NATIONAL LABORATORY --ESt. Ha1ardous Waste t' Alamos National Labs...(505) 667-4218/Fax (505)...

.. ~ jlosAiamos NATIONAL LABORATORY --ESt. l9~J --

Environment Safety & Health PO Box 1663, MS K491 Los Alamos, New Mexico 87545 (505) 667-4218/Fax (505) 665-3811

Mr. John E. Kieling, Chief Hazardous Waste Bureau New Mexico Environment Department 2905 Rodeo Park Drive East, Building 1 Santa Fe, NM 87505-6303

Dear Mr. Kieling:

1£5 NMED \P..'1 Ha1ardous Waste

Los Alamos Field Office, A316 t' c- L

3747 West Jemez Road

Date: Symbol: LA-UR:

Locates Action No.:

Los Alamos, New Mexico, 87544 ( 505) 667-5105

MAR 2 1 2016 AD ESH -16-044 LA-UR-16-21793 N/A

Subject: Settlement Agreement and Stipulated Final Order HWB-14-20, Monthly Progress Report, February 23, 2016 - March 22, 2016

This Monthly Report is submitted as required by Paragraph 35 of the Settlement Agreement and Stipulated Final Order HWB-14-20 (SFO) entered into by the New Mexico Environment Department (NMED) (Complainant) and the U.S. Department of Energy (DOE) and Los Alamos National Security, LLC (LANS) (Respondents) on January 22, 2016. Paragraph 35 of the SFO requires the Respondents to keep NMED apprised of progress made on the corrective actions specified in SFO Attachment A on a monthly basis. The enclosed Summary Table reports the current status of the referenced corrective actions.

The Respondents would be pleased to meet with NMED-HWB personnel to discuss and explain the documentation included herein. If you have comments or questions regarding this submittal, please contact Mark P. Haagenstad (LANS) at (505) 665-2014 or David Nickless (EM-LA) at (505) 665-6448.

Sincerely,

A -- - ?\'~u, Michael T. Brandt, DrPH, CIH Associate Director Environment, Safety & Health Los Alamos National Security, LLC

MTB:KDL:MPH/lm

Sincerely, r ~B~~ Kimberly Da IS Lebak Manager Los Alamos Field Office U.S. Department of Energy

37502

lllllllllllllllllllllllllllllllllll

Mr. John Kieling ADESH-16-044

Enclosure: (1) Summary Table, LANL Settlement Agreement and Stipulated Final Order Report for March 22, 2016

Cy: Ryan Flynn, NMED, Santa Fe, NM, (E-File) Kathryn M. Roberts, NMED, Santa Fe, NM, (E-File) Siona Briley, NMED/HWB, Santa Fe, NM, (E-File) Neelam Dhawan, NMED/HWB, Santa Fe, NM, (E-File) Jody M. Pugh, NA-LA (E-File) Douglas E. Hintze, EM-LA, (E-File) Peter Maggiore, NA-LA, (E-File) Lisa Cummings, NA-LA, (E-File) Ben Underwood, EM-LA, (E-File) David Nickless, EM-LA, (E-File) Jordan Amswald, NA-LA, (E-File) Kirsten M. Laskey, EM-LA, (E-File) Craig Leasure, PADOPS, (E-File) William R. Mairson, PADOPS, (E-File) Randall M. Erickson, ADEP, (E-File) David Funk, ADEM, (E-File) Enrique Torres, ADEM, (E-File) Cheryl D. Cabbil, ADNHHO, (E-File) Michael T. Brandt, ADESH, (E-File) Raeanna R. Sharp-Geiger, ADESH, (E-File) John McCann, EPC-DO, (E-File) Andrew Montoya, WM-DO, (E-File) Jackie Hurtle, WM-DO, (E-File) Mark P. Haagenstad, EPC-CP, (E-File) Deborah Woitte, LC-ESH, (E-File) Susan McMichael, LC-ESH, (E-File) Deborah L. Guffee, SI-DC, (E-File) Yvette S. Branch, SI-DC, (E-File) Luciana Vigil-Holterman, EPC-CP, (E-File) [email protected], (E-File) [email protected], (E-File) [email protected], (E-File) [email protected], (E-File) [email protected], (E-File)

An Equal Opportunity Employer I Operated by Los Alamos National Security, LLC for the U.S. Department of Energy's NN~

Mr. John Kieling ADESH-16-044

CERTIFICATION

I certify under penalty of law that this document w a s prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Michael~ Associate Director Environment, Safety, and Health Los Alamos National Security, LLC Los Alamos National Laboratory Operator

berly Davis Leb k Manager Los Alamos Field Office U.S. Department of Energy Owner/Operator

Date Signe'd

Date &f gned/

A I• C!'-r,~ An Equal Opportunity Employer I Operated by Los Alamos National Security, LLC for the U.S. Department of Energy's NN~ I V A."~~'

........ _ .... ....- .......... ~"''""''''•"-'"'"

Enclosure 1

Attachment A to Settlement Agreement and Stipulated Final Order HWB-14-20, Monthly Status Report for February 23- March 22, 2016

ADESH-16-044

LA-UR-16-21793

Date: MAR 2 1 2016 -----

Page 14 LA-UR-16-21793

Document: Monthly Progress Report, SFO HWB-14-20 Enclosure 1 Date: March 2016

Enclosure 1 A ttac h ment AtSttl 0 e ement A .f,?reemen t d Sf I t d F. I 0 d HWB 14 20 M thl St t R an 1pu a e ma r er - - '

on ly a us epo rtfi Fb or e ruary 23 M h22 2016 - arc '

Topic Response Actions

Ordered Documentation to Target Actual Status/ Action Response (Ordered Action Provide as Evidence of Completion Completion Comments

no. No. description) Complete In-Progress/ Completion1 Date Date

Ongoing0

1 1.0 No later than 60 days after AC0-1 Written report - AC0-1 Written report 22-March-16 22-March-16 Completed this Order becomes final, Description of actions with enclosures noted for Respondents shall submit to Respondents have taken/ ACO 129 below NMED a written report will take to prevent describing any and all recurrence actions Respondents have NOTE: Discussion of the taken to prevent any following ACO Paragraph recurrence of violations 129 response actions will described herein. The be included in the Written written report shall include Report changes to procedures that Respondents have implemented already.

1 1.1 Standing Order for Area ADEP Standing Order, 22-March-16 22-March-16 Completed G - Restrict Nitrate Salt ·Restriction on waste processing Processing Nitrate Salt':

TA-54 AREA G, EP-AREAG-S0-1 242, Rev.a

1 1.2 Standing Order for All ADEP Standing Order, 22-March-16 22-March-16 Completed EWMO Facilities - Pause "EWMO Legacy TRU ALL legacy TRU waste Waste Pause", EP-DIV-processing at EWMO- S0-20222, R.1 supported facilities

Page 11 LA-UR-16-21793



Documentation to Ordered Target Actual Status/ Action Response (Ordered Action In-Progress/

Provide as Evidence of Completion Completion Comments no. No. description) Complete Completion• Date Date

Ongoing11

1 1.3 Standing Order for All ADESH issued Standing 22-March-16 22-March-16 Completed [Laboratory Wide] Waste Order, "Waste Treatment Generators - Waste Requirements" Treatment Requirements -Lab-wide requirement for environmental compliance staff involvement in waste processing or treatment project planning

1 1.4 Centralizing ENV Organization Chart 22-March-16 22-March-16 Completed Environmental (Before incident) Compliance activities ADESH organization withinADESH for LANL Chart (After incident)

Brief summary of how the organizational changes address the violations cited (i.e., how the reorganization intends to fix the problems the previous organization failed to identify/prevent)

1 1.5 Introduction of Senior ADEP Organization Chart 22-March-16 22-March-16 Completed Management Team with (Before incident) technical background to ADEP organization Chart understand complexity of (After incident) chemical operations.

Brief summary of how the organizational changes address the violations cited (i.e., how the reorganization intends to fix the problems the previous organization failed to identify/prevent), timeline and bios.

Page 12 LA-UR-16-21793




no. No. description) Complete In-Progress/ Completion1 Date Date Ongoing11

1 1.6 Develop Briefing to Briefing Summary 22-March-16 22-March-16 Completed Senior Management Attendance Metrics

1 1.7 Standing Order for Standing Order for 22-March-16 22-March-16 Completed incorporation of Exhibit F Subcontractor ESH ENV review of subcontract Oversight, ADESH-SO-scope and requirements 004, Rev.a for LANL Permit Compliance

1 1.8 Review of P1020-2, Memo documenting 22-March-16 22-March-16 Completed Laboratory Document review of LANL P1020-2 Control and basis for no revision

in regards to ACO requirements.

Page j 3 LA-UR-16-21793





1 1.9 Training - Education and • Waste Summary of training 22-March-16 22-March-16 Training training of waste Generation completed and training planned is management workers Overview, planned described in (managers, supervisors, Course 23263 Section 1.9 of technicians, generators) to • RCRA Personnel McCoy's 2015 RCRA

Enclosure 1, recognize when Training (Live), Hazardous Waste

ADESH-16-processing becomes Course 7488 Seminar (3-day), Course

040, treatment. "Response to The following have been

• RCRA Summary Ordered Action

Refresher, Waste Management 1," submitted revised and/or developed Course 28582 Coordinator (WMC) and to NMED and delivered to the appropriate audiences: • Waste ENV Deployed staff under separate

Generation (DEP) Environmental cover. It is in • McCoy's training Overview Annual Personnel RCRA progress and • DEP/WMC RCRA Refresher, Compliance Training - on track for

Compliance training Course 21464 Live Briefing (March 25, 2016

• RCRA Refresher for 2015) - Summary completion,

Waste Managers including:

training RCRA Refresher for

• OJT training for TSO Waste Managers, Course -Review and inspectors 28426

update of the RCRA

Waste Generation Personnel Overview , Course 23263 Training, Waste Generation Course #7488 Overview Annual and RCRA Refresher, Course 21464 Refresher, RCRA Personnel Course Training (Live), Course #28582 7488

-On-the-Job

RCRA Refresher, Course Training (OJT) for TSO

28582 Inspectors, Course

NOTE: The RCRA #27745, Refresher for Waste Managers Training - -Subcontractor Course 28426 to be Technical

Page 14 LA-UR-16-21793



Ordered Documentation to Target Actual Status/ Action Response (Ordered Action In-Progress/

Provide as Evidence of Completion Completion Comments no. No. description) Complete Completion• Date Date

Ongoing11

included as a Representative requirement for (STR) Subcontract Technical Training, Representatives (STRs), Course as noted in the STR #45250; Qualification Standard

NOTE: Both RCRA -Subcontractor Personnel Training, Technical [Course 7488) and RCRA Representative Refresher, [Course (STR) 28582) have been Refresher, reviewed and revised to Course bolster the LANL HWF #46795 permit detail. Both courses are required training for all Subcontract personnel working on LANL property, as noted in Subcontract Exhibits.

LANL Training Analysis for On-the-Job Training for TSO Inspectors, Course 27745 -Summary

Training Analysis for RCRA Refresher for Waste Managers, Course 28426 - Summary

Training Analysis for RCRA Personnel Training, Course 7488-Summary

Page 15 LA-UR-16-21793

Document: Monthly Progress Report, SFO HWB-14-20 Enclosure l Date: March 2016



Provide as Evidence of Completion Completion Comments no. No. description) Complete Completion1 Date Date

Ongoing11

Training Analysis for RCRA Refresher, Course 28582- Summary

Training Analysis for Waste Generation Overview, Course 23263- Summary

Training Analysis for Waste Generation Overview Refresher, Course 21464-Summary

1 1.10 Waste Profile Form 22-March-16 22-March-16 Completed Validation for Mixed and A report wh ich Hazardous Waste identifies the listof Review of the active hazardous waste characterization of all streams reviewed by the currently active LANL generator/ WMC teams Hazardous waste streams. and WM Division, with

conclusions/ summary

Page I 6 LA-UR-16-21793





1 1.11 Evaluation of RCRA Self- CTAP Evaluation and 22-March-16 22-March-16 Completed Assessment program Gap Analysis Report with needs (Compliance Compliance Technical Technical Assistance Assistance Program Program or CT AP) (CTAP) Procedure (ENV-

CP-QP-115) as enclosure.

1 1.12 Operating Record Summary of Compliance 22-March-16 22-March-16 Completed Validation - Validation of Technical Assistance the LANL Operating Program (CTAP) Record at all TSDs (T As 3, Procedure (ENV-CP-QP-50,54,55,63, 14, 16,36, 115) assessments and 39 permitted and interim electronic access to the status areas walk down). current document

revision upon NMED request. Provide periodic [Semi-annually, or upon Respondents NMED request] listing of will provide document(s) revisions. semi-annual

listing of

Summary of P409 Tool, document(s) revisions. First ADESH-TOOL-803 submittal is Facility TSF Operating planned for

Record and EWMO RCRA Permit Operating July 2016.

Record and Compliance Programs, EP-DIV-AP-21, R1 .LANL to provide electronic access to the current document(s) revision upon NMED request. Provide periodic [Semi-annually, or upon NMED request] listing of document(s) revisions.

1 1.13 WCATS Data Change Summary of ENV-RCRA- 22-March-16 22-March-16 Completed Control - Implementation TOOL-719 Using

Page 17 LA-UR-16-21793

Document: Monthly Progress Report, SFO HWB-14-20 Enclosure I Date: March 2016




Ongoing11

of Waste Compliance and WCA TS to Submit Respondents Tracking System (WCATS) Change Requests, and will provide change control process. electronic access to the semi-annual

current document(s) listing of revision Provide periodic document(s) [Semi-annually, or upon revisions. First NMED request] listing of submittal is document revisions. planned for

July 2016.

1 1.14 Waste processing Procedure reviews ENV-CP-AP-200, 22-March-16 22-March-16 The Response procedure review. ongoing. Regulatory Procedure Action Implementation of Review of Waste described in

procedure reviews by Management Procedures Section 1.14 of ENV-CP. Summary of and electronic access to Enclosure 1 ,

findings and procedure the current document ADESH-16-

revisions to date. revision. Provide periodic 040, [Semi-annually, or upon "Response to NMED request] listing of Ordered Action document revisions. 1" (submitted

under separate

AC0-9 response will cover), is complete.

provide details on However, number and type of EPC-CP procedures identified and procedure review status. reviews will

continue as newLANL procedures are created or existing ones revised. They are ongoing.

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no. No. description) Complete In-Progress/ Completion1 Date Date Ongolng11

1,

1 1.15 EOC Review EOG Self Disclosure 22-March-16 22-March-16 Completed The non-compliances Letter - LA-UR-15-

addressed in the EOC self- 26713, DIR-15-127

disclosure letter are the EOG Completion Letter-result of an extensive (ADESH-15-162) review of all legacy non- EOG Plan (EP-PLAN-nitrate salt wastes 10075, RO) processed under deficient

LA-CIN01 Management waste management procedures at LANL. Plan, (WD-PLAN-20280,

RO)

EOC Completion Letter-(ADESH-15-162)

Voluntarily reporting of non-compliances associated with MTRU wastes

EOC Plan (EP-PLAN-10075, RO) -

A plan for managing Extent of Condition by evaluating past remediation activities performed on transuranic (TRU) and mixed TRU (MTRU) waste

LA-CIN01 Management Plan, (WD-PLAN-20280, RO)

Defined steps to conservatively manage the LA-CIN01 waste containers and identify and apply appropriate EPA hazardous waste codes.

Page 19 LA-UR-16-21793





Ongoing11

1 1.16 Description of actions Exhibit F1 will Description of plans to 22-March-16 22-March-16 Pending being taken to strengthen address Industrial Implement major Exhibit actions, as Subcontractors' Health hazards F re-organization to result described in requirements to follow and controls in two Exhibits (F1 and Section 1.16 of LANL ES&H policies and F2) Enclosure 1, requirements through the

Exhibit F2 will ADESH-16-

Exhibit F conditions of their 040, subcontracts. address uResponse to

Environmental Strengthening of Compliance and

Ordered Action Contract Exhibit F Field Waste

1" (submitted

Verification Management under separate

Requirements for requirements cover), are in

environmental risks. progress. Summary of revisions proposed to strengthen P850 - Subcontract Technical Representative Procedure training and subcontractor oversight

2/3 2/3.1 Submit a Permit PMR Permit Modification 01-July-16 TBD PMR submittal Modification Request Request is now targeted (PMR) for treatment of for July 2016 Nitrate Salt wastes per

discussions with NMED-HWB.

Page I 10 LA-UR-16-21793



Ordered - Documentation to Target Actual Status/ Action Response (Ordered Action In-Progress/


Ongoing11

2/3 2/3.2 No later than 60 days after A. Remediated Nitrate Final Report on Chemical Reactivity and 16-May-16 TBD Final Report this Order becomes final, Salt Chemical Surrogate Waste Recommended on Surrogate Respondents shall submit to Reactivity Study Tests Remediation Strategy for Waste Tests NMED for review and Los Alamos Remediated will be comments the following : B. Nitrate Salt Waste Nitrate Salt (RNS) submitted per

Options Assessment Wastes, D. L. Clari<, D.J. the schedule in A. Reports on the scientific Report Funk, LA-UR-15-22393 Enclosure 3 of studies Respondents have ADESH-16-conducted regarding LANL C. Remediation!

Nitrate Salt Options 043,

nitrate salt waste streams Scheduling Plan as "Response to since February 14, 2014. discussed in technical Assessment Report LA-

Ordered meetings. The Plan UR-15-25355

Actions 213, " B. The nitrate salt waste shall include submitted to treatment options referenced plans and Remediation/Scheduling NMED under assessment report. a schedule for the Plan, including the separate

surrogate waste test following: cover. C. A Plan to determine report.

1. Sampling and Analysis treatment methods for the Plan for Unremediated nitrate salt waste streams. NOTE: The response to Nitrate Salt Waste, ENV-The Plan shall include a item C.iii [Final Report on 00-15-0248, LA-UR-15-proposed schedule for Surrogate Waste Tests 26357 submission of the following: (Final Title TBD)] will 2. Treatment Study Worf<

i. Sampling and analysis include UNS and SWERI Plan for Nitrate salt plan for unremediated analytical results. Transuranic (TRU) nitrate salt waste Wastes

ii. Surrogate waste NMED requested LA- 3. A schedule for the testing plan CIN01 .001 Liquid Final Report on

iii. Report on surrogate Sampling Information Surrogate Waste Tests waste tests Letter (ENV-D0-15-0313, (Final Title TBD)

iv. Safe handling and LA-UR-1528468)

treatment plan for both [NOTE: Safe Handling remediated and and Treatment Plan for unremediated nitrate Remediated Nitrate Salt salt wastes (RNS) and Unremediated

Nitrate Salt (UNS) Wastes is addressed under the Remediation! Scheduling Plan]

Page 111 LA-UR-16-21793

Document: Monthly Progress Report, SFO HWB-14-20 Enclosure I Date: March 2016




NMED requested LA-CIN01.001 Liquid Sampling Information Letter (ENV-D0-15-0313, LA-UR-1528468) with the following attachments:

• Ust of Containers sampled;

• List of Containers not sampled , but attempted;

• List of Containers of Interest;

• RTR Videos of Containers of Interest;

• Analytical results

4 4.0 Immediately upon this Summary report Summary report including 22-March-16 22-March-16 Completed Order becoming final, describing the MTRU development of Lessons Respondents shall begin waste stream Learned (to be described review of every mixed TRU characterization in summary report text) . waste stream which is verification review currently managed or generated at LANL to verify that the characterization of the waste streams is accurate, sufficient, and updated. Respondents shall complete and document their review in the Facility Operating Record within 60 days after this Order becomes final.

Page 112 LA-UR-16-21793

Document: Monthly Progress Report, SFO HWB-14-20 Enclosure 1 Date: ' March 2016



no. No. description) Complete In-Progress/ Completion• Date Date Ongoing11

5 5.0 No later than 15 days after Description of Procedure Summary of WSP Annual 03-March-16 Completed this Order becomes final, used for waste streams Review Methodology per Respondents shall submit annual reevaluation WCATS Users Manual, to NMED for review, t h e MAN-5004, R3, Sections methodology by which 4.3.1.4 and 4.2.1 .24 Respondents conduct their annual reevaluation of all

Summary of procedure, hazardous waste streams. Reviewing and Approving Waste Stream Profiles (WPS) in WCATS, WM-SVS-AP-201 and WCA TS Users Manual to describe the process to Respondents enter new and review will provide WSPs, (Sections 4.2.1 semi-annual and 4.2.2). Provide listing of electronic access to the document(s) current document revisions. First revision. Provide periodic submittal is [Semi-annually, or upon planned for NMED request] listing of July 2016. document revisions.

6 6.0 No later than 60 days after Copy of Operating 22-March-16 22-March-16 Completed this Order becomes final, Copy of Operating Record documentation Respondents shall submit (select WCATS printouts) to NMED any Record documentation for all active RCRA waste documentation (selected WCATS stream profiles with Respondents have entered printouts) for all active • WSP number in the Facility Operating RCRA waste stream

Brief description of Record for the most recent, • annual reevaluation of all

profiles the waste stream

hazardous waste streams • Date the WSP was at LANL. activated

• Date of the last annual review

The following WCATS fields were discussed

Page I 13 LA-UR-16-21793





among the technical team and the list updated to provide data:

• WS_ANCILLARY, • C_MASTER_ TRU.M

ATRIX_CODE,, • WS_COMPOSITION

' • access to WS_DOCUMENTAT ION via the WCATS Application,

• access to WS_EDITLOG via theWCATS Application,

• relevant summary of WS_EPACODE,

• Summary of C_PARAMETER at WSP level,

• WS_WORKPATH -active options,

• relevant summary of C_SHIPDESC.HM_I D->DOT _HAZMA T.DO T_ID_NO,

READ-ONLY

• Relevant summary access to

of WCATS

WS_CHAR_METHO through a

D, LANLWCATS navigator will

READ-ONLY access to be provided to WCATS provided to NMED staff NMED staff through a upon NMED LANL WCATS navigator, request. upon NMED request.

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no. No. description) Complete In-Progress/ Completion1 Date Date Ongoingn

7 7.0 No later than 60 days after Description of . Copy of WM-AP-0005, 22-March-16 22-March-16 Completed this Order becomes final, procedure(s) for AK Waste Characterization Respondents shall develop communication system, and Processing Review and submit to NMED internal and external by procedures to implement an establishing a Waste AK communication system Characterization and within and between Processing Review appropriate LANL Process organizations, including • To review waste subcontractors, to ensure stream profiles, that AK documentation is associated accurate, sufficient, and documentation, waste updated. processing

procedures and address complex waste management issues.

• To establish communication systems and protocol to ensure AK documentation is accurate, sufficient, and updated.

• To include provisions to ensure/ strengthen communication of AK information between subcontractors, LANL Subcontract Technical Representatives (STRs) and appropriate LANL organizations.

8 8.0 No later than 60 days after Status report on Ongoing active Copy of CCP/LANL 22-March-16 22-March-16 Revised CCP/ this Order becomes final , CCP/LANL interface participation in Interface Agreement LANL Interface Respondents shall revise agreement revisions CCPIA [revised, approved] Document was and submit to NMED the development delivered to CCP/LANL interface NMED in

Page 115 LA-UR-16-21793




no. No. description) Complete In-Progress/ Completion' Date Date Ongolng11

agreement to ensure ADESH-16-appropriate organizations 043, and subject matter experts "Response to communicate effectively and Ordered Action timely regarding changes in 8, " submitted waste management under separate procedures, waste cover. This generation, waste treatment, action is waste repackaging and remediation, waste stream

complete.

delineation, and waste characterization procedures to ensure that AK documentation is accurate, sufficient, and updated.

9 9.0 No later than 60 days after Description of Summary of [revised] 22-March-16 22-March-16 Completed this Order becomes final, Process(es) for policies and/or Respondents shall revise appropriate review of procedure(s) that have and submit to NMED procedures that have SME review and approval procedures and/or policies waste management of proposed waste that ensure the proper LANL aspects or impacts** (See management aspects or organizations and subject list under Documentation) impacts, including: matter experts review and • Reference to Waste • Summary of revised then approve or reject Characterization and P409 Waste proposed waste Processing Review Management management procedural process used to • ADEP Technical changes. resolve difficult waste Procedure

technical issues Development, EP-AP-10007, RO;

• ENV-CP-AP-200 Regulatory Procedure Review of Waste Management Procedures; and

• ADEP Document Control, EP-AP-10001, RO

• Waste Characterization and

Page I 16 LA-UR-16-21793




no. No. description) Complete In-Progress/ Completion' Date Date Ongoing11

- -Processing Review, WM-AP-0005, and

• Summary of Revised P409 - associated Tools

• ADESH-IG-TOOL-101 -Waste Management Glossary

• AD ESH-AP-TOOL-111 -Waste Characterization

• ADE SH-AP-TOOL-11 5 Waste Compatibility

• AD ESH-AP-TOOL-206-Hazardous Waste (General)

• AD ESH-AP-TOOL-300-Radioactive Waste Management

• ADE SH-AP-TOOL-314-Radioactive Waste Characterization

• ADE SH-AP-TOOL-803 -Facility Operating Record

• AD ESH-AP-TOOL-810-Waste

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Processing at Permitted Units

• ADE SH-AP-TOOL-901-Elementary Neutralization

• AD ESH-AP-TOOL-902-Absorption without a Permit

• ADE SH-AP-TOOL-906-Treatment by the Waste Generator

Electronic access to the Respondents current document(s) will provide revision will be provided semi-annual upon NMED request. listing of

document(s) revisions. First

LANL will provide periodic submittal is [Semi-annually, or upon planned for NMED request] listing of July 2016. document revisions.

9 9.1 Description of Revisions to Memorandum 22-March-16 22-March-16 Completed P300, Integrated Worl< documenting review and Management evaluation. Evaluation

results indicate no revision required to address violations.

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-Response Actions

Ordered Topic Documentation to Target Actual Status/ Action Response (Ordered Action Provide as Evidence of Completion Completion Comments

no. No. description) Complete In-Progress/ Completion1 Date Date

Ongoing11

9 9.2 Revise T A-55 Procedures Technical Procedure Use 22-March-16 22-March-16 Completed to incorporate ENV-CP and Development reviews Process, PA-AP-01016

9 9.3 Define process for T A-54 ADEP Technical 22-March-16 22-March-16 Completed Procedures to incorporate Procedure Development, ENV-CP reviews ER-AP-10007, RO

9 9.4 Revise WETF Procedures Document Development, 22-March-16 22-March-16 Completed to incorporate ENV-CP WETF-AP-10, Rev. H reviews

Other other Monthly reports Monthly, on 22-March-16 Completed 22nd of each month

i Some items being submitted as "Evidence of Completion" will not be "approved" by NMED (e.g., those subject to NMED review and comment); however, pursuant to paragraph 49 of the Settlement Agreement, if NMED disapproves any timely submission required by the Ordered Actions (e.g., response action), NMED shall identify the specific reason(s) for the disapproval, and the Respondent shall have the opportunity to correct any deficiencies and supplement the submission.

ii Ongoing Actions (Actions that will be initiated, but not completed, by March 22, 2016) are listed in the In-Progress/Ongoing Actions column.

Page I 19 LA-UR-16-21793

NATIONAL LABORATORY --ESt. Ha1ardous Waste t' Alamos National Labs...(505) 667-4218/Fax (505)...

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