WIPP Environmental Reporting Requirements

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Report
Type-Scheduled Unscheduled
Frequency
Due Date
Origin of Requirement
Reference
Preparing Organization(s)
Reviewing Organization(s)
Recipient(s)
Annual Mine Ventilation Report S Annual 27-Oct RCRA HWFP IV.F.2.b
The Permittees shall submit to the Secretary an annual report, beginning twelve (12) months after issuance of this permit, describing the implementation and presenting the data and analysis of the Confirmatory VOC Monitoring Plan.		 MOC CBFO Assistant Manager of Operations Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Annual Mitigation Action Report S Annual 7-Jul DOE Order DOE O 451.1B(4)(g) In addition to requirements established in NEPA and the Regulations, DOE's NEPA Compliance Program shall include: g. Tracking and annually reporting progress in implementing a commitment for environmental impact mitigation that is essential to render the impacts of a proposed action not significant, or that is made in a record of decision. MOC CBFO NEPA Compliance Officer DOE Headquarters (EM-1) 1000 Independence Avenue, SW
Washington, DC 20585
Annual NEPA Planning Summary S Annual January DOE Order DOE O 231.1A(5)(c)(1)
In accordance with DOE M 231.1-1A, Chapter IC
(a) report annually on the progress made in implementing, and the effectiveness of, any commitment for environmental impact mitigation that is essential to render the impact of a proposed action not significant or that is made in a record of decision and
(b) prepare an annual NEPA planning summary.		 MOC CBFO NEPA Compliance Officer DOE Headquarters (EH-1) 1000 Independence Avenue, SW
Washington, DC 20585
Annual Site Environmental Report S Annual 1-Oct DOE Order, RCRA, C&C Agreement DOE O 231.1A(5)(b)(3)
Prepare summaries of environmental data annually to characterize site environmental management performance. (See DOE M 231.1-1A, Chapter I.) HWFP L-4e(4)
The results of the statistical comparison will be reported annually in the Annual Site Environmental Report (ASER), and will be reported to NMED as required under20.4.1.500 NMAC (incorporating 40 CFR 264.98(g)).
HWFP L-5a
All analytical results will be provided to NMED., HWFP L-5b
Analytical results from semi-annual ground-water sampling activities will be compared and interpreted by the Team Leader through generation of statistical analyses as specified in Section L-4e. The Team Leader will perform statistical analyses; the results will be included in the ASER in summary form, and will also be provided to NMED as specified in Permit Module V., HWFP L-5c
Data collected from this DMP will be reported to NMED as specified in Permit Module V, and to the EM Manager and NMED in the ASER. The ASER will include all applicable information that may affect the comparison of background ground-water quality and groundwater surface elevation data through time. HWFP V.J.2.c,
L-4c(1)
Groundwater flow and radionuclide sampling results: the Permittees shall submit to the Secretary an evaluation of the groundwater flow data specified in Permit Condition V.H and the results of radionuclide-specific analysis of groundwaters sampled from the DMWs in the Annual Site Environmental Report. 40 CFR 264.91 (20.4.1.500 NMAC)
The owner or operator must institute a detection monitoring program. The Secretary will specify in the facility permit the specific elements of the program. Groundwater monitoring data, including actual levels of constituents must be maintained in the facility operating record. The Secretary will specify in the permit when the data must be submitted for review. The owner or operator must determine the groundwater flow rate and direction at least annually. DOE will continue to provide the State of New Mexico with all available relevant data and documentatioin relating to the environmental aspects of the WIPP operations in a timely manner during the entire operational life of WIPP		 MOC CBFO Assistant Manager of Operations DOE Headquarters (EH-1) 1000
Independence Avenue, SW
Washington, DC 20585, U.S.
Environmental Protection Agency, Region VI,
1445 Ross Avenue,
Dallas, Texas 75202,
Hazardous Waste Permits Program Manager,
Hazardous Waste Bureau,
New Mexico Environment Department,
2905 Rodeo Park Drive East, Building 1,
Santa Fe, New Mexico 87502,
New Mexico Environment Department
DOE Oversight Bureau
2905 Rodeo Park Drive East, Building 1,
Santa Fe, NM 87505
Biennial Environmental Compliance Report S Biennial October 30, even-numbered years LWA LWA Section 9(a)(2)
The Secretary shall, not later than two years after the date of the enactment of this Act, and biennially thereafter, submit documentation of continued compliance with the laws, regulations and permit requirements described in paragraph (1) to the Administrator, and, with the law described in paragraph (1)(C), to the state.		 MOC CBFO Assistant Manager of Operations
CBFO Office of Disposal		 U.S. EPA Headquarters
Office of Air and Radiation
Mail Drop 6101
401 M Street SW
Washington, DC 20460
Administrator, U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202
Secretary, NMED
1190 St. Francis Drive
Santa Fe, NM 87502, NM Energy, Minerals, and Natural Resources Department, 1220 S. St. Francis Drive, Santa Fe, NM 87505, US Bureau of Land Management, 1849 C Street, Washington, DC 20240, US Fish and Wildlife Service, 1849 C Street, Washington, DC 20240, US Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852, DOE HQ Office of NEPA Policy and Compliance, 1000 Independence Avenue, SW
Washington, DC 20585
Annual Change Report S Annual 30-Nov 191/194 40 CFR 194.4(b)(4)
Not later than six months after the Administrator issues a certification, and at least annually thereafter, the Department shall report to the Administrator, in writing, any changes in conditions or activities pertaining to the disposal system that were not required to be reported by paragraph (b)(3) of this section and that differ from information contained in the most recent compliance application.		 MOC CBFO Office of Disposal Office of Radiation and Indoor Air
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Compliance Monitoring Parameters Report S Annual 31-Aug 191/194 40 CFR 194.42 Disposal systems shall be monitored after disposal to detect substantial and detrimental deviations from expected performance at the earliest practicable time…. SNL, MOC CBFO U.S. EPA Headquarters
Office of Air and Radiation
Mail Drop 6101
401 M Street SW
Washington, DC 20460
Administrator, U.S. EPA Region VI
1445 Ross Avenue
Dallas, TX 75202
Geotechnical Analysis Report S Annual 27-Oct RCRA HWFP IV.F.1.b
The Permittees shall submit to the Secretary an annual report, beginning twelve (12) months after issuance of this Permit, evaluating the geomechanical monitoring program and shall include geomechanical data collected from each Underground HWDU during the previous year, as specified in Permit Attachment M2, Section M2- 5b(2), "Geomechanical Monitoring", and shall also include a map showing the current status of HWDU mining. 		MOC CBFO Assistant Manager of Operations Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Hazardous Chemicals Inventory-EPA Form R S Annual CERCLA 40 CFR 372.30 - For each toxic chemical known by the owner or operator to be manufactured, processed, or otherwise used in excess of an applicable threshold quantity at its covered facility for a calendar year, the owner or operator must submit to the EPA and to the state a completed EPA Form R. MOC CBFO Assistant Manager of Operations
CBFO Office of Disposal		 Submitted electronically to EPA via EPACDX through Form R, Preparation Software. TRI Data Processing Center, PO Box 1513, Lanham, MD 20703-1513, New Mexico Department of Public Safety, PO Box 1628, Santa Fe, NM 87501-1628, (505) 476-9681
Hazardous Chemicals Inventory-Chemical Release S Annual 1-Jul CERCLA 74-4E-5(A)(4)
Facility owners or operators employing at least 10 employees and with a covered Standard Industrial Classification (SIC) code must submit a toxic chemical release form on or before July 1 of each year to the public safety department.		 MOC CBFO Office of Disposal Hazardous Materials Program Manager, New Mexico Department of Public Safety, Office of Emergency Services and Security, 13 Bataan Blvd., Santa Fe, NM P.O. Box 1628 Santa Fe, NM 87501-1628
Hazardous Chemicals lnventory S Annual 1-Mar CERCLA 40 CFR 370.25
The owner or operator of a facility shall submit an inventory form to the SERC, LEPC, and the fire department with jurisdiction over the facility for hazardous chemicals at the facility during the preceding calendar year by March 1 of each year.		 MOC CBFO Assistant Manager of Operations
CBFO Office of Disposal		 National Response Center
(800) 424-8802 NMED, (505) 827-9327
Administrator, U.S. EPA Region VI, 1445 Ross Avenue, Dallas, TX 75202 Eddy Co. Emergency Planning Committee, 324 S. Canyon Road, Suite B, Carlsbad, NM 88220, (505) 885-3581 NM Emergency Response Commission, PO Box 1628, Santa Fe, NM 87504-1628, (505)824-9223
Hazardous Waste Generator's Report S Biennial March 1, even numbered years RCRA 40 CFR 262.41 (20.4.1.300 NMAC)
HWFP  ' II.K.2
Each generator of hazardous waste that ships the waste off-site to an approved TSDF must file a report to the EPA by March 1 of every even-numbered year. This report is required to contain a description of the efforts undertaken during the year to reduce the volume and toxicity of the waste and a comparison of the volume and toxicity of the waste to previous year		 MOC CBFO Assistant Manager of Operations NMED
Hazardous Waste Bureau, Data Management Program
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Laboratory Operating Procedures S Annual 31-Dec RCRA HWFP L-4c(3)
The Permittees will provide NMED with an initial set of applicable laboratory SOPs for information purposes, and provide NMED with any updated SOPs on an annual basis.		 MOC CBFO Assistant Manager of Operations
 Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Confirmatory Measurement Complinace Report S Biennial October 30, even numbered years EPA guidance for 40 CFR 191, Subpart A 40 CFR 191.03, 40 CFR 61.94, and May 16, 1995 Memorandum of Understanding between EPA and DOE concerning the Clean Air Act. MOC CBFO Assistant Manager of Operations
CBFO Office of Disposal		 Office of Radiation and Indoor Air
U.S. Environmental Protection Agency
Ariel Rios Building, 6601 J
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
NESHAP Report
 S Annual 30-Jun NESHAP
40 CFR 61.94 and the May 16, 1995 Memorandum of Understanding between EPA and DOE concerning the Clean Air Act
A NESHAP annual report must be submitted by June 30th for facilities subject to Subpart H of NESHAP.
 MOC CBFO Assistant Manager for Operations
CBFO Office of Disposal
U.S. Environmental Protection Agency,
Region VI
1445 Ross Avenue
Dallas, Texas 75202
PCB Report-Document Log
 S Annual 1-Jul TSCA
40 CFR 761.180 Document Log
A written annual document log is prepared by July 1 covering the previous calendar year (January thru December). The log is to include;
-                     Identity of the WIPP site
-                     Manifest numbers
-                     Container numbers
-                     Description of the contents
-                     Dates removed from service
-                     Transportation dates
-                     Dates received at WIPP
-                     Disposal dates
-                     Dates Certificates of Disposal sent to generator/storage site
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Annual Report
 S Annual 15-Jul TSCA
40 CFR 761.180 Annual Report
Annual report (to EPA Region VI) from the written annual document log the owner or operator of a facility prepares the annual report containing information required by 40 CFR 761.180 (b)(3)(i) - (b)(3)(vi) for PCBs and PCB Items handled as PCB waste at the facility the previous calendar year (January through December). The annual report is submitted by July 15 of each year. 40 CFR 761.180
Submit an annual report on PCB waste disposal containing the information required by 40 CFR 761.180(b)(3)(I) through (b)(3)(vi) to the EPA Region 6 Administrator by July 15 of each year.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
RCRA Annual Report
 S Annual 1-Dec RCRA
HWFP VII.B.1
Annually, by December 1, for the previous year ending September 30, the Permittees shall enter into the operating record required by 20.4.1.500 NMAC (incorporating 40 CFR '264.73(b)(9)), a statement certified according to 20.4.1.900 NMAC (incorporating 40 CFR 270.11(d)) specifying that the Permittees have a program in place to reduce the volume and toxicity of hazardous wastes generated by the facility's operation to the degree determined by the Permittees to be economically practicable; and the proposed method of treatment, storage, or disposal is that practicable method currently available to the Permittees which minimizes the present and future threat to human health and the environment. A current description of the program shall be maintained in the operating record and a copy of the annual certified statement shall be submitted to the Secretary.
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Annual Report-Facility Work Plan
 S Annual 21-Jan RCRA
HWFP VII M.1
The Permittees shall submit a Facility Work Plan to the Secretary within ninety (90) calendar days of the effective date of this Permit.
The Permittees shall submit to the Secretary modifications to the Facility Work Plan on an annual basis.
 MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Biennial Report
 S Biennial March 1, even numbered years RCRA
40 CFR 264.75 (20.4.1.500 NMAC)
The owner or operator of a TSDF must submit a copy of a biennial report to the Secretary by March 1 of each even numbered year using EPA Form 8700-13B
 MOC CBFO Assistant Manager of Operations
NMED Hazardous Waste Bureau, Data Management Program,
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Mailing List-Amendments
 S Semi-annual November 30 and May 31 RCRA
HWFP VII.D.2.a
Within thirty (30) calendar days after the effective date of this Permit, the Permittees shall mail a notice to all individuals on the facility mailing list maintained by the Secretary, including all individuals that submitted oral or written comments or testimony on the Permittees' draft Permit during the public comment period. The Permittees shall, within six (6) months after the effective date of this Permit and every six (6) months thereafter, submit to the Secretary amendments to the facility mailing list to include those individuals that submit a written request to the Secretary and/or the Permittees for inclusion in this list.
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Nonconformance Report
 S Monthly As Required RCRA
HWFP Attachment B3-1
For any non-administrative nonconformance related to applicable requirements specified in this Waste Analysis Plan (WAP) which are first identified at the site Project Manager signature release level (i.e., a failure to meet a data quality objective [DQO]), the Permittees shall receive written notification within five (5) calendar days of identification and shall also receive a nonconformance report within thirty (30) calendar days of identification of the incident. The Permittees shall require the generator/storage site to implement a corrective action which remedies the nonconformance prior to management, storage, or disposal of the waste at WIPP. The Permittees shall send NMED a monthly summary of nonconformances identified during the previous month, indicating the number of nonconformances received and the generator/storage sites responsible.
 CTAC CBFO Office of Quality Assurance
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Permit Renewal
 S Every 10 years, 30-April RCRA
HWFP I.B.2
The Permittees may renew this Permit by submitting an application for a new Permit at least one hundred eighty (180) calendar days before the expiration date of this Permit.
 MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Progress Report
 S Quarterly November 15, February 5, May 6, and August 4 RCRA
HWFP VII.I.1
The Permittees shall submit, in accordance with Permit Condition VII.B.5, signed quarterly progress reports of all activities (i.e., RFI, CMS) conducted pursuant to the provisions of this Module
 MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Recertification Application
 S Quinquennial 26-Mar LWA
LWA Section 8(f) - Not later than 5 years after the initial receipt of transuranic waste for disposal at WIPP, and every 5 years thereafter until the end of the decommissioning phase, the Secretary shall submit to the Administrator and the State documentation of continued compliance with the final disposal regulation.
 MOC, SNL, LANL, CTAC CBFO, all
Administrator, EPA,
Washington, DC 20460,
Governor of NM,
Santa Fe, NM 87501
WAP Changes Report
S
Monthly
As Required
RCRA
HWFP Attachment B3-15
Controlled changes to WAP-related plans or procedures shall be managed through the document control process described in the QAPD. The Site Project Manager and the Site Project QA Officer shall review all non-administrative changes and evaluate whether those changes could impact DQOs specified in the Permit. After site certification, any changes to WAP-related plans or procedures that could positively or negatively impact DQOs (i.e., those changes that require prior approval of the Permittees as defined in Attachment B5, Section B5- 2) shall be reported to the Permittees within five (5) days of identification by the project level review. The Permittees shall send NMED a monthly summary briefly describing the changes to plans and procedures identified pursuant to this section during the previous month
 Generator/Site CBFO Office of Characterization and Transportation
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Water Discharge Report-Information Changes
S
Twice each year
July 31 January 31
New Mexico Water Quality Act
20.6.2.3107 NMAC (DP-831)
Requirements include periodic reporting to the Secretary of any information that may be required as set forth in the discharge permit, and notifying the NMED of any facility expansion, production increase, or process modifications that would result in the discharge of water contaminants.
 MOC CBFO Assistant Manager of Operations
New Mexico Environment Department, Ground Water Pollution Prevention Section
P.O. Box 26110
Santa Fe, New Mexico 87502
Water Quality Report
S
Once every three years
National Primary Drinking Water Regulations
40 CFR 141.90
Except as provided in paragraph (a)(1)(viii) of this section, a water system shall report the information specified below for all tap water samples specified in 141.86 and for all water quality parameter samples specified in 141.87 within the first 10 days following the end of each applicable onitoring period specified in 141.86 and 141.87 (i.e., every six months, annually, every 3 years, or every 9 years).
 MOC Assistant Manager of Operations
NMED Regional Office,
1216 Mechem Drive,
Ruidoso, New Mexico 88345
Air Quality Permit Report-Emission Inventory
U
As requested by NMED
As requested by NMED
Air Quality Permit
Permit No. 310-M-2 for Backup Diesel Generators, Annual Emission Inventory
An emission inventory is required annually for any stationary source permitted under 20.2.72 NMAC (except for those sources that are permitted only for toxic air pollutant emissions). Other sources that are required to file an annual emission inventory are those that must file a Notice of Intent under 20.2.73 NMAC or that emit in excess of 1 ton of lead or10 tons of total suspended particulates, particulate matter with an aerodynamic diameter of 10 μ or less (i.e., PM10), sulfur dioxide, nitrogen dioxide, carbon monoxide, or VOCs in any calendar year including and subsequent to 1990.
 MOC CBFO Assistant Manager of Operations
New Mexico Environment Department
Air Quality Bureau
2048 Galisteo
Santa Fe, NM 87502
Air Quality Permit Report-Emissions Control Changes
U
As Required
As Required
Air Quality Permit
Permit No. 310-M-2 for Backup Diesel Generators, Condition 1
Changes in plans, specification, and other representations provided in the application documents shall not be made if they change the method of emissions control or in the character of the emissions or if they would increase the discharge of emissions. Any such proposed change must be submitted as a proposal revision or modification of the permit in accordance with the condition described in Section 28.3.1.4 below.
 MOC CBFO Assistant Manager of Operations
New Mexico Environment Department
Air Quality Bureau
2048 Galisteo
Santa Fe, NM 87502
Air Quality Permit Report-Compliance Testing
U
As Required
30 days after completion of test
Air Quality Permit
Permit No. 310-M-2 for Backup Diesel Generators, Conditions 3-4
Two copies of the compliance test report must be submitted to the NMED within 30 days after completion of testing.
 MOC CBFO Assistant Manager of Operations
New Mexico Environment Department
Air Quality Bureau
2048 Galisteo
Santa Fe, NM 87502
Air Quality Permit Report-Control or Ownership
U
As Required
Within 15 days of change in ownership
Air Quality Permit
Permit No. 310-M-2 for Backup Diesel Generators, Condition 6 If there is any change in control or ownership of the diesel generators, the permittee shall notify the succeeding owner of the permit and its conditions and shall notify the NMED of the change in ownership within 15 days.
 MOC CBFO Assistant Manager of Operations
New Mexico Environment Department
Air Quality Bureau
2048 Galisteo
Santa Fe, NM 87502
Air Quality Permit Report-Sources Changes
U
As Required
As Required
Air Quality Permit
Permit No. 310-M-2 for Backup Diesel Generators, Condition 10. The permittee will notify the NMED in writing or provide the NMED with the following information: The anticipated date of the initial start-up of each new or modified emission source at least 30 days prior to that date and the actual date of the initial start-up of each new or modified source within 15 days after the start-up date.
MOC CBFO Assistant Manager of Operations
New Mexico Environment Department
Air Quality Bureau
2048 Galisteo
Santa Fe, NM 87502
RCRA Monitoring Report
U
As Required
120 calendar days after final sampling is completed
RCRA
HWFP V.J.2.a
L-5a
Data evaluation results - the Permittees shall submit to the Secretary the analytical results required by Permit Conditions V.E.1 and V.I.2, and the results of the statistical analyses required by Permit Condition V.I.3, in compliance with the schedule on Table V.J.2.a, and as required by 20.4.1.500 NMAC (incorporating 40 CFR 264.97(j))
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Unscheduled Change Report
U
As Required
As Required
191/194
40 CFR 194.4(b)(3)
Any time after the Administrator issues a certification, the Department shall report any planned or unplanned changes in activities or conditions pertaining to the disposal system that differ significantly from the most recent compliance application.
 MOC, SNL, LANL CBFO Office of Disposal
Office of Characterization and Transportation
Office of Radiation and Indoor Air
U.S. Environmental Protection Agency
Ariel Rios Building, 6601 J
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
Generator Site Certification Report
U
As Required
As Required
191/194
40 CFR 194.8(b)(2)(i)
DOE will notify EPA by letter that a transuranic waste site is prepared to ship waste to the WIPP and has established adequate waste characterization processes and programs. DOE also will provide the relevant waste characterization program plans and documentation.
 TRU waste generator/storage site Office of Characterization and Transportation
U.S. Environmental Protection Agency
Ariel Rios Building
MS 66085
1200 Pennsylvania Ave, NW
Washington, DC 20460
Generator Site Certification Report-Final Auidit Report
U
As Required
After closure of audit findings.
RCRA
HWFP II.C.2.c
Final audit report - the Permittees shall provide the Secretary a final audit report as specified in Permit Attachment B6. The final audit report shall include all information specified in Permit Attachment B6, Section B6-4, and:
I.  A detailed description of all corrective actions and the resolution of any corrective action applicable to WAP requirements, including re-audits if required;
II. All documentation necessary for the Secretary to determine if the corrective action was resolved.
 CTAC CBFO Office of Quality Assurance
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Generator Site Certification Report-Audit Schedule
U
Monthly
As Required
RCRA
HWFP II.C.2.b
The Permittees shall provide the Secretary with a current audit schedule on a monthly basis and notify the Secretary no later than thirty (30) calendar days prior to each audit.
MOC CBFO Office of Quality Assurance
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
Hazardous Chemicals lnventory-MSDS
U
As Required
As Required
CERCLA
40 CFR 370.21
The owner or operator of a facility shall submit a material safety data sheet (MSDS) for each hazardous chemical present at the facility according to the minimum threshold schedule to the committee, the commission, and the fire department with jurisdiction over the facility. In lieu of the submission of an MSDS, the owner or operator may submit a list of hazardous chemicals for which an MSDS is required.
 MOC CBFO Assistant Manager for Operations
CBFO Office of Disposal
National Response Center
(800) 424-8802 NMED, (505) 827-9327
Administrator,
U.S. EPA Region VI,
1445 Ross Avenue,
Dallas, TX 75202
Eddy Co. Emergency Planning Committee,
324 S. Canyon Road, Suite B,
Carlsbad, NM 88220,
(505) 885-3581
NM Emergency Response Commission,
PO Box 1628,
Santa Fe, NM 87504-1628,
(505)824-9223
Notification Letter
U
As Required
Within 5 working days of report being issued
RCRA
HWFP IV.F.1.c
When evaluation of the geomechanical monitoring system data identifies a trend towards unstable conditions which requires a decision whether to terminate waste disposal activities in any Underground HWDU, the Permittees shall provide the Secretary with the same report provided to the WIPP Operations Manager within five (5) working days of its issuance, as specified in Permit Attachment M2, Section M2- 5b(2)(a), "Description of the Geomechanical Monitoring System".
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
PCB Report-New Panel
U
As Required
As Required
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section II.C. Disposal Unit
For a new panel, the owner/operator may not commence disposal until the Facility has notified in writing the EPA Region VI OK/TX RCRA Permits Section and received a written approval authorizing the new panel for PCB disposal. The notification must include a description and a map of the new panel. The description must include anticipated depth, length, and width of the new panel and how it will be operated.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Facility Modification
U
As Required
As Required
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section II.D. Disposal Unit
Any existing Facility modification or expansion in capacity from what was proposed in the PCB application of March 22, 2002, requires notification and response from EPA Region VI according to the procedures outlined in Section II.C. (i.e. written notification by DOE to EPA Region VI for approval authorizing the change, notification to include description, drawing, and operational reason for the change).
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-New Storage Area
U
As Required
As Required
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section III.B Waste Storage
For a new PCB/TRU storage area, the owner/operator may not commence storage of PCBs until the Facility has notified in writing the EPA Region VI OK/TX RCRA Permits Section and received a written approval authorizing the new storage area. The notification must description the new storage area and its capacity.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Storage Area Modifications
U
As Required
As Required
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section III.C Waste Storage
Any existing storage area modification or expansion in capacity over and above what is authorized in this approval requires notification and response from EPA region VI according to the procedures outlined in Section III. B. of these conditions (i.e. written notification by DOE to EPA Region VI for approval of a modification or expansion of a PCB storage area, notification is to describe the change to storage area and capacity).
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Panel Closure
U
As Required
30 days before closure of a disposal panel begins
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section V.B. Closure
The owner/operator must notify the EPA Region VI OK/TX RCRA Permits Section 30 days before closure of a disposal Panel is to begin, along with any proposed changes to the closure plan.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Ownership Transfer
U
As Required
30 days before transferring ownership
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.J. Transfer of Ownership
The owner/operator must notify EPA Region VI at least thirty (30) days before transferring ownership of the Facility. The owner/operator must also submit to EPA Region VI at least thirty (30) days before such transfer a notarized affidavit signed by the transferee stating that the transferee shall abide by the terms of this approval.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Noncompliance
U
As Required
By phone within 24 hours and within five working days submit a written report.
TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.K.1 Noncompliance Reporting
If the owner/operator finds it is in noncompliance with the Conditions of Approval and the non-compliance may pose a risk to human health or the environment, it must notify the EPA Region VI OK/TX RCRA Permits Section by phone within 24 hours and within five (5) work days submit a written report.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Noncompliance
 U As Required By phone or e-mail within 24 hours; submit written report within five working days TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.K.2 Noncompliance Reporting
If the owner/operator finds it is in non‑compliance with the Conditions of Approval, and the non-compliance does not pose a risk to human health or the environment, it must notify the EPA Region VI Toxics Enforcement Section by phone or e-mail within 24 hours, and submit a written report within five (5) work days. E-mail messages must confirm successful delivery by return e-mail.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Completeness and Correctness
 U As Required As Required TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.L. Other Information
If the owner/operator finds it has failed to submit relevant facts in its application, or submitted incorrect information in any report to EPA Region VI, it must promptly submit such facts or information to the EPA Region VI OK/TX RCRA Permits Section.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Spill Response
 U As Required As Required TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.N.1 Spills
PCB spills occurring at the Facility or from any onsite transport vehicle must be cleaned up according to the PCB Spill Cleanup Policy, 40 CFR. Part 761, Subpart G. PCB spills that must be reported in accordance with Subpart G include;
- A spill that directly contaminates sewers, surface or drinking water supplies
- A spill that directly contaminates grazing lands or vegetable gardens
- A spill that exceeds 10 pounds of PCBs by weight
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Spill Response
 U As Required As Required TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.N.1 Emergency Procedures
If spills cleanup will exceed the time allotted by the PCB Spill Cleanup Policy, the owner/operator must notify the EPA Region VI Toxics Enforcement Section of the spill circumstance, the PCB Spill Cleanup Policy. The EPA Region VI may order cessation of PCB disposal at the Facility if spills are not cleaned up in accordance with the PCB Spill Cleanup Policy.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Physical or Operational Changes
 U As Required Thirty days before a planned physical or operational change related to PCB handling and disposal TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.O. Duty to Notify
The owner/operator must notify the EPA Region VI OK/TX RCRA Permits Section in writing thirty (30) days before a planned physical or operational change related to PCB handling and disposal that may require modification of this approval.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Reauthorization Request
 U As Required 15-May TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section VI.P Re‑authorization
This authorization expires May 15, 2008. The application for re-authorization should be submitted one year before the expiration date, May 15, 2007.
 MOC CBFO Assistant Manager of Operations
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Data Reports
 U As Required As Required TSCA
Conditions of Approval for Disposal of PCB/TRU and PCB/TRU Mixed Waste, Section III.D General PCB/TRU Storage Requirements
4. All PCB Items must be identified in the WIPP Waste Information System to show the date of waste certification for disposal. This electronic database must show the date a PCB Item was removed from service for disposal and the date the PCB Item was sent to the Facility for disposal. This information must be provided to EPA upon request.
 MOC Office of Characterization and Transportation
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
PCB Report-Certificates of Disposal
 U As Required As Required TSCA
Sec. 761.218 Certificate of Disposal
For each shipment of manifested PCB waste that the owner or operator of a disposal facility accepts by signing the manifest, the owner or operator of the disposal facility shall prepare a Certificate of Disposal for the PCBs and PCB Items disposed of at the facility and send the Certificate of Disposal to the generator identified on the manifest which accompanied the shipment of PCB waste.
 MOC CBFO Assistant Manager of Operations
Individual Generator Sites
RCRA Closure Report-Planned Closure
 U As Required 60 calendar days prior to initiating closure RCRA
HWFP II.L.3
The Permittees shall notify the Secretary in writing at least sixty (60) calendar days prior to the date on which they expect to begin partial closure, i.e., closure of an Underground Hazardous Waste Disposal Unit (Underground HWDU), or final closure of the facility as required by 20.4.1.500 NMAC (incorporating 40 CFR ''264.112(d) and 264.601).
 MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Closure Completion
 U As Required Within 60 calendar days of completion of closure RCRA
HWFP II.L.6 and II.L.7
Within sixty (60) calendar days of completion of closure of each Underground HWDU, and within sixty (60) calendar days of completion of final closure, the Permittees shall certify in writing to the Secretary that the Underground HWDUs and/or facility have been closed as specified in the Closure Plan, Permit Attachment I, and as required by 20.4.1.500 NMAC (incorporating 40 CFR ''264.115 and 264.601).
No later than the submission of the certification of closure of each Underground HWDU, the Permittees shall submit a survey plat detailing the location and dimensions of each Underground HWDU with respect to permanently surveyed benchmarks, as required by 20.4.1.500 NMAC (incorporating 40 CFR '264.116).
 MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Land Use Authroity
 U As Required Within 60 calendar days of certifying closure RCRA
HWFP VI.D.1
No later than sixty (60) calendar days after certification of closure of each Underground HWDU, the Permittees shall submit to the Secretary and the local zoning authority, or the authority with jurisdiction over local land use, a record of the type, location, and quantity of TRU mixed waste disposed in each Underground HWDU, as required by 20.4.1.500 NMAC [incorporating 40 CFR 264.119(a)].
 MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Certification
 U As Required Within 60 calendar days of issuing a certification of closure for an underground HWDU RCRA
HWFP VI.D.2, and VI.D.2.b.
Within sixty (60) calendar days of certification of closure of the first Underground HWDU and within sixty (60) calendar days of certification of the last Underground HWDU, the Permittees shall comply with the following conditions, as required by 20.4.1.500 NMAC (incorporating 40 CFR '264.119(b)):
VI.D.2.b. Certification - the Permittees shall submit a certification to the Secretary, signed by the Permittees, stating the Permittees have recorded the notation specified in Permit Condition VI.D.2.a, including a copy of the document(s) in which the notation has been placed, as required by 20.4.1.500 NMAC (incorporating 40 CFR 264.119(b)).
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Post-Closure Care Certification
 U As Required Within 60 calendar days of completion of the post-closure care period for each underground HWDU RCRA
HWFP VI.D.4
No later than sixty (60) calendar days after completion of the post-closure care period for each Underground HWDU, the Permittees shall submit to the Secretary, by registered mail, a certification that the post-closure care for the Underground HWDU was performed in accordance with the specifications in the approved Post-Closure Plan, as required by 20.4.1.500 NMAC (incorporating 40 CFR '264.120). The Permittees and an independent New Mexico registered professional engineer shall sign the certification. The Permittees shall provide to the Secretary upon request the documentation supporting the professional engineer's certification, as required by 20.4.1.500 NMAC (incorporating 40 CFR 264.145(i) and 264.120).
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Intent to Close
 U As Required 30 days before placing the final waste in a panel. RCRA
HWFP I-1d(1)
Notification of intent to close occurs thirty (30) days before placing the final waste in a panel.
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Closure Plan Amendment
 U As Required 60 days prior to the proposed change in facility design or operation or within sixty 60 days of the occurrence of an unexpected event that affects the Closure Plan. RCRA
HWFP I-1d(4) If it becomes necessary to amend the Closure Plan for the WIPP facility, the Permittees will submit, in accordance with 20.4.1.900 NMAC (incorporating 40 CFR '270.42), a written notification of or request for a permit modification describing any change in operation or facility design that affects the Closure Plan. The written notification or request will include a copy of the amended Closure Plan for approval by the NMED. The Permittees will submit a written notification of or request for a permit modification to authorize a change in the approved plan,
The Permittees will submit a written request for a permit modification with a copy of the amended Closure Plan at least sixty (60) days prior to the proposed change in facility design or operation or within sixty (60) days of the occurrence of an unexpected event that affects the Closure Plan. If the unexpected event occurs during final closure, the permit modification will be requested within thirty (30) days of the occurrence. If the Secretary of the NMED requests a modification of the Closure Plan, a plan modified in accordance with the request will be submitted within sixty (60) days of notification or within thirty (30) days, if the change in facility condition occurs during final closure.
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Certification of Closure
 U As Required Within sixty (60) days after completion of closure activities RCRA
HWFP I-2(a)
Within sixty (60) days after completion of closure activities for a HWMU (i.e., for each storage unit and each disposal unit), the Permittees will submit to the Secretary of the NMED a certification that the unit (and, after completion of final closure, the facility) has been closed in accordance with the specifications of this Closure Plan. The certification will be signed by the Permittees and by an independent New Mexico registered professional engineer. Documentation supporting the independent registered engineer's certification will be furnished to the Secretary of the NMED with the certification.
MOC CBFO Assistant Manager of Operations
Hazardous Waste Permits Program Manager
Hazardous Waste Bureau
New Mexico Environment Department
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87502
RCRA Closure Report-Survey Plat
 U As Required Within sixty (60) days of completion of closure activities for each underground HWDU, RCRA
HWFP I-2(b)
Within sixty (60) days of completion of closure activities for each underground HWDU, and no later than the submission of the certification of closure of each underground HWDU, the Permittees will submit to the Secretary of the NMED a survey plat indicating the location and dimens