DRC-2018-005863 - 0901a068808496c2

ENERGYSOLUTIONS
Div e Waste Management and Radiation Control
JUN 1 it 2018

D -RC - Z 0 lei - 005863
June 14, 2018 CD18-0109
Mr. Scott T. Anderson
Director
Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, UT 84114-4880
Subject: Radioactive Material License No. UT 2300249, Condition 16.F.i.
Non-aqueous Liquid Waste Stream 9088-24
Dear Mr. Anderson,
In accordance with License Condition 16.F.i, EnergySolutions hereby requests approval
from the Division of Waste Management and Radiation Control to receive non-aqueous
liquids within Waste Stream 9088-24.
Waste Stream 9088-24 consists of various non-hazardous solid and liquid (both aqueous
and non-aqueous) substances for disposal at the LLRW Facility. Free liquids (both
aqueous and non-aqueous) within the waste stream will be solidified at the Mixed Waste
Facility and the resulting solid residue disposed at the LLRW Facility using the LLRW-
Destined Permit requirements.
The profile for Waste Stream 9088-24 is attached. Additionally, an evaluation of
potentially harmful gases vapors or fumes associated with the waste is included.
Should there be any questions regarding this request, please contact me at (801) 649-
2144.
Sincerely,
Timotlîý L. Orton, P.E.
Environmental Engineer and Manager
Enclosures
cc: Don Verbica, DWMRC
Kevin Carney, DWMRC
Otis Willoughby, DWMRC
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
Attachment 1
Waste Profile
ENERGYSOLUTIONS 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 completing this form.
Please indicate "N/A" if a category does not apply
1. GENERATOR INFORMATION
Generator Name: CH2MHill*B&W West Valley LLC/West Valley, NY EPA ID: NYD980779540
Name of Person Complete Fonn: Jeff Choroser
Phone:[phone] Email: [e-mail]
Location of Waste (City, State): West Valley, NY
2. WASTE STREAM INFORMATION
Waste Stream ID: 9088-24 Waste Stream Name: LLRW Chemicals
Revision: 0 Date: 4/20/2018 5.750E2
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 El If NO, complete and attach the "Low-Level Radioactive Waste Certification Attachment".
Y El 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 lE N El
Is the waste to be treated by Energysolutions? Y N CI
LOW-LEVEL RADIOACTIVE WASTE: Is the radioactive waste defmed as Low-Level Radioactive Waste in accordance with the Low-Level
Radioactive Waste Policy Amendments 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 apphcable. Compact export approval is not required for DOE-generated or 11e.(2) waste streams. Case by case export approval for mixed waste and NORM may be required based on generator's
goveming Compact requirements; contact EnergySolutions Technical Services staff for additional guidance.
N If NO, check appropriate box: NORM/NARM 0 Ile.(2) Byproduct Material El 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 D 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 El N IE If Yes, complete and attach the "PCB Waste Certification" form (EC-98279).
ASBESTOS: Does the waste contain Asbestos Containing Material?
Y D N 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.
List percentage of waste type by volume: Soil %
Other constituents and percentage by volume?
Concrete & n
Metal I % DAW 5 % Resins ° % Sludge 5 %
Other 8° % absorbed loads, aqueous hqu cf non-aqueous liquid. laboratory chernmals, manufacturers products
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 ND If Yes, what is the percent of free liquid by waste 75 %
If Yes, is the liquid aqueous (water-based)? Y 11 N IJ
Density range of the waste. 44 - 75
Does the waste contain absorbent? Y El N
2. MATERIAL SIZE
Gradation of Material: Indicate the percentage of waste material that would pass throuah the followmg 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" 85 % .4" 85 85 % .1/4" 75 % .1/40" 20 % 1/200" 20 %
Does the waste stream contain oversize debris (i.e., no dimension < 10 inches and any dimension > 12 feet)? Y 0 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. The waste material must
not exceed 3 percentage points above optimum moisture upon arnval at EnergySolutions' disposal facility unless approved by EnergySolutions.
Optimum Moisture Content: " % at Maximum Dry Density (1b/ft3): N/A
Average Moisture Content: N/A % Moisture Content Range: N/A % - N/A %
4. WASTE SHIPPING & PACKAGING
transportation Mode: El Highway D Rail
Shipping & Container Packages: Drums* 85 gallons) IE Boxes 100 ft3) CI Soft-Sided Bags (5 10 yd3)
(Check all that apply)
Intermodal Sealand El Gondola** D 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 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
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
Waste Stream ID: 9088-24 Revision: 0 Date of Revision: 4/20/2018
C. RADIOLOGICAL INFORMATION
Obtain sufficient samples to adequately determine a range and weighted average of activity in the waste. Attach the gamma
spectroscopy or radiochemistry data supporting the radionuclide information listed below.
1. Does the waste material contain accessible surfaces with contact dose rates greater than 500 mR/hr? YE NO
2. Please list the following information for each isotope associated with the waste. Provide an explanation in the narrative description
if the waste contains localized "hot spots" or elevated concentrations that significantly exceed the upper concentration range. If
additional space is needed, provide an attachment to this profile record formatted as below.
Isotope
AC-227
Manifested Upper
Concentration
(pCi/g)
1.000E0
Weighted Avg.
per Container
(pCi/g)
1.080E-1
Isotope
N1-63
Manifested Upper
Concentration
(pCi/g)
1.200E3
Weighted Avg.
per Container
(pCi/g)
7.500E2
AG-110M 5.000E1 3.000E1 NP-236 (S) 2.000E0 1.000E0
AM-241 2.800E3 2.000E3 NP-237 1.000E0 1.800E-1
AM-242M 1.000E1 6.450E0 PA-231 1.000E0 2.600E-1
AM-243 2.500E2 2.110E2 PB-212 1.200E3 1.000E3
B1-212 1.500E3 1.000E3 PD-107 1.700E3 1.500E3
C-14 5.000E2 3.090E2 PM-146 2.000E0 1.000E0
CD-113M 1.500E3 1.000E3 PM-147 1.000E3 7.400E2
CE-144 5.000E0 1.000E0 PU-236 1.000E0 1.980E-1
CM-242 1.000E1 6.200E0 PU-238 8.000E2 7.550E2
CM-243 1.500E2 1.000E2 PU-239 7.000E2 6.150E2
CM-244 1.000E0 9.500E-1 PU-240 5.000E2 4.710E2
CM-245 3.000E2 2.550E2 PU-241 1.700E4 1.550E4
CM-246 2.000E2 1.550E2 PU-242 1.000E1 6.450E0
CO-60 1.500E3 1.250E3 RA-226 2.000E2 1.650E2
CS-134 5.000E0 2.160E0 RA-228 3.000E2 2.620E2
CS-135 1.000E0 2.900E-1 RU-106 1.000E3 9.780E2
CS-137 1.200E3 5.000E2 SB-125 1.500E2 1.100E2
EU-152 1.000E2 8.300E1 SB-126 5.000E2 2.500E2
EU-154 2.500E2 2.110E2 SE-79 5.000E1 2.000E1
EU-155 1.000E1 9.900E0 SM-151 1.500E2 1.050E2
FE-55 5.000E2 3.840E2 SN-121M 1.000E0 1.000E-1
H-3 1.000E3 6.700E2 SN-126 1.000E1 7.550E0
1-129 1.000E2 7.350E1 SR-90 5.000E3 5.000E2
1-131 1.000E1 5.000E0 TC-99 1.000E3 8.250E2
K-40 5.000E2 3.690E2 TH-228 5.000E1 4.240E1
MN-54 5.000E0 2.310E0 TH-229 1.000E1 7.000E1
NB-93M 1.000E0 5.200E-1 TH-230 1.000E2 5.000E1
NB-94 5.000E0 2.500E0 TH-232 1.000E2 5.000E1
N1-59 4.000E2 3.150E2 U-232 2.000E1 1.190E1
ADDITIONAL RADIOLOGICAL INFORMATION ATTACHMENT
Isotope Manifested Upper Concentration Weighted Avg. per Container
U-233 1.000E2 pCi/g 9.700E1 pCi/g
U-234 5.000E1 pCi/g 3.420E1 pCi/g
U-235 3.500E1 pCi/g 3.130E1 pCi/g
U-236 5.000E0 pCi/g 2.020E0 pCi/g
U-238 5.000E1 pCi/g 4.220E1 pCi/g
ZN-65 1.000E0 pCi/g 4.930E-3 pCi/g
ZR-93 2.000E0 pCi/g 1.080E0 pCi/g
ZR-95 5.000E1 pCi/g 2.770E1 pCi/g
Physical Properties Narrative
The various non-hazardous wastes covered by this profile were generated through equipment
maintenance, waste management, and general clean-up activities at the West Valley Demonstration
Project (WVDP). The waste consists of fluids drained from equipment (e.g, oil, anti-freeze, hydraulic
fluid, aqueous process and decontamination fluids) in absorbed and non-absorbed forms, in addition
to excess laboratory chemicals and manufacturers' products. The wastes range from liquid, to semi-
solids, to solids. The laboratory chemicals and manufacturers' products are considered radioactive
through their introduction into radiologically controlled areas - in most cases they are contained in
their original manufacturer containers, while other wastes were rendered radioactive through their
use in contaminated facilities/systems. Radiological distributions have been developed for use in
dose rate-to-curie content calculations based on historical sampling and analysis of wastes
generated in the different WVDP areas, or through analysis of the specific wastes in this profile.
Chemical characterizations were conducted through process knowledge in the case of known
entities (e.g., laboratory chemicals), or via sampling and analysis for process wastes that
could contain hazardous constituents. Attached are copies of container records that provide waste
descriptions, radionuclide estimates, and chemical content information for each container of waste.
Absorbent materials have been added to some of the fluids to stabilize them for disposal - Aquadox
(a polymer superabsorbent) for aqueous wastes, and a clay-based absorbent when a non-aqueous
component was present. The amount of absorbent used varied based on the initial fluid volume - in
some cases up to - 20 lbs of Aquadox and/or 50 lbs of clay-based absorbent.
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
LOW-LEVEL RADIOACTIVE WASTE CERTIFICATION ATTACHMENT
This form is required only if the checkbox for Hazardous Waste on page one has been checked No. Otherwise, complete the Hazardous 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
.SW-846 Analytical Methods
PFLT: Fail Pass / Fail Method 9095 Not applicable for liquid radioactive waste sveams.
2. 40 CFR 261.24 Table 1 — Contaminants of Toxicity Characteristic
Metals: 'Methods 6010 & *7470
Arsenic ND
Barium 1.980E0
Cadmium ND
Chromium 5.000E-2
Lead ND
Selenium 7.700E-1
Silver ND
*Mercury ND
Organics, Pesticides/Herbicides: Methods 8081/*8151
Endrin ND Toxaphene ND Chlordane ND
Lindane ND
Methoxychlor ND
*2,4-D ND Heptachlor ND
*2,4,5-TP Silvex ND
.Organics, Semi-Volatile: Method 8270
o-Cresol ND Hexachlorobenzene ND Pentachlorophenol ND
Hexachlorobutadiene ND m-Cresol ND Pyridine ND

p-Cresol ND Hexachloroethane ND 2,4,5-Trichlorophenol ND

Total Cresol ND Nitrobenzene ND 2,4,6-Trichlorophenol ND
2,4-Dinitrotoluene ND
_Organics, Volatile: Method 8260
Benzene ND 1,4-Dichlorobenzene ND Methyl ethyl keytone ND
Carbon Tetrachloride ND 1,2-Dichloroethane ND Tetrachloroethylene ND
Chlorobenzene ND 1,1-Dich1oroethy1ene ND Trichloroethylene ND
Chloroform ND Vinyl Chloride ND
3. Was the waste at the point of generation a RCRA hazardous waste per 40 CFR 261? Y N EJ
If Yes, list former hazardous waste codes and former underlying hazardous constituents. List worst-case concentrations for each
hazardous constituent. If additional space is needed, provide an attachment to this profile record formatted as below. Attach the
most recent chemical analytical results demonstrating compliance with applicable treatment standards.
If No, indicate "NIA" in Section D.3 below.
Low-Level Radioactive Waste Certification Attachment
_,...,,,..,....r........
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
_Former EPA HW Codes or
D. 3. _Underlying Hazardous Constituents
None
Treatment Standard (mg/kg unless noted as mg/L TCLP or Technology Code)
Worst Case
_Concentration (mg/kg unless noted as mg/L TCLP)
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 formatted 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
0 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 form.
0 OTHER LABORATORY CERTIFICATION (Describe below)
6. .CERTIFICATION
I certify that sample results representative of the waste described in this profile were or shall be obtained using state- and EPA-
approved analytical methods. I also certify that where necessary representative samples were or shall be provided to
EnergySolutions and to qualified laboratories for the analytical results reported herein. I 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 form 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. I certify that
the waste does not contain any prohibited items listed in EnergySolutions' Radioactive Material License.
signature: Jeff Choroser Signature Key: cb0ee37b-bd21-471b-8dbe-51f953cedbe9 Date: 4/23/2018

Low-Level Radioactive Waste Certification Attachment
ENERGYSOLUTIOM
CL-WM-PR-001 F3 (EC-0230-SNM)
Revision 4
SPECIAL NUCLEAR MATERIAL EXEMPTION CERTIFICATION
The Special Nuclear Material Exemption Certification form must be completed and signed by each generator
certifying to the following conditions. Please attach this form and all required information to the Radioactive Waste
Profile Record (EC-0230). A completed and signed copy of this form must also accompany each waste
manifest.
Waste Stream ID: 9088-24 Manifest No.
1. Check applicable category below for the waste stream:
4
Uranium
Enrichment
Percent
Weight Percent
of Chemicals
in Condition 2c
Weight Percent of Materials in Condition 2d
U-235 Concentration (pCi/g)
Measurement Uncertainty* (pCi/g)
5 20 % 5 1 % 5 1,900 5. 285
Unlimited 5 20 % 5 1 % 5 1,190 5. 179
Unlimited Sum of both 5 45 % of waste by weight 5 680 5_ 102
Unlimited Unlimited Unlimited 5_ 26 5_ 10
Not Applicable - Enriched U-235 is not present in the waste.
* A concentration value is used for the maximum measurement uncertainty limit rather than a percentage value to
allow greater flexibility for generators with waste having very low SNM concentrations.
2. Certify to the following requirements by checking applicable boxes, A-E for solid waste or A-F if waste
includes liquid:
• a. Concentrations of SNM in individual waste containers do not exceed the applicable values listed in the above table and SNM isotope concentrations listed in Table 1. p b. The SNM is homogeneously distributed throughout the waste or the SNM concentrations in any contiguous mass of 600 kilograms (1,323 lbs) do not exceed on average the specified limits. (Based on process knowledge or testing).
• c. Except as allowed by Condition 1, the waste does not contain "pure forms" of chemicals containing carbon, fluorine, magnesium, or bismuth in bulk quantities (e.g., a pallet of drums, a B-25 box). By "pure forms," it is meant that mixtures of the above elements such as magnesium oxide, magnesium carbonate, magnesium fluoride, bismuth oxide, etc. do not contain other elements. (Based on process knowledge or testing).
▪ d. Except as allowed by Condition 1, the waste does not contain total quantities of beryllium, hydrogenous material enriched in deuterium, or graphite above one percent of the total weight of the waste. (Based on process knowledge, physical observations, or testing).
• e. Waste packages do not contain highly soluble forms of uranium greater than 350 grams of uranium-235 or 200 grams of uranium-233. If the waste contains mixtures of U-233 and U-235, the waste meets the sum of the fractions rule. Highly soluble forms of uranium include, but are not limited to:
uranium sulfate, uranyl acetate, uranyl chloride, uranyl formate, uranyl fluoride, uranyl nitrate, uranyl potassium carbonate, and uranyl sulfate. (Based on process knowledge or testing). 1-2Ti f. For containers of liquid waste with more than 600 kilograms of waste, the total activity (pCi) of SNM in the manifested container does not exceed the SNM concentration in the above table or Table 1 times 600 kilograms of waste (based on process knowledge or testing). For example, the maximum activity
of Pu-239 in any manifested container of liquid waste is 6.0 mCi (6.0E+09 pCi) as shown below:
10,000 x 600,000 g = 6.0X109 pCi = 6.0 mCi Pu - 239
,.------"----""--*
ENERGYSOLUTIONS
CL-WM-PR-001 F3 (EC-0230-SNM)
Revision 4
SPECIAL NUCLEAR MATERIAL EXEMPTION CERTIFICATION
Table 1. Maximum concentrations of SNM in individual waste containers (refer to above table for U-235 limits).
Radionuclide
Maximum
Concentration
(pCi/g)
Measurement
Uncertainty
(pCi/g) Radionuclide
Maximum
Concentration
(pCi/g)
Measurement
Uncertainty
(pCi/g)
U-233 75,000 11,250 Pu-241 350,000 50,000
Pu-236 500 75 Pu-242 10,000 1,500
Pu-238 10,000 1,500 Pu-243 500 75
Pu-239 10,000 1,500 Pu-244 500 75
Pu-240 10,000 1,500
3. Indicate that the following information is attached to the Radioactive Waste Profile Record by checking
each box. (Note: Only the two-page Special Nuclear Material Exemption Certification form needs to be
included with each manifest).
RI a. Provide a description of how the waste was generated, list the physical forms in the waste, and identify the uranium chemical composition.
g b. Provide a general description of how the waste was characterized (including the volumetric extent of the waste, and the number, location, type, and results of any analytical testing), the range of SNM concentrations, and the analytical results with error values used to develop the concentration ranges.
El c. Describe the process by which the waste was generated showing that the spatial distribution of SNM must be uniform, or other information supporting spatial distribution.
g d. Describe the methods to be used to determine the concentrations on the manifests. These methods could include direct measurement and the use of scaling factors. Describe the uncertainty associated with sampling and testing used to obtain the manifest concentrations.
4. Generator's certification of compliance with the SNM exemption: I certify that the information provided on
this form is complete, true, and correct and is based on process knowledge, physical observations, or approved
laboratory testing. I also certify that sampling and radiological testing of waste containing SNM was performed
in accordance with EnergySolutions' Radioactive Material License and that any supporting documentation and
analytical results have been submitted to EnergySolutions.
Jeff Choroser cb0ee37b-bd21-471b-8dbe-51f953cedbe9 4/23/2018
Signature Name Signature Key Date
SNM Attachment - 3.A
The wastes covered by this profile were generated through maintenance activities, waste
management, and general clean-up activities at the WVDP.
The waste consists of liquids, semi-solids, and solids in the form of aqueous and non-aqueous fluids
drained from equipment and/or contaminated facilities/systems, and laboratory chemicals and
manufacturers' products.
The WVDP site originally reprocessed spent nuclear fuel rods until 1972. Uranium and plutonium
were recovered from the fuel using the PUREX process. One campaign of thorium enriched fuel
was recovered in the THOREX process. The uranium and plutonium exist primarily as metal oxide.
SNM Attachment - 3.6
Container specific dimensions and configuration, weight, volume, and dose rates are entered into the
RADMAN program along with the appropriate sample data. The program then uses the data to
calculate the activity of the package and provides the required DOT shipping data and NRC
classification.
SNM concentrations are less than Table 1 concentrations in the SNM certification form.
Analytical data is presented on the profile form (data associated with waste profiles 9088-14 and
9088-16 has been supplied to ES for those profiles)
SNM Attachment - 3.0
The SNM concentration in any contiguous mass of 600 kg does not exceed the average specified
limits. The SNM is uniformly distributed.
SNM Attachment - 3.D
As stated above, container specific data is entered into RADMAN along with the associated sample
data. The program calculates the activity for each package and provides the DOT calculations and
NRC classifications.
Attachment 2
Non Aqueous Liquid Assessment
ENERGYSOLUTIONS
MEMORANDUM
Date: June 14, 2018
To: Vern Rogers
From: Tim Orton
Subject: Waste Stream 9088-24
Non Aqueous Liquid Assessment
The purpose of this memo is to evaluate Waste Stream 9088-24 for compliance with
Radioactive Material License conditions 16.B and 16.C. License conditions 16.B and
16.0 address the waste's potential to be explosive under normal conditions, explosively
reactive with water, or capable of generating toxic gases, vapors, or fumes during the
waste management process. As transporting, handling and disposal of the waste does not
occur under extreme conditions, the waste in question is analyzed assuming normal
environmental conditions (International Union of Pure and Applied Chemisty [IUPAC]
standard temperature and pressure) apply.
Waste Stream 9088-24 consists of various non-hazardous wastes combined for LLRW
disposal. The waste stream contains both absorbed and free-flowing aqueous and non-
aqueous liquids. Free-flowing aqueous and non-aqueous liquids will require solidification
at Mixed Waste prior to disposal at the Low Level Radioactive Waste Facility. The waste
will be managed in accordance with the LLRW-Destined waste Permit requirements.
An inspection of the waste documentation concludes that the non-aqueous liquids in this
profile primarily consist of used and hydraulic oils, non-hazardous scintillation fluid
(Opti-Fluor), and trichlorotrifluoroethane (in a pure product known as Genesolv-D).
Safety Data Sheets (SDSs) was reviewed for these non-aqueous liquid products and the
following information obtained.
Used Oil
The auto ignition temperature for used oil is 500 - 800 deg F dependent upon
the amount of volatile components present. The flash point is >350 deg F.
Although the flash point is high, it should not be transported next to open flame
sources, or subjected to excessively hot conditions. Should it ignite and a fire
start, dense, irritating smoke may be generated at the fire-site. Some of the
combustion products associated with a fire are carbon dioxide, carbon
monoxide, and oxides of sulfur and phosphorous. It will therefore be
important to ensure that transport occurs under normal environmental
conditions. The MSDS for used oil does not state any incompatibilities with
water and it is considered stable under standard conditions.
299 South Maine Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
,,,,......„
ENERGYSOLUTIONS
Hydraulic Oil
Several different hydraulic oil and dielectric fluid MSDSs were examined for
this review. These liquids generally consist of paraffin petroleum solvents,
phosphorous compounds (phosphates and phosphorodithioic acids), and zinc
salts. The auto ignition temperature for hydraulic oils ranges from 600 to 1100
deg F. The flash point ranges from 350 to 700 deg F (higher for fire resistant
high temperature hydraulic fluids). Similarly to used oil, this material should
not be transported next to open flame sources, or subjected to excessively hot
conditions under standard environmental conditions. Should it ignite and a fire
start, dense, irritating smoke may be generated at the fire-site. Some of the
combustion products associated with a fire are carbon dioxide, carbon
monoxide, and oxides of nitrogen, sulfur, and phosphorous.
Opti-Fluor
Opti-Fluor consists primarily of large chain organic compounds (linear dodecyl
benzene, sodium di-octylsulphosuccinate, ethoxylated alkylphenol, and tributyl
phosphate). Opti-Fluor has a flash point of 150 °C, a boiling point between
271 and 312 °C, and an auto-ignition temperature of 400 °C. The specific
gravity of Opti-Fluor is slightly less than water (0.90) and the material is
slightly soluble in water (solubility is 100 ppm or mg/L) and the product is not
reactive with water. The product is stable and the only incompatibility listed is
strong oxidizing reagents. If allowed to burn, decomposition products include
carbon monoxide and carbon dioxide (oxides of carbon).
Genesolv-D
Genesolv-D is the trade name for trichlorotrifluoroethane. Genesolv-D is not
very flammable with no flash point listed and an autoignition temperature of
770 °C. However, the boiling point of Genesolv-D is 46.7 °C and therefore the
waste should be kept out of direct sunlight during storage. Genesolv-D is much
heavier than water with a specific gravity of 1.57. The product also has a vapor
density of 6.5, so vapors generated will accumulate near the ground. Genesolv-
D is slightly soluble (100 ppm) and is not reactive with water. The product is
incompatible with fine metal flakes and powders and those should be avoided
at all times during management of this waste. Although difficult to burn, if it
does, decomposition products include halogens, halogen acids, and carbonyl
halides (e.g., phosgene).
299 South Maine Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS
All waste containers will remained closed during transport and storage and will only be
opened for management within controlled environments where incompatible material
(including ignition sources) will not be present. Based on the SDS information described
above, this waste stream is not capable of generating toxic gases, vapors or fumes in
quantities that are harmful to persons participating in the transporting, handling, or
disposing of this waste under standard temperatures and pressure. None of the waste is
considered water reactive, nor is it unstable or explosive under standard temperature and
pressure.
299 South Maine Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com