N3B-EP-DIR-SOP-10021.pdf

INFORMATION ONLY

N3B Transition Instruction Title: N3B Blue-Sheet Process Instruction No: T-0005 Revision: 1 Effective Date: 03/12/2018 Page 5 of 7

Attachment 1 - N3B Blue-Sheet Form A. Document Number: Revision:

EP-DIR-SOP-10021

B. Document Title (list name of manual, document, procedure series, or specific procedure):

Characterization and Management of Environmental Programs Waste

C. Owner/User Group (i.e. operations, maintenance, etc.):

Environmental Remediation Program

D. Check ( ✓)one of the following:

1. V Document(s) is accepted "as is" with minor revisions.

2. _ _ Attachment 3 has been initiated for procedure intent change (for future

PCR).

3. __ Document is not needed for N3B work and will not be accepted.

4. __ Document to be placed On-Hold and further evaluated post-transition.

E. Comments:

• Effective Date: 7/25/2014

• This procedure was cancelled by LANS during Contract Transition. Post transition ER program staff have identified a need for this procedure. Therefore, the version of this procedure just prior to LANS cancellation is being blue sheeted.

• Reference N3B Blue-sheet Terminology Replacement Guide.

Approvals:

RFP-0000476

Characterization and Management of Environmental Programs Waste

Effective Date: 7/25/14

Procedure Owner: Signature: Date:

Andy Baumer 's/Mike Alexander for Andy Baumer 7/25/14

Environmental Programs Waste

Reference

REVISION HISTORY

Document No./Revision No. Issue Date Action

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

7/25/14 2 of39

Description

EP-DIR-SOP-10021, RO 3/22/12 Major revisions; New document control number Total Rewrite assigned; Supersedes SOP-5238

EP-DIR-SOP-10021, RI 7/25/14 Major revision Added technical content to procedure pertaining to operational waste. Changed forms requirements in Section 5 and added WCATS.

Environmental Programs Waste

Reference

Section

TABLE OF CONTENTS

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

7/25/14 3 of39

TITLE PAGE ................................................................................................................................. I

REVISION HISTORY

TABLE OF CONTENTS

I. PURPOSE

2. REFERENCES

3. BACKGROUND AND PRECAUTION

4. DEFINITIONS

5. CORRECTIVE ACTION PROGRAM WASTE

5.1 Area of Contamination Policy

5.2 Preparation of the Waste Characterization Strategy Form (WCSF)

5.3 Review and Approve the Completed WCSF

5.4 Amendment of the WCSF

5.5 Waste Management and Documentation

5.6 Waste Determinations and Documentation

5.7 Using the "Contained-in" Definition for Wastes

5.8 Minimization and/or Recycling of Waste

5.9 Generator Treatment of Wastes On-Site Prior to Disposal

5.10 Waste Packaging and Transport

6. OPERATIONAL WASTE

6.1 Waste Planning

6.2 Waste Characterization

6.3 Waste Packaging and Storage

6.4 Waste Documentation

6.5 Waste Disposition and Shipping

7. RECORDS MANAGEMENT

8. ATTACHMENTS

Environmental Programs Waste

Reference

I. PURPOSE

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14 4 of39

This Standard Operating Procedure (SOP) delineates the process for characterizing and managing waste generated by the Environmental Programs Directorate (ADEP) at the Los Alamos National Laboratory (LANL or Laborato1y). There are two main programs within ADEP that generate waste and each one has regulatory requirements unique to that program. The Corrective Action Program (CAP) performs environmental investigation, remediation, and decommissioning and demolition (D&D) activities that typically generate bulk volumes of water, soil and debris. The majority of the regulatory requirements for the CAP are found in the Compliance Order on Consent (Consent Order) and the NPDES Individual Permit (IP). The LANL Transuranic Waste Program (L TP) operates waste storage and remediation facilities for the Laboratory. The primary requirements documents for operational waste are DOE 0435.1, Radioactive Waste Management, and the LANL Resource Conservation and Recovery Act (RCRA) Hazardous Waste Facility Permit (HWFP).

2. REFERENCES

This SOP shall be used in conjunction with the most recent revision of LANL documents, policies, or equivalent LANL-approved contactor waste procedures associated with waste management activities.

These documents, policies, and procedures include, but are not limited to:

• ENV-RCRA-QP-010, Land Application of Groundwater

• ENV-RCRA-QA-0 I I, Land Application of Drill Cuttings

• MAN-5001, User Manual for Waste Profile Charge Code Form

• MAN-5002, User Manual for the Waste Item Inventory (Wll) Form

• MAN-5003, User Manual for The Waste Disposal Request (WDR) Form

• PI0J-14, Chemical Management

• PI0J-17, Excavation/Fill/Soil Disturbance

• P 121, Radiation Protection Requirements

• P 151-1, Packaging and Transportation

• P300, Integrated Work Management

• P313, Roles, Responsibilities, Authorities, and Accountabilities

• P330-6, Non-Conformance Reporting

• P322, Issues and Corrective Action Management

• P409, Waste Management

• P78 I -1, Conduct of Training Manual

• P930-l, LANL Waste Acceptance Criteria

• P930-2, Waste Certification Program

• P930-3, Offsite Shipment of Chemical, Hazardous, or Radioactive Waste

• EP-DIR-AP-10003, Records Management Procedure for ADEP Employees

• SOP-5181, Notebook and Logbook Documentation for Environmental Directorate Technical and Field Activities

• EP-DIR-QAP-0001-Quality Assurance Plan for the Environmental Programs Directorate

Environmental Programs Waste

Reference

2. References, cont.

• EP-ERSS-SOP-5056, Sample Containers and Preservation

Document No.:

Revision:

Effective Date:

Page:

• EP-ERSS-SOP-5057, Handling, Packaging, and Transporting Field Samples

• EP-ERSS-SOP-5058, Sample Control and Field Documentation

• EP-ERSS-SOP-5059, Field Quality Control Samples

• EP-ERSS-SOP-5061, Field Decontamination of Equipment

• EP-ERSS-SOP-5029, Drilling Plan Development

EP-DIR-SOP-10021

7/25/14 5 of39

• SOP-12.01, Field Logging, Handling, and Documentation of Borehole Materials

• SOP-06.09, Spade and Scoop Method for Collection of Soil Samples

• SOP-06.10, Hand Auger and Thin-Wall Tube Sampler

• TL-007 /TL-008/TL-1 l 2, Acceptable Knowledge Guidance

• TL-001, Waste Profile Form Guidance

• TL-003, Chemical Waste Disposal Request Guidance

• EP-AREAG-WO-AP-1157, LTP Low-Level/Mixed Low-Level Waste Data Verification/Reclassification

3. BACKGROUND AND PRECAUTION

The Consent Order is an enforcement document signed by the New Mexico Environment Department (NMED), the New Mexico Attorney General, Department of Energy (DOE), and the University of California on March 1, 2005, that prescribes the requirements for corrective action at the Laboratory.

The Consent Order contains specific requirements for management of investigation-derived waste (]DW) generated by the Laboratory in the course of corrective action, investigation, and remediation, which are typically implemented through work plans that are prepared by the Laboratory and approved by the

NMED.

Other non-Consent Order, waste-generating activities conducted by CAP include D&D activities and those driven by the LANL HWFP, such as RCRA pennitted unit closures. L TP activities that generate waste include waste repackaging, decontamination, size reduction, characterization, storage and shipping. In addition, routine facility operations and maintenance activities also generate waste.

Wastes generated by ADEP programs include hazardous waste, New Mexico special waste (NMSW), polychlorinated biphenyls (PCB) waste, low level radioactive waste (LLW), transuranic waste (TRU), mixed waste (MW) (MLLW & MTRU), and industrial and municipal solid waste. Environmental media (e.g., soil, tuff, and groundwater) and other IDW may fall into any of these regulatory classifications.

Documentation and characterization requirements beyond those described in this procedure may exist for waste intended for disposition at off-site Treatment, Storage, and Disposal Facilities (TSDFs).

Environmental Programs Waste

Reference

4. DEFINITIONS

DocumentNo.: EP-DIR-SOP-10021 Revision: I Effective Date: 7/25/14 Page: 6 of39

NOTE: A glossary of definitions associated with P409, Waste Management, is available at:

https://policy.lanl.gov/pods/policies.nsf/MainFrameset?ReadForm&DocNum=P409&FileName =P409.pdf Waste management-specific definitions not included in the glossary are provided in this section. Other definitions were modified as needed to clarify the requirements of this procedure.

Accymylatjop Start Date - T he term "accumulation start date" is the date in which the waste becomes regulated and subject to an accumulation start date. The accumulation start date for various types of wastes is:

• PCB Waste: the date that generator receives data that identifies it as a PCB-regulated waste.

• NMSW: the date that the waste container is sealed and ready for transport.

• Radioactive Waste (does not include mixed waste): the date the waste is packaged for storage or transpo1t. If the material is to be land applied, the accumulation start date does not occur until the determination has been made that the material cannot be land applied and data are available to determine that it is radioactive waste.

• RCRA Waste (hazardous waste and mixed waste): the day the waste was first managed in a <90-day storage area or a permitted unit, unless it is managed within a drill pit or an SAA. For RCRA waste in dri ll pits, the accumulation start is the day the waste is removed from the drill pit. For wastes originating in an SAA, the accumulation start date is the day the waste is removed from the SAA and stored in a <90-day storage area. If the waste is moved from an SAA to a permitted storage or treatment unit, the accumulation start date is the date the waste was received at the permitted unit. If the waste is moved from a <90-day storage area to a permitted storage or treatment unit, the accumulation start date is reset to the date the waste was received at the permitted unit.

• Returned Samples: the day the waste generator receives the returned sample.

NOTE: For making a waste determination, see "Generation Date".

Area of Coptamjpatjop - A discrete area of generally dispersed contamination, which is considered to be equivalent to a RCRA unit. Because an Area of Contamination is equated to a RCRA unit, movement within, consolidation of waste within, or in-situ treatment within the Area of Contamination does not create a new point of hazardous waste generation for purposes of RCRA (EPA Office of Solid Waste and Emergency Response, Publication 530-F-98-026).

Coptact Waste - Contact waste is material that may have come into contact with contaminated media or debris. Contact Waste includes spent personal protective equipment, contaminated sampling supplies, plastic, dry decontamination and other material that may have come in contact with contaminated media or debris.

Coptajped-lp - Environmental Media and debris contains hazardous waste when:

• It exhibits a characteristic of a hazardous waste; or it is contaminated with concentrations of hazardous constituents that originated from listed hazardous waste.

Environmental Programs Waste

Reference

4. Definitions, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14 7 of39

• Environmental Media and debris is considered to no longer contain hazardous waste when it no longer exhibits a characteristic of hazardous waste or the regulatory agency determines that concentrations of hazardous constituents from listed hazardous waste are below health-based levels based on data submitted by the facility.

~ - Debris is defined in 40 CFR 268.2 (g) as a "solid material exceeding a 60 mm particle size that is intended for disposal and that is: A manufactured object; or plant or animal matter; or natural geologic material.

Drill Cuttings Drill Cuttings-Borehole cuttings and core, soil, and rock sediments produced during the drilling, development, and rehabilitation of wells or boreholes.

Data Quality Qhjectjyes (QQQ) Process -The DQO process addresses the planning cycle for a project from problem statement through the data collection design to make decision about whether or not regulatory thresholds are exceeded.

Environmental Media - Borehole cuttings and core, soil, rock, sediments, surface water, and groundwater that are displaced during corrective action.

Generatjon Date For making a waste determination, the term "generation date", is the date the material is generated. This does not include waste generated in drill pits, or Areas of Contamination. For drill pits, the generation date begins when the waste is removed from the drill pit. For Areas of Contamination, the generation date begins when the waste is removed from the boundaries of the Area of Contamination.

Hazardous Constituent !hazardous waste constituenQ (I) a constituent that causes the administrative authority to list the hazardous waste in 40 CFR Part 261, Subpart D, or a constituent listed in Table I of 40 CFR Part 261.24; (2) According to the March I, 2005, Compliance Order of Consent (Consent Order), any constituent identified in Appendix VIII of Part 261, Title 40 CFR (incorporated by

20.4.1.200 New Mexico Administrative Code [NMAC] or any constituent identified in 40 CFR 264, Appendix IX (incorporated by 20.4.1.500 NMAC).

Hazardous Waste I) solid waste (as defined in 40 CFR 261.2 and incorporated by 20.4.1.200 NMAC) that is not excluded from regulation as a hazardous waste and is a listed hazardous waste (as provided in 40 CFR Part 261, Subpart D, incorporated by 20.4.1.200 NMAC) or a waste that exhibits any of the characteristics of hazardous waste (i.e., ignitability, corrosivity, reactivity, or toxicity, as provided in 40 CFR Pa11 261, Subpart D, incorporated by 20.4.1.200 NMAC; or is a mixture of solid waste and one or more hazardous wastes listed in 40 CFR Part 261, Subpart D (also see P409).

lndustrja) Waste - Solid waste generated by manufacturing or industrial processes that is not hazardous waste regulated under Subtitle C of RCRA or radioactive waste (also see P409).

Environmental Programs Waste

Reference

4. Definitions, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

7/25/14 8 of39

Jnvestjgatjon-derjyed waste CJPW} Solid or hazardous waste that was generated as a result of investigation and/or characterization corrective action activities. IDW may include drilling fluids, cuttings and purge water from test pit and well installation; purge water, soil, and other materials from collection of samples; residues from testing of treatment technologies and pump and treat systems;

contaminated PPE; and solutions (aqueous or otherwise) used to decontaminate non- disposable PPE (EPA Office of Solid Waste and Emergency Response, Publication 9345.3-03FS, January 1992) (also see P409).

Land Appljcatjon The placement of drill cuttings, drilling water, purge water, or development water onto land in compliance with ENV-RCRA-QP-10, Land Application of Groundwater and ENV-RCRA QP-11, Land Application of Drill Cuttings or the reuse of environmental media as described in NMED approved documents.

New Mexjco Special Waste CNMSW} - Solid waste identified in the New Mexico Solid Waste Management Regulations (20.9.1.105. BZ) as requiring unique handling, transportation, or disposal to assure protection of the environment and the public health, welfare, and safety. NMSW includes treated formerly characteristic hazardous waste, asbestos waste, ash, infectious waste, sludge, industrial solid waste, spill of a commercial chemical product, dry chemicals that become characteristic hazardous waste when wetted, and petroleum-contaminated soil.

NOTE: P409 contains specific requirements for managing special waste

Ope,-atjonal Waste Waste generated during the operation and maintenance of facilities. Some examples of operational waste though not all inclusive include repackaged waste from other facilities, empty drums, sump water and job waste i.e. plastic tape, gloves, Personal Protective Equipment (PPE), work control.

Pending land appljcation ENV has approved the land application package and the materials are awaiting placement onto land.

Polychlorjnated hjphenyl CPCR} Any chemical substance that is limited to the biphenyl molecule that has been chlorinated to varying degrees or any combination of substances which contains such substance. ( 40 CFR §761.3).

PCB Waste PCB waste is defined at 40 CFR 761.3 as those PCBs and PCB items that are subject to the disposal requirements found at Subpart D, "Storage and Disposal," of 40 CFR Pa11 761.

PCB Remediation Waste - PCB remediation waste encompasses soil, rags, and other debris generated as a result of any PCB spill not cleaned up under Subpart G but cleaned up under 40 CFR 761.61 (including materials from "old spills") or from other unauthorized disposal. Such waste includes, but is not limited to; Bulk PCB Remediation Waste, Non-Porous Surfaces, Porous Surfaces, Liquid PCB Remediation Waste, Cleanup Waste (also see P409).

Environmental Programs Waste

Reference

4. Definitions, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14 9 of39

• Bulk PCB Remediation Waste: Bulk PCB remediation waste includes, but is not limited to, the following non-liquid materials which are contaminated with PCBs: soil, sediments, dredged materials, mud sewage sludge, and industrial sludge [40 CFR 761.6I(a)(4)(i)].

• Non-Porous Surfaces: Non-porous surfaces means a smooth, unpainted surface that limits penetration of liquid containing PCBs beyond the immediate surface. Some examples are as follows: smooth uncorroded metal, smooth glass, smooth glazed ceramics, and high-density plastic that do not absorb organic solvents.

• Porous Surfaces: Unlike non-porous surfaces, porous surfaces do not prevent or minimize penetration of PCBs beyond the immediate surface. Examples are concrete, cement, corroded metal, asphalt, plaster, paint or coating on metal, paper, cardboard.

• Liquid PCB Remediation Waste: Liquid PCB remediation waste [40 CFR 76l.61(a)(4)(iv) and (a)(5)(iv)] includes but is not limited to water removed from dewatering of bulk PCB remediation waste, aqueous decantate from sediment, leachate collected from on-site storage of bulk PCB remediation waste, and run-off from fire suppression involving PCBs.

• Cleanup Wastes: Cleanup wastes [ 40 CFR 761.61 (a)(5(v)] include non-liquid cleaning materials and personal protective equipment waste at any concentration. Examples are rags, gloves, booties, and other disposable items. Cleaning solvents, abrasives, and equipment used in cleanup constitute a subcategory of cleanup wastes.

Radjoactjve Waste Low-level radioactive waste is radioactive waste that is not high-level radioactive waste, spent nuclear fuel, transuranic waste, byproduct material (as defined in Section I le (2) of the Atomic Energy Act of 1954, as amended), or naturally occurring radioactive material.

Use or Reuse A material that is either employed as an ingredient in an industrial process to make a product or employed in a pat1icular function or application as an effective substitute for a commercial product.

Waste Generator !WG) - LANL individuals whose act or process produces hazardous waste or whose act first causes a hazardous waste to become subject to regulation. (40 CFR §260.10; Title 20 of the New Mexico Administrative Code, Chapter 4, Part I, Section 100 (20.4.1 .100 N MAC)) (also see P409).

Waste Management Coordjnator !WMC} The individual responsible for coordinating waste management activities on behalf of waste generators, line managers, facility managers, field project leaders, waste management groups, and other Laboratory organizations. This individual also coordinates resolution of waste management issues on behalf of his/her waste-generating organization and reviews documents pe11aining to the management of waste.

Waste Acceptance Crjterja !WAC} - Criteria established by the receiving facility that must be met before a waste is accepted for treatment, storage, or disposal. Waste acceptance criteria may involve the physical form ofa waste, a waste's container, its radioactivity, packaging, labeling, etc. (also see P409).

Environmental Programs Waste

Reference

4. Definitions, cont.

Document No.:

Revis ion:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14 10 of39

Waste Compliance apd Trackiui: System <WCATS} - A software application that has been specifically designed to manage LANL's waste from cradle-to-grave. The system provides the proper support needed for characterization, generation, processing, and shipment of all waste created at LANL.

REQUIRED DOCUMENTS AND FORMS.

Descriptions of commonly used forms required to document waste management activities are listed below. Forms and guidance can be found at http://int.lanl.gov/environment/waste/flst/full list.shtml

• Land Application Data Certification Sheet. This form is required by ENY-RCRA-QP-1 0. It must be completed by the Generator or their designee and approved by ENV prior to land application of drill ing, development, rehabi litation, and sampling purge waters to ensure the requirements of the NMED-approved NOi Decision Tree, Land Application of Drilling, Development, Rehabilitation, and Sampling Purge Water, can be met.

• Land Application Field Certification Sheet. This form is required by ENY-RCRA-QP-10. It must be completed by the Generator or their designee after land application certifying that all procedural requirements for land application of drilling, development, rehabilitation, and sampling purge waters were met.

• Post Land Application Field Certification Sheet. This form is required by ENY-RCRA-QP-11. It must be completed by the Generator, Project Manager, STR, or their designee at the time of land application of drill cuttings to certify that all procedural requirements were met. Any deviations from the Request for Land Application of Drill Cuttings Form must be documented on the Field Certification Sheet and approved by ENV prior to land appl ication.

• Request for Land Application of Drill Cuttings Form. This form is required by ENY-RCRA-QP-

11. It must be completed by the Generator or their designee and approved by ENV prior to land application of dril l cuttings. It is used to ensure requirements of the NM ED-approved NOi Decision

Tree, Land Application of IDW Solids Form Construction of Wells or Boreholes, can be met.

• Uniform Hazardous Waste Manifest. The manifest is used to track hazardous waste shipped from a generator' s s ite to the site of its disposition.

• Waste Characterization Strategy Form (WCSF). The WCSF is a planning and implementation document to be prepared before certain waste-generating activities are undertaken. The WCSF is required for Consent Order work but may be prepared for other ADEP work as necessary. The WCSF documents planned field activities and the characterization approach for each waste stream expected to be managed. The WCSF is used to implement the IDW requirements of the work plan.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

I

Effective Date: 7/25/14 Reference Page: 11 of 39

5. CORRECTIVE ACTION PROGRAM WASTE

Some steps in the following process must be completed by LANL personnel while others may be completed by subcontractors. When a subcontract activity will generate waste, the Exhibit D or Exhibit F must specify which waste management functions in the procedure will be performed by subcontractor, as well, as whether the subcontractor will complete some of the documentation required by this procedure.

5.1 Area of Contamination Policy

I. Where appropriate, establish an Area of Contamination (AOC) in accordance with this procedure at least 30 days prior to waste generation in the project area. The AOC designation must be approved by NMED prior to implementation.

NOTE: The AOC Policy allows certain discrete areas of generally dispersed contamination to be considered RCRA Land Disposal Units and, thus, movement and in-situ treatment qf hazardous waste is allowed without triggering land disposal restrictions or minimum technology requirements. However, NMED has not supported establishing an AOC during investigation, remediation or corrective measures projects unless they have specifically approved its use.

Investigation and remediation activities will not create a new point of hazardous waste generation if carried out within the NMED-approved AOC. Therefore, the 90-day clock for hazardous waste generation will not be triggered as long as the waste remains inside the

AOC boundary. The AOC Policy applies to any hazardous remediation waste (including non media waste) that is in or on the land. It does not apply to non-hazardous wastes, such as

LLW, PCB remediation waste, TRU, and NMSW, etc. Each of these wastes must be managed in accordance with their specific accumulation requirements.

2. To request an AOC designation, provide the following information to the ENV-CP Rep:

• A schematic showing the boundaries of the AOC (include roads if it will assist in transporting wastes within the AOC).

• The types and forecasted volumes of wastes that will be managed under the policy.

• How the wastes will be managed within the AOC boundaries (e.g., in piles with best management controls, in containers, etc.).

• Whether some of the environmental media will be reused and how the decision will be made for its reuse ( e.g., it meets residential soil screening levels).

3. The ENV Rep prepares the request for AOC designation and submits to NMED for approval.

Distribute copies to the Waste Generator (WG), PM and Waste Management Coordinator

(WMC).

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

I

Effective Date: 7/25/14 Reference Page: 12 of39

5.1 Area of Contamination Policy, cont.

NOTE: For Consent Order-driven work, NMED requires that the AOC designation request be submitted at least 15 days prior to initiation of field activities.

5.2 Preparation of the Waste Characterization Strategy Form (WCSF)

I. The WMC assigned to the waste generating activity prepares the WCSF.

2. Before preparing the WCSF, the WMC shall:

• Identify all waste streams that are anticipated to be generated by the work.

• Working with the subcontractor, identify probable off-site TSDFs for the waste anticipated to be generated. Identified waste streams should align with probably TSDFs waste profiles whenever possible.

• Identify requirements specified in the work plan, closure plan, or other approved work documents.

• Review available data and source information for the planned work sites to determine how to initially manage wastes (e.g., hazardous, non-hazardous, LLW, etc.). Reference appropriate documents and data that support the initial handling decisions in the WCSF.

• Determine whether existing data meets the requirements for acceptable knowledge (AK), as specified in ENV-RCRA-TOOL-112.0, Acceptable Knowledge, for hazardous or radiological constituents. If there is reliable, relevant, and traceable information based on AK, document the AK in the WCSF. lfnecessary, develop a strategy for sampling and analysis that will complete the characterization for the waste stream.

• lfthere is no reliable information concerning hazardous or radiological constituents, develop a strategy for sampling and analysis that will identify and quantify all chemicals of potential concern in the waste stream and document in the WCSF.

• Review the most recent waste acceptance criteria (WAC) for potential receiving TSDFs to ensure that analytical suites identified in the WCSF meet the receiving facilities'

WAC.

• The waste generator shall ensure that any radioactive and mixed wastes anticipated to be generated are covered by an approved Radioactive Waste Management Basis (RWMB).

If not, request that the RWMB report preparer update the RWMB.

• If the waste is a category that can be land applied (drilling fluids, purge water, development water, or drill cuttings), review the land application procedures to ensure that the analytical suites identified in the WCSF are appropriate for land application.

5.3 Review and Approve the Completed WCSF

I. Initiate the review, approval, and tracking of the draft WCSF in accordance with procedure

SOP-4066, Document Development and Deliverables Compliance Process. Typically, allow a two-week minimum for the review and approval process.

Environmental Programs Waste

Reference

5.3 Review and Approve the Completed WCSF, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14 13 of39

2. The PM, ENV Rep, WMC, and WG shall review and confirm that the draft WCSF is consistent with the approved work plan along with any "contained in" determinations, Area of Contamination designations, Due Diligence reports, or other provisions approved by

ENV- and/or the NMED. All shall provide comments on the WCSF.

3. The PM, ENV Rep, and WMC shall approve and sign the final WCSF when comments have been resolved and incorporated into draft WCSF.

4. The WMC and PM shall ensure all field operations personnel are briefed on, and agree to comply with, the WCSF requirements. Briefing documented by attendance signature page.

5.4 Amendment of the WCSF

I. In the event a WCSF Amendment must be prepared, the author shall ensure that a WCSF prepared under previous versions of this procedure is amended as needed to meet current procedural requirements.

2. The author should amend the approved WCSF under the following conditions:

• when an unanticipated waste is generated,

• when an approved strategy for management of a waste stream significantly changes, or

• when a selected TSDF changes necessitating a change to WAC compliance.

3. When a correction to the approved form is necessary, complete the WCSF Amendment Form (Attachment I).

4. Submit the WSCF Amendment to the original reviewers, as appropriate, for review and comment.

5. The author shall obtain resolution to all comments and incorporate them into the WCSF Amendment.

6. The original signatories shall approve and sign the WSCF Amendment.

5.5 Waste Management and Documentation

I. Obtain appropriate waste containers with requisite certification and documentation. If the project contract stipulates the subcontractor provide the waste containers, the subcontractor shall provide the WMC with copies of requisite documentation.

• Personnel will be trained on proper container closure and all packages will be closed according to the manufacturers' instructions.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-1 002 1

I

Effective Date: 7/25/ 14 Reference Page: 14 of39

5.5 Waste Management and Documentation, cont.

• Inspect containers in accordance with DOT standing inspection requirements before use.

If the containers have been previously used, ensure they are adequately decontaminated before re-use.

• Ensure containers are properly marked and labeled and/or meet LANL requirements for free release.

• Do not use compromised or otherwise damaged containers for waste packaging.

2. If WCSF identifies direct offsite disposal of Radioactive Waste to a Non-DOE TSDF, verify with LANL WPS-LL WO that there is an approved Exemption Request in place. If an approved Exemption Request is not in place, supply the required data to WPS-LL WO in accordance with ENV-RCRA-TOOL-602.

3. Establish appropriate areas for accumulating/storing waste (e.g., <90 day accumulation area, SAA, Universal Waste Area, Used Oi l Area, NMSW Area, radioactive waste staging or storage area) in accordance with P409, Waste Management. Register regulated waste storage areas and provide Site ID Number(s) to the FWMT, WMC, and WG.

• RCRA waste accumulation site registration (http://hsr web2.lanl.gov/~esh 19/databases/hwts form.html)

• Radioactive Waste Staging/Storage registration

(http://hsr-web2.lan1.gov/~esh 19/databases/rad registrationform.shtml).

4. Verify that the registered waste area is properly posted, managed, and inspected, as necessary.

5. Store wastes in new, unused containers, unless specifically permitted to use reusable containers. Reusable containers must have documented radiological survey results showing the container is not contaminated and has been released.

6. Perform all necessary inspections, recordkeeping, and reporting requirements for accumulation, staging, or storage areas in accordance with P409, Waste Management and the LANL Hazardous Waste Facility Permit.

7. Participate in periodic LANL and regulatory agency waste management compliance inspections.

8. If the waste(s) requires sampling for characterization, the Subcontract Technical Representative (STR) shall inform the FWMT and WMC of the intent to sample.

Environmental Programs Waste

Reference

5.5 Waste Management and Documentation, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14

9. Collect representative waste samples in accordance with EPA guidance (EPA, 1986. SW- 846, Chapter 9 (Sampling Plan) http://www.epa.gov/epawaste/hazard/testmethods/sw846/pdfs/chap9 .pdf or an approved LANL and/or Subcontractor sampling plan.

I 0. Manage samples in accordance with LANL procedures (EP-ERSS-SOP-5056, Sample Containers and Preservation, EP-ERSS-SOP-5058, Sample Control and Field Documentation).

11. Establish waste management requirements for returned samples, if appl icable, based on the approved work plan, WCSF, or waste characterization plan.

12. The Waste Services Manager should perform independent audits of waste management.

Inform the WG of any waste management issues.

13. Disposition waste in compliance with regulatory time limits. lfregulated waste cannot be dispositioned within required time limits, notify the PM and the ENV Rep at least IO days prior to the time limit expiration.

14. Ensure all wastes, materials, or equipment are dispositioned, and not left on-site at the end of project field-work w ithout the prior approval of the appropriate ADEP Program Director.

5.6 Waste Determinations and Documentation

I. Provide the waste Event Numbers and Sample Numbers to the LANL or project data steward.

2. The data steward shall track the analytical or characterization data from sample ID or Event

Number.

3. Sample analysis turnaround must be appropriate to meet regulatory accumulation time limits.

4. ADESH-O1O performs data validation.

5. The data steward may request Automated Waste Determinations (A WDs), as appropriate, and provide analytical data to the WMC for waste determination. The data steward may provide radiological analytical results to waste characterization engineers for LL W waste determination.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

Effective Date: 7/25/14 Reference Page: 16of39

5.6 Waste Determinations and Documentation, cont.

6. MCs shall make waste determinations/characterization within 30 days of the date of waste generation unless otherwise specified in the WCSF. ENV-may provide assistance in making waste determination, if necessary or requested.

7. If a "No Longer Contained-In" determination is needed (see Section 2.8), request that ENV initiate the "No Longer Contained-In" request when waste determinations are complete but no later than day 70 of the accumulation time limit or 15 working days before the end of the accumulation time limit, whichever time is less.

8. For wastes in <90-day areas:

• For wastes in a <90-day area, if a waste determination cannot be made within 30 days, submit a WEF to LANL Waste Services before day 30 of the waste accumulation time limit.

• If a waste determination is not complete by day 70 or 15 working days before the end of the accumulation time limit (whichever is shorter), request that ENV determine whether there is justification to request a <90 day accumulation time limit extension from the

NMED. Note that extensions can only be granted if there are extenuating circumstances, which do not include failure to make a waste determination, However, providing NMED with time to review a "contained-in" request is a valid reason for requesting a <90 day accumulation time limit extension. Concurrently, begin contingency planning in the event that the extension request is not granted.

• At Day 80 of the <90 day clock, if the request for a <90 Day extension is not granted by

NMED, prepare to ship as regulated waste prior to expiration of the <90 day clock.

9. Determine whether existing Waste Profile Forms (WPFs) that are still active can be used for newly-generated wastes. If not, prepare a new WPF in WCATS. If a "contained-in" determination or due diligence review applies to the waste, upload the appropriate document to the WPF. Ensure that required signatures have been obtained on the EP

Document Signature Form from ENV-CP.

I 0. Submit the WPF through WCATS.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

I

Effective Date: 7/25/14 Reference Page: 17 of39

5.6 Waste Determinations and Documentation, cont.

11. Obtain and complete the offsite TSDF's WPF, and obtain TSDF approval for the off-site

WPF, if applicable.

12. WCA TS will notify the WMC that an approved LANL WPF is in place for waste shipment.

Notify the WG and WMC that an approved off-site TSDF WPF is in place for waste shipment, if applicable.

5. 7 Using the "Contained-in" Definition for Wastes

I. Where appropriate, ENV will implement the "Contained-in Policy" in accordance with this procedure.

• Waste that contains a characteristic hazardous waste can only become non-characteristic ifit is treated. Some types of treatment may occur on-site but restrictions apply.

Coordinate with the ENV Rep and obtain documentation confirming the activity is currently allowed under the LANL HWFP before treating any wastes. Determination that a waste is no longer characteristic requires no formal approval by NMED. Land Disposal

Restrictions (LOR) will still apply to the de-characterized waste (i.e., waste must meet

LOR treatment standards before disposal).

• Regulatory agency approval is required to declare that waste that contains hazardous constituents originating from listed hazardous waste sources (F-, K-, P-, or U-listed) is no longer listed. NMED makes this determination after reviewing data submitted by LANL that shows that the concentrations of hazardous constituents are below health-based levels, such as EPA Drinking Water Standards or NM WQCC groundwater standards.

2. When environmental media and/or debris are contaminated with hazardous constituents from listed hazardous waste, the WMC shall submit all applicable data and site information to the

ENV Rep for assistance in determining whether concentrations of the hazardous constituents are below health-based levels.

3. If contaminant concentrations are below health-based levels, ENV will prepare and submit a request for a No Longer Contained-In approval to NMED on behalf of the project, requesting that NMED determine that the media/debris no longer contains listed waste.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

I

Effective Date: 7/25/14 Reference Page: 18 of39

5.7 Using the "Contained-in" Definition for Wastes

4. ENV will provide a copy of the letter requesting "contained-in" approval and the NMED letter approving the 'contained-in" to the WG, and WMC.

5. Ensure the "No Longer Contained-In" determinations approved by NMED are implanted as pa11 of the project's waste management activities. Upload the "No Longer Contained-In" request and approval letter to applicable WPF_in WCATS.

5.8 Minimization and/or Recycling of Waste

I. Reduce the volume of waste generated by as much as is technically, legally, and economically feasible.

• Evaluate environmental media (soil, rock, and well drilling development, rehabilitation, and purge water) for land application, in accordance with ENV-RCRA-QP-010, Land

Application of Groundwater.

2. Evaluate use of Green is Clean (GIC). GIC waste generated in radiological control areas includes all non-regulated waste that has been actively segregated as "clean" (that is, non radioactive) through the use of waste-generator AK. Environmental program waste meeting the requirements should be considered for GIC: paper products and cardboard, pieces of low density wood small enough to fit into the approved containers (e.g., GIC green-striped bags, 2-cubic foot cardboard boxes with or without plastic lining, or other plastic bags or cardboard boxes as approved by the GIC Operations systems engineer);

plastic products including common Personal Protective Equipment (PPE); and/or cloth or rags, including nylon and other low-density synthetic fabrics. Small amounts of high-density material such as dirt, dust, or other debris incidentally associated with low-density GIC waste are acceptable. However, dirt and dust contain natural radioactivity that may prevent the waste from passing the verification check. Packaging, barcoding, restrictions and weight requirements for Green Is Clean can be found in the LANL WAC, P930-l, Attachment 12.

3. Report waste minimization and/or recycling efforts to the WG at the end of field operations and in Consent Order-required IDW reports.

NOTE: This ieformation is included in an annual report, the Hazardous Waste

Minimization Report, which is a requirement of Permit Section 2.9 of the LANL

HWFP.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

I

Effective Date: 7/25/14 Reference Page: 19 of 39

5.9 Generator Treatment of Wastes On-Site Prior to Disposal

Certain types of treatment can be conducted in <90 day accumulation areas or in-situ in an Area of Contamination. Treatment in these areas does not require a RCRA permit but must be documented by ENV. Contact ENV before any on-site treatment is conducted.

5.10 Waste Packaging and Transport

I. Verify a LANL Waste Profile Form is active for the waste to be shipped.

2. Verify that an off-site waste profile has been completed and is approved and active for the waste to be shipped, if being disposed in an approved non-DOE TSDF in accordance with

P930-3, Off-Site Shipment of Chemical, Hazardous, or Radioactive Waste.

3. Complete the WDR and submit WDRs as required for each waste type in accordance with

P930-1, Waste Acceptance Criteria:

NOTE: Waste generators may request exemptions Ji-om or exceptions to the LANL WAC by using Form 1973 Waste Acceptance Criteria Exception Form (WEF). Exemptions or exceptions are requested when a generator cannot comply with a specific WAC or certification requirement, or when a requirement is not applicable.

4. Notify the WMC and WG when the WDR and Uniform Hazardous Waste Manifest, if required, have been approved.

5. The transpotters shall transport wastes in accordance with the off-site receiving facilities'

WAC and DOT requirements.

NOTE: For wastes managed in a <90-day accumulation or NMSW areas, the WMC must arrange for shipment at Day 80, identified as a compliance driven RUSH to Waste Management Services. At Day 90 of the <90 day clock, if regulated waste is not shipped ji-0111 the <90 day area, notify the ENV representative and support any actions required by ENV.

6. Ensure all waste transp01tation containers for chemical and radiological hazards are labeled in accordance with DOT requirements and P 121, Radiation Protection

7. Ensure that the DOT rating for maximum container weight is observed.

Environmental Programs Waste

Document No.:

Revision:

EP-DIR-SOP-10021

I

Effective Date: 7/25/14 Reference Page: 20 of39

5.10 Waste Packaging and Transport, cont.

8. For radioactive waste stored in supersacks to be shipped off-site:

• Personnel shall be trained in the correct closure of supersacks and all supersacks will be closed in accordance with manufacturers' instructions.

• Supersacks should be stored on plastic sheeting in a slightly or gently sloped area that will allow precipitation or other moisture to drain. In situations where the WG, WMC and/or PM anticipate the supersacks being stored for three months or more, or during snow or rain events, the supersacks should be stored under tarpaulins or other cover.

• The WG, WMC, and PM shall determine whether the supersack should be overpacked.

• Each supersack shall receive a visual inspection to ensure labels are attached and legible, and that the supersack is secure and shows no signs of degradation. Lifting straps and the associated stitching used to attach the straps to the supersacks shall be inspected for integrity.

• Original LANL Item ID numbers shall remain on the original supersack.

• All DOT labels shall be applied to the outer overpack.

• Prior to loading into the overpack, a radiological survey of the outside surface of the supersack shall be performed.

• Prior to loading onto the truck, a radiological survey of the outside surface of the overpack shall be performed.

9. Ensure the waste to be shipped is in compliance with the approved waste profile.

IO If the waste is going to NNSS or a commercial disposal facility that requires containers to be "sealed" by the generator prior to shipment, record the date the container was sealed in the project notebook.

11. Coordinate waste transportation with the disposal facility in accordance with P930-3, Offsite Shipment of Chemical, Hazardous, or Radioactive Waste.

NOTE: Transportation shall be by an approved carrier in accordance with DOE 's Motor Carrier Qualification Program (MCEP approved).

12. Notify the WG, WMC, and LANL Transp011ation Coordinator of scheduled ship/pickup date of waste.

13. Inspect waste containers prior to shipment, and document the evaluation in the project notebook.

14. HMPT personnel complete off-site shipment DOT inspection per DOT checklist.

Environmental Programs Waste

Reference

5.10 Waste Packaging and Transport, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14

15. Verify that all shipping containers are secured by the carrier prior to transportation per DOT checklist.

6. OPERATIONAL WASTE

6.1 Waste Planning

Operational Waste is waste generated during the operation and maintenance of facilities within

Environmental Programs (EP). Some examples of operational waste though not all inclusive include repackaged waste from various facilities, empty drums, sump water and job waste. Since operational waste encompasses a wide variety of waste matrices, a cradle to grave disposal strategy should be mapped out identifying preliminary characterization requirements before waste generation or repackaging. The goal of the waste generation organization is to understand the packaging and disposal requirements before waste generation in order to facilitate waste minimization and eliminate rework due to non-compliant waste.

Characterization of operational waste is to be completed using documentation from the generating organization prior to handoff of data to the Waste Management Coordinator (WMC). The WMC is responsible for entering the applicable data into WCA TS. The WMC verifies a current LANL waste profile exists in WCATS or creates a new LANL profile based on the waste stream identified for off-site disposal. An independent review verification of the characterization and

WCA TS data will be performed via EP-AREAG-WO-1157. The LANL transportation coordinator is responsible for coordinating shipment and manifesting activities with the off-site TSDF shipping subcontractor or Indefinite Delivery/Indefinite Quantity (IDIQ) contract.

The Waste Acceptance Criteria of the final off-site TSDF should be consulted as to waste acceptance requirements applicable to the waste generated during waste planning and characterization. The eight waste types generated under EP include Industrial, Universal, New

Mexico Special, Toxic Substances Control Act (TSCA), RCRA Hazardous Waste, Low Level and

Low Level Mixed and Transuranic (TRU) Waste. Each type of waste stream will have specific requirements in relation to disposal of the final Off-Site TSDF to be addressed in the preliminary planning phase. Examples of components to be addressed during this phase include applicable radiological requirements, RCRA Hazardous and TSCA constituents, and the type of packaging configurations that are acceptable along with DOT requirements. Various resources are available to the generating organization during the waste planning stage. The P409 tools on the LANL intranet are available for waste management and characterization guidance concerning the various waste streams that encompass operational waste. In addition the appropriate Waste Management

Coordinator (WMC), the Low Level waste characterization group and LANL Transportation

Coordinator are available for waste planning assistance. Verification of each waste package is required and is

Environmental Programs Waste

Reference

6.1. Waste Planning, cont.

Document No.:

Revision:

Effective Date:

Page:

EP-DIR-SOP-10021

I 7/25/14 22 of39 formally documented utilizing Attachment 1 & 2 of procedure EP-AREAG-WO-1157. Waste planning should include consideration of the documentation required for the verification process in accordance with EP-AREAG-WO-1157.

The Waste Management Coordinator (WMC) assigned to the area of waste generation should be consulted as to the availability of a LANL Waste Profile Form (WPF) or whether a new profile form will need to be created. The following resources are available during the waste planning process including but not limited to:

• Waste Management Coordinator

• Waste Characterization Group

• LANL DOT Representative

6.2 Waste Characterization

Characterization is performed utilizing the P409 tools in order to meet the various regulatory requirements for the waste streams generated and managed by EP. This ensures all appropriate steps have been taken to characterize and verify the waste characterization process of each waste item. Waste is characterized using Acceptable Knowledge (AK) and/or direct sampling and analysis. In addition characterization methods such as Real Time Radiography, Non Destructive

Assay or Flammable Gas Analysis can be utilized to support AK and determine the physical and chemical components of the waste.

AK is a method used by the waste generator to document characterization of wastes to reduce or eliminate the need for sampling and analysis. Sampling of L TP waste streams is typically difficult due to waste form (i.e. heterogeneous debris) or As Low As Reasonably Achievable (ALARA) concerns. It is therefore essential that AK is well documented.