300 UNION 60 00 CO 80228

TeCH LAw INC E (602) 230-8000

FAX (602) 230-1799

February 25 2002

Mr James Bearzi Mr David Cobrain State of New Mexico Environment Department Hazardous Waste Bureau 2905 Rodeo Park Drive East Building One Santa Fe New Mexico 87505-6303

Reference Work Assignment No Y515 06082350 State ofNew Mexico Environment Department Santa Fe New Mexico General Permit Support Contract Research and Permitting Support for the Los Alamos National Laboratory Permit Conditions and Schedule of Compliance for the Los Alamos National Laboratory rechnical Area 54 Pm1 B Permit Renewal Application Task 3 Deliverable

Dear Mr Bearzi and Mr Cobrain

Enclosed please find the deliverable for the above-referenced work assignment The deliverable consists of permit conditions and a schedule of compliance for the Los Alamos National Laboratory (LANL) Area 54 Part B Permit Renewal Application Dated December 2000 herein referred to as the application

As noted in the Task 1 deliverable the application does not appear to address all units within each area For example Material Disposal Pit A (MDA-A) in Area L and several MDAs in Area G are not addressed within the application but rather referenced to Module VIII Also the application was not complete The closure plans for Area Land TA-54 West were not provided Thus the pennit conditions and schedule of compliance were only developed for the sections and areas of the application that were provided

Since the application was lacking in detail and was found to be severely deficient most of the technical comments wcre incorporated into the schedule of compliance We had provided this schedule atNMFD request but are somewhat concerned that several major deficiencies which are addressed as compliance schedules are of such a magnitude that

32407

1111111 I 11111 11111 1111111111111 ATLANTA BOSTON CHIOGO bull DALLAS DENVER LOS ANGELES MINNEAPOLIS NEW YORK PHILADELPHIA PHOENIX SA gtCvv ONDC

the application should be revised In addition it may be difficult to jllstify the number and magnitude orthe compliance issues to an administrative hearing officer as well as the general public lvlost of the compliance schedules (calendar days) listed in section B of the compliance schedule arc based on best technical estimates and engineering judgment NMED may wish to modify the specified calendar days Also it is not clear what the final format for the permit will be thus at some time in the future it may be necessary to modify the format or numbering of the permit conditions and compliance schedule

Although the table of contents of the permit application indicated that closure plans for all areas in TA-54 were included in the application the application did not contain the closure plans for Area L (Attachment Fl) and TA-54 West (Attachment F3) A compliance schedule (B-l1) was included asking for the closure plans for Area Land 1A-54 West NMED may wish to remove this compliance schedule if these plans have previously been submitted by the Permittees and reviewed by NMED

The document is formatted in Word The permit conditions were formatted in a module (Module III) format while the compliance schedule follows the format of an attachment to a module (Attachment A of Module II General Facility Conditions)

The deliverable was emailed to each of you 011 February 21 2002 at James~Bearzi(c)llmenvstatel1m us and David_ Cobrain(clnmenv statenmus respectively [fyou have any questions please call me at (303) 763-7188

Sincerely

J

June K Dreith Program Manager Enclosure

cc Ntr Carl Will IMED Mr John Keiling IMED Ms Paige Walton TechLaw Mr B Jordan TechLaw Central Files Denver Files

TECH LAw INC

the application should be revised In addition it may be difficult to jllstify the number and magnitude orthe compliance issues to an administrative hearing officer as well as the general public lvlost of the compliance schedules (calendar days) listed in section B of the compliance schedule arc based on best technical estimates and engineering judgment NMED may wish to modify the specified calendar days Also it is not clear what the final format for the permit will be thus at some time in the future it may be necessary to modify the format or numbering of the permit conditions and compliance schedule

Although the table of contents of the permit application indicated that closure plans for all areas in TA-54 were included in the application the application did not contain the closure plans for Area L (Attachment Fl) and TA-54 West (Attachment F3) A compliance schedule (B-l1) was included asking for the closure plans for Area Land 1A-54 West NMED may wish to remove this compliance schedule if these plans have previously been submitted by the Permittees and reviewed by NMED

The document is formatted in Word The permit conditions were formatted in a module (Module III) format while the compliance schedule follows the format of an attachment to a module (Attachment A of Module II General Facility Conditions)

The deliverable was emailed to each of you 011 February 21 2002 at James~Bearzi(c)llmenvstatel1m us and David_ Cobrain(clnmenv statenmus respectively [fyou have any questions please call me at (303) 763-7188

Sincerely

J

June K Dreith Program Manager Enclosure

cc Ntr Carl Will IMED Mr John Keiling IMED Ms Paige Walton TechLaw Mr B Jordan TechLaw Central Files Denver Files

TECH LAw INC

TASK 3 DELIVERABLE

PERMIT CONDITIONS AND SCHEDULE OF COMPLIANCE FOR THE LOS ALAMOS NATIONAL LABORATORY TECHNICAL AREA 54

PART B PERMIT RENEWAL APPLICATION

NMED-HSV Corrective Action Chapter of the RCRA Permit Renewal for the Los Alamos National Laboratory

Submitted by

TechLaw Inc 300 Union Boulevard Suite 600

Lakewood CO 80228

Submitted to

Mr David Cobrain Mr James Bearzi

State of New Mexico Environment Department Hazardous Waste Bureau

2905 Rodeo Park Drive East Building One

S~tnta Fe New Mexico 87505

In response to

Work Assignment No Y513 06082600

February 2002

LANL TA)Part B Renewal Application February 2002

HI Module HI Container Stonlge

lilA Designateci Container St()rage UI1its

This module authorizes the storage and management of hazardous mixed low-level waste and or mixed TRU waste containers in Area L Area G and Technical Area 54 West (TAshy54 West) container storage areas of the Los Alamos National Laboratorys (LANL) TAshy54 described below Specific facility and process information for the storage and management of these wastes is incolllorated in the Permit Renewal Application Container Storage Sections 20 and 40 and Attachments F2 and G

IIIAI Designated Containcr StOlage Areas

TA-54 consists of three container storage areas Area L Area G and TA-54 West Area L is located in the central portion ofTA-54 at LANL Area L comprises a total enclosed area 01258 acres Area G is located on 63 acres in the east-central portion oCTA-54 TA-54 West is located in the northwest corner ofTA-54 and comprises approximately 2 acres

The Permittees may store and manage hazardous mixed low-level andor mixed TRU waste in TA-54 container storage areas in Area L Area G and TA-54 West provided the Permittees comply with the following conditions

[ILAIa Area L Storage Containers - the Permittees shall store hazardous and mixed low-level vaste in containers specitied in the Renewal Application Section 112 These containers are limited to 30- 83- 85- and 11 a-gallon steel polyethylene and fiber drums fiberglass-reintorced plastic on plywood (FRP) boxes steel standard waste boxes (SWBs) steel boxes metal overpack boxes cardboard shipping containers gas cylinders roll-off bins and labpaeks Any other container must be identitied and provided tor approved use as outlined in the Module II Attachment A Container Storage Area Schedule ofCompliancc 1i3n

llL1 b Area G Storage Containers the Permittees shall store hazardous mixed lowshylevel and mixed TRU waste in containers specified in the Renewal Application Section 2122 These containers are limited to 30- 55- 83- 85- and 11 O-gallon steel polyethylene and fiber drums FRP boxes SWBs steel boxes metal overpack boxes wooden boxes roU-offbins and ten-drum overpacks (TOOPs) Any other container such as various small containers must be specifically identified and provided for approved use as outlined in the Module II Attachment A Container Storage Area Schedule of Compliance B3a

IILAte TA-54 Wcst Storage Contltliners - the Permittees shall store solid mixed 10wshylevel and mixed TRU vastc in containers specified in the Renewal Application Section 2132 These containers are I imitcd to 30- 55- 83- 85- and 11 O-gallon steel polyethylene and tiber drums SWBs steel boxes metal overpack boxes TRUPACT-ll containers and TOOPs Any other container such as various small containers and

PERMIT MODULE III Page III-I of 8

LANL TA~rPart B Renewal Application February 2002

irregularly shaped containers must be specifically identified and submitted for approved use as outlined in the Module It Attachment A Container Storage Area Schedule of Compliance B3a

[IlA-Id Storagc contaiI1cr Enlissioll Controls - all containers llsed to contain hazardous waste shall control air pollutant emissions from each containcr in accordance with 2041500 NMAC (incorporating 40 CFR 264 Subpart CC) Pursuant to 2041500 KMAC (incorporating 40 CFR 2641(86) all hazardous waste containers shall meet the appropriate container control based on container capacity of either Container Levell Container Level 2 or Container Level 3 standards

mA2 Storage Structures Locations and Capacitics

The Permittees may store hazardous and mixed low-level waste in the designated areas within the fence line of Area L storage dome TA-54-215 canopy TA-54-216 concrete containment structure TA-54-32 containment structure TA-54-35 sampling pad TA-54shy36 transportation pad TA-54-58 and storage shafts 36 and 37 Other areas that may be used to store hazardous and mixed low-level waste as identified in terms with the Module II Attachment A Container Storage Area Schedule of Compliance Bl The Permittees may store quantities of hazardous and mixed low-level waste at these locations within Area L not to exceed the maximum capacities as provided in accordance with Module [I Attachment A Container Storage Area Schedule of Compliance B2 Area L shaH be limited to an overall storage capacity of453810 gallons or the equivalent of 8251 55-gallon drums

The Permittees may store hazardous mixed low-level and mixed TRl~ wastc in the designated areas within the fence line of Area G storage domes asphalt-covered areas storage shaft field sheds pre-engineered structures TA-54-412 DVRS DVRS Modular Containment Structure and TA-54-420 CHAPS Other areas that may be used to store hazardous mixed low-level and mixed TRU waste as identified in terms with the Module 11 Attachment A Containcr Storage Area Schedule of Compliance Bl The Permittees may store quantities or hazardous mixed low-level and mixed TRU waste at these locations within Area G not to exceed the maximum capacities as provided in accordance with Module II Attachmcnt A Container Storage Area Schedule of Compliance 82 Area G shall be limited to an overall storage capacity of 7331995 gallons of waste

The Permittees may store solid mixed low-level and mixed TRU waste in the designated areas within the fence line of lA-54 West indoor and outdoor storage pads (TA-54-38) Other areas that may be used to store solid mixed low-level and mixed TRU waste as identified in terms with the Module II Attachment A Container Storage Area Schedule of Compliance Bl The Permittees may store quantities of solid mixed low-level and mixed ~rRU waste at these locations within TA-54 West not to exceed the maximum capacities as provided in accordance with the Module II Attachment A Container Storage Area Schedule of Compliance 82 T A-54 West shall be limited to an overall storage capacity of 11660 gaJ Ions or the equivalent of 212 55-gallon drums

PERMIT MODULE 1lI Page lIT -2 of 8

LANL TA-341)art B Renewal Application February 2002

1IlA2a Storage of Containers containers will be stored in a manner preventing contact with any fjee liquids Containers which are not elevated by design or cannot demonstrate waste compatibility shall be stored on either pallets or steel grates over recessed secondary containment as described in Renewal Application Section 2112

IIIA2 b Minimum Aisle Space the Permittees shall maintain a minimum aisle space of 3 feet between rows

lILA2c Storage Configuration - the Permittees shall maintain storage confIgurations as submitted in accordance with Module ll Attachment A Containcr Storage Area Schedule of Compliance B2

The Permittees shall stack drums to a maximum of three high FRP boxes SWBs and other boxes shall be stacked to a maximum of three high unless size and weight restrictions prohibit stacking due to safety concerns The Permittees shall establish a maximum size and weight for the FRP boxes SWBs and other boxes containers to be stacked three high

IllA3 Container Handling and Inspection

Pursuant to 2041500 NMAC (incorporating 40 CFR 26431) the Permittees shall conduct at a minimum weekly inspections of each of the container storage areas Inspections shall include checking for leaking containers and for deterioration of containers and the containment systems as caused by corrosion or other factors The Permittees shall maintain written documentation of the inspections

TILAAPreparedness and Prevention

PUfsuant to 2041500 NMAC (incorporating 40 CFR 26435) lhe Permittees shall ensure that each unit has been or vil I be designed constructed maintained and operated to minimize the possibility of a fire explosion Of any unplanned sudden Of non-sudden release of hazardous or non-hazardous waste constituents to the air sailor suriace water which could threaten human health or the environment

IlLE Permitted and Prohibited Waste Identification

I11B1 Permitted Waste

The Permittees may store and manage hazardous and mixed low-level wastes at Area 10 hazardous mixed low-level and mixed TRU wastes at Area G and solid mixed low-level and mixed TRU wastes at TA-54 West provided the Permittees comply with the following conditions

1IIBIa Waste Analysis Pl~ all waste shall be characterized to comply with the waste analysis plan specified in renewal application Attachment B

PERMIT MODULE III Page JII-3 of 8

UNL TA-)41art B Renewal Application February 2002

IllElb Hazardous Waste Codes all waste shall contain only hazardous waste codes as specified in the waste analysis plan renewal application Attachment B

LILB2 Prohibited Waste

The Permittees shall not store or manage any hazardous mixed low-level or mixed TRU waste that does not comply with Permit Condition IIIB1

lltC Condition of Containers

Pursuant to 20AI500 JMAC (incorporating 40 CFR 264171) the Permittees shall ensure that any waste container that does not satisfy container condition and inspection requirements will be overpacked or the waste repackaged in a container in good condition and that the materials of the overpack container wi I be compatible with both the waste ancl other container The overpack container andor new container shall also be compatible and resistant to environmental conditions

1lID Compatibilitv of Waste with Containers

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264172) the Permittees shall use only containers made of or lined with materials that 7ill not react with and are otherwise compatible with the hazardous mixed low-level andor mixed TRU waste to be stored so that the ability ofthe container to contain the waste is not impaired

IIIE Management of Containers

The Permittees shall manage all containers as specified in the permit renewal application Section 25 and Attachment G and in accordance with the regulatory references listed in Table 0-1 of Attachment O

In accordance with 2041500 NMAC (incorporating 40 eFR 264173(a)) the Permittees shall keep all containers closed during storage except when necessary to add waste remove waste or when containers are opened for visual examination sampling or other characterization activities

Waste containers that may be opcned for waste segregation volume reduction sample collection repackaging coring visual examination andor decontamination shall be opened within a work enclosure that provides waste confinement and prevents release of waste constituents

fhe Permittees shall not open handle or store containers in a manner that may rupture the container or cause it to leak pursuant to 2041500 N1AC (incorporating 40 CFR 264173(b ))

PERMIT MODULE III Page 111-4 of 8

LANL TA~ Part B Renewal Application Februarv 2002

Security and access control to the container storage areas shall be maintained by the Permittees as provided in Sections 1 G-2 and 0-3 of Attachment G of the renewal application

IIIF Containment Svstems

Pursuant to 2041S00 NMAC (incorporating 40 eFR 26417S(b)) and as specified in Section 26 of the permit renewal application the Permittees shall maintain the secondary containment systems for all containers managed in Area L Area 0 and TA-S4 West All secondary containment systems shall be designed to contain at a minimum ten percent ofthe volume of potential liquid-bearing waste containers or the volume of the largest waste container

No containers shall be stored directly on a ground surface or other surface without an impervious base and with secondary containment

The Permittees shall remove all accumulated liquid in a timely manner to prevent overflow of the collection systems

lILO Inspection Schedules and Procedures

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264174) and in accordance with Attachment C of the renewal application the Permittees shall conduct at a minimum weekly inspections of each container storage area within Arca L Area G and TA-S4 West to identify leaking containers deterioration of containers and loss of integrity of containment systems

The Permittees shall ensure that containers holding ignitable or reactive wastes shall be located at least SO feet from the facilitys property line at all times The Permittees shall also ensure that containers with ignitable or reactive wastes are protected from sources of ignition or reaction

Pursuant to 2041S00 NMAC (incorporating 40 CFR 2641 77(craquo) storage containers with incompatible waste shall be separated from other material or be protected from other materials by means of a berm dike wall or another device as defined in this permit and associated attachments

The Permittees shall ensure that no incompatible wastes are mixed and 110 vaste shall be placed in a container that previously held an incompatible waste

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264110 I (a)(3raquo the Permittees shall ensure that in areas managing incompatible wastes the incompatible wastes will not cause secondary containment systems to leak corrode or fail

PERMIT MODULE III Page III -S of 8

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL TA)Part B Renewal Application February 2002

HI Module HI Container Stonlge

lilA Designateci Container St()rage UI1its

This module authorizes the storage and management of hazardous mixed low-level waste and or mixed TRU waste containers in Area L Area G and Technical Area 54 West (TAshy54 West) container storage areas of the Los Alamos National Laboratorys (LANL) TAshy54 described below Specific facility and process information for the storage and management of these wastes is incolllorated in the Permit Renewal Application Container Storage Sections 20 and 40 and Attachments F2 and G

IIIAI Designated Containcr StOlage Areas

TA-54 consists of three container storage areas Area L Area G and TA-54 West Area L is located in the central portion ofTA-54 at LANL Area L comprises a total enclosed area 01258 acres Area G is located on 63 acres in the east-central portion oCTA-54 TA-54 West is located in the northwest corner ofTA-54 and comprises approximately 2 acres

The Permittees may store and manage hazardous mixed low-level andor mixed TRU waste in TA-54 container storage areas in Area L Area G and TA-54 West provided the Permittees comply with the following conditions

[ILAIa Area L Storage Containers - the Permittees shall store hazardous and mixed low-level vaste in containers specitied in the Renewal Application Section 112 These containers are limited to 30- 83- 85- and 11 a-gallon steel polyethylene and fiber drums fiberglass-reintorced plastic on plywood (FRP) boxes steel standard waste boxes (SWBs) steel boxes metal overpack boxes cardboard shipping containers gas cylinders roll-off bins and labpaeks Any other container must be identitied and provided tor approved use as outlined in the Module II Attachment A Container Storage Area Schedule ofCompliancc 1i3n

llL1 b Area G Storage Containers the Permittees shall store hazardous mixed lowshylevel and mixed TRU waste in containers specified in the Renewal Application Section 2122 These containers are limited to 30- 55- 83- 85- and 11 O-gallon steel polyethylene and fiber drums FRP boxes SWBs steel boxes metal overpack boxes wooden boxes roU-offbins and ten-drum overpacks (TOOPs) Any other container such as various small containers must be specifically identified and provided for approved use as outlined in the Module II Attachment A Container Storage Area Schedule of Compliance B3a

IILAte TA-54 Wcst Storage Contltliners - the Permittees shall store solid mixed 10wshylevel and mixed TRU vastc in containers specified in the Renewal Application Section 2132 These containers are I imitcd to 30- 55- 83- 85- and 11 O-gallon steel polyethylene and tiber drums SWBs steel boxes metal overpack boxes TRUPACT-ll containers and TOOPs Any other container such as various small containers and

PERMIT MODULE III Page III-I of 8

LANL TA~rPart B Renewal Application February 2002

irregularly shaped containers must be specifically identified and submitted for approved use as outlined in the Module It Attachment A Container Storage Area Schedule of Compliance B3a

[IlA-Id Storagc contaiI1cr Enlissioll Controls - all containers llsed to contain hazardous waste shall control air pollutant emissions from each containcr in accordance with 2041500 NMAC (incorporating 40 CFR 264 Subpart CC) Pursuant to 2041500 KMAC (incorporating 40 CFR 2641(86) all hazardous waste containers shall meet the appropriate container control based on container capacity of either Container Levell Container Level 2 or Container Level 3 standards

mA2 Storage Structures Locations and Capacitics

The Permittees may store hazardous and mixed low-level waste in the designated areas within the fence line of Area L storage dome TA-54-215 canopy TA-54-216 concrete containment structure TA-54-32 containment structure TA-54-35 sampling pad TA-54shy36 transportation pad TA-54-58 and storage shafts 36 and 37 Other areas that may be used to store hazardous and mixed low-level waste as identified in terms with the Module II Attachment A Container Storage Area Schedule of Compliance Bl The Permittees may store quantities of hazardous and mixed low-level waste at these locations within Area L not to exceed the maximum capacities as provided in accordance with Module [I Attachment A Container Storage Area Schedule of Compliance B2 Area L shaH be limited to an overall storage capacity of453810 gallons or the equivalent of 8251 55-gallon drums

The Permittees may store hazardous mixed low-level and mixed TRl~ wastc in the designated areas within the fence line of Area G storage domes asphalt-covered areas storage shaft field sheds pre-engineered structures TA-54-412 DVRS DVRS Modular Containment Structure and TA-54-420 CHAPS Other areas that may be used to store hazardous mixed low-level and mixed TRU waste as identified in terms with the Module 11 Attachment A Containcr Storage Area Schedule of Compliance Bl The Permittees may store quantities or hazardous mixed low-level and mixed TRU waste at these locations within Area G not to exceed the maximum capacities as provided in accordance with Module II Attachmcnt A Container Storage Area Schedule of Compliance 82 Area G shall be limited to an overall storage capacity of 7331995 gallons of waste

The Permittees may store solid mixed low-level and mixed TRU waste in the designated areas within the fence line of lA-54 West indoor and outdoor storage pads (TA-54-38) Other areas that may be used to store solid mixed low-level and mixed TRU waste as identified in terms with the Module II Attachment A Container Storage Area Schedule of Compliance Bl The Permittees may store quantities of solid mixed low-level and mixed ~rRU waste at these locations within TA-54 West not to exceed the maximum capacities as provided in accordance with the Module II Attachment A Container Storage Area Schedule of Compliance 82 T A-54 West shall be limited to an overall storage capacity of 11660 gaJ Ions or the equivalent of 212 55-gallon drums

PERMIT MODULE 1lI Page lIT -2 of 8

LANL TA-341)art B Renewal Application February 2002

1IlA2a Storage of Containers containers will be stored in a manner preventing contact with any fjee liquids Containers which are not elevated by design or cannot demonstrate waste compatibility shall be stored on either pallets or steel grates over recessed secondary containment as described in Renewal Application Section 2112

IIIA2 b Minimum Aisle Space the Permittees shall maintain a minimum aisle space of 3 feet between rows

lILA2c Storage Configuration - the Permittees shall maintain storage confIgurations as submitted in accordance with Module ll Attachment A Containcr Storage Area Schedule of Compliance B2

The Permittees shall stack drums to a maximum of three high FRP boxes SWBs and other boxes shall be stacked to a maximum of three high unless size and weight restrictions prohibit stacking due to safety concerns The Permittees shall establish a maximum size and weight for the FRP boxes SWBs and other boxes containers to be stacked three high

IllA3 Container Handling and Inspection

Pursuant to 2041500 NMAC (incorporating 40 CFR 26431) the Permittees shall conduct at a minimum weekly inspections of each of the container storage areas Inspections shall include checking for leaking containers and for deterioration of containers and the containment systems as caused by corrosion or other factors The Permittees shall maintain written documentation of the inspections

TILAAPreparedness and Prevention

PUfsuant to 2041500 NMAC (incorporating 40 CFR 26435) lhe Permittees shall ensure that each unit has been or vil I be designed constructed maintained and operated to minimize the possibility of a fire explosion Of any unplanned sudden Of non-sudden release of hazardous or non-hazardous waste constituents to the air sailor suriace water which could threaten human health or the environment

IlLE Permitted and Prohibited Waste Identification

I11B1 Permitted Waste

The Permittees may store and manage hazardous and mixed low-level wastes at Area 10 hazardous mixed low-level and mixed TRU wastes at Area G and solid mixed low-level and mixed TRU wastes at TA-54 West provided the Permittees comply with the following conditions

1IIBIa Waste Analysis Pl~ all waste shall be characterized to comply with the waste analysis plan specified in renewal application Attachment B

PERMIT MODULE III Page JII-3 of 8

UNL TA-)41art B Renewal Application February 2002

IllElb Hazardous Waste Codes all waste shall contain only hazardous waste codes as specified in the waste analysis plan renewal application Attachment B

LILB2 Prohibited Waste

The Permittees shall not store or manage any hazardous mixed low-level or mixed TRU waste that does not comply with Permit Condition IIIB1

lltC Condition of Containers

Pursuant to 20AI500 JMAC (incorporating 40 CFR 264171) the Permittees shall ensure that any waste container that does not satisfy container condition and inspection requirements will be overpacked or the waste repackaged in a container in good condition and that the materials of the overpack container wi I be compatible with both the waste ancl other container The overpack container andor new container shall also be compatible and resistant to environmental conditions

1lID Compatibilitv of Waste with Containers

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264172) the Permittees shall use only containers made of or lined with materials that 7ill not react with and are otherwise compatible with the hazardous mixed low-level andor mixed TRU waste to be stored so that the ability ofthe container to contain the waste is not impaired

IIIE Management of Containers

The Permittees shall manage all containers as specified in the permit renewal application Section 25 and Attachment G and in accordance with the regulatory references listed in Table 0-1 of Attachment O

In accordance with 2041500 NMAC (incorporating 40 eFR 264173(a)) the Permittees shall keep all containers closed during storage except when necessary to add waste remove waste or when containers are opened for visual examination sampling or other characterization activities

Waste containers that may be opcned for waste segregation volume reduction sample collection repackaging coring visual examination andor decontamination shall be opened within a work enclosure that provides waste confinement and prevents release of waste constituents

fhe Permittees shall not open handle or store containers in a manner that may rupture the container or cause it to leak pursuant to 2041500 N1AC (incorporating 40 CFR 264173(b ))

PERMIT MODULE III Page 111-4 of 8

LANL TA~ Part B Renewal Application Februarv 2002

Security and access control to the container storage areas shall be maintained by the Permittees as provided in Sections 1 G-2 and 0-3 of Attachment G of the renewal application

IIIF Containment Svstems

Pursuant to 2041S00 NMAC (incorporating 40 eFR 26417S(b)) and as specified in Section 26 of the permit renewal application the Permittees shall maintain the secondary containment systems for all containers managed in Area L Area 0 and TA-S4 West All secondary containment systems shall be designed to contain at a minimum ten percent ofthe volume of potential liquid-bearing waste containers or the volume of the largest waste container

No containers shall be stored directly on a ground surface or other surface without an impervious base and with secondary containment

The Permittees shall remove all accumulated liquid in a timely manner to prevent overflow of the collection systems

lILO Inspection Schedules and Procedures

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264174) and in accordance with Attachment C of the renewal application the Permittees shall conduct at a minimum weekly inspections of each container storage area within Arca L Area G and TA-S4 West to identify leaking containers deterioration of containers and loss of integrity of containment systems

The Permittees shall ensure that containers holding ignitable or reactive wastes shall be located at least SO feet from the facilitys property line at all times The Permittees shall also ensure that containers with ignitable or reactive wastes are protected from sources of ignition or reaction

Pursuant to 2041S00 NMAC (incorporating 40 CFR 2641 77(craquo) storage containers with incompatible waste shall be separated from other material or be protected from other materials by means of a berm dike wall or another device as defined in this permit and associated attachments

The Permittees shall ensure that no incompatible wastes are mixed and 110 vaste shall be placed in a container that previously held an incompatible waste

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264110 I (a)(3raquo the Permittees shall ensure that in areas managing incompatible wastes the incompatible wastes will not cause secondary containment systems to leak corrode or fail

PERMIT MODULE III Page III -S of 8

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL TA~rPart B Renewal Application February 2002

irregularly shaped containers must be specifically identified and submitted for approved use as outlined in the Module It Attachment A Container Storage Area Schedule of Compliance B3a

[IlA-Id Storagc contaiI1cr Enlissioll Controls - all containers llsed to contain hazardous waste shall control air pollutant emissions from each containcr in accordance with 2041500 NMAC (incorporating 40 CFR 264 Subpart CC) Pursuant to 2041500 KMAC (incorporating 40 CFR 2641(86) all hazardous waste containers shall meet the appropriate container control based on container capacity of either Container Levell Container Level 2 or Container Level 3 standards

mA2 Storage Structures Locations and Capacitics

The Permittees may store hazardous and mixed low-level waste in the designated areas within the fence line of Area L storage dome TA-54-215 canopy TA-54-216 concrete containment structure TA-54-32 containment structure TA-54-35 sampling pad TA-54shy36 transportation pad TA-54-58 and storage shafts 36 and 37 Other areas that may be used to store hazardous and mixed low-level waste as identified in terms with the Module II Attachment A Container Storage Area Schedule of Compliance Bl The Permittees may store quantities of hazardous and mixed low-level waste at these locations within Area L not to exceed the maximum capacities as provided in accordance with Module [I Attachment A Container Storage Area Schedule of Compliance B2 Area L shaH be limited to an overall storage capacity of453810 gallons or the equivalent of 8251 55-gallon drums

The Permittees may store hazardous mixed low-level and mixed TRl~ wastc in the designated areas within the fence line of Area G storage domes asphalt-covered areas storage shaft field sheds pre-engineered structures TA-54-412 DVRS DVRS Modular Containment Structure and TA-54-420 CHAPS Other areas that may be used to store hazardous mixed low-level and mixed TRU waste as identified in terms with the Module 11 Attachment A Containcr Storage Area Schedule of Compliance Bl The Permittees may store quantities or hazardous mixed low-level and mixed TRU waste at these locations within Area G not to exceed the maximum capacities as provided in accordance with Module II Attachmcnt A Container Storage Area Schedule of Compliance 82 Area G shall be limited to an overall storage capacity of 7331995 gallons of waste

The Permittees may store solid mixed low-level and mixed TRU waste in the designated areas within the fence line of lA-54 West indoor and outdoor storage pads (TA-54-38) Other areas that may be used to store solid mixed low-level and mixed TRU waste as identified in terms with the Module II Attachment A Container Storage Area Schedule of Compliance Bl The Permittees may store quantities of solid mixed low-level and mixed ~rRU waste at these locations within TA-54 West not to exceed the maximum capacities as provided in accordance with the Module II Attachment A Container Storage Area Schedule of Compliance 82 T A-54 West shall be limited to an overall storage capacity of 11660 gaJ Ions or the equivalent of 212 55-gallon drums

PERMIT MODULE 1lI Page lIT -2 of 8

LANL TA-341)art B Renewal Application February 2002

1IlA2a Storage of Containers containers will be stored in a manner preventing contact with any fjee liquids Containers which are not elevated by design or cannot demonstrate waste compatibility shall be stored on either pallets or steel grates over recessed secondary containment as described in Renewal Application Section 2112

IIIA2 b Minimum Aisle Space the Permittees shall maintain a minimum aisle space of 3 feet between rows

lILA2c Storage Configuration - the Permittees shall maintain storage confIgurations as submitted in accordance with Module ll Attachment A Containcr Storage Area Schedule of Compliance B2

The Permittees shall stack drums to a maximum of three high FRP boxes SWBs and other boxes shall be stacked to a maximum of three high unless size and weight restrictions prohibit stacking due to safety concerns The Permittees shall establish a maximum size and weight for the FRP boxes SWBs and other boxes containers to be stacked three high

IllA3 Container Handling and Inspection

Pursuant to 2041500 NMAC (incorporating 40 CFR 26431) the Permittees shall conduct at a minimum weekly inspections of each of the container storage areas Inspections shall include checking for leaking containers and for deterioration of containers and the containment systems as caused by corrosion or other factors The Permittees shall maintain written documentation of the inspections

TILAAPreparedness and Prevention

PUfsuant to 2041500 NMAC (incorporating 40 CFR 26435) lhe Permittees shall ensure that each unit has been or vil I be designed constructed maintained and operated to minimize the possibility of a fire explosion Of any unplanned sudden Of non-sudden release of hazardous or non-hazardous waste constituents to the air sailor suriace water which could threaten human health or the environment

IlLE Permitted and Prohibited Waste Identification

I11B1 Permitted Waste

The Permittees may store and manage hazardous and mixed low-level wastes at Area 10 hazardous mixed low-level and mixed TRU wastes at Area G and solid mixed low-level and mixed TRU wastes at TA-54 West provided the Permittees comply with the following conditions

1IIBIa Waste Analysis Pl~ all waste shall be characterized to comply with the waste analysis plan specified in renewal application Attachment B

PERMIT MODULE III Page JII-3 of 8

UNL TA-)41art B Renewal Application February 2002

IllElb Hazardous Waste Codes all waste shall contain only hazardous waste codes as specified in the waste analysis plan renewal application Attachment B

LILB2 Prohibited Waste

The Permittees shall not store or manage any hazardous mixed low-level or mixed TRU waste that does not comply with Permit Condition IIIB1

lltC Condition of Containers

Pursuant to 20AI500 JMAC (incorporating 40 CFR 264171) the Permittees shall ensure that any waste container that does not satisfy container condition and inspection requirements will be overpacked or the waste repackaged in a container in good condition and that the materials of the overpack container wi I be compatible with both the waste ancl other container The overpack container andor new container shall also be compatible and resistant to environmental conditions

1lID Compatibilitv of Waste with Containers

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264172) the Permittees shall use only containers made of or lined with materials that 7ill not react with and are otherwise compatible with the hazardous mixed low-level andor mixed TRU waste to be stored so that the ability ofthe container to contain the waste is not impaired

IIIE Management of Containers

The Permittees shall manage all containers as specified in the permit renewal application Section 25 and Attachment G and in accordance with the regulatory references listed in Table 0-1 of Attachment O

In accordance with 2041500 NMAC (incorporating 40 eFR 264173(a)) the Permittees shall keep all containers closed during storage except when necessary to add waste remove waste or when containers are opened for visual examination sampling or other characterization activities

Waste containers that may be opcned for waste segregation volume reduction sample collection repackaging coring visual examination andor decontamination shall be opened within a work enclosure that provides waste confinement and prevents release of waste constituents

fhe Permittees shall not open handle or store containers in a manner that may rupture the container or cause it to leak pursuant to 2041500 N1AC (incorporating 40 CFR 264173(b ))

PERMIT MODULE III Page 111-4 of 8

LANL TA~ Part B Renewal Application Februarv 2002

Security and access control to the container storage areas shall be maintained by the Permittees as provided in Sections 1 G-2 and 0-3 of Attachment G of the renewal application

IIIF Containment Svstems

Pursuant to 2041S00 NMAC (incorporating 40 eFR 26417S(b)) and as specified in Section 26 of the permit renewal application the Permittees shall maintain the secondary containment systems for all containers managed in Area L Area 0 and TA-S4 West All secondary containment systems shall be designed to contain at a minimum ten percent ofthe volume of potential liquid-bearing waste containers or the volume of the largest waste container

No containers shall be stored directly on a ground surface or other surface without an impervious base and with secondary containment

The Permittees shall remove all accumulated liquid in a timely manner to prevent overflow of the collection systems

lILO Inspection Schedules and Procedures

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264174) and in accordance with Attachment C of the renewal application the Permittees shall conduct at a minimum weekly inspections of each container storage area within Arca L Area G and TA-S4 West to identify leaking containers deterioration of containers and loss of integrity of containment systems

The Permittees shall ensure that containers holding ignitable or reactive wastes shall be located at least SO feet from the facilitys property line at all times The Permittees shall also ensure that containers with ignitable or reactive wastes are protected from sources of ignition or reaction

Pursuant to 2041S00 NMAC (incorporating 40 CFR 2641 77(craquo) storage containers with incompatible waste shall be separated from other material or be protected from other materials by means of a berm dike wall or another device as defined in this permit and associated attachments

The Permittees shall ensure that no incompatible wastes are mixed and 110 vaste shall be placed in a container that previously held an incompatible waste

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264110 I (a)(3raquo the Permittees shall ensure that in areas managing incompatible wastes the incompatible wastes will not cause secondary containment systems to leak corrode or fail

PERMIT MODULE III Page III -S of 8

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL TA-341)art B Renewal Application February 2002

1IlA2a Storage of Containers containers will be stored in a manner preventing contact with any fjee liquids Containers which are not elevated by design or cannot demonstrate waste compatibility shall be stored on either pallets or steel grates over recessed secondary containment as described in Renewal Application Section 2112

IIIA2 b Minimum Aisle Space the Permittees shall maintain a minimum aisle space of 3 feet between rows

lILA2c Storage Configuration - the Permittees shall maintain storage confIgurations as submitted in accordance with Module ll Attachment A Containcr Storage Area Schedule of Compliance B2

The Permittees shall stack drums to a maximum of three high FRP boxes SWBs and other boxes shall be stacked to a maximum of three high unless size and weight restrictions prohibit stacking due to safety concerns The Permittees shall establish a maximum size and weight for the FRP boxes SWBs and other boxes containers to be stacked three high

IllA3 Container Handling and Inspection

Pursuant to 2041500 NMAC (incorporating 40 CFR 26431) the Permittees shall conduct at a minimum weekly inspections of each of the container storage areas Inspections shall include checking for leaking containers and for deterioration of containers and the containment systems as caused by corrosion or other factors The Permittees shall maintain written documentation of the inspections

TILAAPreparedness and Prevention

PUfsuant to 2041500 NMAC (incorporating 40 CFR 26435) lhe Permittees shall ensure that each unit has been or vil I be designed constructed maintained and operated to minimize the possibility of a fire explosion Of any unplanned sudden Of non-sudden release of hazardous or non-hazardous waste constituents to the air sailor suriace water which could threaten human health or the environment

IlLE Permitted and Prohibited Waste Identification

I11B1 Permitted Waste

The Permittees may store and manage hazardous and mixed low-level wastes at Area 10 hazardous mixed low-level and mixed TRU wastes at Area G and solid mixed low-level and mixed TRU wastes at TA-54 West provided the Permittees comply with the following conditions

1IIBIa Waste Analysis Pl~ all waste shall be characterized to comply with the waste analysis plan specified in renewal application Attachment B

PERMIT MODULE III Page JII-3 of 8

UNL TA-)41art B Renewal Application February 2002

IllElb Hazardous Waste Codes all waste shall contain only hazardous waste codes as specified in the waste analysis plan renewal application Attachment B

LILB2 Prohibited Waste

The Permittees shall not store or manage any hazardous mixed low-level or mixed TRU waste that does not comply with Permit Condition IIIB1

lltC Condition of Containers

Pursuant to 20AI500 JMAC (incorporating 40 CFR 264171) the Permittees shall ensure that any waste container that does not satisfy container condition and inspection requirements will be overpacked or the waste repackaged in a container in good condition and that the materials of the overpack container wi I be compatible with both the waste ancl other container The overpack container andor new container shall also be compatible and resistant to environmental conditions

1lID Compatibilitv of Waste with Containers

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264172) the Permittees shall use only containers made of or lined with materials that 7ill not react with and are otherwise compatible with the hazardous mixed low-level andor mixed TRU waste to be stored so that the ability ofthe container to contain the waste is not impaired

IIIE Management of Containers

The Permittees shall manage all containers as specified in the permit renewal application Section 25 and Attachment G and in accordance with the regulatory references listed in Table 0-1 of Attachment O

In accordance with 2041500 NMAC (incorporating 40 eFR 264173(a)) the Permittees shall keep all containers closed during storage except when necessary to add waste remove waste or when containers are opened for visual examination sampling or other characterization activities

Waste containers that may be opcned for waste segregation volume reduction sample collection repackaging coring visual examination andor decontamination shall be opened within a work enclosure that provides waste confinement and prevents release of waste constituents

fhe Permittees shall not open handle or store containers in a manner that may rupture the container or cause it to leak pursuant to 2041500 N1AC (incorporating 40 CFR 264173(b ))

PERMIT MODULE III Page 111-4 of 8

LANL TA~ Part B Renewal Application Februarv 2002

Security and access control to the container storage areas shall be maintained by the Permittees as provided in Sections 1 G-2 and 0-3 of Attachment G of the renewal application

IIIF Containment Svstems

Pursuant to 2041S00 NMAC (incorporating 40 eFR 26417S(b)) and as specified in Section 26 of the permit renewal application the Permittees shall maintain the secondary containment systems for all containers managed in Area L Area 0 and TA-S4 West All secondary containment systems shall be designed to contain at a minimum ten percent ofthe volume of potential liquid-bearing waste containers or the volume of the largest waste container

No containers shall be stored directly on a ground surface or other surface without an impervious base and with secondary containment

The Permittees shall remove all accumulated liquid in a timely manner to prevent overflow of the collection systems

lILO Inspection Schedules and Procedures

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264174) and in accordance with Attachment C of the renewal application the Permittees shall conduct at a minimum weekly inspections of each container storage area within Arca L Area G and TA-S4 West to identify leaking containers deterioration of containers and loss of integrity of containment systems

The Permittees shall ensure that containers holding ignitable or reactive wastes shall be located at least SO feet from the facilitys property line at all times The Permittees shall also ensure that containers with ignitable or reactive wastes are protected from sources of ignition or reaction

Pursuant to 2041S00 NMAC (incorporating 40 CFR 2641 77(craquo) storage containers with incompatible waste shall be separated from other material or be protected from other materials by means of a berm dike wall or another device as defined in this permit and associated attachments

The Permittees shall ensure that no incompatible wastes are mixed and 110 vaste shall be placed in a container that previously held an incompatible waste

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264110 I (a)(3raquo the Permittees shall ensure that in areas managing incompatible wastes the incompatible wastes will not cause secondary containment systems to leak corrode or fail

PERMIT MODULE III Page III -S of 8

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

UNL TA-)41art B Renewal Application February 2002

IllElb Hazardous Waste Codes all waste shall contain only hazardous waste codes as specified in the waste analysis plan renewal application Attachment B

LILB2 Prohibited Waste

The Permittees shall not store or manage any hazardous mixed low-level or mixed TRU waste that does not comply with Permit Condition IIIB1

lltC Condition of Containers

Pursuant to 20AI500 JMAC (incorporating 40 CFR 264171) the Permittees shall ensure that any waste container that does not satisfy container condition and inspection requirements will be overpacked or the waste repackaged in a container in good condition and that the materials of the overpack container wi I be compatible with both the waste ancl other container The overpack container andor new container shall also be compatible and resistant to environmental conditions

1lID Compatibilitv of Waste with Containers

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264172) the Permittees shall use only containers made of or lined with materials that 7ill not react with and are otherwise compatible with the hazardous mixed low-level andor mixed TRU waste to be stored so that the ability ofthe container to contain the waste is not impaired

IIIE Management of Containers

The Permittees shall manage all containers as specified in the permit renewal application Section 25 and Attachment G and in accordance with the regulatory references listed in Table 0-1 of Attachment O

In accordance with 2041500 NMAC (incorporating 40 eFR 264173(a)) the Permittees shall keep all containers closed during storage except when necessary to add waste remove waste or when containers are opened for visual examination sampling or other characterization activities

Waste containers that may be opcned for waste segregation volume reduction sample collection repackaging coring visual examination andor decontamination shall be opened within a work enclosure that provides waste confinement and prevents release of waste constituents

fhe Permittees shall not open handle or store containers in a manner that may rupture the container or cause it to leak pursuant to 2041500 N1AC (incorporating 40 CFR 264173(b ))

PERMIT MODULE III Page 111-4 of 8

LANL TA~ Part B Renewal Application Februarv 2002

Security and access control to the container storage areas shall be maintained by the Permittees as provided in Sections 1 G-2 and 0-3 of Attachment G of the renewal application

IIIF Containment Svstems

Pursuant to 2041S00 NMAC (incorporating 40 eFR 26417S(b)) and as specified in Section 26 of the permit renewal application the Permittees shall maintain the secondary containment systems for all containers managed in Area L Area 0 and TA-S4 West All secondary containment systems shall be designed to contain at a minimum ten percent ofthe volume of potential liquid-bearing waste containers or the volume of the largest waste container

No containers shall be stored directly on a ground surface or other surface without an impervious base and with secondary containment

The Permittees shall remove all accumulated liquid in a timely manner to prevent overflow of the collection systems

lILO Inspection Schedules and Procedures

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264174) and in accordance with Attachment C of the renewal application the Permittees shall conduct at a minimum weekly inspections of each container storage area within Arca L Area G and TA-S4 West to identify leaking containers deterioration of containers and loss of integrity of containment systems

The Permittees shall ensure that containers holding ignitable or reactive wastes shall be located at least SO feet from the facilitys property line at all times The Permittees shall also ensure that containers with ignitable or reactive wastes are protected from sources of ignition or reaction

Pursuant to 2041S00 NMAC (incorporating 40 CFR 2641 77(craquo) storage containers with incompatible waste shall be separated from other material or be protected from other materials by means of a berm dike wall or another device as defined in this permit and associated attachments

The Permittees shall ensure that no incompatible wastes are mixed and 110 vaste shall be placed in a container that previously held an incompatible waste

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264110 I (a)(3raquo the Permittees shall ensure that in areas managing incompatible wastes the incompatible wastes will not cause secondary containment systems to leak corrode or fail

PERMIT MODULE III Page III -S of 8

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL TA~ Part B Renewal Application Februarv 2002

Security and access control to the container storage areas shall be maintained by the Permittees as provided in Sections 1 G-2 and 0-3 of Attachment G of the renewal application

IIIF Containment Svstems

Pursuant to 2041S00 NMAC (incorporating 40 eFR 26417S(b)) and as specified in Section 26 of the permit renewal application the Permittees shall maintain the secondary containment systems for all containers managed in Area L Area 0 and TA-S4 West All secondary containment systems shall be designed to contain at a minimum ten percent ofthe volume of potential liquid-bearing waste containers or the volume of the largest waste container

No containers shall be stored directly on a ground surface or other surface without an impervious base and with secondary containment

The Permittees shall remove all accumulated liquid in a timely manner to prevent overflow of the collection systems

lILO Inspection Schedules and Procedures

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264174) and in accordance with Attachment C of the renewal application the Permittees shall conduct at a minimum weekly inspections of each container storage area within Arca L Area G and TA-S4 West to identify leaking containers deterioration of containers and loss of integrity of containment systems

The Permittees shall ensure that containers holding ignitable or reactive wastes shall be located at least SO feet from the facilitys property line at all times The Permittees shall also ensure that containers with ignitable or reactive wastes are protected from sources of ignition or reaction

Pursuant to 2041S00 NMAC (incorporating 40 CFR 2641 77(craquo) storage containers with incompatible waste shall be separated from other material or be protected from other materials by means of a berm dike wall or another device as defined in this permit and associated attachments

The Permittees shall ensure that no incompatible wastes are mixed and 110 vaste shall be placed in a container that previously held an incompatible waste

Pursuant to 2041S00 NMAC (incorporating 40 CFR 264110 I (a)(3raquo the Permittees shall ensure that in areas managing incompatible wastes the incompatible wastes will not cause secondary containment systems to leak corrode or fail

PERMIT MODULE III Page III -S of 8

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL TA~-)(Part 8 Renewal Application February 2002

IIU Corrective Action for Solid Waste Management Units

Corrective actions shall be implemented in accordance with information requested in the Container Storage Area Schedule of Compliance (Attachment A of Module II) B8

1111 Closure for Area L

Upon closure of the container storage area at Area L the Permittees shall remove all hazardous and mixed low-level waste and waste residues from the area in accordance with the Closure Plan iiJr Area L Renewal Application Attachment FI and Compliance Schedule B-ll and as required by 2041500 NMAC (incorporating 40 CFR 264 and 27014(b)(3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andlor sample for and either decontaminate or remove all soils contaminated with or containing hazardous waste or mixed low-level waste and waste residues

Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)(2) and 2641 13(a) and (b)) the Permittees shall ensure J) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the final volume of waste at each unit and all closure activities will be completed within 180 days from receipt of the final volume of waste at each unit

Per 2041500 NMAC (incorporating 40 CFR 264113(a) and (b)) if the planned closure for Area L is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that j ustities a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation orthe site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment tiom the unclosed but inactive unit

111K Closure for Area G

Upon closure of the container storage area at Area G the Permittees shall remove all hazardous mixed low-level waste and mixed TRU waste and waste residues from the area in accordance with the Closure Plan for Area G Renewal Application Attachment F2 and Compliance Schedule 13-10 and as required by 204 J 500 NMAC (incorporating 40 CFR 264 and 27014(b)(l3))

Pursuant to 2041500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated

PERMIT MODULE 111 Page III -6 of 8

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL TA-541gtart B Renewal Application February 2002

with or containing hazardous waste mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264112(b)(2) and 264113(a) and (braquo the Permittees shall ensure I) all hazardous waste will be treated removed off-site or disposed of on-site within 90 days iiom receipt ofthe final volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt of the final volume of waste at eaeh unit

Per 20Al500 NMAC (incorporating 40 CFR 2641 13(a) and (braquo ifthe planned closure for Area G IS expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time wi II be submitted by the Permittees An extension may only be granted by the Secretary if one of the following is demonstrated closure activities require longer than 90 or 180 days as described above the ullit has the capacity to receive additional wastes there is a reasonable likelihood that another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment hom the unclosed but inactive unit

mL Closure TA-54 West

Upon closure of the container storage area at TA-54 West the Permittees shall remove all mixed low-level waste and mixed TRU waste and waste residues from the arca in accordance with the Closure Plan for TA-54 West Renewal Application Attachment F3 and Compliance Schedule 13-11 and as required by 20Al 500 NMAC (incorporating 40 CFR 264 and 27014(b)(13)

Pursuant to 20Al500 NMAC (incorporating 40 CFR 264178) the Permittees shall monitor andor sample for and either decontaminate or remove all soils contaminated with or containing mixed low-level waste or mixed TRU waste and waste residues

Pursuant to 20Al500 NMAC (incorporating 40 crR 264112(b)(2) and 264113(a) and (b)) the Permittees shall ensure 1) all waste will be treated removed off-site or disposed of on-site within 90 days from receipt of the tinal volume of waste at each unit and 2) all closure activities will be completed within 180 days from receipt orthe final volume of waste at each unit

Per 20Al500 NMAC (incorporating 40 CFR 264113(a) and (braquo) if the planned closure for T A-54 West is expected to exceed the 90 days for treatment removal or disposal of wastes andor the 180 days for completion of closure activities a petition for a schedule of closure that justifies a longer period of closure time will be submitted by the Permittees An extension may only be granted by thc Secretary if one of the following is dcmonstrated closure activities require longer than 90 or 180 days as described above the unit has the capacity to reccive additional wastes there is a rcasonable 1 ikclihood that

PERMIT MODULE III Page III-7 of 8

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

LANL B Renewal Application February 2002

another person or operator will recommence operation of the site within one year or closure would be incompatible with continued operation The Permittees shall also demonstrate that all steps have and shall be taken to prevent threat to human health and the environment 60111 the unclosed but inactive unit

ILM Contingency Plan

Emergency equipment at TA-54 shall be maintained as provided in Table E-2 of the renewal application The Permittees sha]] also follow the contingency plan addressed in the LANL General Part B Permit Application Revision 10 and in accordance with 2041900 NMAC (incorporating 40 CFR 27014(b)(7)) and 2041500 NMAC (incorporating 40 CFR 26450 through 26456 and 26452(b))

PERMIT MODLLE 111 Page 11I-8 018

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

Module 11 ~ General Facility Conditions Attachment A ~ Container Storage Area Schedule of Compliance

A DEFINITIONS

For purposes of this Container Storage Area Schedule of Compliance the tiJllowing definitions shall apply

Release means any spills leaks pumping pouring emitting emptying discharging injecting escaping leaching dumping or disposing of hazardous waste (including hazardous constituents) mixed low-level waste or mixed TRU waste into the environment (including the abandonment or discarding of barrels containers and other closed receptacles containing hazardous waste hazardous constituents or radiological constituents

Solid waste management unit means any discernible unit at which solid wastes have been placed at any time irrespective of whether the unit was intended for the management of solid or hazardous waste Such units include any areas at or around a facility at which solid wastes have been routinely and systematically released and include the container storage areas

Hazardous waste means a solid waste or combination of solid wastes vlhich because of the quantity concentration or physical chemical or infectious characteristics may cause or signiticantly contribute to an increase in mortality or an increase in serious irreversible incapacity reversible illness or pose a substantial present or potential hazard to human health or the environment when improperly treated stored transported disposed of or otherwise managed Hazardous wastes include hazardous constituents as defined below by the term hazardous constituent

Hazardous constituent means any constituent identitied in Appendix VllI of 40 CFR Part 261 andor in Appendix IX of 40 CFR Part 264

Mixed low-level waste means waste that contains radioactivity and is not classified as high-level waste transuranic waste spent nuclear fuel or 11 (e)(2) by-product material as detined in DOE Order 58202A Radioactive Waste Management

TRU waste means waste that is contaminated -vith alpha emitting lransuranic (TRU) radionuclides with half-lives greater than 20 years and concentrations greater than 100 nanocuries per gram at the time of assay and has atomic numbers greater than 92 as defined in DOE Order 58202A Radioactive Waste Management

Mixed TRU waste means waste that contains both a hazardous and a TRU waste component

Permittees include Los Alamos National Laboratory and the University ofCalilornia

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

Facility applies to area TA-54 at the Los Alamos Kational Laboratory Area L Area G and TA-54 West are defined as subareas vithin TA-54

Secretary means the Director of the New Mexico Environment Department or hisher designee

If subsequent to the issuance of this permit regulations are promulgated which redefine any of the above terms the Secretary may at its discretion apply the new definition to the permit

B COMPLIANCE SCHEDULES

The Permittees shall only be granted a permit atter all compliance schedule issues have been approved by the Secretary A summary of the compliance schedules is provided in Table B-1

1) Storage Structures

The Permittees shall provide to the Secretary within 60 calendar days the specific number and location of each storage container structure within Area L Area G and TA-54 West which are to be permitted This shall also include the specific number and location for storage sheds

2) Storage Configuration

The Permittees shall provide to the Secretary vithin 90 calendar days storage configuration diagrams for each container storage area within Area L Area G and TA-54 West The diagrams shall be provided for each type of storage area (including but not limited to all structures pads indoor and outdoor drum areas and shafts) identified in the permit renewal application and shall include the following information

a) An engineering drawing for each specific storage locationstructure showing basic dcsign features (eg airlock personnel entry) and parameters specific dimensions specific materials of construction sloping and direction of sloping and berms

b) Materialsli)r buildingstructure bases and foundations e) A layout of container placement by container type d) Number of each type of container e) Location of aisles I) Location of containment systems and g) V0 I u me of waste and vaste container type

Ir more than one identical type of storage structure (eg manufactured shed) will be used the Permittees shall identify the speci ric number and location of structures that meet each type of dcscription provided

A-2

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

3) Storage Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a list of any additional waste containers not specifically identified in the renewal application Section that may be used to store waste at Area L Area G andor TA-54 West The type of wuste to be stored in these containers the number of eontainers anticipated and the location (specific storage container area) where the containers will be used shall also be provided

b) The Permittees shull provide to the Seeretary within 30 ealendar days the methodology to determine the presence of tree liquid in all container types and what criteria will be used to designate a container as being free of liquids

c) The Permittees shall provide to the Secretary within 30 calendar days details on which containers (those elevated by design) do not require elevation to prevent contact with accumulated liquids and which containers will require placement on either a pallet or a steel grate

4) Condition of Containers

a) The Permittees shall provide to the Secretary within 30 calendar days the methodology that will be used to examine andor survey the exterior surface of all waste containers to verify that the outside surfaces are free of contamination

b) The Permittees shall provide to the Secretary within 30 calendar days information on whether liners will be used for allany containers Provided il110rmation shall also include liner requirements and specifications describing the functional requirements offitting inside the drumcontainer liner material thickness and tolenmces and quality controls and required testing that will be in place to ensure liners meet the specifications (including waste and container compatibility) and quality control procedures to ensure compliance with the requirements

c) Radiological waste containers are typically vented to prevent the buildup of gases In addition the vents are most often filtered to retain particles but still allow [or the escaping of The Permittees shall provide to the Secretary within 30 calendar days whether containers have ventilation ports for prevention of pressurization of waste containers which containers will have ventilation ports and if filtered ports for pnventing the escape of radionuc Iides into the atmosphere will be used

5) Managcmentgf Containers

a) The Permittees shall provide to the Secretary within 30 calendar days a discussion ortbe handling methods and any special handling equipment that may be used for each type of container to ensure waste containers will be handled in a manner that wi II cause not ruptures or leaks

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

b) The Permittees shall provide to the Secretary within 30 calendar days a plan for opening waste containers within a work enclosure that provides confinement preventing any release of waste constituents Included in this plan shall be an outline of specific waste handling requirements for opening waste containers and the work enclosure area including any special ventilation systems and waste containment systems for each type of waste container and waste type

c) The Permittees shall provide to the Secretary within 30 calendar days the maximum size and weight restrictions for FRP boxes SWBs and other boxes containers to be stacked three high

d) The Permittees shll provide to the Secretary withi 11 60 calendar days the procedures lor transporting waste across the LANL facility or TA-54

6) Containment Systems

a) Pursuant to 2041500 KMAC (incorporating 40 CFR 264 I 75(b)( 1 )) the Permittees shall provide to the Secretary within 60 calendar days inlormtiol1 on the underlying base of the containment systems and how it shall be demonstrated that the base will be flee of cracks or gaps and will be sufficiently impervious to contain leaks spills and accumulated precipitation until the collected material is detected and removed

b) Pursuant to 2041900 Nrv1AC (including 40 erR 27015(a)(3)) the Pcrmittees shall provide to the Secretary within 60 calendar days the capacity of the containment system relative to the number and volume of waste to be stored in each container storage area Calculations demonstrating the requirements for secondary containment at each storage area shall be provided The Permittees shall also provide calculations of the surface area and the quantities of liquid that would cover the area for each container storage area

c) The Permittees shall provide to the Secretary within 60 calendar days how waste containers will be kept from contact with any potentially accumulated liquids

d) The Permittees shall provide to the Secretary within 60 calendar days details regarding containers that do not require elevation to prevent contact with accumulated liquids and containers that will require placement on either a pallet or a steel grate

7) Ignitable Reactive and Incompatible Waste

a) The Permittees shall provide to the Secretary within 60 calendar days an engineering drawing or other data that demonstrates that containers of ignitable or reactive waste will be located at least 50 feet from the T boundary

A-4

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

b) The Permittees shall provide to the Secretary within 30 calendar days the policies that are in-place to minimize the possibility of accidental ignition and the precautions that will be taken for prevention of ignition spontaneoLls ignition and radiant heat

c) The Permittees shall provide to the Secretary within 30 calendar days all processes that will be used to prevent reactions that may generate extreme heat or pressure fire explosions or violent reactions produce uncontrolled Ilammable fumes dust or in sufticient quantities to threaten human health or the environment produce uncontrolled flammable fumes dust or gases in sufl1cient quantities to pose a risk of fire or explosions damage the structural integrity of the facility and be a threat to human health or the environment

8) lnspeetion Schedules and Procedures

The Permittees shall provide to the Secretary within 60 calendar days specific inspection plans and inspection logssummaries to be used for each type of waste container at each of the storage areas Pursuant to 2041500 NMIC (incorporating 40 eFR ] 5) the Permittees shall record inspections in an inspection log or summary und at a minimum recorded information must include the date and ti me of iI1spectiol1 name 0 [ iI1spector notation of observations made and the date and nature of any repairs or other remedial actions

9) Correctiye Action for Solid Waste Management Units

a) The Permittees shall provide to the Secretary within 60 calendar days the dimensions materials of construction dates of operation engineering drawings and quantity andor volumes of waste placed in cach container storage area (CSA) in Area L Area G and TI-54 West

b) The Permittees shall provide to the Secretary within 60 calendar days

i) 1 listing of all releases that may have occurred within any of the container storage units in Area L and Area G

ii) The date of release type of waste(s) released quantity or volume of waste released nature of release and

iii) Any groundwater monitoring or other analytical data available to describe the nature and extent of the release

c) The Permittees shall provide to the Secretary within 60 calendar days the methodology and data llsed to determine that there have never been any releases from the container storage areas are TA-54 West

d) Pursuant to 2041500 NMAC (incorporating 40 CFR 264101 and 264 Subpart S) for RCRA permitted status the Permittees shall address the closure and corrective action 0 f the container storage units in Area L Area G and

1-5

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

West The Permittees shall provide to the Secretary within 60 calendar days a corrective action plan and a schedule of compliance for the corrective actions The corrective actions must include implementation beyond area boundaries where necessary to protect human health and the environment

e) The Permittees shall provide to the Secretary within 60 calendar days a discussion for each storage container location as well as for Area L Area G andrA-54 West as a whole that describes the operational controls that will be used to manage run-on and run-olI

10) Area 9 Closure Plan

a) The Permittees shall provide to the Secretary within 90 Calendar days the maximum inventory of waste including waste type maximum capacity based on area and the maximum number of containers by container type for each container storage area at Area G

b) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112(b)( 4 raquo) a detailed description for closure of each container storage area must include the steps needed to remove or decontaminate all waste (hazardous mixed low-level and mixed TRU) residues and contaminated containment system components equipment structures and soils during partial and final closure including but not limited to procedures tlJr cleaning equipment and removing contaminated soils methods for sampling and testing surrounding soils and criteria for determining the extent of decontamination required to satisfy the closure performance standard The Permittees simI I provide to the Secretary within 90 calendar days a sampling and analysis plan for sampling and testing soils surrounding the container storage areas and for removing contaminated soils during either partial closure or closure of the container storage areas

c) The Permittees shall provide to the Secretary within 90 calendar days a Quality Assurance and Quality Control (QAQC) plan outlining the procedures for all soil sampling decontamination and decontamination verification The QAQC plan shall also include laboratory validation and data validation procedures

d) The Permittees shall provide to the Secretary within 90 calendar days a revised schedule for closure activities tor Area G The schedule shall be revised to include time for sampling analysis and potential removal of contaminated soils surrounding the container storage areas time for proper data validation time to treat wastes ti me for additional leaching tests for the asphalt or storage walls and floors and adequate time for transporting wastes to disposal sites

e) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641(1) the closure plan must address corrective aetion of the asphalt-covered areas The Permittees shall provide to the Secretary within 90 calendar days a closure plan tor the asphaltshycovered areas

A-6

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

f) The Permittees shall provide to the Secretary ithin 90 calendar days a revised decontamination and verification plan (the plan) Area G In addition to the information provided in the permit renewal application this plan must address the following items general to all container storage areas within Area G

i) Personal protective equipment (chemical and radiological) needed at each container storage area and a detailed discussion of the radiation and chemical monitoring equipment and monitoring requirements that will be used at each container storage area

ii) Training requirements and medical monitoring requirements for workers iii) Expected contaminants of concern at each container storage area iv) Types or monitoring equipmentinstruments that wi II be employed for

radiological and chemical monitoringcharacterization and how these monitoring instruments will be used (eg scanning percent) to determine the presence of contamination and hot spots

v) Chemical make-up of the wash solution to be used in the decontamination of portable equipment and the appropriateness ofthis solution for organics inorganics and radionuclides

vi) Methods in addition to portable berms that will be used for eontainment of wash water

vii) Decontamination and verification of the wash water collection areas if wash vater analyses indicate contamination is present

viii) Procedures for the verification of decontamination 01 equipment and how levels of residual contamination will be determined

IX) Listing of the sample methods to be used for each typegroup of constituent present and for each medium to be sampled at eaeh container storage area

x) Significance of increase of analytes in contaminated wash down waters is to be determined using statistical methods defined in SW-846 The plan shall provide the specific statistical methods that will be used to determine if wash down waters show a significant increase in analytical parameters when compared to clean wash water solutions Also the plan shall define a significant increase in accordance with SW-846

xi) Decontamination verifieation for radionuclides shall include swipe analyses of structures or other equipment that is 10 be left on-site per NRC Regulatory Guide 186 to verify that removal contamination has been adequately removed and that there are no remaining hot spots of unacceptable level The plan shall include the use of swipes and discuss how many swipes will be taken the amount of coverage of the item requiring swiped and the method of analysis

xii) Veri tication for hazardous waste residues shall also be verified using swipe analysis and discussion of how many swipes will be taken percent surface eoverage and the method of analysis and

xiii) Pursuant to 2041500 NMAC (incorporating 40 CFR 2641 12(b)(4) and 264178) methods for sampling and testing surrounding and underlying soils (affected or unaffected) at each container storage area shall be provided Verification of these soils to closure performanee standards in order to

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

demonstrate that all soils surrounding the container storage areas are free of contamination or exhibit acceptable levels of contamination Include the number and locations of background soil samples and the analytical parameters and appropriate analytical methods

g) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the container storage structures within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule 1 Of this plan must address the following items

i) Monitoring of portable equipment storage structure walls and floors for fixed contamination and how any structure determined to contain fixed contamination will be decontaminated and veritled clean

Ii) Monitoring of storage structures and inspection ft) any cracks or conditions that would potentially lead to loss of decontamination liquids for contamination prior to sealing or other treatment and how these flaws in storage structures wi 11 be monitored to ensure no contamination has migrated into thc Haw prior to rcmedial action (eg sealing of cracks)

iii) Sampling and analytical methods to be employed if leaching from a structure (11001 andor walls) is determined to be the source of contamination in the wash water

iv) Monitoring of drain lines connected to sumps and other recessed areas and v) Method for determining how suflicient numbers of samples will be

determined including a discussion of how the number of verification samples ItH each container storage structure will be determined

h) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the asphalt-covered areas within Area G In addition to the information provided in the permit renewal applieation and in Compliance Schedule 10f this plan must address the following items

i) Procedures that may potentially be used to decontaminate the asphalt-covered storage areas

ii) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo ifthe asphalt is removed sampling of the soil underlying the removed asphalt must be conducted All contaminated underlying soil must also be removed and verification sampling conducted The plan shall include a discussion of how underlying soil will be sampled removal methods for any contaminated soils and veritication procedures lor the remaining soils

iii) Discussion of the sampling and analytical methods that will be used to determine iI leaching of contaminants from the asphalt is the source of contamination in wash water

iv) Pursuant to 2041500 NMAC (incorporating 40 CFR 264112 (b)(4raquo soils surrounding the asphalt-covered areas shall be sampled and tested for potential contamination The plan shall discuss how soils surrounding the asphalt-covercd storage locations will be sampled how many samples will be

A-8

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

taken what sampling methods will be applied and how contaminated soils will be removed and

v) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each asphalt-covered area will be determined

i) The Permittees shall provide to the Secretary within 90 calendar days a revised decontamination and verification plan for the shafts within Area G In addition to the information provided in the permit renewal application and in Compliance Schedule I OL this plan must address the following items

i) Decontamination or the storage shafts including the number and locations of samples and corresponding collection methods the analytical methods to be used for analysis of samples the decontamination methods to be llsed if sampling indicates the presence of hazardous constituents and in the shafts the number and location of veri tic at ion samples to be taken to ensure adequate decontamination

ii) Verification screening for radiological hot spots and localized areas of elevated organics upon completion of shaft decontamination ancl

iii) Method for determining how sufficient numbers of samples will be determined including a discussion of how the number of verification samples for each shaft will be determined

11) Area Land TA-S4 West Closure Plan

The Permittees shall provide to the Secretary within 90 calendar days a closure plan for each of Area Land TA-S4 West The Area Land TA-S4 West closure plans shall meet the requirements for closure as outlined in 2041900 NMAC (incorporating 40 CFR 27014(b)(13) and (IS) through (18raquo) and 204IS00 NMAC (incorporatlng 40 CFR 264110 through 264120 and 264178) The closure plans shall address itcms similar to those contained in the application for Area G and as requested in Compliance Schedules B10 In generaL the closure plans shall address how each container storage area will be closed how final closure for each area will be conducted and the maximum extent of operations that will be left unclosed during the active life ofthe facility Other components ofthe closure plans shall include

i) Closure performance standard ii) Partial closure iii) Maximum waste inventory iv) Schedule for closure v) Time allowed tor closure vi) Extension for closure time vii)Inventory removal viii) Disposal or decontamination of equipment structures and soils and ix) Verilication of decontamination

A-9

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

Weight restrictions

Transportation of waste

60

waste 60

Conta illll1 ent Systems

B-6J Containment Systems

B-73

B-7b

B-8

Location waste

Policies and precautions

Containers B-4c Condition of Ventilation

Containers B-5a Management Container

of Containers ~~~--~ ~~7~---~------~----~~-~--~---------~------~--~~--~

l3-5b Management of Containers

60

A-IO

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II

Decontamination and verification plan general to all areas

Decontam ination and verification plan conta iner storage structures Decontall1~in~a-Ctj-o~n~a~n--(Cverjficationplan asphalt-covered

jance schedules are based on calendar

A-II