DRC-2018-004388 - 0901a0688080ccb4

GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
DRC- 2013- o G 4-366 DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL Scott T. Anderson
Director
Alan Matheson
Executive Director
May 4, 2018
Vern Rogers, Manager
Compliance and Permitting
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, Utah 84111
RE: Compliance Evaluation Inspection
Health Physics Module 13, Liquids Management
Radioactive Material License Numbers UT2300249 and UT2300478
Closeout
Dear Mr. Rogers:
This is to acknowledge the receipt of Energysolutions' letter (CD18-0081) dated April 1 9, 20 1 8
addressing and rectifying the concerns identified during the inspection.
Thank you for your efforts in this regard. The inspection is now considered closed. If you have any
questions, please call Boyd Imai at [phone].
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/BMI/km
c: Jeff Coombs, EHS, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
DRC-2018-003988 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
ENERGY SOLUTIONS
DiW.-Z.0 IS- 00368 (
April 19, 2018 CD18-0081
Mr. Scott T. Anderson
Director
Utah Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, Utah 84114-4880
Subject: Radioactive Material License Numbers UT2300249 and UT2300478
Response to Module 13 Inspection, Liquids Management
Dear Mr. Anderson,
In a letter dated April 12, 2018, the Division of Waste Management and Radiation
Control provided results of Health Physics Compliance Evaluation Inspection Module 13,
Liquids Management. Within that letter, the Division noted two observations that
required attention. Herein, EnergySolutions provides responses and corrections to these
two observations.
Observation 1: The Mixed Waste Treatment Lead was using an outdated (April 4,
2003) listing of approved treatment reagents.
EnergySolutions Response: The Mixed Waste Treatment Lead had an uncontrolled
copy of the reagent list in a folder in his office; however, the currently approved revision
(dated May 27, 2016) is available to all employees via the intranet that can be reached on
any site computer. The Mixed Waste Treatment Lead has been reminded to use this
resource rather than the uncontrolled printed copy in his office.
Observation 2: Radioactive Waste Profile Record B.1. for waste stream 9105-01 "VTD
Liquids / Mixed Waste Debris" indicates that the waste does not contain free liquids
<1%. However, the same section shows the waste contains "other constituents and
percentages by volume" of "liquid, both aqueous and non-aqueous (VTD)" at "2%."
EnergySolutions Response: Both the profile and shipping paperwork of previously
received shipments for 9105-08 was reviewed. Previous revisions of the profile had the
"other constituents and percentages by volume" category blank and was recently changed
to 2% in response to a request from an internal reviewer. However, the generator has
stated that liquids are very low in this waste and the historical liquid volume is <1%.
This profile was revised again and the volume of liquids in the "other constituents and
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
EN ERGYSCEUTIONS
Mr. Scott T. Anderson
CD18-0081
April 19, 2018
Page 2 of 2
percentages by volume" category corrected to 1%. A copy of applicable pages of this
revised profile is attached.
Should there be any questions regarding this response, contact me at 801-649-2144.
Sincerely,
Timothy L. Orton, P.E.
Environmental Engineer and Manager
cc: Don Verbica, DWMRC
l certify under penalty of law that this document and all attachments were prepared under my direction or simervision in accordance widi 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 responsible for gathering the informanon, the mfomsation submitted is, to gse best of my knowledge and belie& true, accurate, and complete l am aware that there are significant penalties for subnuttmg false ingsnnation, including the possibility of fine and impnsonment for knowing violations
299 South Main Street, Suite 1700 • Salt Lake City, Unit 84111
[phone] • Fax: [phone] • www energysolutions.com
ENERGYSOLUTKAN CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
A. GENERATOR AND WASTE STREAM INFORMATION
GENERAL: Complete this form for one waste stream. Contact EnergySolutions at [phone] if you have any questions while completing this form.
Please indicate "N/A" if a category does not apply
1. GENERATOR INFORMATION
Generator Name DOE, Idaho National Laboratory/AMWTP
Name of Person Cmnpiete Form: Kris Smith
EPA ID: 104890008952
ph...208-557-6585 Email. [e-mail]
Location of Waste (City, State): Scoville, ID
2. WASTE STREAM INFORMATION
Waste Stearn Mt 9105-01 Waste Stream Name: VTD Liquids / Mixed Waste Debris
Revision. 8 Date. 4/14/2016
CHECK APPROPRIATE BOXES BELOW. Please verify the required forms requested below are completed and submitted with the Radioactive
Waste Profile Record,
HAZARDOUS WASTE: Is the waste classified as hazardous waste as defmed by 40 CFR 261?
lf NO, complete and attach the "Low-Level Radioactive Waste Certilleation Attachnient"
If YES, complete and attach the "Hazardous Waste Certification Attachment" and check apphcable box below.
Has the waste been treated to meet applicable treatinent standards per 40 CFR 268? Y D NiE
Is the waste to be treated by EnergySolutions? Y gn N
LOW-LEVEL RADIOACTIVE WASTE: is the radioactive waste defined as Low-Level Radioactive Waste in accordrnce with the Low-Level
Radioactive Waste Policy Amendments Act of 1985 or in DOE Order 435.1?
Y If YES„ a cuirent copy of a LLRW Compact Expcnt letter authorizing export must be submitted if apphcable. Compact export approval is not required for DOE-geneiated or 1 le.(2) waste streams. Case by case export approval for mixed waste and NORM may be required based on generator's
governing Compact requirements, contact EnergySolations Technical Services staff for additional guidance.

N 0 If NO, check appropnate box- NORM/NARM El I 1 e.(2) Byproduct Material 0 Other
SPECIAL NUCLEAR MATERIAL: Does the waste stream contain material with uranium ennched in U-235 or any of the following radionuclides.
U-233, Pu-236, Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, Pu-243, or Pu-244?
NO
If Yes, complete and attsch the "SNM Exemption Certification" form (EC-0230-SNM). Supporting statements, analytical results, and
documentation must be included with the submittal.
PCB WASTE: Does the waste contain Polychlorinated Baphenyls (PCB) that are regulated for disposal per 40 CFR 7619

Y 0 N lf Yes, complete and attach the "PCB Waste C'ertification" fonn (EC-98279).
ASBESTOS: Doss the waste contain Asbestos Containing Material?

orj N If Yes, Asbestos Containing Material must be managed in accordance with applicable federal regulations. Provide a detailed
description of the waste contammg asbestos in the Waste Profile nanutive
NcJ
YlJ
Concrete & meta, 44% Dmv 50 %
ENERGYSOLVTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
B. WASTE PHYSICAL PROPERTIES & PACKAGE INFORMATION
1. GENERAL CHARACITRISTICS
Does the waste contain free hquids? (>1%) Y 0 N If Yes, what is the percent of free liquid by waste %
If Yes, is the liqwd aqueous (water-based)? Y N
Density range of the waste: 1 0 — 1 50 lb/ft^3
Does the waste contain absorbent? Y 11:1 N
5 List percentage of waste type by volume: Soil %
other liquid, both aqueous and non aqueous (VTD) Other constituents and percentage by volume?
2. MATERIAL SIZE
Resins % 0 Sludge
Other 1
Gradation of Material: Indicate the percentage of waste material that would pass throw* the following grid sizes. For example, 95% of the
material would pass through a 12" square, 90% passes through a 4" square, 80% passes through a 1" square, etc.
12" 35 % 4" 25 % 1" 20 % ifir 10 % Ago- 5 % um" 5 %
Does the waste stream contam oversize debris (i.e., no dimension < 10 mches and any dimension > 12 feet)? Y D N
If Yes, include a detailed description (i.e., weight, size, drawings, etc.) of the oversize debris in the Waste Profile narrative.
3. MOISTURE CONTENT
For sod or sod-hke materials, please use Std. Proctor Method ASTM D-698 to determine the optimum moisture content The waste material must
not exceed 3 percentage nouns above optimum moisture upon arrival at EnergySolutions' disposal facility unless approved by EnergySolutions.
da3 . N/A Optnnum Moisture Content: N/A at Maximum Dry Density OA, )
Average Moistuie Content: N/A % Moistuie Conten N/A t Range: % - N/A %
4. WASTE SHIPPING & PACKAGING
Transpoitation Mode. 1X1Highway
Shipping & Container Packages: IM Drums* (5 85 gallons) OD Boxes (5 100 fe) Dll Soft-Sided Bags (5 10 yt13)
(Check all that apply)
Intermodat Sealand O Gondolas* Box Car
Other:
*Palletized drums are preferred by the disposal site Please specify in the "Other" field if drums will not be palletized. **Dimensions of gondola railcars must be between 48 to 65 feet m length and 8.5 to 12.5 fixt in height as miaowed from the top of the rail to the
top of the =dear imless approved by EnergySolutions.
5. NARRATIVE DESCRIPTION AND HISTORY OF WASTE
Please submn a narrative description and history of the waste as an attachment to the Radioactive Waste Profile Record. This
attachment should include the following:
• Process that generated the waste
• Waste material physical composition and characteristics
• Radiological and chemical characterization method
• Basis for determining manifested radionuclide concentrations
• Description and amounts of absorbents, if applicable
• Basis of non-hazardous or hazardous waste deternnnations
• Treatment processes, if applicable
• Product information or Matenal Safety Data Sheets associated with the waste as applicable
• Information requested in other sections of this form
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DNISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
April 12, 2018
Vern Rogers, Manager
Compliance and Permitting
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, Utah 84111
RE: Compliance Evaluation Inspection - Health Physics Module 13, Liquids Management
Radioactive Material License Numbers UT2300249 and UT2300478
Dear Mr. Rogers:
Between March 16, 2018 and April 3, 2018, representatives of the Division of Waste Management and
Radiation Control inspected the Clive, Utah disposal facility. Results of the inspection were discussed
with Brian Beynon, Curtis Kirk and Dale Thorne at the conclusion of the inspection.
The inspection was an examination of the activities conducted at the Clive Facility as they relate to
compliance with radiation safety requirements. The inspection consisted of a visual assessment of the
facility, interviews of personnel and observations by the inspector.
During the inspection, two observations were made that warrant your attention. First, the Mixed Waste
Treatment Lead was using an outdated (April 4, 2003) listing of approved treatment reagents. Second,
Radioactive Waste Profile Record B.1. for waste stream 9105-01 "VTD Liquids / Mixed Waste Debris"
indicates that the waste does not contain free liquids >1%. However, the same section shows the waste
contains "other constituents and percentage by volume" of "liquid, both aqueous and non-aqueous
(VTD)" at "2%." Please provide information on any actions taken to address these observations.
Based on the findings documented during the inspection, the items reviewed were found to be in
compliance with the Utah Administrative Code and requirements for the licenses.
If you have any questions, please call Boyd Imai at [phone].
(Over)
DRC -2018-003241 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.dectutallgov
Printed on 100% recycled paper
Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control
STA/BMI/km
c: Jeff Coombs, EHS, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
•
INSPECTION REPORT
INSPECTION REPORT FOR:
EnergySolutions, LLC
H.P. Module13, Liquids Management
DATE(S) OF INSPECTION:
March 16, 2018 — April 3, 2018
FACILITY ADDRESS:
Exit 49, Clive, Interstate 80, UT
FACILITY CONTACT:
Dave Squires, General Manager
801 649 2160
APPLICABLE REQUIREMENTS:
Radioactive Material Licenses: UT2300249 and UT2300478
Waste Characterization Plan
TYPE OF INSPECTION:
Health Physics Module 13, Liquids Management
PARTICIPANTS:
DWMRC: Boyd Imai, Inspector; Don Verbica, Accompanying Manager
Licensee: Brian Beynon, Mike Cantone, Kraig Edde, Albert Evans, Craig Erickson, Jan Hatfield,
Curtis Kirk, Justin Lee, Tim Orton, Bret Rogers, Chance Spradling, Dale Thorne, Dan Webinger
WEATHER CONDITIONS:
Date Time Temperature Skies Wind Wind Speed
3/16/18 1025 hr 37.2° F Mostly Sunny Calm 5.3 mph ave.
3/16/18 1520 hr 49° F Mostly Sunny Breezy 18.8 mph
3/28/18 0930 hr NA* NA* NA* NA*
4/3/18 1330 hr 43° F Sunny Calm 4.9
*Inspection activities conducted indoors at the Licensee's corporate office
TIME IN:
Date Time
3/16/18 0920 hr
3/28/18 0930 hr
4/3/18 0955 hr
TIME OUT:
Date Time
3/16/18 1520 hr

1
3/28/18 1030 hr
4/3/18 1420 hr
REPORT PREPARED BY:
Boyd Imai
FACILITY DESCRIPTION:
EnergySolutions is a low-level radioactive waste disposal facility employing approximately 100
individuals at the disposal site. The facility is located in an arid high desert terrain. Class A
radioactive waste storage, treatment, and disposal activities take place at the disposal facility.
The Licensee has been approved for the disposal of radioactive waste since February 2, 1988.
There were no changes in operations observed from the last inspection.
MANAGEMENT ACTIVITIES:
Liquid wastes are managed throughout the Licensee's property. Waste treatment processes are
performed exclusively at the Mixed Waste Facility. Vacuum Assisted Thermo Desorption
treatment is conducted at the Mixed Waste Facility in the VTD building, liquid verification
examinations are conducted at the Mixed Waste Facility and the Containerized Waste Facility.
Liquid radioactive wastes are not typically generated at the Clive facility. No liquids
management activities were taking place on March 16, 2018 at the Clive facility. Engineering
and Groundwater inspectors oversee runoff waters that may contact waste material. These liquids
were not addressed in this inspection.
NARRATIVE:
With the unavailability of D. Squires, Site General Manager, the inspection was opened on
March 16, 2018 with a meeting among the inspector, D. Verbica, and J. Hatfield, Plant
Administration Manager.
At the conclusion of the inspection an Exit Meeting was held on April 3, 2018 among the
inspector and Licensee's representatives B. Beynon, C. Kirk, and D. Thorne
Items inspected included the following:
1. Waste Characterization and Profiling
2. Waste Classification at Receipt
3. Non-aqueous liquid wastes
4. Noncompliant incoming wastes (Condition Reports) Notifications
5. Approved absorption/stabilization/solidification agents
6. Liquid content following treatment
7. Unanticipated liquids detection
8. % liquid determination/calculation
9. Liquid shipping containers
2
Inspection Item Summaries
Waste Characterization and Profiling
Waste profiles are initiated between Technical Services and waste generators. Technical Services
inserts all the relevant information into the Electronic Waste Information System (EWIS). The
waste profile is reviewed from four perspectives: physical properties, health physics, Resource
Conservation and Recovery Act (RCRA), and safety and reviewed by operations, assistant
radiation safety officer, environmental program manager, and safety and health manager,
respectively. Only after all conflicts, differences, and incompatibilities are resolved among all
parties is a profile approved and the generator is authorized to ship the waste for disposal.
Any special instructions for managing and handling any waste by the reviewers above are
documented and communicated to the operations personnel via EWIS including final destination
(MW or LLRW) for disposal.
A sample of profiles of wastes known to contain liquids was reviewed and it was confirmed the
wastes were characterized as having liquids.
Radioactive Waste Profile Record B.1. for waste stream 9105-01 "VTD Liquids / Mixed Waste
Debris" indicates that the waste does not contain free liquids >1%; however, the same section
shows the waste contains "other constituents and percentage by volume" of "liquid, both
aqueous and non-aqueous (VTD)" at "2%."
Non-Aqueous Liquid Wastes
By license condition, only elemental mercury and aqueous liquid wastes are specifically
permitted for receipt, treatment, and disposal; however, on approval by the Division Director
non-aqueous liquids may be authorized. The Licensee has made multiple requests for acceptance
of wastes containing non-aqueous wastes. Such requests are reviewed by the Division's Health
Physics and Hazardous Waste personnel and based on the characteristics and the proposed
treatment and disposition of the waste, the waste may be approved for receipt, management,
treatment, and disposal at the Licensee's facility. Clarification and/or additional information
have been requested in the past before acceptance of the waste was approved. Since June 20,
2017 ten requests have been made and approved. The Licensee stated that the approval applies to
the waste stream and does not submit requests for subsequent shipments of wastes of the same
waste stream.
Waste Classification at Receipt
A waste classification (Class A Verification) check continues to be performed by EWIS on each
shipment as it has in the past.
Noncompliant incoming wastes (Condition Reports) Notifications
A sample of Condition Reports (CRSD17-024, CRSD177-025) involving liquids were reviewed
to confirm that required notifications were made and that corrective action plans (CAPs) were
submitted when required.
3
Procedure CL-AD-PR-040, Classification and Administrative Control of Discrepant Incoming
Shipments, Attachment 5.1 — Discrepant Incoming Shipment Condition Report Classification
Guide specifies when a CAP is required. For non profiled free-liquids infractions, a CAP is
required after the first discrepant occurance.
For CRSD17-024 the Condition Report prepared by the waste shipper was considered the CAP
since it contains all the elements required for a CAP.
Approved absorption/stabilization/solidification agents
Bentonite and Lime Kiln Dust (LKD) are used extensively in solidifying/stabilizing liquids
which are approved treatment agents. A ratio of agents to waste liquid was 1.1 : 1.0 (30% (of
liquid) Bentonite and 80% (of liquid) LKD) as documented in the treatment of waste stream
9509-04, Treatment Run # 180309, March 9, 2018.
The Mixed Waste Treatment Lead indicated that the reagents used for solidification/stabilization
are those listed on the posting on his wall. The posting is an outdated list of approved reagents.
The posted list is dated April 4, 2003. The current list is dated August 7, 2016.
Liquid content following treatment
Treatments are run in batches. A Paint Filter Liquids Test is performed on the completion of the
first batch. A passing test result indicates that the recipe/formula is effective for the waste. If
successful for the first batch, the test is waived for the remaining batches of the run. This is
documented on the Waste Treatment Formula and Treatment Record, CL-MT-PR-007-F1,
example Treatment Run # 180309, March 9, 2018.
Unanticipated liquids detection
Unanticipated liquids in waste containers can be detected in four different ways.
1. A shipping container is leaking upon arrival
2. Containers are opened and visually inspected e.g. all containers at the Mixed Waste
Facility or for LLRW waste sampling
3. While dumping waste containers
4. Liquid Waste Verification operations for containerized waste
When a waste shipment arrives at the site and is found to be leaking liquids, the contingency plan
is activated, the security office is notified which broadcasts to all personnel including Emergency
Coordinators and spill response teams. A sample is taken to measure the pH and to ascertain if
the liquid is from the waste or incidental non-contact liquid, the shipment is taken into the
restricted area for management, and a condition report is initiated.
All containers taken to the Mixed Waste Facility are opened and visually inspected for
noncompliant items, including liquids, in the waste. The observed waste material is compared
with the waste profile description.
On occasion when an intermodal container is taken to the cell to be dumped, when the door is
loosened liquids can be detected coming from the interior. If this occurs the door is re-secured,
the container is taken to an approved storage location, e.g. intermodal unloading facility, a 1%
liquid content is determined and a condition report is initiated, and the liquid is either absorbed
4
(diatomaceous earth) or removed from the container and placed in the drainage system for
contaminated liquids. Mostly the liquids are absorbed.
When railcars are rolled at the rotary facility and previously undetected liquids are poured into
the waste pit, the liquid is pumped along with any water from the decon water cannons to the
Northwest Corner pond.
In accordance with the Waste Characterization Plan and Licensee procedure CL-CW-PR-200,
Package Liquid/Void Verification a liquid verification is performed on containers at the
Containerized Waste Facility. For ALARA purposes, only containers/liners that have contact
exposure rates less than 80 mRem/hr are candidates for liquid verification. The results of the
verification process are documented on the Package Liquid Verification Form CL-W-PR-200-
F1. The last verification was performed on November 17, 2017 where no liquid was detected in
the waste container.
% liquid determination/calculation
The % liquid determination is performed by the Operations Manager who completes the I%
Volume Freestanding Liquids Chart, CL-CH-PR-106 Fl. This is an electronic form which
automatically calculates the percent volume of the liquid based on the physical dimensions of the
contained liquid and the manifested volume of the waste in the container. Last year's inspection
(2017) confirmed that the calculations contained in the form were verified and validated by the
Environmental Program Manager and Laboratory Lead.
A sample calculation was provided for shipment # 0716-23-0002 which documented that the
shipment had less than 1% free liquids.
Liquid shipping containers
The Licensee receive liquid waste in three types of containers: drums in overpacks, Intermediate
Bulk Containers (IBCs) "totes", and tankers. No containers were directly assessed during this
inspection. Documentation of the specification for the totes was requested and provided for last
year's inspection. The totes are 300 gal. cube shaped rigid plastic inner receptacles with outer
steel body cages meeting Packing Group and Packing Group III packaging specifications for
liquids.
License Condition 16.F.v. states: Only containers authorized by the US. Department of
Transportation as specified in the regulations (49 CFR parts 100 thru 180) for transporting
liquid radioactive materials shall be accepted for all liquid radioactive wastes, regardless of
radioactivity concentrations. A tanker truck transporting shipment # 9720-38-1801 was received
on March 12, 2018. The waste was non DOT regulated material. The shipment was not leaking
when it was accepted at the disposal facility.
The Shipping and Receiving Manager indicated that the totes are typically used to ship liquids
from the facility and infrequently used for incoming liquids. Incoming liquid wastes arrive
primarily in drums which are often time overpacked in poly drums to ensure that there is no
leakage of material. No liquid wastes and containers were available for inspection.
5
UA4-2 DATE: April 5, 2018
Boyd Imai)
SIGNATURE:
ISSUES:
Sometimes unanticipated liquids are detected only when the waste containers are dumped or
emptied. At that point only gross estimates can be made to determine the amount of liquid
contained in the waste package.
The Mixed Waste Treatment Lead uses an outdated listing of approved reagents.
The Licensee regards the Director's approval to receive non-aqueous liquid waste as a blanket
approval for the requested waste stream.
The waste profile record for waste stream 9105-01 contains contradictory information: no free
liquids vs 2% aqueous and non aqueous liquids.
EXIT MEETING:
The inspector held an exit meeting with B. Beynon, C. Kirk, and D. Thorne on April 3, 2018
summarizing the above inspection.
6
Page 1 of 5
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
INSPECTION MODULE 13 (2018)
LIQUIDS MANAGEMENT
ENERGYSOLUTIONS' CLIVE FACILITY
RADIOACTIVE MATERIAL LICENSE UT2300249/UT2300479
bm a( I j) VQ4-bic
Personnel c`
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INSPECTION ITEMS Liquid Waste Requirements
Management of Unanticipated Liquids
Containerized Waste Facility Liquid Verification
Requirements, Procedures, Policies, Standards:
R313-15-1009(2)(a)(iv)
License Condition 9.G.
License Condition 16.F.
License Condition 17.
Waste Characterization Plan (WCP)—Step 3
Waste Characterization Plan—Step 4, Requirements for Liquid Waste
Waste Characterization Plan—Exhibit 2, Certified Containerized Waste Characterization
EnergySolutions Procedure CL-CH-PR-106, I% Free Liquid Volume Determination
EnergySolutions Procedure CL-CW-PR-200, Package Liquid/Void Verification
EnergySolutions Proceudre CL-CH-PR-252, Incoming Shipment Inspection and Sampling
LICENSE CONDITION 16 (Prohibitions and waste acceptance requirements)
16.F. Liquid Waste Restrictions
i. Except for liquid rnercury, receipt of nonaqueaous liquid waste is prohibited unless specifically
approved by the Executive Secretary.
Treated liquid radioactive waste shall be disposed at the Mixed Waste Facility or the LLRW Facilities
in accordance with Exhibit 3 of the current Waste Characterization Plan.
Only the Division approved solidification or absorption agents as listed in the State-issued Part B Permit
are authorized for liquid waste treatment.
iv. Liquid radioactive waste shall be solidified or absorbed in a manner such that no liquid component is
disposed.
v. Only containers authorized by the U. S. Departrnent of Transportation as specified in the regulations (49
CFR parts 100 thru 180) for transporting liquid radioactive materials shall be accepted for all liquid
radioactive wastes, regardless of radioactivity concentrations.
LICENSE CONDITION 17 (Management of Free Liquids)
In accordance with UAC R313-15-1009(2)(a)(iv), solid waste received for disposal shall contain as little free standing and
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Inspection Dates. Start /air--(4— , 20 End , 20
Inspectors:
TIME IN: 1)30
Date Time
3/4/ ir 6 1 7/0
3/2 y/(7 O ef 30
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Page 2 of 5
non-corrosive liquid as reasonable achievable, but shall contain no more free liquids than one percent of the volume of the
waste. Solid waste received and containing unexpected aqueous free liquid in excess of 1% by volume shall have the liquid
removed and placed in the evaporation ponds or the liquid solidified prior to management. Unexpected non-aqueous free
liquids less than 1% of the volume of the waste within the container shall be solidified prior to disposal. In addition, the
licensee shall notify the Division within 24 hours that the shipment(s) failed the requirements for acceptance and manage in
accordance with the Waste Characterization Plan.
Note: Notwithstanding License Condition 16.F.; Liquids associated with incoming waste is generally viewed as
inadvertent liquid and is basically dealt with by managing the liquid portion outlined in License
Condition 17 and in the Waste Characterization Plan—Step 3. Radiation Control Rule, R313-15-
1009(2)(a)(iv) states; solid waste containing liquid shall contain as little free-standing and non corrosive
liquid as is reasonably achievable, but in no case shall the liquid exceed one percent of the volume.
Based on this rule, the licensee will determine 1% liquid volume using procedure CL-CH-PR-106.
Waste shipments with a liquid volume less than 1% free standing liquid will be routinely managed as
physically solid waste.
WEATHER CONDITIONS:
Date Time Temperature Skies Wind Wind Speed
511.6118" op-o 33' F if1 StA-A6y e,l,,,,,, 3(24-1(r- oq 30 /
/030 35 c'r -54-tist-4k-1/ Erres_ ( 1 1-1 CI VIA
C—ey-^r Pe-Y; a
644A"
TIME OUT:
Date Time
/536/M,,
3/2- /03o4}e.
i,),(,), 475fie
at q5 b ci - o cl NTT " L'
SECTION I—Wastes Characterized as Liquid " P( tAi fY-exeicsaj 1) Are wastes characterized as containing >1% free liquids profiled as liquid wastes? (WCP Step 4)
Yes X No Violation
Comments: Vc,fryi 0--v. cot,J3z - (4.)m (4-:1-7.: 906/ --- CI
40-2,o - 's---45, /opt/.I--
502) Regardless ot concentrations, are radioactive liquid wastes received in containers authorizeci y the (11-bij ---',
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Page 3 of 5
U.S. Department of Transportation as specified in 49 CFR parts 100 thru 180 for transporting Class 7
liquid radioactive material? (Check and review "generator's packaging and transportation plan")
(License Condition 16.F.v. and WCP Step 4)
Comments: —.7C)1,-(AAAA-s
Yes No Violation
ero-a-sc r '?-AA-1)2k, O Ltk
Are liquid radioactive wastes Class A wastes at receipt? (License Condition 9.G.)
Yes 'X" No Violation
Comments: L.:, w--&
Are liquid radioactive wastes either liquid mercury or aqueous liquid or otherwise approved by the
DWMRC Director? (License Condition 9.G. and License Condition 16.F.i.)
e Yes No Violation
Comments: pk_e-a s fi-t.f(
/0 '- ah./Are-
Only Utah Division of Waste Management and Radiation Control approved solidification or
absorption agents as listed in the State-issued Part B Permit are used for liquid radioactive waste
treatment. (License Condition 16.F.iii.)
No Violation
Has liquid radioactive waste been solidified or absorbed in a manner that no liquid component is
disposed? (License Condition 16.F.iv.)

Yes No Violation

Comments: 171:1---i Lei
Yes )4,
Comments: (.5
7) Has all treated liquid radioactive waste been disposed in the Mixed Waste Landfill Cell or the
LLRW Facilities in accordance with Exhibit 3 of the Waste Characterization Plan? (License
Condition 16.F.ii.)
Yes No Violation
Comments: S. 14-k ak evlsx-op-c, I C(2ArLiA. , c-eQt_Lic c
SECTION II—Solid Wastes with Incidental/Unanticipated (>1%) Liquids
U:\Staff Shared Folders\Boyd Imai\Inspections \2018 Inspections\Mod 13 Liquid Mgt\Mod 13 Liquids Mgt (2018).doc
9)
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Page 4 of 5
Does the Licensee confirm the absence/presence of free liquids in wastes received?
(EnergySolutions Procedure CL-CH-PR-252, Section 4.1.1.4)
Yes y No Violation
Comments: I yl5 \Act Li 4,
If unexpected free liquids are present in a waste container, is the shipment either, entirely rejected for
receipt; specific containers rejected for receipt; or liquids separated and re-profiled?
(EnergySolutions Procedure CL-CH-PR-252, Section 4.1.1.5.1)
Yes No Violation
Comments:
Is a 1% Free Liquid Volume Verification Performed (by completing CL-CH-PR-252, Fl, 1% Volume
Freestanding Liquids Chart)? (EnergySolutions Procedure CL-CH-PR-252, Section 4.1.1.5)
Yes `)(- No Violation
Comments: 40..
Are liquids determined to be a hazardous waste (pH less than or equal to 2 or greater than or equal to
12.5) managed at the Mixed Waste Facility? (EnergySolutions Procedure CL-CH-PR-252,
Section 4.1.1.7)
Yes y- No Violation
Comments: r..),2".C"
If the pH is 2 or less or 12.5 or greater has the Licensee notified the "Executive Secretaries of the
Radiation Control Board and the Utah Division of Solid and Hazardous Waste Control Board"
within 24 hours? (WCP Step 3)
Yes K No Violation
Comments: ?;7„—rtrcz_. / 7-- • > 12-5 (7._

13) Does the Licensee notify the generator and the Division of Waste Management and Radiation

I Control within 24 hours of determining that the volume of Unanticipated Free Liquids exceeds 1%.
; (WCP Step 3 and License Condition 17.D)
Yes A No Violation
Comments: (212.5.b l 4 — 6 2- cf occu.Aora,at /0 I .5/ cg- le164- -,4P---..,---- tofeit 'f-
11: \Staff Shared Folders \Boyd Imai\Inspections\2018 Inspections Nod 13 Liquid Mgt\Mod 13 Liquids Mgt (2018).doc
16)
2)4‘.
17)
cere:.4a,('
Page 5 of 5
14) Does the Licensee provide the Director with a written description of the event and corrective actions
, taken within 7 calendar days? (WCP Step 3)
Yes No Violation
Comments: C(2Õ _ 14i* I I -3L ot (3 I 17- G)jr
15) For generators having repeat occurrences of shipments with free-liquids in excess of 1% by volume,
does the Licensee require a corrective action plan from the generator? (WCP Step 3)
Yes No Violation
Comments: iey's fabedwv-t t 4 /4) tz. c'c c4 r
57- tYe2A-• C 1Z /3 0E13 S,ftme-Vcs- -as C
Are Unanticipated Free Liquid •s excess f 1% by volume solidified, absorbed, evaporated, or c
removed and placed in th evaporation ponds (License Condition 17.B)

Yes No

Comments: ixt

6 cc - (57- 2-- (c. 3_0 - 2-y) 5.6471Lte. s r<4 411 7-
Are shipments that have free liquids observed or are leaking brought into the Restricted Area and
managed only at an approved liquid management facility? (EnergySolutions Procedure CL-CH-
PR-252 Section 4.1.1.9)
No Violation
Cen-vk fritp„. N./ a-k-eS
6Ird C ?,(k Carckv,_._,,, 5 FLO la SA .%e 214.1,_ . p.
5 e[4-- 6.,A,L4-2(
Does the Licensee verify compliance with the 1% free liquid (by volume) limit in accordance with
standard operating procedure "Package Liquid Verification" at the Containerized Waste Facility?
(WCP Exhibit 2, See also, EnergySolutions Procedure CL-CW-PR-200, Package Liquid/Void
Verification)

Yes No Violation
Comments:
g - y
Vio ation
Yes
Comments:
051CR 2( mdcR
ibc
«
Lt
U:\Staff Shared Folders\Boyd Imai\Inspections\2018 Inspections\Mod 13 Liquid Mgt\Mod 13 Liquids Mgt (2018).doc
Envirocare of Utah, Inc.
Issued — April 4, 2003
ATTACHMENT I1-1-2-1
APPROVED TREATMENT REAGENTS
REAGENT CAS Number1 1
Ammonium Sulfate 7783-20-2
Ammonium Phosphate (Monobasic) 7722-76-1
Anionic and Cationic Floculants None
Aquaset 14808-60-7
Aquaset II 14808-60-7
Aquaset II-H None
Calcium Hypochlorite 7778-54-3
Calcium Superphosphate None
Calcium Sulfate 10101-41-4
Calcium Bisulfite 1344-81-6
Calcium Polysulfide (Lime, sulfurated) None
Calcium Dimethyldithiocarbamate 20279-69-0
Calcium Dimethyldithiocarbonate None
Calcium Chloride 10043-52-4
Calcium Tetrathiocarbonate None
1 Reference. Hawley's Condensed Chemical Dictionary, Eleventh Edition, Revised by N. Irving Sax and
Richard J. Lewis, Sr., Van No strand Reinhold, New York, NY, 1987; Library of Congress Catalog
Card Number 86-23333, ISBN 0-442-28097-1.
Attachment 11-1-2-1- Approved Treatment Reagents - Page 1
UNCONTROLLED COPY. SEE DOCUMENT CONTROL FOR CURRENT REVISION.
Envirocare of Utah, Inc.
Issued — April 4, 2003
Carbon 7440-44-0
Cellulose Xanthanide None
Cement (Portland) 65997-15-1
Cement Kiln Dust None
Copper None
Ferric Oxide 1309-37-1
Ferrous Oxide 1345-25-1
Ferrous Sulfate 7720-78-7
Ferrous Ammonium Sulfate 10045-89-3
Fly Ash (Class C & F) None
Green Phosphate (Triple Superphosphate) 7664-38-2
Hg Buster 72 None
Hydrogen Peroxide 7722-84-1
Iron Chips None
Lime 1305-78-8
Magnesium Oxide 1309-48-4
Methanol (when used with Petroset liI or lil-H) 67-56-1
2 Hg Buster 7 shall be used in accordance with the manufacturer's instructions for process monitoring and
controls, as documented in the treatment formula summary. Form EC-2300 shall be customized, as needed,
for each treatment formula using Hg Buster 7 so that process monitoring and control data is documented.
Attachment 11-1-2-1- Approved Treatment Reagents - Page 2
UNCONTROLLED COPY. SEE DOCUMENT CONTROL FOR CURRENT REVISION.
Envirocare of Utah, Inc.
Issued — April 4, 2003
Nickel None
Petroset 1318-93-0
Petroset H None
Petroset II-H 1318-93-0
Potassium Pesmanganate 7722-64-7
Potassium Phosphate (Monobasic) 7778-77-0
Salt Water ( - 8%) None
S elenium 7782-49-2
Sodium Sulfate 7757-82-6
Sodium Percarbonate 15630-39-4
Sodium Sulfonate None
Sodium Metabisulfite 7681-57-4
Sodium Thiosulfate 7772-98-7
Sodium Dimethyldithiocarbamate 128-04-1
Sodium Sulfide (Flake) 16721-80-5
Sodium Hydroxide 1310-73-2
Sodium Silicate 1344-09-8
Sodium Dimethyldithiocarbonate None
Sodium Aluminate 1302-42-7
Sodium Carbonate 497-19-8
Sodium Hydrosulfite (Sodium Bisulfite) 7631-90-5
Attachment 11-1-2-1- Approved Treatment Reagents - Page 3
UNCONTROLLED COPY. SEE DOCUMENT CONTROL FOR CURRENT REVISION.
Envirocare of Utah, Inc.
Issued — April 4, 2003
Sodium Hypochlorite 7681-52-9
Sodium Tetrathio carbonate 7345-69-9
Starch Xanthate None
Sulfur (elemental) 7704-34-9
Sulfuric Acid 7664-93-9
Tin 7440-31-5
Zeolites (Clinoptilolites, Aluminum Silicates) None
Zinc None
(Note: Treatment reagents shall be selected on the basis of the goals of the treatment process.
For example, where inorganics and aqueous slurries are the object of the treatment, such reagents
which stabilize inorganics shall be used. Similarly, where organics are to be treated, such
reagents which stabilize organics shall be used. Where both inorganics and organics are the
object, a combination of treatment reagents may be used.)
Attachment 11-1-2-1- Approved Treatment Reagents - Page 4
UNCONTROLLED COPY. SEE DOCUMENT CONTROL FOR CURRENT REVISION.
Envirocare of Utah, Inc.
Issued — April 4, 2003
10. SOLIDIFICATION MATERIALS
Material
Aquaset
Aquaset II
Aquaset II-H
Cement Kiln Dust
Cement (Portland)
Diatomaceous Earth
Fly Ash (Class C & F)
Lime
Lime Kiln Dust
Natural clay
Perlite
Petroset
Petroset II
Petroset II-H
Sand
Soil
Zeolites (Clinoptilolites, Aluminum Silicates)
CAS Number
14808-60-7
14808-60-7
None
None
65997-15-1
None
None
1305-78-8
None
None
None
1318-93-0
None
1318-93-0
None
None
None
END OF ATTACHMENT 11-1-4-1
Attachment II-1-4-1 - Analytical Procedures For Formula Development
Liquid Waste Solidification
Method EC-2301 - Page 4
UNCONTROLLED COPY. SEE DOCUMENT CONTROL FOR CURRENT REVISION.
EnergySolutions, LLC
Issued — April 4, 2003
Revised-May 27, 2016
Selenium 7782-49-2
Sodium Sulfate 7757-82-6
Sodium Percarbonate 15630-39-4
Sodium Sulfonate None
Sodium Metabisulfite 7681-57-4
Sodium Thiosulfate 7772-98-7
Sodium Dimethyldithiocarbamate 128-04-1
Sodium Sulfide (Flake) 16721-80-5
Sodium Hydroxide 1310-73-2
Sodium Silicate 1344-09-8
Sodium Dimethyldithiocarbonate None
Sodium Aluminate 1302-42-7
Sodium Carbonate 497-19-8
Sodium Tetrathiocarbonate 7345-69-9
Sodium Sesquicarbonate 533-96-0
Starch Xanthate None
Sulfur (elemental) 7704-34-9
Sulfuric Acid 7664-93-9
Tin 7440-31-5
Zeolites (Clinoptilolites, Aluminum Silicates,
Instazorb) None
Zinc None
(Note: Treatment reagents shall be selected on the basis of the goals of the treatment process.
For example, where inorganics and aqueous slurries are the object of the treatment, such reagents
which stabilize inorganics shall be used. Similarly, where organics are to be treated, such
reagents which stabilize organics shall be used. Where both inorganics and organics are the
object, a combination of treatment reagents may be used.)
END OF ATTACHMENT 11-1-2
Attachment 11-1-2 - Approved Treatment Reagents - Page 3
EnergySolutions, LLC
Issued — April 4, 2003
Revised-May 27, 2016
ATTACHMENT II-1-2
APPROVED TREATMENT REAGENTS
REAGENT CAS Number
Ammonium Sulfate 7783-20-2
Ammonium Phosphate (Monobasic) 7722-76-1
Anionic and Cationic Flocculants None
Aquaset 14808-60-7
Aquaset II 14808-60-7
Aquaset II-H None
Bentonite 1302-78-9
Calcium Hypochlorite 7778-54-3
Calcium Superphosphate None
Calcium Sulfate 10101-41-4
Calcium Bisulfite 1344-81-6
Calcium Polysulfide (Lime, sulfurated) None
Calcium Dimethyldithiocarbamate 20279-69-0
Calcium Dimethyldithiocarbonate None
Calcium Chloride 10043-52-4
Calcium Tetrathiocarbonate None
Carbon 7440-44-0
Cellulose Xanthanide None
Cement (Portland) 65997-15-1
Cement Kiln Dust None
Copper None
Commercial Detergents, Non-hazardous None
Attachment II-1-2 - Approved Treatment Reagents - Page 1
EnergySolutions, LLC
Issued — April 4, 2003
Revised-May 27, 2016
Ferric Oxide 1309-37-1
Ferrous Oxide 1345-25-1
Ferrous Sulfate 7720-78-7
Ferrous Ammonium Sulfate 10045-89-3
Fly Ash (Class C & F) None
Green Phosphate (Triple Superphosphate) 7664-38-2
Hydrogen Peroxide 7722-84-1
Iron Chips None
Lime 1305-78-8
Magnesium Oxide 1309-48-4
Methanol (when used with Petroset II or II-H) 67-56-1
Nickel None
Natural clay None
Organoclay BM-Qt-199 None
Petroset 1318-93-0
Petroset II None
Petroset II-G None
Petroset II-H 1318-93-0
Potassium Permanganate 7722-64-7
Potassium Phosphate (Monobasic) 7778-77-0
RegenOx Part A (commercial mixture of
sodium percarbonate,
sodium carbonate, sodium
silicate, & silica gel)
None
RegenOx Part B (commercial mixture of
silicic acid, sodium salt,
sodium silicate, & silica gel)
None
Salt Water ( - 8%) None
Attachment 11-1-2 - Approved Treatment Reagents - Page 2
03/16/2016
-
EN ERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
A. GENERATOR AND WASTE STREAM INFORMATION
GENERAL: Complete this fonn for one waste stream. Contact Energysolutions at [phone] if you have any questions while cornpleting this fonn.
Please indicate "N/A" if a category does not apply
1. GENERATOR INFORMATION
Generator Name: DOE, Idaho National Laboratory/AMWTP EPA ID:
Narne of Person Complete Form: Kris Smith
phone.[phone] Email: [e-mail]
Location of Waste (City, State): Scoville, ID
2. WASTE STREAM INFORMATION
Waste Stream ID: 9105-01 Waste Stream Name: VTD Liquids / Mixed Waste Debris
Revision: 8 Date: 11/14/2015
CHECK APPROPRIATE BOXES BELOW. Please verify the required forms requested below are completed and submitted with the Radioactive
Waste Profile Record.
HAZARDOUS WASTE: Is the waste classified as hazardous waste as defined by 40 CFR 261?
N 0 If NO, complete and attach the "Low-Level Radioactive Waste Certification Attachment".
Y If YES, complete and attach the "Hazardous Waste Certification Attachment" and check applicable box below. Has the waste been treated to meet applicable treatment standards per 40 CFR 268? Y D N Ej
Is the waste to be treated by EnergySolutions? Y JJ N
LOW-LEVEL RADIOACTIVE WASTE: Is the radioactive waste defined as Low-Level Radioactive Waste in accordance with the Low-Level Radioactive Waste Policy Atnendments Act of 1985 or in DOE Order 435.1?
Y If YES„ a current copy of a LLRW Compact Export letter authorizing export must be submitted if applicable. Compact export approval is not required for DOE-generated or Ile.(2) waste streams. Case by case export approval for mixed waste and NORM may be required based on generator's governing Compact requirements; contact EnergySol Wiens Technical Services staff for additional guidance.
N 0 If NO, check appropriate box: NORM/NARM D Ile.(2) Byproduct Material D Other: .
SPECIAL NUCLEAR MATERIAL: Does the waste stream contain material with uranium enriched in U-235 or any of the following radionuclides:
U-233, Pu-236, Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, Pu-243, or Pu-244?
Y El N 0 If Yes, complete and attach the "SNM Exemption Certification- form (EC-0230-SNM). Supporting statements, analytical results, and
documentation must be included with the submittal.
PCB WASTE: Does the waste contain Polychlorinated Biphenyls (PCB) that are regulated for disposal per 40 CFR 761?
y Ng If Yes, complete and attach the "PCB Waste Certification" form (EC-98279).
ASBESTOS: Does the waste contain Asbestos Containing Material?
y g No If Yes, Asbestos Containing Material must be managed in accordance with applicable federal regulations. Provide a detailed
description of the waste containing asbestos in the Waste Profile narrative.
et-Q-JLA:sa 2,,z
erv, 01.)-
TS - 0230 Waste Profile Record - 9/14/2015
iaivyt lAaix
503— a•O ft
1? I 1 tiAlkA3
Pr
Ye k 0-"<1
03/16/2018
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
B. WASTE PHYSICAL PROPERTIES & PACKAGE INFORMATION
1. GENERAL CHARACTERISTICS
Does the waste contain free liquids? (>1%) Y E3 N lf Yes, what is the percent of free liquid by waste %
If Yes, is the liquid aqueous (water-based)? Y121
Density range of the waste: 1 0 — 150 IbIft^3
Does the waste contain absorbent? Y. N
List percentage of waste type by volume: Soil 5 %
other: liquid, both aqueous and non aqueous (VTD) Other constituents and percentage by volume?
2. MATERIAL SIZE
Concrete &
Metal 43% DAW 50% Resins ° % Sludge %
Other 2 %
Giadation of Material: Indicate the percentage of waste material that would gam throne the following grid sizes. For example, 95% of the
material would pass through a 12" square, 90% passes through a 4" square, 80% passes through a I" square, etc.
.12., 35 % .4,, 25 % 2o % .114 10 .1140- 5 % moo, 5 %
Does the waste stream contain oversize debris (i.e., no diinension < 10 inches and any dimension > 12 feet)? Y D N
If yes, include a detailed description (i.e., weight, size, drawings, etc.) of the oversize debris in the Waste Profile narrative.
3. MOISTURE CONTENT
For soil or soil-like materials, please use Std. Proctor Method ASTM D-698 to determine the optimum moisture content. Tbe waste material must
not exceed 3 percentage points above optimum moisture upon arrival at EnergySolutions' disposal fseility unless approved by EnergySolutions.
Optimum Moisture Content: NIA % at Maximum Dry Density (fts/ft3): N/A
Average Moisture Content: N/A % Moisture Content Range: N/A % - N/A %
4. WASTE SIHPPING & PACKAGING
tnansportation Mode: gl Highway El Rail
Shipping & Container Packages: ig Drums* 85 gallons) p Boxes (5_ 100 10 Soft-Sided Bags 10 yd3)
(Check all that apply)
hitennodal IEI Sealand Gondola 13 Box Car
Other:
*Palletized drums are pieferred by the disposal site. Please specify in the "Other" field if dmms will not be palletized. **Dimensions of gondola railcars mist be between 48 to 65 feet in length and 8.5 to 12.5 feet in height as measured from the top of the rail to the
top of the railcar unless approved by EnergySolutions.
5. NARRATIVE DESCRIPTION AND HISTORY OF WASTE
Please submit a narrative description and history of the waste as an attachment to the Radioactive Waste Profile Record. This
attachment should include the following:
• Process that generated the waste • Waste material physical composition and characteristics
• Radiological and chemical characterization method
• Basis for determining manifested radionuclide concentrations • Description and amounts of absorbents, if applicable
• Basis of non-hazardous or hazardous waste determinations
• Treatment processes, if applicable
• Product information or Material Safety Data Sheets associated with the waste as applicable
• Information requested in other sections of this form
TS - 0230 Waste Profile Record - 9/14/2015
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
HAZARDOUS WASTE CERTIFICATION ATTACHMENT
This form is required only if the checkbox for Hazardous Waste on page one has been checked YES. Otherwise, complete the
Low-Level Radioactive Waste Certification Attachment instead of this attachment. EnergySolutions may waive the chemical
laboratory analyses if the material is not amenable to chemical sampling and analysis (e.g., debris items including metal pieces, concrete, plastic, etc.). Justification for waiving the chemical analyses must be provided in the Waste Profile narrative.
D. MINIMUM REQUIRED CHEMICAL ANALYSIS
The following parameters must be analyzed by a Utah or NELAC certified laboratory. Typical SW-846 analytical methods have been
listed. Other approved methods are acceptable. Attach the most recent or applicable chemical analytical results representing the waste.
1. GENERAL CHEMICAL PARAMETERS
SW446 Analytical Methods

pH (Liquid only): N/A Method 9045 Please provide the range of the pH analyses performed.

PFLT: N/A Pass / Fail Method 9095 Not applicable for liquid radioactive waste streams.
Analyze the waste for volatile or semi-volatile constituents (Methods 8260 & 8270), and attach the data.
Any distinguishing color or odor? yo N 0 lf yes, color: Ntmle • odor: Nme
2. HAZARDOUS WASTE CODES AND TREATMENT STANDARDS (40 CFR 268)
List all hazardous waste codes and treatment standards. Include hazardous waste codes that have been removed through treatment
and indicate "Former" in the second arlumn. Worst-case concentrations only need to be provided for concentration based
treatment standards. If additional space is needed, provide an attachment to this profile record formatted as below. Include a
description of hazardous waste determinations and any variances, exclusions, etc. in the Waste Profile nanative.
EPA HW
Codes
Description, Constituent of Concern,
or Subcategory
Treatment Standard (mg/kg unless noted as mg/L TCLP or Technology Code)
Worst-Case
Concentration (mg/kg unless noted as mg/L TCLP)
CHLOROFORM- MACRO N/A
Not-Specified MACRO N/A
D001 Not Specified MACRO N/A
D002 Not Specified MACRO N/A
D005 Not Specified MACRO N/A
0006 Not Specified MACRO N/A
D007 Not Specified MACRO N/A
D008 Not Specified MACRO N/A
D009 Not Specified MACRO N/A
D010 Not Specified MACRO N/A
D011 SILVER MACRO N/A
D018 Not Specified MACRO N/A
D019 Not Specified MACRO N/A
D021 CHLOROBENZENE MACRO N/A
D022 CHLOROFORM mg/kg mg/kg
D026 CRESOL MACRO N/A
0027 1,4-DICHLOROBENZENE MACRO N/A
Hazardous Waste Certification Attachment
03/16/2018
TS - 0230 Waste Profile Record - 9/14/2015
3. UNDERLYING HAZARDOUS CONSTITUENTS (40 CFR 268.48)
List all underlying hazardous constituents (UHCs) and treatment standards. Include UHCs that have been removed through
treatment. Worst-case concentrations only need to be provided for concentration based treatment standards. lf additional
space is needed, provide an attachment to this profile record formatted as below.
Underlying Hazardous Treatment Standard (mg/kg unless noted as Worst-Case Concentration Constituents mg/L TCLP or Technology Code) (mg/kg unless noted as mg/L TCLP)
03/16/2018
ENERGYSOLLITIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
None
D. 4. OTHER CHEMICAL CONSTITUENTS
List any other chemical constituents of concern (e.g., PCBs, chelating agents, etc.) and worst-case concentrations. If additional
space is needed, provide an Attachment D.4 to this profile record fonnatted as below.
Worst Case Worst-Case Other Concentration Other Concentration Chemical (mg/kg unless noted Hazardous (mg/kg unless noted Constituents as mg/L TCLP) Constituents as mg/L TCLP)
None
5. LABORATORY CERTIFICATION INFORMATION
UTAH or NELAC CERTIFIED
The Utah or NELAC certified laboratory holds a current certification for the applicable chemical test methods insofar as such
official certifications are given. Please provide a copy of the laboratory's current certification letter for each parameter
analyzed and each method used for chemical analyses required by this fonn.
OTHER LABORATORY CERTIFICATION (Describe below)
6. CERTIFICATION
I certify that sample results representative of the waste descnbed in this profile were or shall be obtained using state- and EPA-approved analytical methods. l also certify that where necessary representative samples were or shall be provided to
EnergySolutions and to qualified laboratories for the analytical results reported herein. l further certify that the waste described in
this record is not prohibited from land disposal in 40 CFR 268 (unless prior arrangements are made for treatment at EnergySolutions) and that all applicable treatment standards are clearly indicated on this form. I also certify that the information
provided on this fonn is complete, true, and correct and is accurately supported and documented by any laboratory testing as
required by EnergySolutions. I certify that the results of any said testing have been submitted to EnergySolutions. l certify that
the waste does not contain any prohibited items listed in EnergySolutions' Radioactive Material License or RCRA Permit.
Signature: Kris Smith Signature Key: 76808213-d04c-48ba-ma.2194c.8a0e5ed Date: 9/14/2015
Hazardous Waste Certification Attachment
TS - 0230 Waste Profile Record - 9/14/2015
Physical Properties Narrative
CO OS -01
'\.z8
Process that generated the waste
Waste stream described in this profile was previously profiled on 9048-03. The Advanced Mixed
Waste Treatment Project (AMWTP) was awarded to the Idaho Treatment Group (ITG). The waste
stream must now be shipped under a contract with ITG but is considered the same waste stream as
9048-03 without the PCB component.
The VTD Liquid/Mixed Waste Debris profile establishes bounding parameters of waste generated as
a result of activities at several facilities within the DOE Complex. The wastes were shipped to and
stored at the Idaho National Laboratory (INL) formally known as the Idaho National Engineering and
Environmental Laboratory (INEEL). The wastes were generated from Decommissioning and
Decontamination (D&D), facility modification, facility closure, materials retrieval and equipment
maintenance, and waste repackaging efforts. The waste associated with this profile was originally
generated at DOE facilities including, but not limited to, Rocky Flats, Mound Facility, Bettis
Laboratory, Battelle Columbus Lab and INL. In July of 2010, AMWTP began accepting waste from
other DOE facilities for processing including but not limited to Hanford. Incoming waste is expected
to be Transuranic Waste (TRU) and will be shipped to WIPP however newly generated waste will be
generated while handling this waste. Hazardous waste codes have been updated to include any
codes associated with incoming waste.
The INL's, AMWTP has performed characterization of the waste as part of the TRU process for
disposal at the Waste Isolation Pilot Project (WIPP). The wastes were originally believed to be
classified as TRU Wastes, however as a result of classification activities at the INL, some waste has
been determined to be Low Level Mixed Waste (LLMW) meeting the definition of LLMW found in the
Low Level Radioactive Waste Policy Act, Public law 96-573.
The waste radionuclide concentrations have been reviewed against the requirements of the
classification tables found in Utah Administrative Code (UAC) R313-15-1008 and meet the
requirements as Class A Unstable waste for disposal at the EnergySolutions Bulk Waste Disposal
Facility located in Clive, UT.
The waste is packaged in metal, wood, and fiberglass containers. Containers are 55 gallon, 83
gallon, 85 gallon, and 100 gallon product drums. Box sizes include, but are not limited to BR-90's M-
III/M-IV Bins, and SWB and half SWBs. The boxes and drums may not have DOT pedigree. If DOT
pedigree cannot be provided waste will be shipped in IP-1/IP-2 soft-sided bags or may also be
placed in IP-1 or IP-2 sealand/cargos containers for shipping purposes and will be removed from the
sealand/cargos for management at Clive.
Waste materials physical composition and characteristics
Waste shipped under profile 9105-01 will primarily be comprised of debris including, but not limited
to electrical components, lead shielding, concrete, laboratory debris, process piping and equipment,
TS - Waste Description - 9/14/2015
03/16/2018
03/16/2018
and DAW (plastic sheeting, PPE, wood, paper, etc.). Containerized liquids, both aqueous and non-
aqueous, are expected to be present in small volumes.
Product drums will also be included. Product drums contain the same debris as is present in the
boxes however it has been inspected prior to packaging and then compacted into pucks within the
product drum.
Newly generated debris will be characterized based on Acceptable Knowledge of the codes and
isotopes contaminating new gen waste, operational procedures, operational logs and visual
examination of the waste. RTR may also be used in rare cases to assist in characterization of new
gen waste. Primary waste will also be characterized utilizing visual examination. In addition to a
thorough review of historical documentation, each primary waste container has undergone
processing through a Real Time Radiography (RTR) system. RTR analyses with container specific
content descriptions have been completed for each container and will be made available to Energy
Solutions with the 5 day advanced notification. Every effort has been made to ensure waste
characterization is accurate and will provide EnergySolutions with the information necessary to
safely and compliantly manage this waste stream.
An example of RTR container analysis that will be made available to EnergySolutions is provided
below:
Containers NWI RTR Review Comments
10000872
Overpacked FRP, electrical cable, rubber hose,
scrap metal, glove boxes, metal tubing, sheet
metal of lead in glove box (-3"x14"), electric
motor, 3 lead bricks, pliers, metal trays, glass lab
wear. Cannot penetrate, - 7 gallons of potential
hydraulic oil in tank 7"x16"x", 1/4 cup liquid in
plastic bottle, several areas of containerized
liquid (total 1 pint). Could not identify the
aerosol can the operator called out. Greg
believes it is actually a connection on the glove
box.
10001042
Cardboard Liner, plastic liner, scrap metal tubing
with fittings, electrical boxes, drum rings, cloth,
structural steel, wood, electric motor. Large steel
object (electric motor??) in bottom corner could
not be penetrated. 20 ml residual liquid in metal
pipe.
TS - Waste Description - 9/14/2015
03/16/2018
10001048
Cardboard, plastic sheeting, PPE, scrap metal,
poly bottles, electrical cord, scissors, metal wire,
metal pipes, respirator cartridges. Large dense
metal sealed container with - 1 gallon of what
appears to be oil. The impenetrable area
appears to be multiple layers of metal pipes, this
area encompasses the lower quarter of the box. 2
cups liquid in poly bottles and 2 tablespoons
liquid in poly bottle. 1 cup liquid in bag
pocket. 1/2 cup liquid in bag pocket behind
edge of dense piping.
3. Waste Management
The AMWTP has completed due diligence efforts to ensure identification and exclusion of waste
items that are not in compliance with EnergySolutions Waste Acceptance Criteria and applicable
licenses and permits. There remains, however, some small probability that non-conforming items
will be identified during sort and segregation operations. Should non-conforming items be identified,
AMWTP will be notified immediately and an alternate disposition path forward will be implemented.
Prior to waste processing, the RTR summary will be reviewed by EnergySolutions site personnel for
each container. The focus of the review will be to pre-identify items that may require treatment other
than macroencapsulation. These items may include:
Liquids: All liquids are believed to be contained. Liquids, both aqueous and non-aqueous, will be
segregated for processing through the vacuum-assisted thermal desorption unit (VTD). VTD
condensate will be shipped off-site for incineration. VTD residues will be sampled and stabilized (if
necessary) prior to disposal.
Aerosol Cans: AK documentation indicates the potential presence of aerosol cans in this waste
stream. RTR provides an indication of whether or not the cans have been depressurized. All
aerosol cans will be segregated and inspected for depressurization. Depressurized aerosol cans will
be managed as debris and macroencapsulated. Aerosol cans believed to be pressurized can be
accepted at Clive, punctured and managed. The generator will notify ES Technical Services if a
shipment will include pressurized cans.
Sealed Sources: AMWTP recognizes that EnergySolutions is prohibited from the receipt of sealed
sources. Every effort has been made to ensure sources are not present in this waste stream.
However, as a legacy waste there exists a very small potential that physical segregation activities
reveals the presence of a source. Should a source be identified, AMWTP is to be immediately
contacted and arrangements will be made for retum shipment to the INL.
Incidental Soils/Sludges: Incidental (<50% by volume) soils or sludges will not be segregated from
TS - Waste Description - 9/14/2015
03/16/2018
the debris waste stream. Soils or sludges present in appreciable volumes (>50% by volume) will be
segregated, sampled, and stabilized (if required).
PCB Items: PCB items will not be shipped in the 9105-01 profile but rather another EnergySolutions
profile specifically established for the management of PCBs.
Lead Acid Batteries: Lead acid batteries may be found within debris boxes and will need to be
removed and drained by Energy Solutions.
The following may be present in the waste and requires special labeling and handling.
Asbestos: Debris waste may contain small volumes of friable asbestos in the form of D&D waste.
Suspected asbestos waste will be properly packaged and containers will be properly marked and
labeled.
Beryllium: A percentage of containers will be labeled with Beryllium stickers. The concentration of
Beryllium in the containers is known to be less than 2 ug/g, as was measured at AMWTP. AMWTP
monitors for Beryllium due to the acceptable knowledge documentation but has never had to control
worker environments from an IH perspective due to Beryllium measurements in the waste.
4. AK Debris Constituents:
Most of the low-density debris material is organic in that it is a chemical compound that contains
carbon (blotter paper, plastics, cotton cloth).
Low-density hazardous debris is comprised of the following:
Plastic materials (polyethylene, polyurethane, and PVC) primarily used for radioactive
contamination control purposes (bags, sheets, tubing, HEPA ventilation duct), and personnel
protective equipment (PPE-bubble hoods, booties, shoe covers)
PPE — Tyvek, cloth anti-contamination clothing, rubber, latex and neoprene gloves, leather gloves,
respirator cartridges, rubber boots
Miscellaneous — Masslin wipes, terry towels, blotter paper, duct tape, filters, cotton, tools and
equipment, scrap metal
Graphite molds and cores
Plexiglas and Benelex materials
Blacktop (asphalt, concrete, dirt and sand)
Fire brick and insulation materials
Filter media and CWS Filters
Leaded rubber gloves and aprons, bricks, sheets, etc.
Wood — pieces of dimensional lumber, plywood, used pallets.
Organic constituents are typically associated with various EPA listed waste numbers applied to the
debris. The listed waste codes are applicable to the debris enveloped by this waste stream because
TS - Waste Description - 9/14/2015
03/16/2018
it has come in contact with listed organic waste contaminants. See Attachment D.2. for a list of the
applicable EPA hazardous waste numbers.
Inorganic Constituents:
Lead is suspected to be present in the form of standard 2"x 4"x 8" brick or pieces of brick, lead
blankets enclosed in plastic, lead wool, lead plates and sheets, lead shot, and various molded lead
configurations to conform to the shape of pipes, valves, and other components for the purpose of
radiological shielding.
Metal debris items consist of generic stainless and carbon steel shapes and sizes, pieces of chain,
nuts and bolts, brass, bronze, cadmium plates and sheet, copper, leaded cable, fuel racks with
cadmium sheeting or filters with cadmium plated metal housings.
Radiological and chemical characterization methods
The waste containers have been characterized for radionuclide content by direct method
measurement utilizing WIPP certified spectral gamma measurement techniques. The spectral
gamma measurements for all containers in this waste stream have identified nuclides below the
lower limit of detectibility for the instrumentation and geometry utilized.
While it is not possible to define an accurate radiological source term for individual drums that fall
below the LLD of the NDA instrumentation, it is possible to define an aggregate radiological source
term for a defined waste stream.
The method used to define such a source term is based on the simple summation of the gamma ray
spectra associated with the NDA measurements of the individual drums in the waste stream. This
composite spectrum is then analyzed using the same algorithms that are applied to the individual
measurements. This method provides a means to determine the radiological content of the entire
waste stream; the radiological content of the individual containers may then be estimated based on
the assumption that the radiological source term is evenly distributed throughout the waste stream.
The advantage of this approach is that the composite spectrum represents a significantly longer data
acquisition time than is practical on an individual container basis. This increase in the effective data
acquisition time results in significantly improved counting statistics. This allows for a determinate
measurement of the radiological source term for the waste stream. A description of the spectral
summation methodology is provided as an attachment to this profile.
The LLD for an NDA measurement is defined as; The LLD is that level of radioactivity, which, if
present, yields a measured value greater than the critical level with a 95% probability, where the
critical level is defined as that value which measurements of the background will exceed with 5%
probability. It turns out that the LLD is entirely due to the quality of the counting statistics, and, as a
rule of thumb the LLD corresponds to a measurement for which the uncertainty, due to counting
statistics, is approximately 30%. The radionuclide distribution comes from two sources depending on
TS - Waste Description - 9/14/2015
03/16/2018
the original generator of the waste. Waste covered by this profile was generated during the
development of radioactive sources for the production of heat for conversion to electric power (Heat
Source Plutonium - HSP) and waste generated for the production of nuclear weapons (Weapons
Grade Materials — WGM).
Nuclides that are not identifiable, by the use of gamma ray spectroscopy, were scaled using scaling
factors developed from the expected nuclide distribution identified in the respective AK document.
Any waste stream, per AK document, that identifies the presence of Cs-137 will also carry the
appropriate Sr-90 contribution based on a one to one scaling.
Chemical content determinations are made by review of available AK documentation. Each waste
stream has been subject to an extensive document review and has been characterized as having a
chemical constituent, if in the processes that generated the waste involved the use of an identified
chemical constituent.
In many cases, materials were identified during the inspection of the waste materials at the INL
AMWTP. If during the inspection processes a hazardous material identification was made, the
appropriate hazardous waste code was applied to the container. An example of this is, a waste code
applied to a waste container after head gas measurement confirmed the presence of a volatile
organic.
Basis for determining manifested radionuclide concentrations
The methodology that will be used to develop radionuclide activities that are entered on the manifest
will utilize a nuclide distribution for Weapons Grade Materials and/or Heat Source Plutonium
Materials. The nuclide distribution is developed by utilizing the actual nuclide activity or LLD for the
detection system and establishing an average nuclide concentration. This concentration is then
multiplied by the net weight of the waste materials to establish the total manifested activity for the
given waste volume.
Nuclides that were identified in a small number of containers will be identified in those specific
containers. An example of those nuclides are U-233, which was identified in approximately seven
containers will be manifested in those containers.
The concentration value of each container will be determined using the appropriate nuclide
distribution model. This method should provide a conservative radionuclide concentration for a given
container.
In some cases, both nuclide distributions will be utilized for a single container. These containers will
be those that contain "Super Compacted" drums from multiple generators and placed into the same
large over pack container. In these cases, the individual compacted drum will be characterized and
the total contents will be added together to obtain the final waste activities.
The nuclide distribution for HSP generated waste is Pu-238 (80% to 83.5%), Pu-239 (13.8% to
TS - Waste Description - 9/14/2015
03/16/2018
16.5%), Pu-240 (2.0% to 3.05%), Pu-241 (0.39% to 0.8%) and Pu-242 (0.08% to 0.2%).
The nuclide distribution for WGM is Pu-238 (.01 to .05%), Pu-239 (92.8% to 94.4%), Pu-240 (4.85%
to 6.5%), Pu-241 (0.3% to 1%) and Pu-240 (0.005% to 0.06%). This source term may also contain a
small amount of Enriched Uranium (enrU) contaminated waste. The distribution of nuclides
associated with the enrU is Th-231 (<0.001%), Th-234 (< 0.001%) U-234 (- 0.1%), U-235 (90% to
93%), U-236 (-0.4%) and U-238 (-5.3%) There could also be a small amount of Depleted Uranium
(depU) contaminated waste identified in this waste stream. The nuclide distribution for depU is Th-
231 (<.001%), Th-234 (<.0001%), U-234 (<.0001%), U-235 (-. 02%) and U-238 (99.8%).
Other isotopes that have been identified in the WGM waste stream include small quantities of fission
products that were added due to research and development activities at the initial generator sites.
Natural occurring isotopes have also been identified in the waste materials during analysis. These
isotopes include Th-232, Ra-226 and K-40.
New gen pallets were generated for shipment on New Gen 8 campaign. Pallets would not fit into the
assay unit. Source term was determined by determining the surface activity and applying it across
the surface area of the pallets and /or the average concentration distributed according to the waste
mass, as appropriate.
Basis of non-hazardous or hazardous waste determinations
a. Listed Hazardous Waste:
The EPA listed hazardous waste codes associated with this campaign are as follows: F001, F002,
F003, F004, F005, F006, F007, F009, P030, P098, P099, P106, U003, U103, U108, U134 and
U151. These codes originate from listed waste that has come in contact with the debris addressed
in this waste stream. This determination is based upon knowledge of the parent waste streams and
processes involved in the generation of the waste, and are documented by the applicable
Acceptable Knowledge Documents identified in the reference section. The application of these listed
hazardous waste codes is per the "Contained-ln Rule" 261.3(f)(2). No appreciable concentrations of
solvents or other listed hazardous wastes (per respective hazardous waste code) are expected.
Containers that have containerized liquids and are subject to U134 EPA Hazardous Waste Code will
not be shipped to Energy Solutions for treatment and/or disposal. Containers that do not have
containerized liquids and have been assigned the U134 EPA Hazardous Waste Code because of
possible contact with Hydrofluoric Acid could be shipped to Energy Solutions for treatment and/or
disposal.
Containers that have containerized powders and are subject to P098, P099 and P106 EPA
Hazardous Waste Codes will not be shipped to Energy Solutions for treatment and/or disposal.
Containers that do not have containerized powders and have been assigned the P098, P099 and
P106 EPA Hazardous Waste Code because of possible contact with potassium cyanide, potassium
silver cyanide and sodium cyanide could be shipped to Energy Solutions for treatment and/or
TS - Waste Description - 9/14/2015
03/16/2018
disposal.
Attachment D.2. provides a list of the hazardous waste codes.
b. Characteristic Hazardous Waste:
The waste contains various metallic lead items, cadmium metal pieces, residues from various metal
handling and chemical operations. The waste was also generated through the decontamination and
decommissioning efforts of the various facilities. The EPA waste code numbers are: D001, D002,
0004, D005, D006, D007, D008, 0009, D010, D011, D018, D019, D021, D022, D026, D027, D028,
D029, 0030, D031, D032, D033, D034, D035, D036, D037, 0038, D039, D040, and 0043 and
applied based upon knowledge of the material itself and/or historical handling and clean up from the
handling of such materials as discussed herein. D001 is also applicable when a container is noted as
having an aerosol can present. The aerosol can will be separated from the debris and treated
appropriately.
The low-density debris is declared to exhibit the toxicity characteristic for lead, cadmium, chromium,
arsenic, barium, and mercury. The D006 and D008 EPA waste numbers are typically declared for
the low density debris because it was used in or around processes where it was known to have
come in contact with lead and cadmium metal, or was exposed to lead or cadmium in the form of
small particles, oxides, or pigments. ln addition, data (TCLP, EP Toxicity, and Total Metals) from
historical sampling and analysis efforts and additional process knowledge information supports
declaration of EPA waste numbers D002 (corrosive - batteries), D004 (arsenic), 0005 (barium),
D007 (chromium), D009 (mercury - low mercury subcategory), D010 (selenium) and D011 (silver).
When container contents warrant regulatory subcategories they will be applied appropriately (i.e.
batteries will receive a "Radioactively contaminated cadmium / mercury battery category" and
elemental lead will receive the "Radioactive Lead Solids Subcategory".
Some of the debris in this campaign may have come in contact with waste carrying the following
characteristic codes,D018 (Benzene), D019 (Carbon Tetrchloride), D021 (Chlorobenzene), D022
(chloroform), D026 (Cresol Mixtures), D027 P-Dichlorobenzene, D028 (1,2-Dichloroethane), D029
(1,1-Dichloroethylene), D030 -2,4-Dinrtrotoluene, D031 (Heptachlor), D032 (Hexachlorobenzene),
D033 (Hexachlorobutadiene ), D034 (Hexachlorobutadiene ), D035 (Methyl ethyl ketone), D036
(Nitrobenzene), D037 (Pentachlorophenol ) D038 (Pyridine ), D039 (Tetrachloroethylene), D040
(trichloroethylene) and D043 (Vinyl Chloride). This debris consists of gloves, bag cutters, parts of
plastic liners and PPE. Codes are applied based on the potential of the debris to come in contact
with waste.
ln summary, application of characteristic EPA waste numbers is based primarily upon process
knowledge of the material itself (e.g. metallic lead, cadmium, silver or lead solder) as documented in
Acceptable Knowledge documents identified in Section 10, References. Waste numbers applied to
the low-density debris is also based upon process knowledge of the debris and are declared based
upon that knowledge as described above. Historical data exists that supports declaration of the EPA
TS - Waste Description - 9/14/2015
Briefing by: Date:
Section III: Safety attd Compliance
Mora qii 0 wr.e1 t-4., Kor f d . I/
Section IV: Brïeflne Attendance
Signature —lob Description
ekc-
Name
f7611,04,;r14
. 1.

ENERGYSOLUTIONS
PRE-JOB IIEFING CL-RS-PR-14044
Revision 3
Date: 11/17/17
Bates Number Go 4795 A
RWP 111) Task S&R Ops
Section 1: Job Description: Cask Unloading of Liner at CWF
Conveyance Type:
iif¿fsti -3
Generator 1065-C-0093
Container Type: PL14-215FR Container it: 667438-2 Weight:80001bs
Alara Review
Y es ItEl N o
Void Reme4iation
O Yes go No
Liqujd Verification
Eli Yes O No O Ycs 114 N
Cask or Conveyance mR/hr Disposal Container mR/hr
Contact Dose Rate <I Contact Dose
Rate 0.1
1 meter Dose Rate
30 cm Dose
Rate
2 meter Dose Rate 4.1 1 Meter Dose
Rate
Plane of open cask 4 I
Operator Cab < I
Operations Review: beA,Zr evt-f Radiation Safety Review:
Page L of j._
ENERGYSOLUIIONS
CWF Void Space Worksheet
Form CL-CW-PR-200-F2 Rev. 1

•
Shipment 1065-C-0093 Sates * Coq IctS Container 0 667438-2
MANIFESTED WASTE VOLUME VS CONTAINER CAPACITY
Manifested waste volume from the net waste volume arid any 188.00
additional fill material per container of Form 541 =
Volume from the container from the approved container
volume per manufacturer specifications or container
engineering review of Form 541 OR internal volume per 188,00 ft/
manufacturers specifications
Fdl % = 100 (Waste volume / Container intemal volume)
100.00
CALCVLATED WASTE VOLUME VS CONTAINER CAPACITY
Gross weight born block 8 of Form 541 = 8000 lbs
Tare weight frorn manufacturers specification = 1250 lbs
Waste weight = Gross weight - Tare weight 6750 lbs
Waste density 37 lbsift3
Waste volume = Waste weight / Waste Density = 182.43 ft3
Volume from the container from the approved container
volume per manufacturer specifications or oontainer 188 fe
engineering review of Form 541 OR internal volume per
manufacturers specifications
Fill % = 97.04
Comments:
Prepared by Albert Evans Date 11/16/2017
Reviewed by rfeer..05T— Date 11-1 7
Radiological Survey Farm CL4S-PR-11151 itts.1
les flumes in(ersiw
beta beta
Maximum *LAW results dprn/100cm2
Maximum
Total dpel 004=2
Limits FloodDeolc
alpha beta cipher
240 3,400 240 -
a 2,400
RST
3 Disc smears werc taken internally (Floor, Side, Lid) its cask. Highest removable contamination was
4 PIPif
4141D
dpm/ 10Dem2 alpha and dpm/100cm2 beta
Large Area Wipes (LAW) taken on external surfaces. Highest removable contamination was
/111 dpm/100cm2 alpha
AIM 04 dpm/100m2 bets and
Remarks: *Denotes: Highest reading measured on a Lam Ares Wipe.**Denotes highest readitAby swipe counted on L3030. Open WitadOW Reading 4 Cid toremfbr. Seal A 1.-4 0 a 1 8 447 g if the Mils is returned with braeleaferibbIng inside the ractiotogleal data underneath thesep e Id not be obta
ii-'ii-qi Survved by (Print): /in Gr411.11.1"-41 Sign: /
Sward bY Otil# frIrj Siam JiCLe
lievieued by (Print): // "5 Sip" Date
tiERGYSOLUTIOM
gunit1,- information Date: /7-/ 7 Efficiency MDA Survey number: NA Shipment A: See Below e fl lie • Cask ITrailtr „Reason: Modified DOI` Empty
Serial Number P3271
.AJO
tyr
Cal Due 2.k7 -21.- -0 S.41.2? 6 01
, l .2471
Cask Trailer
Shipment No: Generator No: lD No: lD No:
.. - ,def...„.7 /g-,.? GRA Max Contact Dose Rate
Maximum Removable dpm/100cm2
mrernihr alpha beta
., , a a x A L
Limits NA 24,000 cingo- 240,000 (00R- Side* Side* O.Or
Side* I i Botutm ../g1,1.7 TOP° bpx RST ink: w "7 Emptied As Far As practical ' ii
RST 16100,0
t a * a a x A L
Limits 03 , 240 2,400
Side" 0, OA 4070#
Side" 1
Side"
)
1 Side"
Top'• (). 02 DA RST loft: gi5 jitim 1
ENERGYSOLVTIM
Cask Operations Checklist
Form CL-CW-PR-OlO-F1
Rev 3
D4 n /Cc"-
it4 %bl"
RST
Batts 0: a y 79 1"--
Date: ,// -/ Cult lD #: /y 2/0 he
Con ED#: --Iv3ir„
Cask Handier (CH)
RST
ask Team Supervisor (CST)
Description Wormed by (Rrfl
, • Verified isy (ers Wan)
ALARA Review performed if disposal > 10 R/hr 44_
Acceptance process completed, Bates # assigned. Or,
The pre-job briefing conducted and documented.
Directions: The qualified person performing the ask shall bulimia obe woe provided threxh step in thc gçk11u lrss step is not applicable to the cask. Wthe
"WA" in the space provided fir initials When a conlitiot is dimmed:idyl:1g the performance of this checklist that is oat no compliance with CI,CW,PR•OlO, Containerized thasts Unloading vid Hand/ire STOP WORK end ;0111=1 the RSO, or designee for direction.
RST verified dose rates of the open cask. Or/
Perform radiological survey on internal and external surfaces in accordance
with applicable RS Prosalure. Cask cleaned (if applicable). Max internal contamination, <1/11,1VH— . Dose Rate .4 I 1 OS
Visually irtspect the interior for damage, liquid, or din/debris.
Radiological survey of cask and conveyance completed and documented in
accordance with applicable RS procedure. .0a
Remove, cover, or obliterate placards, labels and rnarkings used for
incoming shipment.
Apply all applicable labels and/or markings for the return shipment. 0 /I
•
Description Performed by (CH1 Verified by (CTS initials)
Controlled copy of cask manual specific to incoming cask on file and readily
available (i( applicable), • Af) Z Liquid Verification Requited? lek ve,
Void Remediation Required? _ (10 gig
Page t fif 2
Beetconie &cements, once printed. ore uncontngled and snay become outdated, Refer to the thannocb or the document control authority for Ow AVM reVIS1011.
EN ERGYSOLUTIONS
Cask Operations Checklist
Form CL-CW-PR-010-F1
Rev 3
61) 1117-1-1 .
Verify that tamper seal is in place and unbroken on the primary and
secondary lids or lifting lug covers. Type A and B shipments only. 4)
Verify that the IDN on each disposal container rnatches the ID" on the
Manifest and that each disposal container is marked "Class A Unstable"
waste as required by 10CFR 61.57. ,
A 0/ (
Inspect gasket to ensure that it is intact and fully secured to the cask lid. Ensure that the seal area is free of dirt and debris. Ilic X
Verify cask is empty and notify S&R of status, if "No", list contents:
c
h
te
c
s
,t
) No
Co :A 111.fr.rgv..,,,j
Dale: 1 I-1 7-1/
Time: lo()
„ .
, , , A e• .>I I
Torque wrench
setting: S V
Torque wrench #: al IS loc:qqvU
Calibration due date: q-i-7-1 V
setting -
wrench length r7
:
.
X 2.21__s) pec
binder length /1-1- wrench length I -7
Place an ariti-tamper seal on cask. ,...0 f•
Inspect tie-downs to ensure they are taut.
Security notified of disposal as applicable?
Sean Cask Operations Check List to Clive CWF and return to S&R.
Date
Page 2 ol2
Elethamie exemene. awe printed, am uncontrolled sad may Imam *tamed. Refer to the ithmuth or the documem venni authority for the omens coition
ENERGYSOLVTIONS
Package Liquid Verification
Form CL-CW-PR- Rev. 2
200-F1
DATE: Ail\
CUSTOMER: -2.;1)
PACKAGE NO. (9(p3 • 2- MANIFEST NO. tt44.5•C • ari3TRACKING NO. CtAic15
Reason for verification:
00X cZ- Bo en?1_111-
inspectOn Authorized By:
c,..r. TS. DHP ill VI 1 Date
Liquid Found Yes ti No
If yes. how much solidi tication agent added
A B C D E F G
Gallons
Collected Multiply by
0.1336806
Cubic Feet
of Liquid
Divide by
Waste Volume
Wro 1
nit4anifest
Fraction
of • t* Multiply by
• 100
otai IreCcent
of Liquid by
Volume
pH reading kt
Inspection Sup rvisor.
Comm ts:
Date:
Prepared By: _Z4.•• Date: /1Vi
Of Reviewed By: Date: PH 7
Page 1 of 1
ElmnInic umnt.one.: printed. are unc4untolle.1 aud may hcconte outdated. RAT to thc ituranvb or the document control authority for the currou reckinn.
CL-CH-PR-252 Fl
NERGYSOLUI7ONS Revision 0
1% Volume Freestanding Liquids Chart
Part 1
Gen ID/WS/Shipment #: 0716-23-0002 pH reading(s): 7
Bates#: L128122 Aqueous X Non-Aqueous Both
Container ID(s): CYAU026313 Corrective action:
Condition Report #:
NOTES/COMMENTS: (2) small puddles inside container
(1) - 3"x4"xl"
(2) - 3"x2"xl"
Part 2 (Enter Values Only in Highlighted Cells)
Volume in Cylinder / Drum
A B C D E F G H l J K
1T
Diameter
(inches)
Depth of
Liquid
(inches)
Vol. Of
liquid
(Cu.ln.)
AxBxC
Cu. In. per
Cu. Ft.
Liquid Cu.Ft.
(actual)
Manifested
Net Waste
Volume per
Container
Fraction of
Liquid
If Column J:
Total % by
volume
<= 1.0, Pass
> 1.0, Fail
3.14 0 1728 0.000 x 100
Volume in Puddle / Box
A B C D E F G H l J K
Length of
Puddle
(inches)
Width of
Puddle
(inches)
Depth of
Puddle
(inches)
Vol. Of
liquid
(Cu.ln.)
AxBxC
Cu. In. per
Cu. Ft.
Liquid Cu.Ft.
(actual)
Manifested
Net Waste
Volume per
Container
Fraction of
Liquid
If Column J:
Total % by
volume
= < 1.0, Pass
> 1.0, Fail
36 1728 0.021 810 0.000026 x 100 0.00% Pass
Performed By Date Manager, Waste Disposal Operations Date
Reviewed by Applicable Manager Date
Page 1 of 1
CL-CH-PR-252 Fl
ENERGYSOLUTIONS Revision 0
1% Volume Freestanding Liquids Chart
Part 1
Gen ID/WS/Shipment #: pH reading(s):
Bates#: Aqueous Non-Aqueous Both
Container ID(s): Corrective action:
Condition Report #:
NOTES/COMMENTS:
Part 2 (Enter Values Only in Highlighted Cells)
Volume in Cylinder / Drum
A B C D E F G H I J K
1T
Diameter
(inches)
Depth of
Liquid
(inches)
Vol. Of
liquid
(Cu.ln.)
AxBxC
Cu. In. per
Cu. Ft.
Liquid Cu.Ft.
(actual)
Manifested
Net Waste
Volume per
Container
Fraction of
Liquid
If Column J:
Total % by
volume
< = 1.0, Pass
> 1.0, Fail
3.14 0 1728 0.000 x 100
Volume in Puddle / Box
A B C D E F G H I J K
Length of
Puddle
(inches)
Width of
Puddle
(inches)
Depth of
Puddle
(inches)
Vol. Of
liquid
(Cu.ln.)
AxBxC
Cu. In. per
Cu. Ft.
Liquid Cu.Ft.
(actual)
Manifested
Net Waste
Volume per
Container
Fraction of
Liquid
If Column J:
Total % by
volume
<= 1.0, Pass
> 1.0, Fail
0 1728 0.000 x 100
Performed By Date Manager, Waste Disposal Operations Date
Reviewed by Applicable Manager Date
Page 1 of 1
03/16/2018
ADDITIONAL HAZARDOUS WASTE CODES AND TREATMENT STANDARDS
ATTACHMEN'T
EPA HW Codes Description,Constituent of Concern,
or Subcategory Treatment Standard Worst-Case Concentration
D028 1, 2-DICHLOROETHANE MACRO N/A N/A
D029 1, 1-DICHLOROETHYLENE MACRO N/A N/A
D030 2, 4-DINITROTOLUENE MACRO N/A N/A
D031 Not Specified MACRO N/A N/A
D032 Not Specified MACRO N/A N/A
D033 Not Specified MACRO N/A N/A
0034 Not Specified MACRO N/A N/A
D035 2-BUTANONE MACRO N/A N/A
D035 Not Specified MACRO N/A N/A
0036 NITROBENZENE MACRO N/A N/A
0036 : Not Specified MACRO N/A N/A
0037 PENTRACHLOROPHENOL MACRO N/A N/A
D037 Not Specified MACRO N/A N/A
D038 PYRIDINE MACRO N/A N/A
0038 Not Specified MACRO N/A N/A
0039 TETRACHLOROETHYLENE MACRO N/A N/A
0039 Not Specified MACRO N/A N/A
0040 Not Specified MACRO N/A N/A
0043 Not Specified MACRO N/A N/A
F001 Not Specified MACRO N/A N/A
F002 Not Specified MACRO N/A N/A
F003 Not Specified MACRO N/A N/A
F004 Not Specified MACRO N/A N/A
F005 Not Specified MACRO N/A N/A
F006 Not Specified MACRO N/A N/A
F007 Not Specified MACRO N/A N/A
F009 Not Specified MACRO N/A N/A
P030 Not Specified MACRO N/A N/A
P098 Not Specified MACRO N/A N/A
P099 Not Specified MACRO N/A N/A
P106 Not Specified MACRO N/A N/A
0003 Not Specified MACRO N/A N/A
U103 Not Specified MACRO N/A N/A
U108 Not Specified MACRO N/A N/A
U133 HYDRAZINE MACRO N/A N/A
U134 Not Specified MACRO N/A N/A
U151 Not Specified MACRO N/A N/A
TS - Waste Description - 9/14/2015
03/16/2018
JUSTIFICATIONS FOR WAIVING PH CHEMICAL ANALYSES ATTACHMENT
Primarily debris for MACRO.
TS - Waste Description - 9/14/2015
XL-Bates Free Liquid Management Matrix
Sampler (Brian's Group) checks 100% of containers in shipment.
Sampler fills out Sample Collection Report (SCR) describing the amount of free liquids found.
If NO Free Liquids Found: If Free Liquids ARE Found:
Lab (Jared) sends email to Tim, Barbie,
Shanon, Justin, Brian, Craig, Brett, and Dave
stating that no free liquids were found and the
waste is approved for LLRW disposal.
The sarnpler will mark each container that had
free liquid and the SCR will note that free liquids were found in the shipment.
NOTE: Since the waste has not changed,
the original manifest may be used
to 'ship' the waste to LLRW for
disposal. Therefore, Shipping &
Receiving has no action.
Lab (Jared) sends email to Tim, Barbie,
Shanon, Justin, Brian, Craig, Brett, and Dave
stating that free liquids were found.
Operation's (Craig's Group) opens the
containers identified to have free liquid and
manages the liquid appropriately.
The Tracker (Barbie/Shanon) will change the
EWIS status of the shipment to AD-LLRW.
Operation's completes repack/solidification
paperwork and obtains samples, if necessary.
NOTE: Additional lab approvals may be
needed prior to disposal. The
Tracker will not change the status
until all required laboratory work
has been completed.
Operation's then sends a request for a manifest
to Shipping & Receiving (Justin).
Shipping & Receiving creates a manifest for
shipment to LLRW and sends to operations
(Craig).
The waste will be disposed at LLRW after the
status has been changed.
Operation's (Craig) packages the
repack/solidification paperwork with the
manifest and approval(s) and sends to
Document Control.
Operations (Craig) sends an email to Trackers
(Barbie/Shanon) informing them that the
manifest is received and the status may be
changed.
The Tracker (Barbie/Shanon) will change the
EWIS status of the shipment to AD-LLRW.
The waste will be disposed at LLRW after the
status has been changed.
03/16/2018
Transuranic Waste — Rocky Flats Plant
AMWTP — TRUW-30, Current Rev., Acceptable Knowledge Summary for Supercompacted
Debris Waste (BN510)
AMWTP-TRUW-04, Current Re., Acceptable Knowledge for Battelle Columbus Laboratories
Building JN-4 Plutonium Laboratory
AMWTP-RPT-TRUW-83, Current Rev. Acceptable Knowledge Summary for Supercompacted
Debris (BN510.1)
EDF-0775, Engineering Design File, Mixed Low Level Waste Debris Characterization , K.A.
Smith
AMWTP-RPT-TRUF-92, Acceptable Knowledge Document for Select Idaho National Laboratory
(INL) Facilities
An NDA Technique for the disposition of Mixed Low Level Waste at the Advanced Mixed Waste
treatment Project, M.J. Clapham, J.V. Seamans
[1] Contact-Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,
DOE/WIPP-02-3122 Rev. 3.0
www.wipp.ws/library/wac/CH-WAC.pdf
TS - Waste Description - 9/14/2015
03/16/2018
waste numbers for these items but in some cases is specific processes (PPE generated while
handling lead or cadmium, discarded leather gloves) and is used generically to support declaration
of EPA waste numbers.
Treatment Processes, if applicable
The debris waste stream has not been subject to treatment processes; some wastes have been
volume reduced via "Super Compaction". Some items are identified for segregation prior to treatment
to ensure proper treatment in compliance with the Land Disposal Restrictions.
Information requested in other sections of this form
a. Special Nuclear Materials
The waste contains Special Nuclear Materials (SNM) in solid physical form. The SNM are in the
metal oxides with a very small fraction (<1%) as metal nitrate form. The wastes were generated as
a result of nuclear weapons production or heat source production operations.
The SNM isotopes are distributed through the waste essentially uniformly as contaminated debris
materials. There are no discrete objects or point source materials within the waste matrix containing
SN M.
The document "Determination of Radioisotopic Content in TRU Waste Based on Acceptable
Knowledge" AMWTP-RPT-TRUW-07 is the basis for determination of the SNM content of the
wastes. Each container of waste has received nuclide identification by WIPP certified spectral
gamma measurement techniques. Nuclides that are not identifiable by the use of gamma ray
spectroscopy were scaled using scaling factors developed from the expected nuclide distribution
defined in the respective AK documentation.
The LLD for an NDA measurement is defined as; The LLD is that level of radioactivity, which, if
present, yields a measured value greater than the critical level with a 95% probability, where the
critical level is defined as that value which measurements of the background will exceed with 5%
probability. It turns out that the LLD is entirely due to the quality of the counting statistics, and, as a
rule of thumb the LLD corresponds to a measurement for which the uncertainty due to counting
statistics is approximately 30%. Gram concentrations are developed by utilizing specific activity
calculations for the identified nuclides applied to the waste mass. In many cases, gram quantities
have been verified by neutron analysis of the containers. The debris waste stream containers are
expected to contain less than 10 grams of fissionable materials.
10. REFERENCES:
AMWTP-RPT-TRUW-05, Current Rev., Waste Matrix Code Reference Manual
AWMTP-RPT-TRUW-07, Current Rev., Determination of Radioisotopic Content in TRU Waste
Based on Acceptable Knowledge
AMWTP-RPT-TRUW-12, Current Rev., AMWTP Waste Stream Designations
AMWTP-RPT-TRUW-13, Current Rev., Acceptable Knowledge Document for INL Stored
Transuranic Waste — Mound Plant Waste
AMWTP-RPT-TRUW-56, Current Rev., Acceptable Knowledge Document for INL Stored
TS - Waste Description - 9/14/2015
REAGENT
(Common Name)
REAGENT
(Chemical Abbr.) Notes
Aquaset II Aqua II
Aquaset II H30 Aqua II H30
Calcium Polysulfide CaSx
Calcium Superphosphate CaH2PO4
Cement (Portland) Cement
Ferrous Sulfate FeSO4
Magnesium Oxide MgOx
Potassium Permanganate KMNO4
Sodium Carbonate NaCO3
Sodium Dimethyldithiocarbamate NaDTC
Sodium Hydroxide NaOH
Sodium Sulfate Na2SO4 _
Sodium Sulfide Na2S
andiagina Sevnits an.
Te-,st Repr ,T

IEMN40121 -11
antobor 20. 2016
Page 3 of 18

SECTION I CERTiPICATION
DESIGN QUAUFICATION of the industrial Container Services, LLC
390 Gallon Composite IBC with Mauser Cage anti Schuetz Bottle
TEN-E Packaging Services, Inc. Is a currant DOT UN Thkd-Party Certification Agency under §107.403 and cettlfies that the Industrial Container Services, LLC packaging referenced above has passed tha standouts of the DEPARTMENT OF TRANSPORTATION'S TITLE 49 CFR; Performance Oriented Packaging Standards, Section 178. This package is also certified under IMDG and the UN Reconvnendations on the Transport of Dangerous Goods. It is the responsibity of the end user to &tontine outhorization for use under these regkdations. The use of other packaging methods or components other than those documented in this report may render this certification invalid.
1' -- -, -,;;;;- ii •
suriltvIARY OF PERFORMANCE TESTS
- •-•••
t
Vgjrrt 1 8.819 3.3 Hz - 1 Hour Wafer , October 17, 2016 PASS
Bottom lit 178.811 2,659.6 Kg •Water October 19, 2016 PASS
Shutting 178.816 • 3.866 Kg - 24 Hours Water October 20, 2016 PASS Leakproofness 178.813 20 kPa - 10 Minutes BMW October 20. 2016 PASS
Hydrostslic • 178.814 70 kPik - 10 binutes Water , October 20,2016 PASS
Drop 178.810 1.8 m Mathanol/Water October 19, 2016 PASS
TEST REPORT NUIMIER(S): 16-MN40121
UN MARKING: (CFR 49- 178.703)
iti?-.2
31HA1 I Y / • / USA / M`fr" /3865/ 2032
PACKAGING IDENTIFICATION CODE: PERFORMANCE STANDARD: 1 (178.707 Composite 1124 Y (Packaging meets Packing 11 and 111 tests)
MONTH MID YEAR OP MANUFACTURE: * . STATE AUTHORIZING ALLOCATION OP THE MARK: USA '
PACKAGING CERTIFICATION AGEITCY: (+AA) TEN-E Packaging Services, Inc. (Newport MN CAA 62000030022)
THIRD PARTY PACKAGU40 IDENTIFICATION: 14**** Insert Manufacturer's Registered Number
IIT TEST LOAM 3.855 Ka 01.600 Lbs.) MAXIMUM IMMIISSLE GROSS MASS: 2.032 Ka (4.481.5 Lbs.) PERIODIC DESIGN REQUALWICATION DATE: October 20, 2017 AtIbITIONAL REQUIRED RIGID PLASTIC& COMPOSITE eat MARKINGI (CPR 49 - 178-703(0»: RATED CAPACITY AT 20IC (liters): Insert rated madly of ISC In Likofs TARE MASS (KO " Insert individual IBC tam mass
DATE OF LAST WAKMOR, TEST: insert Month & Year of Last Leakproofnass Test
DATE OF LAST INSPECTION: Insert Month & Year of Last Inspection
GUAGE TEST PRESSURE (Ws): 70 kPa
ALL OTHER WARRANTIES, EXPRESSED OR IMPUED, INCLUDING ANY WARRANTY THAT THE PACKAGING TESTED IS MERCHANTABLE OR FIT FOR A PARTICULAR PURPOSE, ARE DISCLAIMED. In no event shall TEN-E Packaging Services, Inc. fiablity exceed the total amount pakl by industrial Container Services. LLC for services rendered. In the
evert c4 *Aura changes to the above referenced test standards, it is du responsthiltly of industrird Container Services, LLC to determine whether additional testing or updating of past testing is necessary to verify that the packaging we have tested remains in compliance with those standards.
MANUFACTURER:
Industrial Container Services, LL.0
1540 South Greenwood
.11. Montebello, CA 90640
Catterlrlion9 - berry .1. Anderson
Technician Manager. Technical Semites TEN.E Packaging Sinatek, inC. I EN+. Packaging Sentian. Inc.
1666 County Rend 74 1666 County Road 14
Newport. MN 5S055 Nowpott. MOSS
I ENERC -SOLUTIONS
CL-MT-PR-007-F5
Revision 0
Waste Solidification Record
Solidification Run # : /71 z..15-5
1-1:) (int.)
GEN. MS # : 2-0 - 38
1. Process Area cleaned from previous waste stream
# of cont. Bates/Run #
X 4 6° Li 7Z.
2. Verify all tanks and equipment have been triple rinsed and documented on Decontamination Verification Record
CL-MD-PR-100-F1, prior to managing LLRW-Destined Waste. gb (int.) Or if not applicable circle NA
3. Certify that all re-use containers are Visibly Clean by removal of all material that can removed with a broom, shovel
or other tool. 16t:. (int.) Or if not applicable circle NA
Operator: Bitc--bikU IS
Operator: tAt.e vvt
Operator: issol,,
Operator: 4:2or/
Liquid Waste Solidification Formula
Ratio of Material to Waste: I. q 410
Solidification Material(s): 3.01447,11-1..e L.k.b
Additional Information: Nip
LBS.
Waste
LBS.
Material
Added
PFLT piF
pw/
FW
# of Cont.
Created from
Batch
Container Type Batch Notes
A Z. 000 .18ao P i S o Pegs Acir--
E3 z000 Z Boo No I Sup6ies'Ac-k
C 2.000 2-Soo Pk.) 1 So Peg5A CK
D 2.60o 28o0 rt4 1 su Ft R_SACK
E L000 2.800 No l 5 OP6- R.% AcK
F 2 obo 2.8 o 0 ?1,3 1 suFsesAe-K
G 2o0o zee*, pto \ SoMR.SAc...y..
H 2. opt) 2-2 ob PIA) 1 So c'e es ACk.
I 20oo 28 ex) PIO I So PER.sAc_5,
J 2000 2 eoo ?to k SupeRsAdc.
Total LBS. Of waste for run : L.tiObO
Notes (remarks, observations) : YL.Ckoct-7z pimysti-eb im THIS gut4
-MTAL ov 2-1 ?...tkizs ILI 6 c..01,1e.. ckAk \ oc- 2- \-1.7 \15-.
Date
Date
Z-16--- 17
reatment/Facility Operator Signature
Reviewincervisor Initials
CL-MT-PR-007-F6
CYSOLUTIONS Revision 0
Waste Solidification Record Continued
lg # c1/2-c.-38 x /717_15 s Page 2- of 2..
LBS.
Waste
LBS.
Material
Added
PFLT
P/F
PW/
FW
# Of COnt
Created
from
Batch
Container
Type Batch Notes
21) oo 2Roo Ro I soneAsocts
2.00o 2800 po..) 1 s I) pAgsActs
2 00 o 2-Son PtAi 1 StiPti2SAGg
i 0 00 2800 ?tA) I 514761254K
Z000 agoo PL1/43 1 Sv PiesAck
2. 0 0 0 2-8 oo 11.0 t ..51RAttsAcK
2 0 tso 2..Šon Pu.3 I S 0 Pigs Adc.
2o0o 2Soo p Lk) 1 5 oPeRsAcg.
2000 Z800 RA) I S uPetsAcK
2000 2 8 or, Pa-) 1 SoPeasAcK
l000 1 L-1 00 Pid.) I so Peimacici
'
I
:
'
0
\I
D
P
Q
R
s
'eatment Operator Initials Date Reviewing Supe isor Initials Date
Tim Orton
From: Brett Davis
Sent: Thursday, February 15, 2018 2:16 PM
To: Barbie Hymer; Tim Orton; Jared Stark
Cc: Craig Erickson
Subject: 9105-01 M13751 Status change
9105-01 M13751 contained 1 drum with 5 aerosol cans that were identified by the generator. The cans were removed,
punctured and returned with the waste. There were no liquids found in the shipment. The status can be changed to AM
with your approvals.
1
Classification and Administrative
Control of Discrepant Incoming
Shipments
C OPY CL-AD-PR-040
Revision 6
Attachment 5.1 — Discrepant Incoming Shipment Condition Report Classification Guide
(Page 1 of 3)
Discrepant Incoming Shipment Condition Report Classification Guide (Updated 5A2/2014)
Type of Discrepancy Significance
Level Options CAP Required
Regulatory
Notification
Required
Incorrect Wastc Classification 2 1 ° Occurrence Yes
Waste Received with SNM Above Clive's License Limits 2 1° Occurrence Yes
Packages non-exchisive use in a transport vehicle e\eceds a CSI of more than 50
(exclusive use ntif to exceed 100) 4
As requested by
ShippMg and
Receiving
No
Received shipment V, Ith manifest that identifies radionuclide concentrations above
license limits 2 I° Occurrence Yes
Received slsrprtsent exceeds DUIMôrstortom I.imits 2 Occurrence Yes
Quantity ofConccrris Issues 2 or 3
(severity Depentkial I ° Occurrence Yes
Unmanifested I S 3310 3 or 4
(So:My Dmendenil 3'4 Occurrence
Yeti and requires
an Linmanifested
I lazardous Waste
Report
Manifest not in compliance with CL-SKTR-041, Incoming &Whine:ire Waste
Shipment Acceptance (with potential License Impact) 3 or 4 (Severn,. 11(mendenO 2.4 Oc-surretice Yes
Waste Noi MeetMg WPR Description 3 or 4 3r° Occurrence No
Container Integrity Issues (PCB Shipment) 2 or 3
(Seten4 Dependent) 1 ° Occurrenee Yes
Container Integrity Is - a i ion detected (Non-PCB) 2 Oi 3
(Sever()) Dependent(
d 3 Otcurrcncc Yes
Container Integrity Issues - no contamination detected (Non-PCB) .3 or 4
isesenty ix-Nadi-an 3'4 Occurrence Yes
Faikd package integrity and/or failure to contain waste material adequately (non-
reeulated material) 3 or 4 1°' Occurrence Yes
Package breach in transit to the facility - rršults in contaminatkm but does riot
impact health or the environment I ° Occurrence Yes
I fasardous materials incident defined in 49 CFR 171.15 1 or 2
isevam oeixixteen 1 ° Occurrence
Yes and Natl.
Response Center
Notification within
12 hours
PCB Shipment with a Breached Liner 3 3- Occurrence No
Identified Staining on PCBItem(s) 3 3° Occurrence
No (Yee, if wipe
test results are
greater than 10
tut,l00 crn2)
Failure to utilize the proper packaging .3
As requested by
Shipping and
Receiving
Not unless the
packaging results
in failure to
contain waste
Loosening, failed, or unintentional release of closing devices of manifested
package(s) 3 or 4
(Seven)) Dependent(
As requested by
Shipping and
Receiving
Yes
Inadequate or failed bracing resold!) a ' 3 or 4
(Seamy Dependent)
As requested by
,1-
Shipping ,,,,.. .".'' Receiving
Yes, if results in 3
breach of container
Page 1 of 3
Non-Proprietary Page 9 of 12
CL-AD-PR-040
Classification and Administrative Revision 6 l
Control of Discrepant Incoming
Shipments
Attachment 5.1 - Discrepant Incoming Shipment Condition Report Classification Guide
(Page 2 of 3)
Discrepant incoming Shipment Condition Report Classification Guide (Updated smpoi4)
r ney Significance
Level Options CAP Required
Regulatory
Notification
Required
State Notification
required if not
resolved within 15
days of snivel
Weight Difference greater thag 10% from UnifornsIaasss W st as i
(Mixed Waste Only) m Occurrence
PCB Shipment with a weight discrepancy greater than. 10,4 OF tpieet count
which does not ncatch the manifest a oceureence
Ves (if the
discaepancy is not
resolved within 15
days after
receiving the waste,
must go to the
Exec Sec and EPA
Region S
Administrator)
Radiological Analysis Concerns 3 3'd Occurrence Yes
Deferred Charlie, LDR issues 3 ri Occurrence Yes (if Disposed)
Presence of non-profiled free liquids (total of aqueous and.nNEgqueous) ,.1% 3 I" Occurrence Yes
•
N. (PCB Sh .; 'c1J%
•
•
3 la Occurrence
No, (Yes, if the
discrepancy is not
resolved within 15
days after
receiving the waste
must go to the
Executive
Secretary and EPA
Region 8
Administrator)
Non-profiled InadecpustelyDrainet s) 3 Oevsirrace
Sec PCB Shiprnent
with Non-profiled
Free laquids
Rigging issues with CW.F Shipment 3 la Occurrence No
Loose radioactive material in a shipping conveyance (no coniaiacr integrity issues
identified) 19 Occurrence Yes
Contamination above DOT limits on a vehicle, railcar, conveyance; or package
(all shipments except intmal surfaces of e Nc lusive use) l'' Occurrence Yes
Contamination helow DOT but above Clive's release Ihnits on a vehicle, railcar,
conveyance, or package 3' Occurrence Yes
Excess Dar radiation tevnls for cab, surface, plane, or at least 2 meters from
plane
2 or 3 Omsk) Dependeul l lst currence Yes
Packages in a transport vehicle,e,sls a T1 of more than 50 (exclusive use
shipinents are excepted) 4
As requested by
Shipping and
Receiving
No
Arrival of Pre-Shipment Samples Without a Manifest (540-541 el:ached to or
accompanied with shipme.ni) 3 la Occurrence Yes
Anise{ of waste without a valid Notice to Transport ,i 1 Occurrence Yes
Page 2 of 3
Non-Proprietary Page 10 of l2
CL-AD-PR-040
Classification and Administrative Revision 6 I
Control of Discrepant Incoming
Shipments
Attachment 5.1- Discrepant Incoming Shipment Condition Report Classification Guide
(Page 3 of 3)
Digrepant I aming Stilgiment Condition Report Cloglifleetirm G ide (Updated 5/01/2014)
Tpe of Discrepancy Sign ificance
Level Options CAP Required
Regulatory
Notification
Required
Arrival mf a shiprorq withont a compact export approval letter on file. 3
A.,, requested by
Shipping and
Recei t' i t lg.
Regulatory
notification is not
requirectif the
shipmem/comaincr
(Wapplitable) is
rejected prior to
recelpt
Failure to register as a g,..-r,erator Of shipper uf hazardous material with ths: State of
Utah OSA program (missing or invalid OSAP number) 3
As requested by
Shipping and
Receiving
Yr,5
Failure to provide shipping par,r, kí tent uf hazard i ;Akt. 3 Or 4
,Se,crity
As requested by
Shipping and
Reeeiviog
Yes
Unresolved ritìssing data from rnanítvri or r11311! .
_ .......
,,Vi requested by
Shipping and
Receiving
No
Failure to label each package withClass A (minimum of it a
contrasting color
M requested b. ..,
Shipping and
Receivirig
No
Failure to properly mark a poc loge h aired or incoîretctly marking a
package ,hen not required 4
A$ requested by
Shipping and
Receiving
No
Failure to apply Dar labels when required 01, eac:h package, placing a label that
represents a hazard other than the actua: ha,nrd prrient, or incorrectly labeling a
package when not required
4
As requestedb
Shipping and
Receiving
No
Type A or u pckit,14 must incorporate a tamper proofsetaì or similar 4
As requested by
Shipping and
Receiving
No
Note': Significance leiels and CAP request frequencies may
adjusted as necessary as determined by Energ y solutjons management
(e.g. fornegative trends, etc.)
Page 3 of 3
Non-Proprietary Page 11 of 12
CL-AD-PR-040
Classification and Administrative Revision 6
Control of Discrepant Incoming
Shipments
DOCUMENT SUMMARY FORM
Please provide the following information for new/revised documents.
Forward the completed forrn, review comment forms, approved document,
and electronic file, to Document Control.
Document No.: CL-AD-PR-040 Revision No.: 6
Title: Classification and Administrative Control of Discrepant Incoming Shipments
Special Status (i.e. Restricted; SSI; etc.): None
If special status is applicable, please note any special distribution/handling requirements:
Summary of changes (if this is a revision):.
Minor administrative changes to include update of job titles
Revised procedure to maintain consistency that CRSDs may be closed upon RECEIPT of a CAP rather than
receipt and approval.
Yes
No
n Yes
No
xl This document requires evaluation per the requirements of a license. If yes, attach evaluation
results.
This document requires regulatory agency approval before implementation. If yes, contact
Document Control.

Type of revision: n Contains technical changes n Contains only administrative changes
Distribution (or changes to distribution) for controlled copies of this document.
Non-Proprietary Page 12 of 12
ES CP - Waste Profile Page 1 of 37
Profile Information
Generator DOE, Idaho National Laboratory/AMWTP

Waste Location (City, State) nscoviw ID

Waste Profile ID 9.105.0.1

ES Facility 'Clive, UT
: CWF
Revision Date 11/14/2015

Waste Stream Name vTD Liquids mixed Waste Debas
Revision 8

Approval Date 11/7/2016
EPA ID
Status
Is ResinSolutions?
Is Navy?
r- - Select one —
Approved
0

Help Profile has been approved.
For Internal Use 0

Renewal Í -None
(5 9. ( •
64.0toGv
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
Waste Form
Secondary Treat Type
Waste Kind
Waste Type i MW TREATMENT

Primary Treat Type vm

Disposal Cell Location Mixed Waste Embankmen
Approve Full Class A for
this Waste Stream
ES CP - Waste Profile Page 2 of 37
TS Review
TS Approval:
Profile approved?
0 Yes 0 No
Comments:
10/19/17 TS Edit to rewrite section of narrative that discusses unpunctured aerosol cans. As written, we will retum unpunctured cans to the generator; revised to indicate
that we can puncture at Clive and we require notification of unpunctured cans prior to shipment receipt. JG
11-04-16 Added Letter of Update for Annual review VP
07-14-16 added code to match hard copy VP
5/26/16 TS Edit to attach contract transfer letter. JG
9/23/15 Profile approved. JG
9/23/15 Re-released to Tim to address comments. JG
9/17/15 Add U133 hydrazine, Revision 8. JG — •
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
Page 9 of 37 ES CP - Waste Profile
9105-01
RSO Review
General Information:
<1% Free Liquid
-DRC Non-Aqueous Liquid Approval letter dated 9/26/07 under former WS ID 9048-03
g Require Special Handling label on containers?
Requirements for Waste Management:
Waste Contains Resins:
0 Yes o No
Waste Contains LC 29 Soluble Isotopes:
0 Yes @No
, A Specific Radiation Work Permit is Required for this Waste Stream:
0 Yes C) No
Utah Division of Radiation Control approval has been granted for receipt of non-aqueous liquid:
@Yes 0 No 0 N/A
Please indicate which (if any) of the following Waste Management processes are required:
0 Soil Lift Disposal 0 DU Management
0 MW Macro MW Sort/Seg
0 CLSM Disposal 0 Large Component Disposal
S&R evaluate each manifest for any or all of the following:
g Class A M Radiological
0 SNM Exemption 0 Compact Export Authorized
0 Sharps
SNM Exemption Certification Review
0 Not Applicable
0 Reviewed and Approved with the Previous Revision
@ Reviewed and Approved with Current Revision. Energysolutions has a written copy of all information required by License.
g 13.F.1 Waste Description including uranium chemical composition
, g 13.F.2 Waste Characterization
g 13.F.3 Uniformity Description including spatial distribution information
13.F.4 Manifest Concentration
Review Summary:
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP - Waste Profile Page 10 of 37
9105-01
Profile approved: Yes
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
11/7/2016 11:37:35 AM EST
11/4/2016 5:13:37 PM EST
8/24/2016 3:04:55 PM EST
8/24/2016 3:00:26 PM EST
CSV Show rilin entries
ES CP - Waste Profile Page 36 of 37
9105-01
Showing 1 to 10 of 28 entries . . _
User Name User Email Status Button Action
Jeffrey Ginsburg JFGINSBURG©energysolutions.com Under Revision Restore Button Clicked
Matthew Vargesko [e-mail] , Approved Revise Button Clicked
Matthew Vargesko [e-mail] Approved Revise Profile Revision Started
Jeffrey Ginsburg JFGINSBURG©energysolutions.com TS Review Approve Button Clicked
Jeffrey Ginsburg JFGINSBURG©energysolutions.com Save Update
Jeffrey Ginsburg JFGINSBURG©energysolutions.com Approved TS Edit Button Clicked
Jeffrey Ginsburg JFGINSBURG©energysolufions.com TS Review Approve Button Clicked ^ p
Veronica Pitts [e-mail] Approved : TS Edit Button Clicked
Bret Rogers [e-mail] TS Review Approve Button Clicked µ .
Bret Rogers brogersepenergysolutions.com Approved TS Edit Button Clicked
Previous 1 2 3 Next
Transaction History
Search: I
Date/Time
11/2/2017 12:26:25 PM EST
10/24/2017 10:32:21 AM EST
10/24/2017 10:32:21 AM EST
10/19/2017 5:47:59 PM EST
10/19/2017 5:42:58 PM EST
10/19/2017 5:39:04 PM EST
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP - Waste Profile Page 1 of 37
Profile Information
Generator DOE, Idaho National Laboratory/AMWTP Waste Location (City, State) Scoville, ID
Waste Profile ID
ES Facility
r9-105-01
Clive, UT
CWF
Waste Stream Name VTD Liquids /Med Waste Debds
Revision 8
Revision Date 11/14/2015 Approval Date 11/7/2016
EPA ID I -- Select one --
Status Approved Help Profile has been approved.

Is ResinSolutions? For Internal Use

Is Navy? Renewal None
kkttc( Se-icr)( 'cgs
?Irt)(k-12-
(2--k--11(etti
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
MW TREATMENT
VTD
Waste Form í solid
Secondary Treat Type
Waste Kind v-rD
ES CP - Waste Profile Page 2 of 37
TS Review
Waste Type
Primary Treat Type
Disposal Cell Location
Approve Full Class A for
this Waste Stream
TS Approval:
Profile approved?
Yes 0 No
, Mixed Waste Embankment
Comments:
10/19/17 TS Edit to rewrite section of narrative that discusses unpunctured aerosol cans. As written, we will retum unpunctured cans to the generator; revised to indicate
; that we can puncture at Clive and we require notification of unpunctured cans prior to shipment receipt. JG
11-04-16 Added Letter of Update for Annual review VP
07-14-16 added code to match hard copy VP
5/26/16 TS Edit to attach contract transfer letter. JG
9/23/15 Profile approved. JG
9/23/15 Re-released to Tim to address comments. JG
9/17/2 5 Add U133 hydrazine, Revision 8. JG
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP - Waste Profile
9105-01
Page 8 of 37
OPS Review
General Information
0 Require Special Handling label on containers?
Requirements for Waste Management
Requirements for Waste Management: Sort and Seg. Macro debris, VTD non debris. Lead acid batteries may require draining and stabilization treatment.
Special handling Notes: Lead acid batteries.
Mixed Waste Treatment And Liquid Solidificafion Approval:
LJ Stabilzation
0 MACRO
VTD
Liquid Solidification
El Amalgamation
El MICRO
El Spray Wash
El Other
„
Has the Treatment formula been established for the Waste Stream? If No, then approval from VP of Compliance is required.
! 0 Yes 0 No NIA
Review Summary:
Profile approved: Yes
Comments:
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ES CP - Waste Profile Page 36 of 37
9105-01
Transaction History
1 to 10 of 28 entries Search: Showing
DatelTime User Name User Email Status Button Action
11/2/2017 12:26:25 PM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com Under Revision Restore Button Clicked
10/24/2017 10:32:21 AM EST Matthew Vargesko [e-mail] Approved Revise Button Clicked
10/24/2017 10:32:21 AM EST Matthew Vargesko [e-mail] Approved Revise Profile Revision Started
10/19/2017 5:47:59 PM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com TS Review Approve Button Clicked
10/19/2017 5:42:58 PM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com Save Update Y4
10/19/2017 5:39:04 PM EST Jeffrey Ginsburg JFGINSBURG©energysolufions.com - Approved : TS Edit Button Clicked
11/7/2016 11:37:35 AM EST Jeffrey Ginsburg JFGINSBURG©energysolufions.com TS Review Approve Button Clicked
11/4/2016 5:13:37 PM EST Veronica Pitts [e-mail] Approved TS Edit Button Clicked
8/24/2016 3:04:55 PM EST Bret Rogers [e-mail] TS Review Approve Button Clicked
8/24/2016 3:00:26 PM EST Bret Rogers brogersegenergysolutions.com Approved TS Edit Button Clicked
Copy CSV Showl10 Lel entries Previous 1 2 3 Next
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP - Waste Profile Page 1 of 37
, Profile Information
Generator DOE, Idaho National Laboratory/AMWTP
Waste Profile ID 9105-01
ES Facility , Clive, UT
LJ CWF

Waste Location (City, State) Scoville, ID

Waste Stream Name VTD Liquids / Mixed Waste Debris
Revision 8
Revision Date 11/14/2015 Approval Date 11/7/2016
EPA ID — Select one --
Approved
LJ

El

Status
Is ResinSolutions?
Is Navy?

Help Profile has been approved.
For Internal Use 1:1
Renewal None
„sr
3/0° Jc4litsNi
rpc
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
Waste Form
Secondary Treat Type
Waste Kind 1 vm
Waste Type' MW TREATMENT
Primary Treat Type r \Tip
Disposal Cell Location ;Mixed Waste Embankmen
Approve Full Class A for
this Waste Stream
ES CP - Waste Profile Page 2 of 37
TS Review
TS Approval:
Profile approved?
Yes 0 No
Comments:
10/19/17 TS Edit to rewrite section of narrative that discusses unpunctured aerosol cans. As written, we will return unpunctured cans to the generator; revised to indicate
that we can puncture at Clive and we require notification of unpunctured cans prior to shipment receipt. JG
11-04-16 Added Letter of Update for Annual review VP
07-14-16 added code to match hard copy VP
5/26/16 TS Edit to attach contract transfer letter. JG
9/23/15 Profile approved. JG
9/23/15 Re-released to Tim to address comments. JG
9/17/15 Add U133 hydrazine, Revision 8. JG
https://customerportal.energysolutions.com/Profile/Profile?ProfileIc1=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP - Waste Profile Page 6 of 37 9105-01
; IH Review
Does this waste have any known incompatibilities?
Yes @No
Known Incompatibilities:
Does this waste contain the following hazards?
o Beryllium > 0.2 ug/100cm2 or > 1000 mg/kg RI Friable Asbestos
0 Reactive Olndustrial
Ed Chemical El Respiratory
0 Skin Hazard 0 Other
Personal Monitoring Requirements: FM—a; require asbestos or VOC sampling
Additional PPE Requirements:
none
Ed Require Special Handling label on containers?
Special Handling Instructions:
handle post VTD waste as asbestos containing materials
Review Summary:
Profile approved: Yes
Comments:
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
Transaction History
ES CP - Waste Profile Page 36 of 37
91 05-01
Search: I
Date/Time
Showing 1 to 10 of 28 entries
User Name User Email Status Button Action
11/2/2017 12:26:25 PM EST Jeffrey Ginsburg [e-mail] ! Under Revision Restore Button Clicked
10/24/2017 10:32:21 AM EST Matthew Vargesko [e-mail] Approved Revise Button Clicked
10/24/2017 10:32:21 AM EST Matthew Vargesko [e-mail] Approved Revise Profile Revision Started
10/19/2017 5:47:59 PM EST Jeffrey Ginsburg [e-mail] v n TS Review Approve Button Clicked
10/19/2017 5:42:58 PM EST Jeffrey Ginsburg [e-mail] Save Update
10/19/2017 5:39:04 PM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com Approved TS Edit Button Clicked
11/7/2016 11:37:35 AM EST Jeffrey Ginsburg [e-mail] TS Review Approve Button Clicked
11/4/2016 5:13:37 PM EST Veronica Pitts [e-mail] Approved TS Edit Button Clicked
8/24/2016 3:04:55 PM EST Bret Rogers [e-mail] TS Review Approve Button Clicked
8/24/2016 3:00:26 PM EST Bret Rogers [e-mail] Approved TS Edit Button Clicked
Copy CSV Show 10 vl entries Previous 1 2 3 Next
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
Generator DOE, Idaho National Laboratory/AMWTP Waste Location (City, State) I Scoville, 10
Waste Stream Name VTD Liquids / Mixed Waste Debris
Revision 8
Waste Profile ID 9105-01
ES Facility Clive, UT
ES CP - Waste Profile Page 1 of 37
Profile Information
0 cvvF
Revision Date 11/14/2015
EPA ID — Select one --
Status Approved
Is ResinSolutions? EJ
Is Navy? 10
Approval Date 11/7/2016
Help Profile has been approved.
For Internal Use 0
I Renewal None
6t)uvs-QA
ero 1 e
cD6 c
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
TS Review
Waste Type
Primary Treat Type
Disposal Cell Location
Approve Full Class A for
this Waste Stream
1

Waste Form Solid .„_

Secondary Treat Type MACRO

Waste Kind ki-rD
ES CP - Waste Profile Page 2 of 37
TS Approval:
Profile approved?
0 Yes 0 No
Comments:
10/19/17 TS Edit to rewrite section of narrative that discusses unpunctured aerosol cans. As written, we will return unpunctured cans to the generator; revised to indicate
that we can puncture at Clive and we require notification of unpunctured cans prior to shipment receipt. JG
11-04-16 Added Letter of Update for Annual review VP
07-14-16 added code to match hard copy VP
5/26/16 TS Edit to attach contract transfer letter. JG
9/23/15 Profile approved. JG
9/23/15 Re-released to Tim to address comments. JG
9/17/15 Add U133 hydrazine, Revision 8. JG —
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
. _
Analysis Waived Analysis Date Laboratory Certification Commands
No records found.
Justification if analyses are waived: I r
Additional Requirements for Deferred Chemical Analysis:
Sampling Frequency: r- -- Select one --
ES CP - Waste Profile Page 3 of 37
9105-01
EE Review
Specifics
Non RCRA RCRA
EE NonRCRA Review

Is this a Mixed Waste Treatment Residue with Former Codes?
0 Yes 0 No

Former Waste Codes:

Can the Lab Results section be waived?
0 Yes 0 No
Were analytical results provided in a previous profile revision?
0 Yes 0 No
Lab Results
EE RCRA Review
Can the Laboratory Results section below may be waived? If Yes, the profile must describe the physical properties of the waste justifying waiver of the non-radiological
analyses.
0 Yes @ No
https://customerportal.energysolutions.com/Profile/Profile?ProfileId=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
Metals
Certification Laboratory Waived Analysis Date
Lab Results
Analysis
pH Yes
Paint Filter Liquids Yes
Volatile Organics
Semi-Volatile Orgar No
NA NA
September, 2014 > GEL Utah
September, 2014 GEL Utah
Commands
Justification if analyses are waived:
PFLT - Visual (+ liquids at up to 2%).
Data from HSWA analysis of Shipments -0081.
Disposal/Analytical Information
Additional Analytical for HWSA
0 Full UTS
2 Pesticides
First Other HSWA Analytical
0 F039
0 PCBs
0 Second Other HSWA Analytical
0 Herbicides
0 Third Other HSWA Analytical
September, 2014
ES CP - Waste Profile Page 4 of 37
,91 05-01
Are analytical results provided in a previous profile revision?
Yes 0 No
Lab Data Source
If the Lab Data is from prior discussions with EnergySolutions, then this data may only be used if one or more of the following conditions apply:
0 N/A
0 Results of quality control samples from the same run (set of samples) in which the sample was run
0 Results must include acceptable ranges and must clearly show that the data was in control 0 Quality control samples shall include all those required by SW-846 or other methods approved by the EPA.
Waste Treatment Standards
Are all treatment standards listed in the Radioactive Waste Profile Record?
@ Yes 0 No
Does the waste meet all applicable treatment standards?
yes @ No
Is the waste a residue of treatment? If yes, HSWA sampling is required every 6 months
Yes No
https://customerportal.energysolutions.com/Profile/Profile?ProfileIc1=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP - Waste Profile Page 5 of 37
9105-01
General Information:
I—Revision 8 Adds U133.
Primarily debris with small volumes (up to 2%) of aqueous and non-aqueous liquids. The waste is the same as 9048-03. A non-aqueous' liquid approval for 9048-03 was given by
the DRC in a letter dated September 26, 2007. Friable asbestos, if present, will be packaged and labeled in accordance with regulations. The generator has performed RTR on all
containers and will provide descriptions of each container prior to each shipment. Some pressurized aerosol cans may be present. Undrained lead-acid batteries may also be
present
0 Require Special Handling label on containers?
0 Risk Assessment Required?
Requirements for Waste Management:
Sort and seg. MACRO debris. For non-debris, determine treatment path (VTD, stabilization, etc.) based on knowledge of the waste and analytical data. Aerosol cans found should
be examined for pressure and set aside for aerosol can treatment as needed. Lead-acid batteries will require draining into absorbent, and the absorbed liquid sampled and
analyzed for metals.
Review Summary:
Profile approved: Yes
Comments:
09/22/2015: The total percentage is only 98%. Need to add 2% of something else (liquids?)
In the first paragraph of the narrative, change the former waste stream from 9105-01 to 9048-03 (twice).
I don't think D003 was in the waste previously. Remove this from the hazardous codes list.
Please add analytical data from a HSWA analysis (attached in email).
09/23/2015: Comments Resolved. Profile Approved. One other small comment - please add U133 to the code listing in the narrative.

https://customerportal.energysolutions.com/Profile/Profile?ProfileIc1=49b483aa-df50-4931-9330-78e2fc52cd0b 12/13/2017
ES CP -yaste Profile Page 36 of 37
9105-01
Transaction History
Showing 1 to 10 of 28 entries
User Name User Email Status Button Action
Search:
Date/Time
11/2/2017 12:26:25 PM EST Jeffrey Ginsburg JFGINSBURGeenergysolutions.com Under Revision Restore Button Clicked
10/24/2017 10:32:21 AM EST Matthew Vargesko matthew.vargeskogicp.doe.gov Approved Revise Button Clicked
10/24/2017 10:32:21 AM EST Matthew Vargesko [e-mail] Approved Revise Profile Revision Started
10/19/2017 5:47:59 PM EST Jeffrey Ginsburg JFGINSBURG©energysolufions.com TS Review Approve Button Clicked _ .
10/19/2017 5:42:58 PM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com Save Update
10/19/2017 5:39:04 PM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com Approved TS Edit Button Clicked . =
11/7/2016 11:37:35 AM EST Jeffrey Ginsburg JFGINSBURG©energysolutions.com TS Review Approve Button Clicked
11/4/2016 5:13:37 PM EST Veronica Pitts vpittsrgenergysolutions.com Approved TS Edit Button Clicked
8/24/2016 3:04:55 PM EST Bret Rogers brogers©energysolutions.com TS Review Approve Button Clicked
8/24/2016 3:00:26 PM EST Bret Rogers brogers©energysolutions.com Approved TS Edit Button Clicked
Copy CSV Show Frj entries Previous 1 2 3 Next
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