, or remediation activities.

Demolition and removal of man-made debris - This activity includes the demolition and removal of man made debris.

Non-intrusive field surveys - This activity includes the use of various instruments to perform non intrusive geodetic site surveys. Geodetic surveys will involve the use of Global Positioning System (GPS) or Total Station instruments to determine coordinates of sampling locations and structures as necessary.

Removal of contaminated environmental media - This activity includes the excavation and disposal of contaminated environmental media.

All wastes will be managed in accordance with Newport News Nuclear BWXT - Los Alamos, LLC (N3B) procedures P409 "LANL Waste Management" (N3B 2018) and 10021 "Characterization and Management of Environmental Program Waste" (N3B 2018), and approved integrated work documents.

This WCSF will be implemented before any waste generating activity is undertaken. An amendment to this WCSF will be prepared and submitted for review and approval if any of the waste streams change in description or characterization approach or unanticipated waste streams are generated. The generation of no path forward waste must be approved by the U.S. Department of Energy (DOE) before waste generation.

The activities described in this WCSF will be conducted in a manner that minimizes the generation of waste. Waste streams will be recycled/reused, as appropriate.

Relevant Site History and Description

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TA-21 is located on DP Mesa on the northern boundary of Los Alamos National Laboratory (LANL or the Laboratory) and is immediately east-southeast of the Los Alamos town site. TA-21 extends from the mesa top to the stream channels in two adjacent canyons, DP Canyon to the north and Los Alamos Canyon to the south. 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 Ma ram an 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 for developing and demonstrating effective technology for handling and processing deuterium and tritium fuels used in fusion reactors.

CHARACTERIZATION STRATEGY

Subcontractors shall furnish qualified personnel, equipment, materials, and facilities to remove, package, label, and transport to staging areas, most waste generated under this activity. The Subcontractors will coordinate and work with N3B-assigned personnel to ensure that all N3B requirements, DOE orders, and State and Federal regulations are met.

The characterization strategy for waste generated for the identified activities in this WCSF will be based upon direct sampling of the waste, historical site sampling, and approved acceptable knowledge (AK) data/documentation. AK includes a review of existing historical documentation associated with the site, and source term/process identification to identify whether listed hazardous waste may be present (i.e., due diligence review). Waste storage area postings, regulated storage duration, and inspection requirements will be based on the waste type and its regulatory classification.

The selection of waste containers is based on U.S. Department of Transportation requirements, waste types, estimated volumes of waste to be generated, transportation, and the disposal facility waste acceptance criteria. The Contractor (N3B) has determined that a variety of approved Department of Transportation waste containers will be used, and will be provided by the Contractor, based on the waste material being packaged for disposal. For the use of IP-1 type bags, the Contractor will be responsible for providing pallets, a certified scale, a covering (for filled bags), a bag loading frame, and a bag lifting device attachment. The Contractor will be responsible for establishing staging/storage areas, required staging/storage area inspections, loading for transportation for disposal, and final disposal of all wastes.

Note: The Subcontractor is responsible for the removal of the filled bags from the loading frame and on-site movement of filled bags to the staging area.

Immediately following containerization, each waste container will be individually labeled with a unique container identification number and with information regarding waste classification, contents, WCSF: TA-21 D&D and Cleanup Campaign, and MDA A & T Remedy Campaign

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Effective date 6/26/18 date generated (out of service date for polychlorinated biphenyls [PCBs]), and responsible generator (individual responsible for the management of waste container). Waste containers shall be weighed and placed in a Contractor-designated staging/storage area. All soft sided (SS) bags and drums must be stored on pallets (to be provided by the Contractor) and covered to prevent deterioration. The Subcontractor shall provide a daily waste inventory to the Contractor.

Required sampling and documentation will be performed in accordance with the U.S. Environmental Protection Agency (EPA) Resource Conservation and Recovery Act (RCRA) "RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation, and Assessment" (EPA 2002), and EPA publication "Test Methods for Evaluating Solid Waste: Physical Chemical Methods SW-846" (EPA 2014;

https://www.epa.gov/hw-sw846).

Sampling personnel must record sampling information in accordance with EPA's RCRA Waste Sampling Draft Technical Guidance Section 7.2.3 Documentation of Field Activities. Sampling personnel must also record field conditions, problems encountered, local sources of contamination (e.g., operating generators or vehicles), the personnel involved, equipment and supplies used, waste generated, and field observations.

To facilitate the staging and segregation of the remediation waste, N3B will submit area of contamination designation requests for the consolidated units, SWMUs and AOCs outside of the NES boundary to NMED for approval. The request will specify the boundaries of the proposed areas of contamination and will describe the activities to be conducted within the boundaries.

Expected Waste Streams:

Waste #1 - Contact Investigation Derived Waste (IDW): This waste stream is comprised of solid waste generated during investigation and removal activities that has come into contact with contaminated environmental media and equipment. This includes, but is not limited·to, personal protective equipment (e.g., gloves), plastic sheeting (e.g., tarps, liners), plastic and glass sample bottles, disposable sampling supplies (e.g., filters, tubing, plastic bags), and dry decontamination wastes (e.g., paper items). It is estimated that less than 100 yd3 of contact IDW will be generated.

Anticipated Regulatory Status: Industrial, Hazardous, Radioactive Low-Level, Toxic Substances Control Act (TSCA)

Characterization Approach: Contact IDW will be managed based upon the regulatory classification of the waste in which it came into contact with.

Storage and Disposal Method: Contact IDW may be containerized in Contractor-provided drums or placed into the same Contractor-provided containers as the media with which they are contaminated, or may be stored separately from the environmental media until the waste determination is made. At that time, the contact waste may be combined with the media for disposal if appropriate (the waste profile form will document the decision to combine the waste streams). These wastes will be stored in secure, designated waste staging areas. Wastes will be treated and/or disposed in authorized facilities.

Waste #2 - Municipal Solid Waste (MSW): This waste stream primarily consists of non-contact trash including but not limited to paper, cardboard, wood, plastic, food and beverage containers, empty solution containers, and other non-contact trash. This waste stream may also include vegetation from sites with no radioactive contamination. It is estimated that less than 2000 yd3 of MSW will be generated.

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Anticipated Regulatory Status: MSW

Document No: ER-DIR-SOP-10021 Revision: 2

Effective date 6/26/18

Characterization Approach: MSW will be characterized based on AK of the waste materials and the methods of generation or safety data sheets.

Management and Disposal Method: MSW will be segregated from all other waste streams. It is anticipated that the waste will be stored in plastic trash bags or other appropriate containers and transported to the Los Alamos County Eco Station or other authorized solid waste facility.

Waste# 3 - Environmental Media: This waste stream will consist of soil and tuff removed from within or adjacent to (e.g., from benching to stabilize a trench) or below excavated material. This waste stream will also include vegetation from site maintenance activities. It is expected that vegetation, including trees and brush, will remain on site for reuse. If vegetation is present with soil, the vegetation must be reported in waste stream for off-site profile. Manmade debris may be encountered during soil removal and if possible, will be segregated from the soil and managed appropriately based upon AK of the soil.

The small amounts of man-made debris that may be present in the excavated material waste stream must be reported for the off-site profile. The total amount of media generated is estimated to be 800 yd3.

Based on past operations at TA-21-257 and DP West, including spill histories and past decontamination and decommissioning (D&D) projects, there is a potential to encounter transuranic (TRU) and mixed transuranic (MTRU) waste during the D&D of TA-21-257, DP West slabs, and/or removing industrial waste lines. If TRU/MTRU waste is detected, an amendment to this WCSF will be completed.

Anticipated Regulatory Status: Radioactive Low-Level, Fill

Characterization Approach: Characterization will be based upon historical site sampling and approved AK data/documentation. Historical site sampling detected radionuclides above background values;

therefore, if this media does not meet residential risk based screening levels, this media will be classified as waste, and disposed of as radiological contaminated. Historical site samples were, at a minimum, analyzed for volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), total metals, PCBs, total cyanide, nitrates, perchlorate, toxicity characteristic metals, gamma spectroscopy, isotopic uranium, isotopic plutonium, americium-241, tritium, and strontium-90.

Soil and tuff will be stored either in roll-off bins, or other suitable containers, or on the ground surface with appropriate best management practices. The media will remain within the area of contamination awaiting analytical results. Samples will be collected as the soil and tuff are excavated and composited.

If appropriate, one composite sample will be collected for every 100 CV depending on the homogeneity of media.

If process knowledge, odors, or staining indicates the media may be contaminated with petroleum products, the materials will be analyzed for total petroleum hydrocarbons (TPH) diesel range organics/gasoline range organics (DRO/GRO). Other constituents may be analyzed as necessary to meet the waste acceptance criteria for a receiving facility.

Storage and Disposal Method: If the soil and tuff are determined to be suitable for reuse (i.e., meeting the criteria of the NMED approved NOi decision tree for land application), the evacuated environmental media will be segregated from any man-made debris, and the soil will be used to backfill the excavations. If the media cannot be land applied, it will be disposed of in an authorized

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Effective date 6/26/18 facility. the excavated media will be containerized and stored in a secure, designated waste staging area. The containers will be appropriate for the quantity of wastes generated. Media will be managed in a registered radioactive storage or staging area until it can be shipped for disposal. Excavated environmental media will be treated and/or disposed of in an authorized disposal facility appropriate for the waste regulatory classification.

Waste# 4 - Construction and Demolition Debris (C&D): This waste stream is comprised of concrete, metal, drywall, wood, and building debris from the demolition of buildings. The waste stream may also contain trace soil from concrete foundations. The anticipated volume of C&D that will be generated is estimated to be 6500 yd3•

Based on past operations at TA-21-257 and DP West, including spill histories and past D&D projects, there is a potential to encounter TRU and MTRU waste during the D&D of TA-21-257, DP West slabs, and/or removing industrial waste lines. lfTRU/MTRU waste is detected, an amendment to this WCSF will be completed.

Anticipated Regulatory Status: Radioactive Low-Level, TRU, MTRU, TSCA

Characterization Approach: Characterization of the debris will be based on one or any combination of the following methods: AK of the waste materials, direct sampling, the methods of generation, the extent of contamination, and analysis of the material contacted (e.g., excavated soil).

Storage and Disposal Method: The excavated debris will be containerized at the point of generation and stored in secure, designated waste staging areas. Excavated debris will be treated and/or disposed of in authorized facilities appropriate for the waste regulatory classification.

Waste# 5 - Petroleum Contaminated Soils (PCS) (potential): This waste stream is comprised of soils contaminated because of the accidental release of commercial or chemical products such as hydraulic fluid, motor oil, unleaded gasoline, or diesel fuel (e.g., from the rupture of hydraulic or fuel hoses, or spills during maintenance, etc.). The waste stream may also include absorbent padding, paper towels, spill pillows or other approved absorbent material used to contain the released material and added to the containerized PCS waste for storage and disposal. The amount of potential PCS is expected to be less than 1 yd3•

Anticipated Regulatory Status: New Mexico Special Waste (NMSW), Hazardous, Radioactive Low-Level, TSCA, Industrial

Characterization Approach: PCS will be characterized based upon either AK or direct waste sampling. If the material spilled is known and the spill occurs on known material (historical site sample data, clean base course), AK can be used to characterize the waste. If the spill is of an unknown material/origin or occurs in an area with no historical sampling data, characterization will be based upon the analytical results from direct sampling either performed in place (same day as spill/containerization) or from the containerized waste within 10 days of generation. For spills of an unknown material/origin, samples will be collected in the following way:

• For spills containerized, or shallow spills being sampled in place, the samples will be collected in accordance with EPA "RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation, and Assessment" (EPA 2002).

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The analysis of the samples will be dependent on where the spill occurred as follows:

• If the spill occurred on soil (non-hazardous, non-radioactive), samples will be analyzed for VOCs, TPH DRO/GRO, and toxicity characteristic leaching procedure (TCLP) metals, at a minimum. These analytical suites are required to determine whether the waste is NMSW. Other constituents may be analyzed as necessary to meet the disposal facility waste acceptance criteria.

• If the spill occurs on soils with no available/reliable AK documentation, soil will be sampled for TCLP voes, TCLP SVOCs, pesticides, herbicides, TCLP metals, PCBs, cyanide, nitrates, perchlorate, gamma spectroscopy, isotopic uranium, isotopic plutonium, americium-241, tritium, strontium- 90, and TPH DRO/GRO.

All samples will be submitted with no longer than a 21-day turnaround time for analysis so that a waste determination can be made within 30 day of generation. The "initial" date or date of generation for NMSW is the date the container is completely full or the date in which no additional NMSW will be added to the container. The "final" date (or the date starting the 90-day NMSW clock) is the date that the validated analytical data is received.

Sampling personnel must record sampling information in accordance with EPA "RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation, and Assessment" (EPA 2002).

Storage and Disposal Method: PCS will be containerized at the point of generation on the same day that the spill occurred. If AK for the site indicates that the soil will not be contaminated with radioactive or hazardous materials, the PCS will be managed as NMSW and the NMSW start date will be the date the container is completely full or the date in which no additional NMSW will be added to the container.

If AK for the site indicates that the soil could be contaminated with hazardous materials, the PCS will be stored in a clearly marked and constructed waste accumulation area appropriate to the anticipated waste type. Waste accumulation area postings, regulated storage duration, and inspection requirements will be based upon the waste classification. Spill cleanup materials will be accumulated and managed in accordance with N3B procedure P409 "LANL Waste Management" (N3B 2018).

Waste# 6 - Decontamination Fluids (potential): This waste stream consists of liquid wastes generated from the decontamination of excavation, sampling, and drilling equipment. This waste stream will be generated only if dry decontamination methods are not effective. It is estimated that 200 gal. of decontamination fluids will be generated.

Anticipated Regulatory Status: Radioactive Low-Level, TSCA

Characterization Approach: The decontamination fluids will be characterized by direct sampling of the containerized fluids within 10 days after generation. Representative waste characterization samples will be collected with no longer than a 21-day analytical data turnaround to ensure that waste can be dispositioned within 90 days, if necessary. Analyses of the media associated with the decontamination fluids may also be used to augment the characterization.

Storage and Disposal Method: Decontamination fluids will be containerized at the point of generation and initially managed as non-hazardous/non-radiological pending review of analytical results to determine final waste characterization.

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If the fluids are characterized as PCB-contaminated at greater than 50 ppm, they will be managed in a registered PCB storage area until they can be shipped for disposal. Decontamination fluids will be treated and/or disposed of in authorized facilities appropriate for the waste regulatory classification.

Waste# 7 - Universal Waste: This waste stream is comprised of non-radiological contaminated mercury-containing switches, equipment, and thermometers; lead acid and other batteries; aerosol cans; light tubes; and incandescent light bulbs. The Subcontractor shall remove all universal waste (light tubes, incandescent light bulbs, mercury thermostats, emergency lights, batteries, aerosol cans, etc.) before any structural demolition work for appropriate packaging and disposition by the Contractor. This waste will be managed as universal waste. Universal waste that cannot be "free released" will be re-classified and managed under the appropriate waste stream based on the appropriate characterization. It is estimated that 10 yd3 of universal waste will be generated.

Note: A used mercury-containing lamp becomes waste on the date the generator/handler permanently removes it from its fixture. An unused mercury-containing lamp becomes waste on the date the handler decides to discard it.

Anticipated Regulatory Status: Universal

Characterization Approach: AK, SOS Safety Data Sheet

Storage and Disposal Method: All universal waste will be managed by the Contractor in accordance with N3B procedure P409 "LANL Waste Management" (N3B 2018).

Waste# 8 - Asbestos-Containing Material (ACM): This waste stream is comprised of non-hazardous contaminated ACM. It is estimated that 40 yd3 of ACM waste may be generated.

Anticipated Regulatory Status: NMSW, Regulated Asbestos Low-Level Waste (RALLW)

Characterization Approach: Prior to demolition, the Subcontractor will determine the presence, location, and quantity of ACM. AK and/or direct sampling will be used.

Storage and Disposal Method: The Subcontractor shall remove all ACM for appropriate packaging and disposition before the initiation of any structural demolition work. Asbestos can only be removed by certified asbestos workers

Non-regulated asbestos waste, as defined in New Mexico Solid Waste Rules 20 New Mexico Administrative Code 9.8.12 Asbestos Waste, shall be handled as NMSW. NMSW must be stored in a registered area designated by the Contractor.

RALLW is defined as any low-level waste-containing friable asbestos material; Category I non-friable ACM that has become friable; Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or Category II non-friable ACM that has a high probability of becoming or has become crumbled. Packages containing RALLW shall meet the applicable shipping requirements for the radioactive contents of the package.

Waste# 9 - Used Oil: The Subcontractor will drain all oil and fill with an approved appropriate absorbent to prevent fluid releases from pumps, compressors, motors, etc. to be disposed or recycled as scrap metal. It is estimated that 300 gal. of drained oil may be generated.

Anticipated Regulatory Status: Recycle

Characterization Approach: Drained oil will be sampled for PCBs, voes, and SVOCs. For salvageable equipment with reservoirs, oil will not be drained, but will be sampled for PCBs, VOCs, and SVOCs.

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Storage and Disposal Method: Used oil must be stored in Contractor-provided containers that are in good condition and closed. If more than 10 gal. are stored in a single location, a log sheet must be maintained to include the origin of the oil and the waste generator. The oil must be stored in a Contractor-designated registered Used Oil Area. Individual containers must have a Used Oil label.

Note: Any material generated from the maintenance of Subcontractor-provided equipment (e.g., oil, coolant, hydraulic fluids) is the responsibility of the Subcontractor and shall not be stored at TA-21.

Waste# 10 - Recyclable: Recyclable material includes non-radiological contaminated scrap metal, concrete, wood telephone poles, piping and solder joints, non-PCB light ballasts, non-PCB and non ACM wiring, salvageable equipment, etc. These materials, approved by Contractor, will be reused onsite or sent off-site for recycling or salvage. Scrap metal for recycling shall not contain any PCBs, liquids or hazardous waste. Any material sent off-site for recycle must have prior approval from N3B CH-TRU Management.

Waste# 11 - Un-containerized Liquid: This waste stream will consist of un-containerized liquid waste which includes, but is not limited to, the liquid which is known to be present in the sump pit.

Other un-containerized liquid wastes may be discovered/generated as the project progresses. Un containerized liquid wastes will be transferred to appropriate containers at the point of generation.

Approximately 600 gallons of Un-containerized liquid waste are expected to be generated.

Anticipated Regulatory Status: Industrial, Sanitary, Hazardous, LLW, MLLW, TSCA

Characterization Approach: Un-containerized liquid waste will be transferred to appropriate containers, such as 55-gallon drums. The waste will then be sampled for characterization.

Un-containerized liquid waste will be characterized by direct sampling. Samples will be collected from the storage container in accordance with EPA (Environmental Protection Agency) 2002. "RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation, and Assessment," document number EPA530-D-02-002 (August 2002). Liquids may be solidified for disposal off-site. The Safety Data Sheet (SDS) for any absorbent used for solidification will be used as AK for waste characterization.

NOTE: Solidification activities must be reviewed by N3B before being conducted.

Storage and Disposal Method: Un-containerized liquid wastes will be transferred to appropriate containers at the point of generation and initially managed in a secure, designated waste area.

Acceptable knowledge will be used to determine the appropriate waste area. If insufficient AK is available, the waste should initially be managed as hazardous, until analytical data is available for characterization. If analytical data changes the waste classification, the waste will be stored in an area appropriate for the type of waste.

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Waste Description

Estimated Volume

Packaging

Regulatory classification:

Radioactive Waste

MSW

Waste destined for LANL's SWWS or RLWTFa Hazardous Waste

Mixed (hazardous and radioactive) Waste

PCBs-Contaminated Waste

NMSW

Industrial Waste

Characterization Method

AK: Existing Data/Documentation

AK: Site Characterization

Direct Sampling of Waste

Analytical Testing voes (EPA 8260-B)

SVOCs (EPA 8270-C)

Organic Pesticides (EPA 8081-A)

Organic Herbicides (EPA 8151-A)

PCBs (EPA 8082)

Total Metals (EPA 6010-B/7471-A or EPA 6020) Total Cyanide (EPA 9012-A)

High Explosives Constituents (EPA 8330/8321-A) Asbestos (EPA 600M4)

TPH-GRO (EPA 8015-M)

TPH-DRO (EPA 8015-M)

TCLP Metals (EPA 1311/6010-B)

TCLP Organics (EPA 1311/8260-B & 1311/8270-C) TCLP Pest. & Herb.

(EPA 1311/8081-A/1311/8151-A)

Gross Alpha (alpha counting) (EPA 900)

Gross Beta (beta counting) (EPA 900)

Tritium (liquid scintillation) (EPA 906.0)

Gamma spectroscopy (EPA 901.1)

Isotopic plutonium (HASL-300)

Isotopic uranium (HASL-300)

Document No: ER-DIR-SOP-10021

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CHARACTERIZATION TABLE

Waste #1 Waste #2 Waste #3 Waste#4 Waste Waste #6 Contact MSW Environmental C&D #5 Decon

IDW Media Debris PCS Flu ids

100 yd 3 2000 yd3 800 yd3 6500 yd3 <l yd3 200 gal.

Approved Approved IP-1 Bags Approved Approved Approved Containers Containers Conta iners Containers Containers

X X X X X X

X

X X X X X X

X X

X X X X X X X X X X X* X* X* X X

X X X X X X X X

X X

X X X X X X

X X X

X* X*

X X X

X X X X X X X X X X X X X X X X X X X X X X X X

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Waste Description

Americium-241 (HASL-300)

Strontium-90 (EPA 905)

Perchlorates (EPA 6850)

Nitrates/Nitrites (EPA 300.09-soil or 343.2-water) Oil/ Grease (EPA 1665)

Fluorine, Chorine, Sulfate (EPA 300)

TTO (EPA 8260-B and EPA 8270-C)b TSS and TDS (EPA 160.1 and 160.2)

COD (EPA 410.4)

pH (EPA 904c)

Microtox or BODc Waste Stream Profile

Waste Description

Estimated Volume

Packaging

Regulatory classification:

Radioactive Waste

MSW

Waste destined for LAN L's SWWS or RLWTFa Hazardous Waste

Mixed (hazardous and radioactive) Waste

PCBs-Contaminated Waste

NMSW

Industrial Waste

Recycle

Characterization Method

AK: Existing Data/Documentation

AK: Site Characterization

Direct Sampling of Waste

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CHARACTERIZATION TABLE

Waste #1 Waste #2 Waste #3 Waste #4 Waste Waste #6 Contact MSW Environmental C&D #5 Decon

IDW Media Debris PCS Fluids

X X X X X X X X X X X X X X

Request voes and SVOCs above

X X X X

TBDd TBD TBD TBD TBD

CHARACTERIZATION TABLE

Waste #7 Waste #8 Waste #9 Waste #10 Waste #11 Universal ACM Used Oil Recyclable Un-containerized Liquid

10 yd 3 40 yd 3 300 gal. 100 yd 3 600 Gallons Approved Approved Approved Approved Approved Containers Containers Containers Containers Containers

X X

X X

X

X X

X X X X X X X X X

X* X* X

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Waste Description

Analytical Testing voes (EPA 8260-B)

SVOCs (EPA 8270-C)

Organic Pesticides (EPA 8081-A)

Organic Herbicides (EPA 8151-A)

PCBs (EPA 8082)

Total Metals (EPA 6010-B/7471-A or EPA 6020) Total Cyanide (EPA 9012-A)

High Explosives Constituents (EPA 8330/8321-A) Asbestos (EPA 600M4)

TPH-GRO (EPA 8015-M)

TPH-DRO (EPA 8015-M)

TCLP Metals (EPA 1311/6010-B)

TCLP Organics (EPA 1311/8260-B & 1311 /8270-C) TCLP Pest. & Herb.

(EPA 1311/8081-A/1311/8151-A)

Gross Alpha (alpha counting) (EPA 900)

Gross Beta (beta counting) (EPA 900)

Tritium (liquid scintillation) (EPA 906.0)

Gamma spectroscopy (EPA 901.1)

Isotopic plutonium (HASL-300)

Isotopic uranium (HASL-300)

Americium-241 (HASL-300)

Strontium-90 (EPA 905)

Perchlorates (EPA 6850)

Nitrates/Nitrites (EPA 300.09-soil or 343.2-water) Oil/ Grease (EPA 1665)

Fluorine, Chorine, Sulfate (EPA 300)

TTO (EPA 8260-B and EPA 8270-C)b TSS and TDS (EPA 160.1 and 160.2)

COD (EPA 410.4)

pH (EPA 904c)

Microtox or BODc Waste Stream Profile

* As needed.

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CHARACTERIZATION TABLE

Waste #7 Waste #8 Waste #9 Waste#lO Waste #11 Universal ACM Used Oil Recyclable Un-containerized Liquid

X X

X* X

X

X* X X* X X* X X*

TBDd TBD TBD TBD TBD a in addition to other analytes needed to characterize the waste (e.g., VOC, SVOC, total metals), analyze for total suspended solids (TSS), total dissolved solids (TDS), oil and grease, gross alpha, gross beta, tritium, and potential of hydrogen (pH) for

WCSF: TA21 D&D and Cleanup Campaign, and MDA A & T Remedy Campaign t>8-Et2018-0041 t:=M

Document No: ER-DIR-SOP-10021 Revision: 2

Effective date 6/26/18 liquids destined for the LANL sanitary waste water system (SWWS). For wastes destined for the Radioactive Liquid Waste Treatment Facility (RLWTF), additional constituents include total toxic organics (TTO), TSS, chemical oxygen demand (COD), pH, total nitrates/nitrites, and gross alpha, gross beta (not including tritium), and gross gamma or the sum of ind ividual alpha-, beta-, and gamma-emitting nuclides.

b TTO is the total of voe and SVOC contaminants. Request methods EPA 8260-B (VOCs) and EPA 8270-C (SVOCs) .

c If Microtox analysis is not available, request biological oxygen demand (BOD) .

d TBD = to be determined.

References:

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

Laboratory," Los Alamos Scientific Laboratory report LA-3542, Los Alamos, New Mexico (April 1969).

• EPA (Environmental Protection Agency) 2002. "RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation, and Assessment," document number EPA530-D-02-002 (August 2002).

• EPA (Environmental Protection Agency) 2014. "Test Methods for Evaluating Solid Waste :

Physical Chemical Methods SW-846" (https://www.epa.gov/hw-sw846) (July 2014).

• LANL (Los Alamos National Laboratory) 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 (May 1991).

• N3B (Newport News Nuclear BWXT - Los Alamos, LLC) 2018. "LANL Waste Management," document number P409 Revision 1 (effective date June 8, 2018) .

• N3B (Newport News Nuclear BWXT - Los Alamos, LLC) 2018. "Characterization and Management of Environmental Programs Waste," document number ER-DIR-SOP-10021 Revision 2 (effective date June 26, 2018).

• N3B EPC-CP-QP-011 R4, Land Application of Drill Cuttings

WCSF : TA21 D&D and Cleanup Campaign , and MDA A & T Remedy Campaign

#3-&2018-0041 et\\

Document No: ER-DIR-SOP-10021 Revision: 2

Effective date 6/26/18

Signatures Date

Project Manager (Print name and then sign below.) Duane Parsons

Waste Generator (Print

Waste Management Coordinator (Print name and then sign below.) Jeff Lee ive (Print name and then sign below.) Ellen Gammon resentative (Print name and then sign below.) Ellen Gammon

WCSF: TA21 D&D and Cleanup Campaign, and MDA A & T Remedy Campaign

-NJ..8,2018-0041

Et\,\

Amendment to the WCSF

Title: WCSF TA-21 D&D and Cleanup Campaign, and MDA A & T Remedy Campaign, W-1?,2018-0041, Amendment 1

EM

Reason for Change: #1

Revise Waste Streams #4-Construction and Demolition Debris.

Waste Description:

Document No: ER-DIR-SOP-10021 Revision: 2

Effective date 6/26/18

Records Use Only

Waste Stream# 4-Debris: This waste stream is composed of concrete, metal, wood, asphalt, clay pipe, plastic, rubber, glass, paper products, and other miscellaneous material meeting the definition of debris as sited at

40 Code of Federal Regulations 268.2(g). This waste stream may also include trace soil.

Characterization, Management, and Disposal:

Anticipated Regulatory Status:

No Change

Characterization Approach:

No Change

Storage and Disposal Method:

Debris will be packaged and stored in secure, designated waste staging areas pending transportation for disposal.

Debris will be treated and/or disposed of in authorized facilities appropriate for the waste regulatory classification.

WCSF: TA-21 D&D and Cleanup Campaign, and MDA A & T Remedy Campaign, -N3-82018-0041, Amendment 1

CM

taft2018-0064

EM

EMID-700096

Signatures

Project Manager (Print name and then sign below.)

Duane Parsons

Generator {Print name and

Ron Desotel

Waste Management Coordinator (Print name and then sign below.)

Jeff Lee

RC A Representative (Print name and then sign below.)

Emily Day

Document No: ER-DIR-SOP-10021 Revision: 2

Effective date 6/26/18

Date

Waste Certification Program Representative (only if radioactive wastes will be he sign belo~

Ellen Gammon ~

WCSF: TA-21 D&D and Cleanup Campaign, and MDA A & T Remedy Campaign, #3-&2018-0041, Amendment 1 ~M fiHB,2018-0064 eM

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