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DOE OSTI2023

Addendum 2 to the Closure Report for CAU 577 Area 5 Chromium Containing Waste Disposal Cells, NNSS, Nevada

Corrective Action Unit (CAU) 577, “Area 5 Chromium Containing Waste Disposal Cells,” includes five low-level waste cells at the Nevada National Security Site Area 5 Radioactive Waste Management Site where buried waste received from Nuclear Fuel Services, Inc., was subsequently determined to contain chromium that exceeded the toxicity characteristic leaching procedure regulatory limit, which would require the waste to carry hazardous waste code D007. CAU 577 was created to satisfy the requirements of the Settlement Agreement (SA) executed between the Nevada Division of Environmental Protection (NDEP) and the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO) on April 25, 2019 (NDEP 2019). The SA required that the chromium-containing waste received from NFS would be addressed following the closure process laid out in the Federal Facility Agreement and Consent Order (FFACO). The FFACO process ensures proper closure of the chromium-containing waste and documentation of that closure through FFACO-type documents. The following three Corrective Action Sites (CASs) were closed, and their closure was documented in the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030, dated September 2021 (U.S. Department of Energy [DOE] Environmental Management [EM] Nevada Program 2021a): • CAS 05-21-02, Waste Disposal Cell 12 • CAS 05-21-03, Waste Disposal Cell 15 • CAS 05-21-04, Waste Disposal Cell 17 Closure of the following CAS was previously documented in the Addendum to the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030-ADD, dated September 2022 (DOE EM Nevada Program 2022): • CAS 05-21-05, Waste Disposal Cell 20 This second addendum to the Closure Report documents the closure activities that have occurred for CAS 05-21-06, Waste Disposal Cell 21. This is the last CAS in CAU 577. The final waste shipment was placed in the waste disposal cell on November 21, 2022. Following this, closure activities began on November 28, 2022, and were conducted according to the Corrective Action Decision Document/Corrective Action Plan (CADD/CAP) for CAU 577 (DOE EM Nevada Program 2021b). The following closure activities were performed: • Constructing an engineered evapotranspiration cover • Installing two subsidence monuments and vadose zone monitoring equipment • Seeding the cover with a mixture of native plant species • Installing four concrete monuments on the corners of the cover and placing two use restriction (UR) warning signs on each monument These activities fulfill applicable federal and state regulations for closure of CAS 05-21-06 and minimize potential future exposure pathways to buried waste. Completed closure activities are also consistent with closure of the nine historical Resource Conservation and Recovery Act (RCRA) units included in Section 10.2.2 of the RCRA Permit that governs hazardous waste management activities at the Nevada National Security Site (Permit NEV HW0101) (NDEP 2023). UR documentation for this CAS is included in Appendix B of this report. The post-closure plan is presented in detail in the CADD/CAP for CAU 577 (DOE EM Nevada Program 2021b), and the requirements are summarized in Section 5.2 of this document. In accordance with paragraph 5D of the SA, a request to incorporate the requirements for post-closure monitoring of CAU 577 was included with the permit application for RCRA Permit NEV HW0101 that was submitted in January 2022 (NNSA/NFO 2022). The request included the post-closure requirements for the three CASs that had been closed at the time of submittal of the application as well as requirements that would be implemented upon future approval of closure of the remaining two CASs. All CAU 577 post-closure monitoring requirements have been captured in the April 4, 2023, Revision 7 of the RCRA Permit (NDEP 2023). As the RCRA Permit NEV HW0101 has been revised since the submittal of the original CAU 577 Closure Report (DOE EM Nevada Program 2021a) and Addendum 1 (DOE EM Nevada Program 2022), the post-closure requirements in this Addendum 2 report do not align with the previous documents. Specific changes resulting from the issuance of Revision 7 of the RCRA Permit are discussed in Section 5.2 of this report. The requirements in this report are consistent with the current permit (NDEP 2023) and supersede all requirements listed in the CAU 577 Closure Report and Addendum 1. All CAU 577 post-closure requirements should be conducted in accordance with the version of the RCRA Permit that is current at the time of the activities being performed. The DOE EM Nevada Program is requesting a Notice of Completion from NDEP for closure of CAU 577. Although CAU 577 is not a legacy site, the FFACO process is being followed to ensure proper closure of the chromium-containing waste. Therefore, transfer of CAU 577 from Appendix III of the FFACO to Appendix IV, Closed Corrective Action Units, is requested, as all closure activities have been completed.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗
DOE OSTI2022

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada (CY2021)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): CAU 90, Area 2 Bitcutter Containment, CAU 91, Area 3 U-3fi Injection Well, CAU 92, Area 6 Decon Pond Facility, CAU 110, Area 3 WMD U-3ax/bl Crater, CAU 111, Area 5 WMD Retired Mixed Waste Pits, and CAU 112, Area 23 Hazardous Waste Trenches. This report covers calendar year 2021. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. This report will address all monitoring requirements noted in the RCRA Permit NEV HW0101, except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2021

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada: For Calendar Year 2020 (Rev. 2)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): 1) CAU 90, Area 2 Bitcutter Containment; 2) CAU 91, Area 3 U-3fi Injection Well; 3) CAU 92, Area 6 Decon Pond Facility; 4) CAU 110, Area 3 WMD U-3ax/bl Crater; 5) CAU 111, Area 5 WMD Retired Mixed Waste Pits; 6) CAU 112, Area 23 Hazardous Waste Trenches The locations of the sites are shown in Figure ES-1. This report covers calendar year 2020. The post-closure requirements for these sites are described in RCRA Permit NEV HW0101 and are summarized in each CAU-specific section of this report. The results of the inspections, a summary of maintenance activities, and an evaluation of monitoring data are presented in this report. Site inspections are conducted annually at CAUs 90, 91, and 112; semiannually at CAUs 92 and 110; and quarterly at CAU 111. Additional inspections are conducted at CAUs 92 and 111 if precipitation occurs in excess of 1.0 inch in a 24-hour period. Inspections include an evaluation of the condition of the units, including covers, fences, signs, gates, and locks. At CAUs 110 and 111, soil moisture monitoring and subsidence surveys are conducted in addition to the visual inspections. At CAU 110, the site fence, gate, lock, and use restriction signs are evaluated. At CAU 111, an ecological survey, direct radiation monitoring, air monitoring, radon flux monitoring, and groundwater monitoring are also conducted. This report will address all monitoring item notes above except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site. All required inspections, maintenance, and monitoring were conducted in accordance with the post-closure requirements of the permit. Revision 6 of RCRA Permit NEV HW0101 was issued effective December 10, 2015, and remained in effect until December 10, 2020. At the time of this report submittal, the new RCRA permit application was in review.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2022

Post-Closure Report for Closed Resource Conservation and Recovery Act Corrective Action Units, Nevada National Security Site, Nevada, For Calendar Year 2021 (Revision 1)

This report serves as the combined annual report for post-closure activities in compliance with the requirements listed in Resource Conservation and Recovery Act (RCRA) Permit Number NEV HW0101 associated with the following closed corrective action units (CAUs): CAU 90, Area 2 Bitcutter Containment; CAU 91, Area 3 U-3fi Injection Well; CAU 92, Area 6 Decon Pond Facility; CAU 110, Area 3 WMD U-3ax/bl Crater; CAU 111, Area 5 WMD Retired Mixed Waste Pits; and CAU 112, Area 23 Hazardous Waste Trenches. This report will address all monitoring requirements noted in the RCRA Permit NEV HW0101, except groundwater monitoring. Groundwater monitoring is documented in the Nevada National Security Site Data Report: Groundwater Monitoring Program Area 5 Radioactive Waste Management Site.

54 ENVIRONMENTAL SCIENCES↗