Exhibit_D_Appendix_D-8_WCSF_Chaq_Cyn_Agg_Area_022519.pdf

Characterization and Management of Environmental Programs Waste

Document No: DIR-SOP-10021 Revision: 1

Effective date 6/26/18

Waste Characterization Strategy form

Project Title: WCSF: Chaquehui Canyon Aggregate Area

Solid Waste Management Unit or Area of Concern# Main Site, Area 6, South Site, NRAO

Activity Type: Nature and Extent, Remediation

Project Manager: Brenda Bowlby

Waste Management Coordinator: Jeff Lee

Waste Generator: Ron Desotel

Completed by: Ron Desotel

Date: 1/30/2019

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

Description of Activity:

The objective of the project is to finalize the nature and extent, and to re mediate any potential contaminated media and associated debris. The following activities are planned:

Geodetic survey- This task involves surveying new and old sampling locations using a global positioning system (GPS) unit.

Mobilization - This task involves mobilizing equipment and supplies to the sites.

Sampling - This task involves sampling. Soil, fill, sediment, and tuff samples will be collected by the most efficient and least invasive method practicable. The methods will be determined by the field team based on site conditions, such as topography, the nature of the material to be sampled, the depth intervals required, accessibility, and level of disruption to Los Alamos National laboratory (LANL or the laboratory) activities. Typically, samples will be collected using spade and scoop, hand auger, or drill rig.

Excavation - This task involves excavations. Excavations will be completed using a track excavator or backhoe at selected site(s). Excavated soil will be staged a minimum of 3 ft from the edge of the excavation, and excavations deeper than 4 ft below ground surface [bgs] will be properly benched to allow access and egress, if necessary. After completion of confirmatory sampling and any necessary over excavation work, the excavations and/or trenches will be backfilled with clean fill material or overburden, if they are not contaminated. Excavators may also be used to collect grab samples.

Waste management - This task involves waste management. All investigation-derived waste (IDW) generated during field investigation activities will be managed in accordance with applicable Federal, State, local, and LANL requirements.

Site restoration - This task involves the restoration of the sites; reseeding, if necessary; and repairing fences, if necessary.

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Demobilization - This task involves demobilizing equipment and supplies from the sites.

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

This waste characterization strategy form (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:

Technical Area 33 (TA-33) was initially developed in 1947 as a test site for implosion-type initiator experiments using conventional high explosives (HE), depleted uranium (DU), and beryllium.

Polonium-210 was prepared off-site and used as the radiation source for the experiments. The experiments were performed in underground chambers, on surface firing pads, and at firing sites equipped with large guns that fired projectiles into earthen berms. Initiator testing at TA-33 ceased in 1972. After 1972, TA-33 has been used for offices, laboratories, and storage in support of electronics design and fabrication and experiments formerly conducted at the Hot Dry Rock Program. An antenna for the National Radio Astronomy Observatory (NRAO) Very Long Baseline Array radiotelescope was sited at TA-33 in 1985 and is operational. The high-pressure tritium facility (former building 33-0086) was constructed at TA-33 in 1955 and operated until 1990. The tritium facility was decommissioned and demolished in the mid-1990s.

TA-33 consists of five operational areas: a laboratory and office complex near the entrance of TA-33 at NM 4 (Main Site); the former western firing site (Area 6}; the former southern firing site (South Site); the former eastern firing site (East Site); and the current site of the antenna for the NRAO Very Long Baseline Array radiotelescope.

The Chaquehui Canyon Aggregate Area has been disturbed as a result of many years of new construction, demolition of former structures, and historical firing-site activities. Before sampling is conducted, geodetic and geophysical methods, in conjunction with radiological surveys, may be used to verify specific solid waste management unit (SWMU) and area of concern (AOC) boundaries.

Thirty-three sites [SWMUs 33-00l(a-e), 33-002(a-e), 33-004(a), 33-004(g), 33-004(h), 33-004(i), 33-004(j), 33-004(m), 33-00S(a-c), 33-007(b), 33-007(c), 33-009, 33-0ll(a-e), 33-012(a), 33-014, 33-016, and 33-017 and AOCs C-33-001 and C-33-003] are proposed for nature and extent sampling. Ten sites [SWMUs 33-004(b), 33-004(d), 33-006(a), 33-008(a), 33-0l0(c), 33-0lO(f), 33-0lO(g), 33-0lO(h), and 33-015 and AOC 33-008(c)] are proposed for cleanup and nature and extent sampling.

Chaquehui Canyon Aggregate Area includes sites that N3B has determined to be beryllium contaminated sites. Beryllium-contaminated sites are locations where beryllium soil concentrations exceed natural background levels.

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The Following Sites are Purposed for Cleanup:

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Excavated Waste from SWMU 33-0l0(f) (60 yd3 radioactive low-level waste [LLW] debris/ 60 yd3 LLW soil) SWMU 33-0l0(f) is a former surface disposal area. Based on the previous investigations and site visits, significant amounts of debris are not expected to be encountered. Small amounts of debris associated with former site activities (e.g., pieces of concrete; piles of tuff and cured asphalt; rusted metal cans, rebar, and strapping bands; and other debris) may be encountered. Any debris remaining at the surface disposal area will be removed.

Surface Debris Removal from SWMU 33-00G(a} (0.05 yd3 radioactive/hazardous mixed low-level waste [MLLW] debris) Any firing site debris observed within the proposed sampling area will be flagged and subsequently removed, containerized, and characterized for disposal. The location where debris is removed will be field screened for radioactivity and HE; any soil with gross radioactivity detected above background values (BVs) or with detected HE will be excavated.

Excavated Waste from SWMU 33-008{a) (600 yd 3 LLW debris/ 60 yd 3 LLW soil) SWMU 33-008(a) is proposed for remediation. Historical information indicates that the landfill is approximately 50 ft x 60 ft x 8 ft deep. Once located and characterized, all visible waste and stained soil and/or tuff will be removed from the landfill and the bottom and sides of the excavation area. This waste stream will consist of excavated material that may consist of large debris, including telephone poles, timbers, railroad ties, and contaminated soil.

Excavated Waste from AOC 33-008(c} (0.3 yd3 LLW debris) This waste stream consists of any debris in the watercourse and surface areas of AOC 33-008(c) that has been exposed since 1999. Debris expected to be encountered at AOC 33-008(c) may consist of machined metal turnings, cable, glass bottles, and general trash based on previous site cleanup activities. Some of the debris may be mixed with soil. To the extent practicable, soil will be brushed off or otherwise removed from the debris.

Excavated Waste from SWMU 33-004(b) (5 yd3 MLLW debris/ 20 yd 3 IVILLW soil) The septic tank (structure 33-0033) and any contents will be characterized, excavated, and disposed of in accordance with applicable LANL waste management requirements. The inlet and outlet drainlines will be plugged. Following removal of the septic tank, the excavated area will be surveyed for radiation, explosive compounds, metals, and volatile organic compounds (VOCs). Additional media will be excavated until field-screening results indicate no detected VOCs or explosive compounds and no gross radiation or metals above background. Building 33-0024 housed a darkroom and electronic equipment and was also used for storage. There is no documented historical use of hazardous or radioactive materials within building 33-0024, although photographic chemicals were likely used.

Inorganic chemicals detected above BV in the Phase I Resource Conservation and Recovery Act facility investigation (RFI) soil or tuff samples were aluminum, barium, calcium, chromium, copper, cyanide, iron, lead, magnesium, silver, and uranium. Six organic chemicals were detected [benzo(b)fluoranthene, di-n-butylphthalate, fluoranthene, methylene chloride, phenanthrene, and pyrene]. Cesium-137 was the only radionuclide detected or detected above BV/fallout value (FV) in soil or two tuff samples. Arsenic, chromium, copper, cyanide, lead, nickel, mercury, silver, and zinc were detected in the septic tanks contents along with eleven organic chemicals [acetone; anthracene; benzo(a)anthracene;

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Effective date 6/26/18 benzo[b]fluoranthene; benzo(a)pyrene; chrysene; di-n-butylphthalate; fluoranthene; isopropyl alcohol;

phenanthrene; and 1,1,2-trichloroethane].

Excavated Waste from SWMU 33-004{d) (4 yd3 LLW debris) The septic tank is no longer needed so it will be removed and the drainlines plugged. A 1993 study of drains and discharges at TA-33 identified the only discharges to the septic system were from a lavatory, toilet, and sink drain.

Excavated Waste from SWMUs 33-0lO(c), 33-0lO(g), and 33-0lO(h) (10 yd3 LLW debris) SWMUs 33-0lO(c,g,h) are former disposal areas. This waste stream will consist of surface debris including copper and aluminum shrapnel, pieces of electronic cable, and wood debris from former firing site activities that were not removed during previous removal actions at the sites. Soil at locations with elevated radioactivity and/or metals within these three sites will be excavated.

Excavated Waste from SWMU 33-015 (10 yd3 LLW debris) SWMU 33-015 consists of an incinerator. This waste stream will consist of the small metal incinerator and the concrete pad it sits on. Only soil from beneath the concrete pad with visible staining or elevated field screening results (VOCs and/or radiological) will be removed. However, since the incinerator was only used to burn uncontaminated office trash, no soil is expected to be excavated from SWMU 33-015.

Borehole Cuttings from Consolidated Unit 33-002(a)-99, Material Disposal Area (MDA) K (400 yd3 LLW soil) Seven boreholes will be advanced to the top of the basalt at the following locations: within the former location of the SWM U 33-002(a) septic tank leach field, north of the former location of the SWMU 33-002(a) septic tank leach field, south of the former location of the SWMU 33 002(a) septic tank leach field, within the former location of the building 33-0086 (former tritium facility), and east of the SWMU 33-002(a) septic tank leach field where the mesa top drops into the drainage.

Borehole Cuttings from Consolidated Unit 33-00l(a)-99, MDA E (10 yd3 LLW soil) To determine if any releases have occurred from any of the SWMUs within MDA E, five boreholes will be drilled to a minimum depth of 70 ft bgs (or until field radiological and VOC screening indicates no detects above background). This waste stream will consist of borehole cuttings.

Characterization Strategy

The Subcontractor shall furnish qualified personnel, equipment, materials, and facilities to remove, package, label, and transport to the staging area all waste generated under this activity. The Subcontractor 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 proposed Nature and Extent sampling associated with site-specific sampling, direct sampling of waste containers, and approved acceptable knowledge (AK) data/documentation. AK includes (1) a review of existing historical documentation associated with the site and (2) 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.

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If analyses indicate the presence of listed constituents, a due diligence may be performed to identify whether these constituents meet the listing description. If there is no or inconclusive documentation that the contaminants are from a listed source, the waste will not be considered listed hazardous waste.

lfthe waste is listed hazardous waste and the contaminant levels are below screening levels and Land Disposal Restriction Treatment Standards, a no-longer-contained-in request may be submitted to the New Mexico Environment Department (NMED). A copy of either the N3B-Resource Conservation and Recovery Act (RCRA} approved due diligence or the NMED no-longer-contained-in approval must accompany all waste profiles prepared for the subject waste(s).

Required sampling and documentation will be performed in accordance with U.S. Environmental Protection Agency's (EPA's) "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 waste sampling information in accordance with EPA's "RCRA Waste Sampling Draft Technical Guidance" Section 7.2.3, Documentation of Field Activities (EPA 2002).

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.

Samples shall be delivered to the N3B Sample Management Office in accordance with N3B procedure 10094, Revision 1 "Sample Receiving and Shipping by the N3B Sample Management Office" (N3B 2018c).

The implementation of this WCSF complies with the requirements in Chapter Nine "Sampling Plan" found in 11Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA publication SW-846 (1986a).

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 (WAC). The Contractor (N3B) has determined that use of 20-yd3 roll-offs are appropriate containers for the re mediated debris and soils. Smaller waste containers, such as drums, may be used for the containerization of hazardous waste based on the amount of material generated.

All containers shall be approved and provided by the Contractor. The Contractor will be responsible for providing compliant waste containers; pallets; a covering for filled bags, if required; a bag loading frame, if required; a bag lifting device attachment, if required; establishing staging/storage areas; required staging/storage area inspections; weighing for transportation and disposal; loading for transportation for disposal; and final disposal of wastes.

Note: The Subcontractor is responsible for the closure of waste containers to ensure no spillage of material during on-site movement of filled waste containers to the staging/storage area. The Subcontractor shall weigh each empty 20-yd3 roll-off container and record tare weight before filling.

Subcontractor shall weigh each filled roll-off container and record gross weight (not to exceed 39,000 lb).

The Subcontractor shall visually inspect waste packages before filling for any holes, tears, or other damage to the package that could affect the integrity of the package. Immediately following containerization, the Subcontractor shall ensure each waste container is individually labeled with a

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Effective date 6/26/18 unique container identification number for tracking and inventory purpose. N3B Waste Management personnel will be responsible for labeling waste containers with the appropriate information regarding waste classification, contents, date generated, and responsible generator (individual responsible for the management of the waste container). Subcontractor shall place waste containers in a Contractor designated staging/storage area. Containerized waste (bags) will be stored on pallets (to be provided by the Contractor). The Subcontractor shall provide a daily waste inventory to the Contractor.

Expected Waste Streams:

Waste #1 - Contact Investigation Derived Waste: This waste stream is composed 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). less than 1 yd 3 of contact IDW is estimated to be generated.

Anticipated Regulatory Status: lLW, Hazardous, MlLW

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 placed into the same containers as the media with which it is contaminated, or it 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 environmental 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 of in authorized facilities.

Waste #2. - Municipal Solid Waste: This waste stream primarily consists of noncontact trash including, but not limited to, paper, cardboard, wood, plastic, food and beverage containers, empty solution containers, and other noncontact trash. less than 0.5 yd3 of municipal solid waste (MSW) is estimated to be generated. (Note: the volume may change if vegetation removal is required.)

Anticipated Regulatory Status: MSW

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

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

Waste# 3 - Environmental Media: Contaminated soil, sediment, and tuff will be excavated to remove media that exceeds risk-based cleanup objectives. This waste stream also includes cuttings from surface and subsurface sampling. Environmental media from all identified SWMUs and AOCs in this WCSF may be combined. Cuttings may be segregated from other excavated media for possible land application in accordance with N3B-EPC-CP-QP-011, "Land Application of Drill Cuttings" (N3B 2018d). Man-made debris encountered during soil removal will be segregated from the soil and managed appropriately

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Effective date 6/26/18 based upon AK of the soil. Small amounts of man-made debris and vegetation may be present in the excavated media waste stream; however, it must be reported in the profile. The total amount of media generated is estimated to be 550 yd3•

Anticipated Regulatory Status: LLW, Hazardous, MLLW, Land Application

Characterization Approach: Characterization will be based upon nature and extent sampling and/or approved AK data/documentation. For containerized waste that requires additional sampling for characterization, a representative sample will be collected for each waste container. A hand auger or thin-wall tube sampler will be used to collect multiple "grab" samples of waste material from each container, auguring from the surface to the bottom of the waste in a sufficient number of locations to obtain a representative composite sample. Composite samples will be analyzed for VOCs, semivolatile organic compounds {SVOCs), toxicity characteristic leaching procedure {TCLP) metals, target action level (TAL) metals, nitrate, cyanide, explosive compounds, gamma-emitting radionuclides isotopic plutonium, americium-241, radium, tritium, isotopic uranium, total uranium, and polychlorinated biphenyls (PCBs). Other constituents may be analyzed as necessary to meet the WAC for a receiving facility or if process knowledge or visual observations indicate other contaminants may be present.

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 and gasoline range organics (DRO/GRO).

Storage and Disposal Method: The excavated media will be containerized at the point of generation and stored in secure, designated registered radioactive waste storage or at a staging area pending analytical results. The containers will be appropriate for the quantity of wastes generated. Cuttings meeting the criteria of the NM ED-approved notice of intent decision tree for land application may be land applied.

Cuttings that cannot be land applied will be treated and/or disposed in authorized facilities. Excavated environmental media will be treated and/or disposed of in authorized facilities appropriate for the waste regulatory classification and disposal facility WAC.

Waste# 4 - Excavated Debris: This waste stream consists of residual man-made debris encountered during soil excavation. If possible, the debris will be segregated from the soil and managed appropriately based upon AK of the soil. Debris will contain less than 1% associated soil. The total amount of debris to be generated is estimated to be less than 680 yd3•

Anticipated Regulatory Status: Radioactive Low-Level, Hazardous, MLLW

Characterization Approach: Characterization of the excavated debris will be based on AK of the waste materials, the methods of generation, the extent of contamination, and analysis of the material contacted (e.g., excavated soil) and visual verification.

Storage and Disposal Method: The excavated debris will be containerized at the point of generation and stored in secure, designated registered radioactive waste storage or staging area. The containers will be appropriate for the quantity of wastes generated. Excavated environmental debris will be treated and/or disposed of in authorized facilities appropriate for the waste regulatory classification.

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Waste# 5 - Petroleum-Contaminated Soils (potential): This waste stream is composed of soils contaminated because of the accidental release of commercial 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 adsorbent padding, paper towels, spill pillows, or other adsorbent material used to contain the released material and added to the containerized petroleum-contaminated soils (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, LLW, MLLW

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 final generation. For spills of an unknown material/origin, samples will be collected in the following way:

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

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

111 If the spill is unknown and occurred on soil (nonhazardous, nonradioactive), samples will be analyzed for VOCs, TPH DRO/GRO, and 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 WAC.

• If the spill occurs on soils with no available/reliable AK documentation, soil will be sampled for TCLP VOCs, 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 a 21-day turnaround time for analysis so that a waste determination can be made within 30 days of generation. The "initial" date or date of generation for NMSW is the date the container is completely full or the date on 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's "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 on 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

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Effective date 6/26/18 stored in a clearly marked and constructed waste accumulation area appropriate to the anticipated waste type. The hazardous waste generation date is the date the soil was first placed into the container.

Waste accumulation area postings, regulated storage duration, and inspection requirements will be based upon the waste classification.

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. Less than 55 gal. of decontamination fluids is estimated to be generated.

Anticipated Regulatory Status: LLW, Hazardous, MLLW

Characterization Approach: The decontamination water will be characterized by direct sampling of the containerized fluids within 10 days after final generation. Representative waste characterization samples will be collected with a 21-day analytical data turnaround to ensure that wastes 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. Liquids may be solidified for disposal off-site.

Note: Solidification activities must be reviewed and approved by N3B before being conducted.

Storage and Disposal Method: Decontamination water will be containerized at the point of generation and initially managed as nonhazardous/radioactive low-level pending review of analytical results to determine final waste characterization.

Waste# 7 - liquids (not expected): This waste stream may consist of liquid present in septic tanks.

liquid wastes will be transferred to appropriate containers at the point of generation. The amount of liquid, if any, that may be generated is unknown at this time.

Anticipated Regulatory Status: Industrial, Sanitary, LLW, Hazardous, Toxic Substances Control Act

Characterization Approach: Liquid waste will be transferred to appropriate containers, such as 55-gal.

drums. The waste will then be sampled for characterization. Liquid waste will be characterized by direct sampling. Samples will be collected from the storage container in accordance with EPA's "RCRA Waste Sampling Draft Technical Guidance, Planning, Implementation, and Assessment" (EPA 2002). Liquids may be solidified for disposal off-site. Direct samples shall be analyzed, at a minimum, for voes, SVOCs, PCBs, total metals, TCLP metals, total cyanide, nitrates/nitrites, phosphorus, perchlorates, fluoride/chlorine/sulfate, total suspended solids (TSS), total dissolved solids (TDS), chemical oxygen demand (COD), pH, explosive compounds, dioxins/furans, gamma spec, gross alpha and gross beta, isotopic uranium, isotopic plutonium, americium-241, radium, tritium, strontium-90, total uranium.

Note: Solidification activities must be reviewed and approved by N3B before being conducted.

Storage and Disposal Method: Liquids will be containerized at the point of generation and initially managed as nonhazardous/nonradioactive pending review of analytical results to determine final waste characterization.

Waste #8 - immunoassay Test Kit Wastes: Investigation samples will be field-screened for RDX (Royal Demolition Explosive) and TNT (2,4,6-trinitrotoluene) using EN SYS immunoassay test kits. Wastes

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Effective date 6/26/18 generated from field screening includes spent solvent, water, and soil-crushed tuff. Less than 5 gal. of solid waste is estimated to be generated.

Anticipated Regulatory Status: LLW, MLLW, Hazardous, MSW

Characterization Approach: The soil-tuff in the wastes will be characterized using data from the samples collected. The solvent waste will be characterized based on the safety data sheet. The nonhazardous components of the test kit will be segregated.

Management and Disposal Method: Acetone-containing wastes will be containerized in an appropriate container and stored within a satellite accumulation area or central accumulation area. Nonhazardous waste will be managed and disposed of as MSW or contact waste as appropriate. These waste streams will be disposed of in authorized facilities appropriate for the waste regulatory classification and disposal facility WAC.

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Waste Description

Estimated Volume

Packaging

Regulatory Classification

Radioactive Waste

MSW

Recycle, Land Application

Hazardous Waste

Mixed (hazardous and radioactive) Waste

PCB-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}

TAL 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 RCRA 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}

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Waste Characterization Table

Waste #1 Waste #3

Contact Waste #2 Environmental IDW MSW Media

<lyd3 <0.5yd3 <550 yd 3

Approved Approved Roll-Offs

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

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Waste #4 Waste #6

Excavated Waste #5 Decon Debris PCS Fluids

<680 yd 3 <l yd 3 <55 gal.

IP-1 bags Approved Approved

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 (as needed}

X (as needed}

X X

X X

X X

X X

X X

Waste Description

Isotopic plutonium (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, Chlorine, Sulfate (EPA 300} no (EPA 8260-B and EPA 8270-C)•

TSS and TDS {EPA 160.1 and 160.2}

COD (EPA 410.4}

pH (EPA 904c}

Microtox or BODb

Moisture content (ASTM D-698)

Waste Stream Profile

Waste Characterization Table

Waste #1 Waste #3

Contact Waste#2 Environmental IDW MSW Media

X

X

X

X

X

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Waste #4 Waste #6

Excavated Waste #5 Decon Debris PCS Fluids

X X

X X

X X

X

X

Request voes and SVOCs above

X

X

X

X

X

TBD' TBD TBD TBD TBD TBD

• no is the total of VOC and SVOC contaminants. Request methods EPA 8260-B (VOCs} and EPA 8270-C (SVOCs} .

b If Microtox analysis is not available, request biological oxygen demand (BOD}.

c TBD = to be determined.

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Waste Characterization Table

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

PCB-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)

TAL Metals (EPA 6010-B/7471-A or EPA 6020)

Cyanide (EPA 9012-B)

High-Explosives Constituents (EPA 8330/8321-A)

Asbestos (EPA 600M4)

TPH-GRO (EPA 8015-M)

TPH-DRO (EPA 8015-M)

TCLP RCRA 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)

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Waste #7 Waste#S

Liquid Test Kits

Not Expected <5 gal.

Approved Containers 5-gal. buckets

X X

X

X

X X

X

X X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Waste Characterization Table

Waste Description

Americium-241 (HASL-300)

Strontium-90 (EPA 905)

Radium 226 & 228 (EPA 9320)

Total Uranium (EPA 6020)

Perchlorates (EPA 6850)

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

Oil/Grease (EPA 1665)

Fluorine, Chlorine, 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

Dioxins/Fu rans

Moisture content (ASTM D-698)

Waste Stream Profile

X

X

X

X

X

X

Document No: DIR-SOP-10021 Revision: 1

Effective date 6/26/18

Waste #7 Waste #8

Liquid Test Kits

X (as needed)

X

Request voes and SVOCs above

X

X

X

TBDd TBD

• In addition to other analytes needed to characterize the waste (e.g., VOC, SVOC, total metals), analyze for TSS, TDS, oil and grease, gross alpha, gross beta, tritium, and pH for 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, COD, pH, total nitrates/nitrites, and gross alpha, gross beta (not including tritium), and gross gamma or the sum of individual 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.

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References:

Document No: DIR-SOP-10021 Revision : 1

Effective date 6/26/18

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

• EPA (U.S. 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) 1992. "RFI Work Plan for Operable Unit 1147," Los Alamos National Laboratory document LA-UR-92-969, Los Alamos, New Mexico (May 1992).

• LANL (Los Alamos National Laboratory) 2015. "Investigation Work Plan for South Ancho Canyon Aggregate Area," Los Alamos National Laboratory document LA-UR-15-25429, Los Alamos, New Mexico (July 2015) .

• N3B (Newport News Nuclear BWXT - Los Alamos, LLC) 2018a. "N3B Waste Management," N3B document number P-409 Rl (effective June 8, 2018) .

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

• N3B (Newport News Nuclear BWXT - Los Alamos, LLC) 2018c. "Sample Receiving and Shipping by the N3B Sample Management Office," N3B procedure 10094, Revision 1 (2018) .

• N3B (Newport News Nuclear BWXT - Los Alamos, LLC) 2018d. "Land Application of Drill Cuttings," N3B document number EPC-CP-QP-011 R04 (effective April 4, 2018).

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Signatures

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

Waste Acci!{~'t ~epre/~:=:t name and then sign below.) Ellen Gammon

[)!,_1vl.-✓ U

Document No: DIR-SOP-10021 Revision: 1

Effective date 6/26/18

Date

21 j

Waste Certification Program Representative (Print name and then sign below.) Greg Geisinger

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Waste Characterization Strategy Form

Project Title: WCSF: South Ancho Canyon Aggregate Area

Solid Waste Management Unit or SWMUs 33-003(a,b), 33-004(c, k), 33-006(b), 33-007(a), 33-008(b), Area of Concern # and 33-0l0(a,b,d) and AOC C-33-002

Activity Type: Nature and Extent, Remediation

Project Manager: Brenda Bowlby

Waste Management Coordinator: Jeff Lee

Waste Generator: Ron Desotel

Completed by: Ron Desotel

Date: February 12, 2019

The SUBCONTRACTOR shall implement the requirements under this CONTRACTOR prepared Waste Characterization Strategy Form (WCSF).

Description of Activity:

The objective of the project is to finalize the nature and extent, and to remediate any potential contaminated media and associated debris. The following activities are planned:

Geodetic survey- This task involves surveying new and old sampling locations using a global positioning system {GPS) unit.

Mobilization - This task involves mobilizing equipment and supplies to the sites.

Sampling- This task involves sampling. Soil, fill, sediment, and tuff samples will be collected by the most efficient and least invasive method practicable. The methods will be determined by the field team based on site conditions, such as topography, the nature of the material to be sampled, the depth intervals required, accessibility, and level of disruption to Los Alamos National Laboratory {LANL or the Laboratory) activities. Typically, samples will be collected using spade and scoop, hand auger, or drill rig.

Excavation - This task involves excavations. Excavations will be completed using a track excavator or backhoe at selected site{s). Excavated soil will be staged a minimum of 3 ft from the edge of the excavation, and excavations deeper than 4 ft below ground surface {bgs) will be properly benched to allow access and egress, if necessary. After completion of confirmatory sampling and any necessary over excavation work, the excavations and/or trenches will be backfilled with clean fill material or overburden, if they are not contaminated. Excavators may also be used to collect grab samples.

Waste management -This task involves waste management. All investigation-derived waste {IDW) generated during field investigation activities will be managed in accordance with applicable Federal, State, local, and LANL requirements.

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Site restoration - This task involves the restoration of the sites; reseeding, if necessary; and repairing fences, if necessary.

Demobilization - This task involves demobilizing equipment and supplies from the sites.

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

This waste characterization strategy form (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:

The South Ancho Canyon Aggregate Area, located in Technical Area 33 (TA-33; East Site) at LANL, includes a total of 10 solid waste management units (SWMUs) and 1 area of concern (AOC). Of these 11 sites, 1 site has been approved for no further action. The "Investigation Work Plan for South Ancho Canyon Aggregate Area" (LANL 2015a) identifies and describes the activities needed to complete the investigation of the remaining 10 SWMUs and AOC. Details of previous investigations and analytical results for these 10 sites are provided in the "Historical Investigation Report for the South Ancho Canyon Aggregate Area" (LANL 2015b). SWMUs 33-004(k), 33-006(b), 33-007(a), 33-008(b), 33-0l0(a,b,d), and 33-003 (a,b) and AOC C-33-002 are proposed for nature and extent sampling. SWMU 33-004(c) is proposed for cleanup and nature and extent sampling.

Releases at sites within South Ancho Canyon Aggregate Area may have occurred as a result of normal site operations or potential spills/leaks. Previous sampling results indicate contamination from inorganic chemicals, organic chemicals, and radionuclides (LANL 2015b). Potential contaminant sources associated with TA-33 include firing sites, former shot chambers, septic system, drainline and outfall, landfill, former transformer, and surface disposal areas.

The following sites will generate additional IDW in addition to excess nature and extent sample media.

MDA D-SWMUs 33-003(a,b), (Borehole cuttings) (22 yd3 radioactive low-level (LLW) cuttings) Material Disposal Area (MDA) D consists of SWMUs 33-003(a) and 33-003(b). Both SWMUs are former underground chambers that were used to conduct experiments involving radioactive materials and high explosives. MDA Dis located at the east end of TA-33 on a mesa bordered by Ancho and White Rock Canyons.

Four boreholes will be drilled to a depth of 60 ft bgs, approximately 5 ft laterally from the chamber walls for each SWMU. Three additional boreholes will be drilled approximately 50 ft laterally from the center

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Effective date 6/26/18 of the chamber to a depth of 60 ft bgs to determine lateral extent of potential contamination for each SWMU. At each location, samples will be collected at 0-1 ft, 9-10 ft, 19-20 ft, 29-30 ft, 39-40 ft, 49-50 ft, and 59-60 ft bgs.

SWMU 33-004{c), Septic System {Septic Tank Removall_(5yd3 LLW debris/20 yd3 LLW soil) SWMU 33-004(c) consists of an inactive septic tank (structure 33-96) and associated drainline and drain field located at TA-33 East Site. This septic tank received wastewater from building 33-87, which was constructed in June 1955 to serve as the control bunker for the firing site at East Site. The septic tank has a capacity of 768 gal. and is located approximately 100 ft northeast of building 33-87. Wastewater was conveyed to the tank through a 4-in.-diameter vitrified clay pipe, and effluent from the tank flowed through a similar pipe to a small drain field approximately 30 ft east of the septic tank. No outfall is or has been associated with this septic tank. Building 33-87 was used as a control bunker for experiments conducted by Group W-3 until 1972. It has since been used for storage and for occasional short-term experiments. There is no documented use of hazardous or radioactive materials within building 33-87.

Septic tank 33-96 was operated under New Mexico Environment Department (NMED) Permit Number LA 34; however, no discharges to the septic system have occurred since the late 1980s. ·

Soil, fill, or other material covering the septic tank will be excavated and stockpiled next to the excavation. The septic tank and its contents will be removed. After the tank has been removed, three samples will be collected from one location below the tank. Samples will be collected from three depths (0-1 ft, 2-3 ft, and 5-6 ft below the base of the tank). Four samples will be collected below the septic tank inlet and outlet lines. Samples will be collected from two depths (0-1 ft and 4-5 ft below the base of inlet and outlet lines). The excavated area will be backfilled with clean fill and material excavated from the surface of the septic tank.

SWMU 33-004{k), Drainline and Outfall {Trenching/drainline removal) (4 yd3 LLW soil) SWMU 33-004(k) is described in the 1990 SWMU report as two parallel drainlines for building 33-87 that merged and discharged to a single outfall located near gun mount 33-116 (LANL 1990). The outfall reportedly received discharge from a toilet, sink, floor drains, and an electrical water cooler within the building. The engineering drawing for building 33-87 depicts a cast-iron drainpipe exiting the south wall of the building, and extending approximately 125 ft southeast of the building. Building 33-87 was constructed in 1955 to support firing site experiments that were conducted until the early 1970s.

Attempts to locate the drain line and outfall in 1994 and 1995 using geophysics and test trenches were unsuccessful. An inspection of the building performed in 1996 revealed that no floor drains existed in the building. The sink and toilet in the building discharge to septic tank 33-96 [SWMU 33-004(c)], located north of the building. Therefore, it is likely that the drain line and outfall never existed.

The location of the drain line could not be confirmed during the 1994 Phase I Resource Conservation and Recovery Act facility investigation (RFI). Two additional trenches will be excavated on both sides of the access road to verify if the drain line exists. If the drainline is not located, soil will be placed back into trench, no samples will be collected at this site, and the conclusion will be the drainline was never installed. If the drain line is located, sampling locations will be targeted at the locations of the drainline and outfall to define the nature and extent of contamination. Nineteen samples will be collected from seven locations. Four samples will be collected at two locations below the drainline. Samples will be collected at depth intervals of 0-1 ft and 2-3 ft below the drainline. Three samples will also be collected

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Effective date 6/26/18 from one location at the outfall and twelve samples will be collected from four locations downgradient of the outfall. Samples will be collected at depth intervals of 0-1 ft, 2-3 ft, and 5-6 ft bgs.

Characterization Strategy

The Subcontractor shall furnish qualified personnel, equipment, materials, and facilities to remove, package, label, and transport to the staging area all waste generated under this activity. The Subcontractor 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 proposed Nature and Extent sampling associated with site-specific sampling, direct sampling of waste containers, and approved acceptable knowledge (AK) data/documentation. AK includes (1) a review of existing historical documentation associated with the site and (2) 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.

If analyses indicate the presence of listed constituents, a due diligence may be performed to identify whether these constituents meet the listing description.