11-261852-0_Radiological_Waste_Handling___Disposal_Plan_FINAL_08262026.pdf

Radiological Waste Handling & Disposal Plan

Client Name: Haley & Aldrich Construction Services Project Name: Tuba City Dump – Radiological Waste Handling & Disposal Project Number: 11-261852

June 3, 2026 Revised 8/20/2026

Table of Contents

1.0 PROJECT UNDERSTANDING

2.0 REGULATORY FRAMEWORK

3.0 RADIOLOGICAL WASTE CONCERNS

4.0 ROLES AND RESPONSIBILITIES

4.1 Project Radiation Safety Officer

4.2 Radiological Control Technicians

4.3 Site Workers

4.4 Members of the Public

5.0 TRAINING

5.1 Project Specific Radiation Safety Worker Training

5.2 Department of Transportation (DOT) Training

5.3 Task Specific Training

6.0 SUMMARY OF RADIOLOGICAL HAZARD/RISK ANALYSIS

6.1 Radiological control and worker protections

7.0 EVALUATION OF TCD FOR POTENTIAL OF RADIOLOGICAL WASTE

7.1 Very Low Risk Phases

7.2 Low Risk Phases

7.3 Medium Risk Phases

7.4 Increased Risk Phase

8.0 RADIOLOGICAL WASTE MANAGEMENT

8.1 Sampling and Screening

8.2 Segregation and Control

8.3 Waste Container Management

8.3.1 Waste packaging, labeling, and inventory

8.3.2 Waste Container Storage Area

8.3.3 Emergency Response

8.4 Shipping Papers and Signature Authority

8.5 Establishment of New Waste Streams and Profiles

8.6 Quality Control

9.0 DOCUMENTATION AND RECORD RETENTION

10.0 REFERENCES……………………………………………………………………………………………………….12

APPENDICES

APPENDIX A

NRC Forms 540 and 541

The U.S. Department of the Interior, Bureau of Indian Affairs (BIA) is implementing plans to continue to excavate wastes at the former Tuba City Dump (TCD) site, located on Navajo Nation and Hopi Tribal Lands in Coconino

County, Arizona, and dispose of the waste at permitted municipal solid waste landfill (MSWLF) facilities. Haley &

Aldrich Construction Services (Haley & Aldrich) has prepared this Radiological Waste Handling and Disposal Plan

(Plan) to provide MSWLF facilities with a detailed description of the procedures used to screen excavated materials for potential radiological contamination and prevent radiologically impacted wastes from being transported to an MSWLF. This Plan also outlines the procedures that will be followed if radiologically impacted materials are identified during excavation activities.

The current phase of work is focused on Areas 1-A and 1-B, as shown in Figure 1. Waste excavation activities are anticipated to generate materials that, based on previous investigations, are expected to be suitable for management and disposal as municipal solid waste (MSW). The designated receiving disposal facilities for this phase of work are Waste Management Painted Desert Landfill (WM). If materials is encountered that cannot be accepted at the WM facility, they will be characterized and managed in accordance with applicable regulatory requirements. This Plan addresses the screening, handling, segregation, and disposition of potentially radiologically impacted materials encountered during excavation activities in Areas 1-A and 1-B. This Plan is intended to be implemented in conjunction with the Municipal Solid Waste Characterization Plan (MSWCP) and the Sampling and Analysis Plan (SAP) to ensure proper characterization, management, and recommendation for disposal of waste materials generated during the project.

1.0 PROJECT UNDERSTANDING

The TCD was open to area residents for disposal of waste from 1940 to 1997. The unregulated facility was comprised of two cells (Old and New). TCD was typical of small dumps serving rural communities across the U.S.

until the late 1980s. Common household (i.e., solid) wastes were reportedly dumped in large shallow excavations or in open piles at the Old Cell and burned. At the New Cell, waste was reportedly dumped directly or pushed into open trenches and burned. BIA’s Final Remedial Investigation Report (RI) (AMEC 2015) provides a comprehensive operational and investigative history of the TCD including the environmental setting.

Composition and disposition of the wastes that affect its handling and disposal during closure include:

Groundwater occurrence – Shallow, unconfined, perched groundwater is present under most of the TCD. The water resides in the Navajo Sandstone, hindered from infiltration by an underlying, less-permeable siltstone. Much of the bottom layer of waste is saturated.

Strontium and Uranium in shallow groundwater – Assessments of groundwater quality show elevated concentrations of strontium and uranium in isolated areas of the TCD (i.e., proximity to MW-7, Old Cell). The Rare

Metals uranium processing plant formerly operated 3.5 miles northeast of the TCD. Residents have reported seeing milling balls at the TCD, but no direct evidence of solid radiological waste has been noted in the numerous boreholes advanced within the TCD.

Hazardous waste potential – The burning of waste may generate dioxins and/or furans. Isolated detection of low-level concentrations of VOCs during soil gas surveys has been documented, but no direct evidence of hazardous wastes have been reported from subsurface investigations.

2.0 REGULATORY FRAMEWORK

WM Painted Desert (Penn-Robb) Landfill near Joseph City, Arizona has been identified as the landfill for non-hazardous TCD waste disposal. WM is operated as MSWLFs in accordance with Resource Conservation and

Recovery Act (RCRA) Subtitle D rules and regulations administered by the State of Arizona. This MSWLFs has been identified to receive the excavated, non-hazardous waste as defined in Subtitle D.

Three disposal facilities for potential radiological waste have been identified for potential radiological wastes appropriate for disposal at the MSWLF. US Ecology Idaho is a Subtitle C, Waste Control Specialists (WCS) of

Andrews Texas hosts the Texas Compact Waste Facility (CWF), and Energy Solutions Clive. Final selection of potential radiological disposal facilities will depend on the characteristics of any potential radiological waste discovered.

3.0 RADIOLOGICAL WASTE CONCERNS

The TCD site has been thoroughly investigated since its closure in 1997. No direct evidence of licensed or byproduct materials has been found. Elevated levels of uranium and strontium have been found in ground water near monitoring well MW-7 which may be the product of natural features in the area or may indicate the presence of radiological waste.

The concerns which drove the extensive sampling are the presence of the Rare Metals Facility, a former uranium processing plant, located 3.5 miles northeast of TCD. Area residents recall seeing trucks from this facility dumping material at TCD historically and there is concern that potential radiological waste may have been disposed of at

TCD. In addition, there was an illegal dump site found north of the Rare Metals site, located approximately 4 miles from TCD and a concern exists that similar materials were illegally placed in the TCD.

This combination of proximity to locations that would become a Uranium Mill Tailings Remedial Action (UMTRA) site, historical recollections, limited controls while the TCD was active, and elevated Uranium and Strontium in groundwater has led to a need for due caution while removing and disposing of TCD wastes.

The radionuclides of concern are Sr-90, U-235, U-238, Th-230, Th-232, Ra-226, and Ra-228. The presence of naturally occurring isotopes is expected in low concentrations consistent with nearby geology. Disposal of such wastes would not require invocation of a radioactive materials license. If, however, radiological items are found which indicate they are from a Uranium Mill, it will require that the wastes are generated and controlled under the auspices of a radiological material license. In either case, radiological wastes will need to be segregated from

MSW.

There is a low probability that the generation of radiological waste occurs at the same time as hazardous wastes are generated. Should a material qualify as both hazardous and radiological waste, such mixed wastes will need to be segregated into a separate waste stream and treated prior to disposal at a properly permitted facility.

4.0 ROLES AND RESPONSIBILITIES

The Project Radiation Protection Program is an element of the Project Health, Safety, Security, and Environment

Program. However, due to the unique aspects of radiological hazards, the roles and responsibilities of the project’s radiation protection staff are organized in a distinct line of organizational authority.

4.1 Project Radiation Safety Officer

The project Radiation Safety Officer (PRSO) is the individual who has been designated as having the primary responsibility for implementing the Project Radiation Protection Plan (PRPP). The PRSO has a direct reporting line to the Project Manager making him responsible for the project implementation of the radiological controls described in the approved PRPP as they relate to maintaining the safety of workers.

The project PRSO:

Is responsible for aspects of the day-to-day radiological operations and activities conducted at the site

Works with the Site Safety and Health Officer (SSHO) to coordinate PRPP requirements and radiation protection measures with other applicable Health & Safety (H&S) requirements.

Conducts site-specific radiation safety training and ensures that field personnel have completed required radiation safety training.

Stopping work if unacceptable health or safety conditions exist and taking necessary action to re-establish and maintain safe working conditions.

Responsible for maintaining control of radiological materials (e.g., radioactive check sources, radioactive waste) associated with the radiation protection program.

Recommend corrective actions for identified deficiencies for radiological issues.

Oversee radiological corrective actions and track identified radiological safety and health deficiencies with the goal of ensuring they are not repeated.

Ensure field documentation is completed daily and reviewed expeditiously.

Completes supervisory review, assessment of the data to evaluate the radiological conditions and verify that controls, mitigation methods, and monitoring remain appropriate.

Is recognized as a radiation protection subject matter expert and has completed project radiation protection training.

4.2 Radiological Control Technicians

Radiological Control Technician(s) (RCT)s are responsible for assisting the PRSO in implementing the PRPP.

The RCT will have 3 years’ experience and training in radiological health and safety monitoring. Haley & Aldrich has retained Certerra Southwest to provide qualified Radiological Control Technician (RCT) services for Areas 1- A and 1-B during the current phase of work.

Specific duties of the RCT include:

Performing radiological health and safety monitoring in accordance with the PRPP and at the direction of the PRSO.

Ensuring that radiological field data and activities are documented and recorded as acquired using approved forms and recording tools.

Presenting documented records of radiological field data and activities to the PRSO for review and approval daily.

Stopping work if unacceptable health or safety conditions exist and taking necessary action to re-establish and maintain safe working conditions.

Coordinating, as necessary, with the PRSO regarding site-specific radiation protection procedures and issues.

Implementing the PRPP and making PRSO-approved adjustments to ensure worker, visitor, public and environmental exposures are maintained as-low-as-reasonably-achievable (ALARA).

Assisting workers with self-surveys at radiological access control points.

Assisting with the delivery of site-specific radiation safety training.

Is recognized as competent in relevant radiation projection skills and has completed project radiation protection training.

4.3 Site Workers

Site workers are personnel assigned to a work-related role on the project site which are not classified as visitors.

Site workers who perform work in areas controlled for radiation protection purposes, who directly handle radioactive materials, or who may receive exposures in excess of that permitted for a member of the public are classed as Occupational Radiation Workers and must be trained accordingly. Occupational Radiation Workers are responsible for conducting work activities in accordance with the PRPP, radiation work permits (RWPs), and direction of the project radiological protection staff (PRSO and RCTs). They shall notify the radiation protection staff of conditions or concerns that may impact radiation protection of site workers or the public.

Please note that the discovery and management of radioactive waste is a possibility that must be planned for but is not currently anticipated. Until such time as radioactive wastes are identified, site workers will fall under the general protections and responsibilities of a member of the public and do not require the specific training or monitoring associated with being an Occupational Radiation Worker.

4.4 Members of the Public

A “member of the public” in the context of a radiation protection program includes all individuals except those who will receive an occupational dose arising from their work responsibilities. In order to receive occupational radiation dose in excess of that permitted for any member of the public (100 mrem in one year), one must be trained as an occupational radiation worker. Persons who do not receive Project-specific Radiation Safety

Training are considered “members of the public” even if they are site workers.

5.0 TRAINING

Training is an essential mitigation tool for managing and controlling workplace hazards. This is especially true for radiation hazards as most workers are infrequently involved in work tasks where they encounter radioactive materials and potential for radiation exposures. For this project, Haley & Aldrich has identified two levels of project-specific radiation safety training.

Site-specific radiological training for new personnel who require unescorted access to the work site will be conducted by the PRSO (or designee), where applicable.

Task specific radiological training will also be performed for intrusive work that requires its own RWP. The

PRSO (or designee) must create and retain a record of current training of each site worker given training involved with radiological waste, for as long as that employee is employed on the project and for 90 days thereafter. They must make a record of current training available upon request, at a reasonable time, to authorized officials or internal auditors.

5.1 Project Specific Radiation Safety Worker Training

Project-specific Radiation Safety Worker Training qualifies a worker as an Occupational Radiation Worker.

This training is required for project personnel who are assigned to the site and whose work requires them to directly handle potential radioactive material, wear PPE exclusively for radiological purposes, be monitored for exposure to radiation, or to access and enter areas that are posted and controlled for radiation protection purposes unescorted. Personnel who take part in and satisfactorily complete this training will be considered

Occupational Radiation Workers.

5.2 Department of Transportation (DOT) Training

Should hazardous or radiological waste be generated that will require shipment as Hazardous Materials per 49

CFR 172.102 or 49 CFR 173.403, all project personnel involved with generation or shipment of such wastes

(Hazmat Employees) must receive general awareness training. Each hazmat employee shall be provided general awareness training designed to provide familiarity with regulatory requirements and to enable the employee to recognize and identify hazardous materials consistent with hazard communication standards.

5.3 Task Specific Training

To ensure workers are well trained on the specific hazards and mitigating strategies associated with higher risk activities, such work requires task specific training. This training will require familiarization with PPE and engineering controls defined by the JSA and RWPs. If the personnel have not had an opportunity to engage in a practical or on the job training with the PPE or tools involved with the work, they will be trained, and their training documented at that time. DOT function specific training may also be included as part of this training.

6.0 SUMMARY OF RADIOLOGICAL HAZARD/RISK ANALYSIS

An important element of planning to potentially handle radiological waste is the radiological hazard/risk analysis.

The radiological hazard/risk analysis is designed to assess the magnitude of the exposures that might reasonably be expected to occur given Haley & Aldrich’s understanding of the radionuclides of concern, the historical radiological data provided, and the activities that will occur in the execution of the scope of work. The objective of the radiological hazard/risk analysis is to identify and anticipate radiological health and safety hazards that may be encountered in performing project work, such that appropriate monitoring and mitigation measures can be prescribed.

Based off of the negative radiological data indicated by the vast majority of boreholes and other investigations, the radiological risks to personnel working at the TCD are considered low. The potential for heterogenous waste deposition exists, but other than the results of the MW-7 water testing, there doesn’t appear to be a pathway for significant exposure of project personnel to radiological hazards. The presence of elevated uranium and strontium readings in the MW-7 groundwater does require further evaluation of potential risks, especially as excavation begins to encroach on areas that could be affected by or be the cause of the elevated readings.

6.1 Radiological control and worker protections

Due to the potential for a heterogeneous distribution of radiological waste, a tiered approach for radiological controls is appropriate. The radiation protection program will describe the various elements for collection of environmental data and establishing baselines for potential exposures for personnel at the TCD and general public and are not detailed here. Due to the low potential risk of radiological exposure to personnel at the TCD, the radiological controls will likewise be commensurate with risk. The goal of these controls is to identify the potential for wastes to contain a small amount of radionuclides, not to identify acute hazards to workers as the probability of an acute risk is near zero.

Radiological controls will include the following:

The establishment of perimeter and general air monitoring for potential internal radiological exposure. The fenced area constitutes the perimeter required for air monitoring.

The area being excavated will be scanned, at minimum weekly, for changing radiological conditions.

Suspect objects or discolored soil or debris should be scanned with a gamma sensitive device. Alpha and beta instruments should also be available for further investigations as needed. Screening of excavated soils will be performed with a Geiger counter and sodium iodide probes. These measurements will be taken at direct contact with soils.

Trucks taking waste to the MSWLF should be subject to a radiological survey to verify there is not heterogeneously deposited radioactive material within the load and that the loads conform to the waste profile accepted by the MSWLF.

While there’s currently no anticipated need for external exposure monitoring, the project should be evaluated, at minimum quarterly, for the need for additional air monitoring or the introduction of external exposure monitoring. If site workers are likely to exceed 100 mRem of exposure through a combination of external exposure and/or internal exposure (calculated and assigned via air monitoring) then they must be trained as Occupational Radiation Workers.

Should the nature of the risks change as more data is gathered, this situation should be addressed by the PRSO.

Such additional controls would be outside the scope of this plan.

7.0 EVALUATION OF TCD FOR POTENTIAL OF RADIOLOGICAL WASTE

As mentioned in section 6.0, the potential for finding radiological waste while excavating material from the TCD varies depending on its proximity with MW-7. Figure 1 shows the various phases planned to approach the excavation of the TCD. Each phase corresponds to an area within the TCD. Figure 2 shows those phases in relationship to MW-7 and the radionuclide concentrations in groundwater. The concentrations have been interpolated and color coded to show intensity of the groundwater activity. The current phase of work is limited to excavation activities within Areas 1-A and 1-B. Activities conducted under this Plan, including radiological screening, monitoring, waste characterization, and disposal coordination, will apply to these areas.

Figure 1

Excavation Phases of the TCD

7.1 Medium Risk Phases

Phases 1-B is considered to have a medium risk of encountering radiological waste. The radiological controls described in section 7.2 should be sufficient to protect site workers and the public.

The field screening and sampling regime of waste described by the SAP and MSWCP should be sufficient to show compliance with waste profiles for disposal at the MSWLF with the following enhancement:

Rather than scanning each stockpile after it’s been put in place in its entirety, the stockpiles should be scanned in approximately 1-foot lifts. This will allow a more controllable geometry with a reduced probability of a discrete piece of radioactive material to be shielded by soil or debris.

7.2 Increased Risk Phase

Phase 1A is considered to be at increased risk of encountering radiological waste compared to phase 1-B, as it is the closest to MW-7. In addition to the controls described in section 7.3, the excavation should be carried out with the following enhancements:

Excavation will be performed in 1-foot lifts, with radiological scans performed after each lift. This combination of controlled survey geometry prior to and after the excavation of the TCP waste should be sufficient to show compliance with waste profiles and protect site workers and the public.

As an alternative to excavating in 1-foot lifts, a soil scanning and sorting system could be implemented. This would also achieve the goal of controlled geometry for scanning and would likely prove to allow increased productivity. Should such technology be implemented, it is recommended that it be used for the western half of phases 1-B and for the south and west halves of phase 7 since there appears to be a positive groundwater contamination gradient as MW-7 is approached.

8.0 RADIOLOGICAL WASTE MANAGEMENT

This section of the plan describes the management of radiological wastes should they be discovered. These controls (other than scanning and sampling) do not apply to MSW. Data management is a key component of waste management and maintaining traceability of any data generated to its associated wastes is of highest priority.

8.1 Sampling and Screening

As described in section 7, qualified onsite technical personnel will provide oversight of the excavation progress and verify waste removal is suitable for disposal at the MSWLF. Screening of the excavation material will include:

Radiological screening of excavated material by a certified Radiological Control Technician using calibrated sodium-iodide probes, or equivalent devices; material with readings greater than two times background will be considered suspect and be eligible for further screening with controlled geometry (laid out in 1-foot lifts and rescanned) or analytical sampling. Probes will test via direct contact with the soil to ensure accurate readings.

Background level readings used for classification of soils will be 1.31 counts per minute (CPM) with a Geiger counter (2X background level equivalent to 2.62 CPM) and 1.0 picocuries per gram (pCi/g) with a sodium iodide probe (2X background level equivalent to 2.0 pCi/g).

Suspect waste shall be sampled within 24 hours of indication of any radiological activity as read by calibrated Geiger counter and sodium iodide probe.

The following items will be visually screened and segregated during the excavation phase. All waste streams will be separated and staged using heavy equipment.

• Asbestos containing materials will be visually screened and separated during the excavation phase

• Petroleum impacted materials will be visually screened. If material contains visual staining or gives off petroleum odors then these materials will be separated during the excavation phase.

• Tires will be visually screened during excavation phase

Excavation will be visually screened for recyclables such as scrap metal, batteries, appliances, and electronic waste. These items will be segregated from regular non-hazardous waste via heavy equipment.

Sampling and analysis will be performed in accordance with the Sampling & Analysis Plan. Excavated soil will be screened as it is stockpiled on-site with a sodium-iodide probe, or equivalent, to determine if radiological contamination is present. Material that is screened and reported as two times (2x) the natural background levels

(as provided earlier in this section) will be segregated and not sent to the selected municipal landfill until sampled for further analysis. The materials will be analyzed for Toxicity Characteristic Leaching Procedure (TCLP) RCRA 8

Metals, TCLP Volatile Organic Compounds (VOCs), TCLP Sem-Volatile Organic Compounds (SVOCs), TCLP

Organocholorine Pesticides, TCLP Chlorophenoxy Acid Herbicides, Total Furans, Total Dioxins, and Total

Sulfate.

Additionally, the samples will be analyzed for Isotopic Radium (Ra-226 and Ra-228), Thorium, and Uranium, Gross Alpha/Beta Radioactivity, and Gamma Spectroscopy. Samples will be submitted to an Arizona Department of Health Services (AZDHS) accredited laboratory within 24 hours of identification. Material determined to not being suitable for disposal at the municipal landfill will be left in a discrete stockpile location in the excavation area and cordoned off.

The selected landfill will determine the frequency of the testing for disposal purposes. Haley & Aldrich has assumed that one test for every 1,000 CY will be required for disposal. The characteristic radiological sample taken from each of the 1000 loose cubic yard stockpiles will be sent to an offsite laboratory for analysis. Haley &

Aldrich is planning on testing 144 samples (sidewall and floor samples) during the course of this phase of project work.

8.2 Segregation and Control

Waste stockpiles containing approximately 1,000 loose cubic yards will be constructed in the waste staging area

(located just south of the target excavation area). Eleven (11), or more, stockpiles, measuring approximately 70 feet x 70 feet x 8 feet, will be constructed on the waste staging area. During waste excavation and stockpiling, recyclable materials (such as scrap metal, appliances, tires, and large plastics) will be segregated and stored on site, until enough is accumulated for transport to a recycling facility.

The Materials Recovery Facility and Cinder Lake Landfill in Flagstaff, Arizona, have been identified as accepting recyclable materials.

Material suspected of not being suitable for disposal at the MSWLF will be left in a discrete stockpile in the excavation area. Each stockpile will be cordoned off and either further screened and/or sampled for contaminants of potential concern based on the screening.

If more than one type of suspect material is identified, multiple analyses will be performed. Materials identified as containing characteristically hazardous materials will be segregated and not hauled to the MSWLF. The TCD FY

2024 Cleanup Work Plan addresses how these materials will be handled.

Waste stockpiles cordoned off due to positive identification of radiological wastes shall be posted as a radioactive materials storage area. People not trained as Occupational Radiation Workers may not enter such an area without escort of a fully trained worker. Should an inclement weather event be imminent, such stockpiles should be protected. Tarps, poly sheeting, or similar along with erosion controls are appropriate for maintaining segregation prior to packaging.

Radiological waste may not be loaded into a container that contains MSW. This would create additional radiological waste, cause unnecessary expense, and potentially lead to inadvertent disposal of radiological waste at the MSWLF. Containers that are loaded with radiological waste must be conspicuously marked to differentiate them from those containing MSW. These markings are different from DOT marking and may consist of simple paper signs or reusable magnetic markings. Such site-specific markings shall be removed immediately prior to transport for disposal.

After a stockpile identified as radiological waste has been loaded into a container, the area posted as a radioactive materials storage area will be scanned with a sodium iodide probe (or similar) to confirm that no radiological material was left behind. Once the survey has been completed and the PRSO approves the survey, the area may be down posted and removed from radiological controls.

8.3 Waste Container Management

Should radiological wastes be discovered at the TCD, it is imperative that such wastes be tracked from generation through disposal. Due to the extended process for managing and disposal of radiological waste, waste container management needs to be given a high priority. While maintaining traceability with the characteristic data for each container is of paramount importance, the challenges associated with keeping a physical inventory of large containers for an extended period needs to be addressed.

8.3.1 Waste packaging, labeling, and inventory

It is anticipated that if radiological materials are identified in the TCD, it will lead to bulk packaging of waste.

Intermodal containers, supersacks, roll-offs, or similar containers suitable for shipping DOT Class 7 waste are acceptable to store radiological waste prior to shipment. Should a waste sorting and segregation technology be utilized, drums may also be necessary for the packaging of discrete items.

Should radiological wastes be discovered at the TCD, those wastes will need to be controlled. The best way to protect such waste from the elements is by packaging them.

If required, packages containing radiological wastes will be able to be marked with unique identifiers that will allow tracking and inventory of the packages. Such markings must be weather resistant and capable of standing up to the conditions found in the Arizona desert for multiple months. These marking will allow the traceability of the wastes to the sampling and characterization efforts described in section 8.1.

8.3.2 Waste packaging, labeling, and inventory

A waste container storage area has been identified south of the east cells. Should a container be loaded with radiological wastes, it may be stored there. Should a container have more than 350 uCi of U-238, 1 uCi of Sr-90, or a Sum of Fractions greater than one of any nuclides listed in Appendix E of 10 CFR 835 or Appendix C of 10

CFR 20, then the area around that container must be posted as a radioactive materials area. As mentioned in section 8.2, any container holding radiological waste must be marked as such to not be accidentally sent for disposal as MSW.

8.3.3 Emergency Response

Project emergency response procedures will be detailed in a Health and Safety Plan. The radiological hazards/risks at this project are very low. An emergency response for a life safety hazard that may arise should never be delayed or foregone because of a radiological work control or hazard mitigation measure otherwise required. For example, should an emergency situation that arises require a person to immediately evacuate a work zone that is demarcated and controlled for radiological purposes, the indicated emergency response action should take precedent over a radiological control requirement that would ordinarily require that personnel perform a radiological contamination check (frisk) upon exit. The evacuation order overrides the radiological control requirement.

If radiological controls are overridden in an emergency response situation, the PRSO should be notified immediately. The PRSO will determine the reasonable and appropriate recovery measures to be implemented for radiological controls and radiation protection purposes. The recovery measures should be documented and summarized before the return to normal site operations is approved.

Under no circumstance should life-saving or critical medical response be delayed or hindered in an attempt to enforce radiological control measures.

8.4 Shipping Papers and Signature Authority

For MSWLF shipments, a waste manifest including analytical results for the stockpile from which the haul truck was loaded will be submitted at the MSWLF scale house. Copies of each fully executed waste manifest will be provided to BIA along with scale tickets for each load. These shipments are not considered hazardous material by the DOT. There are no regulatory requirements for the signing or preparation of such a waste manifest.

For radiological shipments that do not qualify as DOT hazardous material, a bill of lading will be prepared for the shipment which includes the waste profile number. Special instructions will be provided to the driver that includes emergency contact information for the load. The waste facility may request an NRC 540 / 541 form be filled out for such a shipment. NRC 540 and 541 forms can be found in Appendix A. Copies of all shipping papers for radiological wastes will be provided to the BIA.

For radiological shipments that do qualify as DOT hazardous material, a hazardous waste manifest will be necessary for the shipment. The manifest must be prepared by a shipper who has the current training per 49

CFR 172.704 and has been deemed competent and qualified to do so. Special instructions will be provided to the driver that includes emergency contact information for the load.

For radiological shipments of licensable material (i.e., if an NRC license has been invoked to possess and handle the radiological materials) an NRC 540 and 541 form must be prepared. A representative of either the nuclear materials license holder or the generator (BIA) must sign these forms.

8.5 Establishment of New Waste Streams and Profiles

Currently there is only a single waste stream identified: Non-hazardous, non-radiological solid waste bound for the

MSWLF. Should additional waste constituents be discovered, the associated wastes should be segregated and characterized per the SAP and MSWCP. Waste profiles will then be developed based on the results of the characterization for this new waste stream..

It may be possible to combine waste streams going to a compatible disposal facility. This will require the modification of waste profiles to accommodate both waste streams but will require agreement from regulatory oversite / stakeholder representatives.

8.6 Quality Control

The PRSO is responsible for the management of radiological quality through the use of approved procedures, observation of radiological work practices, and review of radiological data collected. Radiological quality will be coordinated with the project quality assurance program with respect to documentation and client reporting processes.

Throughout the course of project work where radiological controls are being implemented, the project radiation protection staff will perform and document the performance of surveillances and inspections of the implementation of the requirements of the project RPP. The PRSO will compile and review the documented surveillances and inspections, note any issues or concerns as well as good practices. The PRSO will use the observations noted in subsequent briefings for the purpose of providing feedback to the work force.

Where corrective actions are identified, they will be administered and dispositioned using the project’s corrective action process.

9.0 DOCUMENTATION AND RECORD RETENTION

Records resulting from implementation of this plan will document radiological waste generation and disposal.

Field measurements and count rate data will be recorded electronically and/or on paper. Records of field-generated data will be reviewed for completeness, consistency, and accuracy, by the PRSO, or a designee knowledgeable in the measurement method.

Supervisory review and assessment of the data will include comparisons of the observed data with established action levels and with the magnitude of like data that was anticipated and that which has been observed until that time. Implicit in the review of newly collected data is an assessment of the adequacy of the emplaced radiological controls, exposure mitigation methods, and radiological monitoring. If ever a question or uncertainty over the adequacy of the emplaced radiological controls, exposure mitigation methods, or radiological monitoring is raised or recognized, the PRSO will evaluate the radiological conditions and determine whether controls, mitigation methods, or monitoring should be revised accordingly.

Changes or corrections to project documentation will be made by crossing out the erroneous item with a single line, initialing (by the person performing the correction), and dating the correction. The new information will be written above the crossed-out item. Corrections will be written clearly and legibly.

Information supporting the generation and/or modification of waste profiles and shipping papers, including but not limited to radiological surveys, sampling results, and sorting and segregation reporting, shall be maintained through the life of the project plus 3 months. Radiological data used to assign exposure to personnel shall be maintained through license termination should a radioactive materials license be invoked.

10.0 REFERENCES

AMEC. 2015. AMEC Environment & Infrastructure, Inc., Golden, CO, Final Remedial Investigation Report, Tuba City Dump Site, prepared for Bureau of Indian Affairs, U.S. Department of the Interior, Western Regional Office, Phoenix, AZ. May 1.

BIA. 2023. Department of the Interior Bureau of Indian Affairs, Tuba City Dump Closure Work Plan, Fiscal Year 2024. May

Stephens. 2008. Waste Characterization and Expanded Groundwater Investigation Tuba City Landfill, Daniel B.

Stephens & Associates, Inc. February 8.

WSP (WSP USA Inc.). 2023a. Draft Municipal Solid Waste Characterization Plan.

WSP. 2023b. Draft Sampling and Analysis Plan, Tuba City Dump Cleanup, prepared for Bureau of Indian Affairs. February 24.

APPENDIX A

NRC Forms 540 and 541

A P

P R

O V

E D

B Y

O M

B

N O

0-

E st im at ed b ur de n pe r re sp o ns e to c o m pl y w ith th is in fo rm at io n co lle ct io n r eq ue st m in u te s.

T h is u n ifo rm m a ni fe st is r e qu ire d by N

R C t o m e et r ep or tin g re qu ire m en ts o f F e de ra l a nd S ta te

A ge nc ie s fo r th e s a fe tr an sp or ta tio n a n d di sp os a l o f l ow

-l ev el w a st e

S en d c om m e nt s re ga rd in g b ur d en e st im a te to th e F

O

IA

, L ib ra ry an d In fo rm a tio n C o lle ct io ns B ra n ch

T -6

A

0M

U .S

. N u cl ea r R eg ul a to ry C o m m is si o n, W as h in g to n

, D C

5-

1, o r b y e m a il to

In fo co lle ct s.

R es o ur ce n rc

.g o v, a nd th e O

M B re vi ew er a t:

O M

B O ffi ce o f I nf or m at io n an d

R eg ul at or y

Af fa irs

-0

4) , A ttn

D es k O ffi ce r f or th e

N uc le ar

R eg ul at or y

C om m is si on

, 7

7t h St re et

N W

, W as hi ng to n, D C

; e m ai l:

o ir a_ su b m is si o n@ om b .e op .g o v .

T he

N R

C m ay n ot c on du ct o r s po ns or

, a nd a p er so n is no t r eq ui re d to re sp on d to , a c ol le ct io n of in fo rm at io n un le ss th e do cu m en t r eq ue st in g or re qu iri ng th e co lle ct io n di sp la ys a c ur re nt ly v al id O

M B co nt ro l n um be r.

N R

C F

O R

M

U .S

N

U C

L E

A R

R E

G U

L A

T O

R Y

C O

M M

IS

S

IO

N

U N

IF

O

R M

L O

W -L

E V

E L

R A

D

IO

A C

T

IV

E

W

S T

E M

A N

IF

E

S T

S H

IP

P

IN

G

P A

P E

R

S e e N

U R

E G

/B R

-0 fo r d et a ile d in st ru ct io n s fo r co m p le tin g th is f o rm h tt p:

w w w .n rc .g o v/ re ad in g

-r m

/d oc

-c o lle ct io ns

/n u re g s/ b ro ch u re s/ b r0

E m e rg e n c y

T el e p h o n e

N u m b er

In cl u d e a re a c od

O rg a n iz a ti o n

Y e s N o

Is t h is a n

E x c lu s iv e

U se h ip m e n t? Y e s N o

S h ip p e r

N a m e a n d

F a c il it y

U s e r

P e rm it

N u m b e r

S h ip m e n t N u m b e r

C o n ta ct

C ar ri e r

N a m e a n d A d d re s s

C o n ta ct

S ig n at u re

A u th o ri ze d c ar ri er a ck n o w le d g in g w as te r ec ei p t

S h ip p e r

ID

N u m b er

C o lle ct o r

P ro ce ss or

G e ne ra to r

T yp e

S p e ci fy

P h o n e N o

In c lu d e A re a

C o d e

E P

A I

.D . N u m b e r

S h ip p in g

D a te

D a te

P h o n e N o

In c lu d e A re a

C o d e

N R

C F o rm a n d g e o f

N R

C F o rm a n d

A

N R

C F o rm a n d

A

A d d it io n a l I n fo rm a ti o n C o n ta ct

P a g e

(s

P a g e

(s

P a g e

(s

P a g e

(s

E le ct ro ni c

M a n if e s t N u m b e r

P h o n e N o

In c lu d e A re a

C o d e

D a te

C o n si g n e e

N am e a n d F a c ili ty

A d d re s s

S ig n at u re

A u th o ri ze d c o n s ig n ee a ck n o w le d g in g w as te r ec ei p t

C

E R

T

IF

IC

A

T

IO

N “T hi s is to c er tif y th at t he h er ei n-na m ed m at er ia ls a re p ro pe rly c la ss ifi ed , d es cr ib ed

, p ac ka ge d, m a rk ed , a nd la be le d an d ar in pr op e r co nd iti o n fo r tr an sp or ta tio n ac co rd in g to th e ap pl ic ab le r eg ul at io ns o f t h e

D e pa rt m en t of

T ra n sp or ta tio n, th e

C om m is si on an d e qu iv al en t st at e re gu la tio ns

F o r m at er ia ls th a t a re c o ns ig ne d to a la nd d is po sa l f a ci lit y or w as te c ol le ct o r, th is c er tif ie s th at th m at er ia ls a re c la ss ifi ed p er th e ap p lic ab le r eq u ire m en ts o f 1

C F

R P ar t 6

1, m ee t t he la nd d is po sa l f ac ili ty 's w as te a cc ep ta nc e cr ite ria

, a nd a re in p ro pe r co nd iti o n fo r di sp os al a s de sc rib ed in a cc or da nc e w ith th e ap pl ic ab le r eq ui re m e nt s of

C

F R

P ar ts an d

1, o r eq ui va le n t s ta te r e gu la tio n s.

A c o lle ct or in s ig n in g th e ce rt ifi ca tio n is c er tif yi ng th at n ot hi ng h as b ee n do ne to th e co lle ct ed w as te w hi ch w ou ld in va lid at e th e w as te g en er at or

's c er tif ic a tio n.

A u th o ri ze d S ig n a tu re a n d

T it le D a te

U

S

. D e p a rt m e n t o f T ra n s p o rt a ti o n

D e s cr ip ti o

(I c lu d in g

U N

I D n u m b e r, p ro p e r s h ip p in g n a m e h az a rd c la ss a n d a n y a d d it io n a l in fo rm a ti o n

D

O T

L a b el s

T ra n sp rt

In d e x

P h y s ic al a em ic al F o rm

In d iv id u a l

R ad io n u cl id e s

M a x im u m

P a c k ag c ti v it y in

S I

U n it s

T o ta l W e ig h t o r

V o lu m e (U s e a p p ro p ri a te u n it s

Id e n ti fi c a ti

N u m b e r o f

P a c k a g e

F o r C o n si g n e e U s e

O n ly

N R

C F

O R

M

-2

-2

T o ta l

N u m b e r o f p a c k ag e s id e n ti fi t h is m a n if es t?

D o e s

E P

A r e g u la te d w a s te r eq u ir in g m n if e st a c co m p a n y t h is s h ip m e t?

If

Y es p ro v id e

M a n if e st

N u m b er

E P

A M a n if e s t

N u m b r

P R

O V

E D

B Y

O M

B

N O

0-

Es tim at ed b ur de n pe r r es po ns e to c om pl y w ith th is in fo rm at io n co lle ct io n re qu es t:

3.

ho ur s.

T hi s un ifo rm m an ife st is re qu ire d by N

R C to m ee t r ep or tin g re qu ire m en ts o f F ed er al a nd S ta te

A ge nc ie s fo r t he s af e tra ns po rta tio n an d di sp os al o f l ow

-le ve l w as te

Se nd c om m en ts re ga rd in g bu rd en e st im at e to th e

FO

IA

, L ib ra ry , a nd In fo rm at io n C ol le ct io ns B ra nc h (T

-6 A

M

U

.S . N uc le ar R eg ul at or y C om m is si on , W as hi ng to n, D

C

-0

1, o r b y em ai l t o

In fo co lle ct s.

R es ou rc e@ nr c.

go v, a nd th e O

M B re vi ew er a t:

O M

B O ffi ce o f I nf or m at io n an d re gu la to ry A ffa irs

(3

0-

At tn

D es k O ffi ce r f or th e

N uc le ar

R eg ul at or y

C om m is si on

, 7

7t h St re et

N W

, W as hi ng to n, D C

; e m ai l:

o ira _s ub m is si on om b.

eo p.

go v.

T he

N R

C m ay n ot c on du ct o r s po ns or

, a nd a p er so n is n ot re qu ire d to re sp on d to

, a c ol le ct io n of in fo rm at io n un le ss th e do cu m en t r eq ue st in g or re qu iri ng th e co lle ct io n di sp la ys a c ur re nt ly v al id

O M

B co nt ro l n um be r.

N R

C F

O R

M

U .S

N

U C

L E

A R

R E

G U

L A

T O

R Y

C O

M M

IS

S

IO

N

U N

IF

O

R M

L O

W -L

E V

E L

R A

D

IO

A C

T

IV

E W

A S

T E

M A

N

IF

E

T

N T

A

IN

E R

A N

D W

A S

T E

D E

S C

R

IP

T

IO

N

S e e N

U R

E G

/B R

-0 fo r d et a ile d in st ru ct io n s fo r co m p le tin g th is f o rm h tt p:

w w w .n rc .g o v/ re ad in g

-r m

/d oc

-c o lle ct io ns

/n u re g s/ b ro ch u re s/ b r0

N R

C F

O R

M

-2

-2

A d d iti o n al N uc le a r

R e gu la to ry

C o m m is si on

N R

C

R e qu ir e m e n ts f or C o n tr o l, T ra n sf er a n d D is p o sa l o f R ad io a ct iv e

W a st e

M a n if e s t T o ta ls

M a n if e s t

N u m b e r

N o

. o f

P k g s

D is p o s al n ta in e rs

N e t W as te

V lu

(m

S p e c ia l

N u cl e a r

M a te ri al g ra m s

N e t

W ig h t (k g

U -2

U

-2

P u

T o ta l

A ct iv ity

M

B q

A ll

N u c li d es

T ri ti u m C

-1

T c-

I-

S o u rc e k g

P a g e( s

P ag e o f

S h ip p e r

N am e

S h ip p e r

ID

N u m b e r

D is p o sa l C o nt a in e r

D e sc ri p tio n

C on ta in e r

Id e nt ifi ca tio m be r/ G en e ra to r

ID

N u m b e r( s)

C on ta in

D es cr ip ee N o te

V o lu

(m

W n ta in e r W e ig h t ( kg

W ig t

(k rf ce

R ad ia tio n

L e ve l

(µ v/ h r)

(m S v/ r)

S u rf ac n ta m in a

M

B q

/1 c m

A lp h a

B e ta

G a m m a

2.

st sc ri pt o r (S e e

N ot e

. A p pr o xi m at st

V lu m e (s in n ta in e r

S or b nt lid ifi ca tio n

S ta b ili za tio n

M ed ia

S ee N ot e

P h ys ic a l D e sc ri p tio n

C h e m ic a l D es cr ip tio n

C h e m ic a l F o rm

C h e la tin g

A g e n t

W e ig h t

C h e la tin e n t if

.1

R a d io lo g ic a l D es cr ip tio n

In di vi du a l R a d io n uc lid e s a n d A ct iv ity

B q) a nd

C o n ta in e r T o ta l;

o r C o n ta in e r

T ot a l A ct iv ity a n d

R ad io n u cl id e

P e rc e n t

W as te

C la ss

-C la ss A

S ta bl

U -C la ss

A U ns ta b le

-C la

-C la

W oo d e n B o x or C ra te

M e ta l B o x

P la st ic

D ru m o r P a il

M e ta l D ru m o r

P a il

M e ta l T a n k or

L in er

C on cr e te T an k o r

Li n e r

P o ly et h yl e n e T a n k or

L in er

C h a rc oa l

In ci n e ra to r

A sh

S oi l

G a s

A qu e o u s Li q u id

E

P A o r

S ta te H a za rd o u s

S o rp tio n

N O

T E

C o n ta in er

D e sc ri pt io n C o d es

F or c o n ta in e rs / w re q u ir in g d is p o sa l i n a p p ro ve d s tr u ct u ra l o ve rp a ck s, t h e n u m er ic a l co d e sh o u ld b e f o llo w e d b y

O P

G a s

C yl in d e r

B ul k

U np a ck a g ed W a st e

U n p a ck a ge d C o m p o n e nt s

H ig h

I n te g ri ty

C o nt a in e r

O th r.

sc ri be in it e m ad d iti o n a l p a g e

A ni on

I o n -e xc h a ng e M ed ia

M ix e d B e d

Io n

-e xc h a n g e M e di a

P ai nt o r

P la tin g

F ilt e r M e d ia

C o n ta m in a te d

E q ui p m e n t

O rg an ic L iq u id e xc e p t o il)

G la ss w a re o r La b w a re

S ea le d S o u rc e

/D e vi ce

S ol id

A S o rb

A ni m l rc a ss

B io lo g ic a l

M at e ri a l ( e xc e p t a n im a l c a rc as s)

A ct iv at te ri a l

N O

T E

W as te D e sc ri pt o r

C od s.

(C ho o se u p t o t hr e e w hi ch p re do m in at e b y vo lu m e

O th sc ri be in it

, o r a dd iti o n a l p a ge

F lo rc o X

. C h e m si l 3

. C he m si l 5

. C he m si l 3

. D ic ap e rl H

P

. D ic ap e rl H

P

. P e tr o se t

C o n cr et e en ca p su la tio n

B itu m e n

V in yl

C hl or id e

V in yl

E st e r

S ty re n e

O th sc ri be in it e m a d d iti o na l p a g e

0.

n e

R eq u ir e d

S pe e d D ri

C e le to m

F lo o r D ry up e rf in e

H ig h

D ri

S af e

T S o rb

S af e

N D ri

F lo rc o

C e m e nt

S o lid ifi ca tio n

F ib e rg la ss

T a n k o r

L in e r

D em in e ra liz e r

D e m o lit io n

R u b b le

O il

M e ch an ic a l F ilt er

. P e tr o se t

II

A qu a se t

A qu a se t

II

O th e r.

D e sc ri b e in it e m o r a d d iti o na l p a

T E

: F o r so lid ifi ca tio n m e d ia th a t m e e t d is p os a l s ite s tr u ct u ra l s ta b ili ty r eq u ir e m e n ts th e n u m e ri ca l c od sh ul d b e f ol lo w e d b y

F or a ll so lid ifi ca tio n m ed ia th e ve n d o r (m a n u fa ct u re r) a nd b ra n d n am e s h ou ld a ls o b e id e n tif ie d in it e m

C od

0=

N O

N E

R E

Q U

IR

E

D

C a tio n I on -e xc ha n g e M e d ia

N o n co m p a ct ib le

T ra sh

C o m p ac tib le

T ra sh

E va p o ra to r

B o tt om s/ lu dg e s/

C o n ce n tr at e s

W a st e

D e sc rip tio n fo r

E a ch W a st e T yp e in C o n ta in e r

(0

-2 6-

3)