DRC-2024-007574

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
November 18, 2024 CD-2024-235
Mr. Doug Hansen
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 9720-36 Dear Mr. Hansen,

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 9720-36.
Waste Stream 9720-36 consists Mixed Low Level Waste (MLLW) liquids, sludges, and solids
for stabilization treatment. The non-aqueous oil waste consists of 1 drum of 10% oil, 90% water being added to the waste profile as Revision 7. The waste will be stabilized/solidified at the Mixed Waste Facility prior to disposal.
The profile for Waste Stream 9720-36 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 [phone].
Sincerely,
Steve D. Gurr
Environmental Engineer and Manager
enclosures
Digitally signed by Steve D.
Gurr
Date: 2024.11.18 11:18:27
-07'00'
Attachment 1
Waste Profile
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
Location of Waste (City, State):
Email:
2.WASTE STREAM INFORMATION
Waste Stream ID:
Revision:
Waste Stream Name:
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 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 N Is the waste to be treated by EnergySolutions? Y N
LOW-LEVEL RADIOACTIVE WASTE: Is the radioactive waste defined 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 applicable. 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 governing Compact requirements; contact EnergySolutions Technical Services staff for additional guidance.
N If NO, check appropriate box: NORM/NARM 11e.(2) Byproduct Material Other: U
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 N 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 N If Yes, complete and attach the “PCB Waste Certification” form (EC-98279).
ASBESTOS: Does the waste contain Asbestos Containing Material?
Y 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.
Date:
Phone:
Name of Person Complete Form:
Generator Name: EPA ID:
Volume:
Oak Ridge, TN
Michael Kane
865-803-7254 [e-mail]
9720-36 MLLW Liquids/Sludges/Solids for Stabilization/Chemical Oxidation
7 1/14/2024 1.000E3 ft^3
8
8
8
8
8
8
8
United Cleanup Oak Ridge LLC (UCOR)/OR TN TN1890090003
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 N If Yes, what is the percent of free liquid by waste %
N
Does the waste contain absorbent? Y N
If Yes, is the liquid aqueous (water-based)? Y
Density range of the waste:
List percentage of waste type by volume: Soil % Concrete & Metal % DAW % Resins % Sludge %
Other constituents and percentage by volume?
2.MATERIAL SIZE
Gradation of Material: Indicate the percentage of waste material that would pass through 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” %4” %1” %1/4" %1/40” % 1/200” %
Does the waste stream contain oversize debris (i.e., no dimension < 10 inches and any dimension > 12 feet)? Y 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 mustnot exceed 3 percentage points above optimum moisture upon arrival at EnergySolutions’ disposal facility unless approved by EnergySolutions.
Optimum Moisture Content: % at Maximum Dry Density (lb/ft3):
Average Moisture Content: % Moisture Content Range: % - %
4.WASTE SHIPPING & PACKAGING
2BTransportation Mode: Highway Rail
Shipping & Container Packages: Drums* (≤ 85 gallons) Boxes (≤ 100 ft3) Soft-Sided Bags (≤ 10 yd3) (Check all that apply)
Intermodal Sealand Gondola** 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. Thisattachment 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
Other %
8 80
8
8
40
60
100 100 100 100 80 80
8
N/A
8
8 8
1.1 g/cc1 g/cc
N/A
N/A N/A N/A
110-gal overpack
aqueous liquid -50%, oily liquid - 6%, Solid Residues (e.g., floor sweepings, epoxy coating) - 4%
CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
Waste Stream ID: Revision: Date of Revision:
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? Y N
2.Please list the following information for each isotope associated with the waste. Provide an explanation in the narrative descriptionif the waste contains localized “hot spots” or elevated concentrations that significantly exceed the upper concentration range. Ifadditional space is needed, provide an attachment to this profile record formatted as below.
Isotope Manifested Upper Concentration (pCi/g)
Weighted Avg. per Container (pCi/g) Isotope Manifested Upper Concentration (pCi/g)
Weighted Avg. per Container (pCi/g)
8
AC-228
AM-241
BE-7
CO-60
CS-137
H-3
K-40
NB-95
NP-237
PA-233
PA-234M
PB-212
PB-214
PU-238
PU-239
PU-240
RA-226
SR-89
SR-90
TC-99
TH-228
TH-230
TH-232
TH-234
TL-208
U (DEP)
U-232
U-233
U-234
U-235
1.700E1
6.000E2
1.500E1
6.000E2
6.000E2
3.000E0
6.000E2
5.000E0
6.000E2
7.000E0
2.000E4
6.000E2
7.000E0
1.000E3
1.000E3
1.000E3
1.500E1
6.000E2
6.000E2
1.500E4
6.000E2
6.000E2
6.000E2
1.650E4
6.000E0
5.000E3
2.600E0
1.000E3
2.500E3
7.000E2
5.000E0
1.500E1
5.500E0
2.000E0
5.000E0
1.500E0
3.000E0
1.000E0
7.000E-1
3.500E0
1.250E3
2.000E0
2.000E0
1.500E2
1.600E2
1.600E2
5.000E0
2.000E1
2.000E1
1.000E3
2.000E1
3.500E0
1.500E0
1.250E3
2.000E0
1.500E3
1.300E0
5.000E1
2.480E3
2.000E1
U-236
U-238
6.000E2
1.650E4
7.600E1
1.250E3
9720-36 7 1/14/2024

Beryllium, Chromiium, Nickel, Silver, and Thallium.
D004, D006, D008, D009 (low mercury subcategory), and D010; and UHCs are Antimony, Barium,
approximately 150 sample bottles of granular coal. Based upon PK, coal is RCRA hazardous for
Revision 3 of the profile submitted to add D009 to support shipment of 1 55-gal drum with
sludge) the aqueous liquids are considered non-wastewaters for UHC purposes.
liquids also has a D002 code. Due to the presence of elemental mercury and suspended solids (i.e.,
exceedances according to 40 CFR 268.48. Based upon field pH of 14, the mercury-contaminated
Hazardous Constituents (UHCs) of lead (4.44 mg/L) and nickel (11.4 mg/L) due to concentrations
Based on the sample results, the mercury-contaminated aqueous liquid also has Underlying
with a mercury concentration of 1130 mg/l in the aqueous liquid and visible elemental mercury.
radioactive elemental mercury subcategory to support shipment of a 55-gal drum of aqueous liquid
concentration of 5,550 mg/l (ppm), and (b) adds D009 high mercury subcategory waste and
barium is the only constitue of concern for LDR treatment, but the purge water has a high nitrate
shipment of a 55-gal drum overpacked into a 110-gal drum of groundwater well purge water where
Revision 4 of the profile includes the following changes: (a) adds F039 for barium to support
decontamination solution.
agent (i.e., citric acid); and (3) adds citric acid and hexalene glycol as additional constituents for the
decontamination/detergent solution, which is included on this profile because it contains a chelating
2023: (a) 1 55-gal drum of MLLW sodium hydroxide, and (b) 1 10-gal drum of LLW
laboratory analytical data/SDS for the following two waste streams anticipated for delivery in June
to reflect more material on average passing through the 1/40in and 1/200in screens; (c) adds
80%, with the range actually being 20% to 100% free liquids; (2) changes the graduation of material
Revision 5 of the profile includes the following changes: (a) increases the estimated free liquids to
wells to complete data gaps.
taken from the two drums as well as results from prior samples taken from the same associated
the attached laboratory analytical data. The laboratory analytical data includes results from samples
oxidation. Characterization is based upon process knowledge to identify constituents of concern and
contaminated with low-concentrations of organic compounds which are suitable for chemical
concern to support the shipment of 2 55-gal drums of wastewater from groundwater monitoring wells
Revision 6 of the profile adds EPA Code D043 and adds additional UHCs/F039 constituents of
changes the profile name to remove the word "Aqueous."
limits. The revision also adds a small amount of non-aqueous (oily) liquid to this profile and
codes and UHCs have been added because the detection limits are higher than the regulatory
D037, D038, and D042 and UHCs to support a shipment of 1 drum of 10% oil/90% water, where
Revision 7 of the profile adds EPA codes D023, D026, D027, D030, D032, D033, D034, D036,
Physical Properties Narrative
Revision 2 submitted to add D002 waste codes and trichlorophenol as UHC. Trichlorophenol
concentration labeled on bottle as 0.28 mg/L.
NARRATIVE DESCRIPTION AND HISTORY OF THE WASTE
A. Process that generated the waste:
This mixed low-level waste (MLLW) material may originate from any of the facilities at the
Department of Energy – Oak Ridge Reservation (DOE-ORR) including the East Tennessee
Technology Park (ETTP) (which is the former the K-25 Gaseous Diffusion Plant), Y-12 National
Security Complex, and the Oak Ridge National Laboratory (ORNL). The waste is generated as a
result of residuals from on-site waste treatment operations; RCRA closures; decontamination and
demolition (D&D) activities; and routine maintenance and operations, including chemical storage
area cleanouts (Rev. 2) (past and current) at these facilities; and is primarily generated as a result of
the cleanout of sumps, basins and similar structures. May also contain miscellaneous sample
quantities of material identified from the cleanout of laboratories and facilities.
B. Waste material physical composition and characteristics:
The waste consists of aqueous liquids, sludges, and solid residue (Rev. 1). A small amount of non-
aqueous liquid may be present greater than 1% in any single container (Rev. 7). Some of the sludge
may contain bio-mass such as decomposed leaves, algae, etc. The sludge may also contain small
quantities of debris (wood, metal, concrete). There may be a very small amount of oil (oily sheen)
present in some of the containers. Solid residues may include floor sweeping, epoxy coatings, and
other solid materials not meeting the definiition of hazardous waste debris (Rev. 1) including granular
coal (Rev. 3)
The waste materials are radioactively contaminated as a result of direct or residual contact with
various uranium isotopes, their daughter products and several other nuclides present on the DOE-
ORR.
The liquids and sludges will be packaged typically in 55-gal liquid-rated drums, but may also be in
30-gal liquid-rate drums or overpacked into 85-gal drums or 110-gal drums (Rev. 4). Some waste
may be small containers shipped in labpacks (Rev. 2)
The waste stream is radioactive and hazardous under the Resource Conservation and Recovery Act
(RCRA) and as such is classified as MLLW. It is not regulated by the Toxic Substances Control Act
(TSCA. There are land disposal restrictions / prohibitions associated with this waste stream. Post
waste generation controls include visual verification, periodic sampling (radioisotope, TSCA and
RCRA), and installation of tamper indicating devices, inventory control posted / restricted storage
areas and periodic inspections of containers and storage areas. Special waste streams, which are
not RCRA hazardous but require disposal in the MLLW landfill (e.g., wastes with chelating agents),
may be included in this profile (Rev. 5).
The waste does not include Transuranic (TRU) radioisotopes in concentration greater than 100 nCi/g
of the waste matrix. The waste does not contain sealed radioactive sources.
C. Radiological and chemical characterization method:
Characterization of the liquids,sludges and solid residues will be performed through a combination of
process knowledge, and sampling and analysis. Depending upon the specific waste stream,
samples may be taken prior to the waste being containerized or following containerization. Samples
will be analyzed for Toxic Characteristic Leaching Procedure (TCLP) metals, volatile and semi-
volatile organics, pesticides, herbicides, polychlorinated biphenyls (PCBs), and radionuclides, as
applicable based upon process knowledge. Sampling performed on each specific sub-waste stream
will determine the applicable codes under 40 CFR 261.21 – 261.24 and Underlying Hazadous
Constituents (UHCs). Sampling and analysis will also verify that the waste stream does not contain
PCBs requiring treatment and disposal under the provisions of 40 CFR 761.60.
Identification of data needs, intended data use and the inclusion of quality requirements is addressed
through the implementation of Environmental Protection Agency (EPA) guidance on the Data Quality
Objectives (DQO) process to ensure compliance with the Waste Acceptance Criteria (WAC) of the
receiving disposal facility. As applicable, EPA-SW846 methods are used for laboratory analysis.
Those analyses requiring laboratories with State of Utah certification are sent to such laboratories.
MLLW liquids may also be in the form of small containers of waste, such as samples and waste used
and un-used products and chemicals (Rev. 2)
PCB Statement
Analysis of the liquid and sludge will confirm that any concentration of PCBs in the waste is less than
49 ppm; and PCBs, if present, are not from a PCB source 50 ppm or greater.
Radiological characterization
Radiological characterization will be performed through laboratory analytical analysis from direct
sampling of the subpopulation of waste being shipped, based upon historical sampling, or process
knowledge (Rev. 2). The radiological characterization performed on the population will be based on
the number of random grab samples and composites required to meet EPA guidance.
D. Basis for determining manifested radionuclide concentrations
During more than forty years of operations on the DOE-ORR, various radioactive wastes have been
generated from the diffusion cascade, reactor research, manufacture and assembly of nuclear
weapons components, and chemical processing. The principal radionuclides that are commonly
recognized are the uranium isotopes (in oxide form) and their daughter products, transuranic (TRU)
radionuclides with moderate half-lives: Np-237, Pu-238, and Pu-239. In addition, fission and
activation products are common on the DOE-ORR. The presence of these radionuclides is
confirmed routinely through characterization efforts at the individual sites.
Laboratory analytical data associated with each subpopulation of liquids, sludges, and solid residues
will be used to determine manifested radionuclide concentrations. For populations with both liquid
and sludge phases, either a mass balance or the higher analytical result will be used for
characterization purposes. Characterization of solid residues may include use of radiological
surveys and scaling factors based upon process knowledge of radionuclide distribution for the
generating facilitiy or associated waste streams with laboratory analytical data (Rev. 1). In addition,
Rev. 1 of the profile increases the radionuclide limit for Tc-99.
The waste does not include pure forms of the chemicals likely to increase the reactivity of the matrix.
E. Description and amounts of absorbents
No absorbents will be added to this waste stream, except for the annular space between the inner
drum and outter overpack, if the container is overpacked. (Rev. 4).
F. Basis of hazardous waste determination
Process knowledge and sampling and analysis will verify that the liquids and sludges are RCRA
hazardous.
“F” Listed Codes
Process knowledge will confirm that the waste stream does not meet requirements for “F” listed
codes as applicable for wastes shipped under Revisions 0 to 3 of the profile. Rev. 4 of the profile
covers 1 drum of F039 listed purge water, which is listed for barium. Rev. 6 of the profile incldues 2
drums of wastewater that are RCRA hazardous for F039 (and D043).
“U” Listed Codes
Process knowledge will confirm that the waste stream does not meet requirements for “U” listed
codes.
“K” Listed Codes
Process knowledge will confirm that the waste stream does not meet requirements for “K” listed
codes.
“P” Listed Codes
Process knowledge will confirm that the waste stream does not meet requirements for “P” listed
codes.
Characteristic “D” Codes
Process knowledge and sampling and analysis will confirm the characteristic codes applicable under
40 CFR 261.21 – 261.24. The codes applicable to this waste stream are shown in Section D2 of the
waste profile. Rev. 1 of this profile adds D005 (Barium), D010 (Selenium) and D011 (Silver). Rev. 2
adds D002 (corrosivity). Revision 3 adds D009 (low mercury subcategory). Rev. 4 adds D009 high
mercury inorganic subcategory and radioactive elemental mercury subcategory for a 55-gal drum of
aqueous mercury-contaminated liquids. Rev. 6 of the profile incldues 2 drums of wastewater that
are RCRA hazardous for D043 (and F039). Revision 7 of the profile adds EPA codes D023, D026,
D027, D030, D032, D033, D034, D036, D037, D038, and D042 and UHCs to support a shipment of
1 drum of 10% oil/90% water, where codes and UHCs have been added because the detection limits
are higher than the regulatory limits.
Underlying Hazardous Constituents
UHCs applicable to this waste stream are shown in Section D3 of the waste profile. Rev. 4 adds
lead as UHC. Rev. 6 adds multiple UHCs/F039 constituents of concern. Rev. 7 adds multiple
UHCs because detection limits for 1 drums of 10% oil/90% water are higher than regulatory
limits.
G. Waste classification
The radioisotope content of each container will be evaluated to ensure that each meets the
requirements of 10 CFR 61.55 for Nuclear Regulatory Commission (NRC) Burial Class A. Activated
metals are not present in this waste. Characterization data will show that C-14, Tc-99, I-129,
transuranics, Pu-241, and Cm-242, if present, are at concentrations at or below 0.1% of the Table 1
values. For radionuclides in Table 2, activated metal are not present in this waste. Characterization
data will show that Ni-63 and radionuclides with half-lives less than 5 years, if present, are at
concentrations less than 0.1% of Table 2, Column 1 values. Concentrations of H-3, Co-60, Sr-90,
and Cs-137 will be compared against the values of Table 2, Column 1 for each container of waste.
This comparison is made through a spreadsheet calculation which is part of the backup information
for each shipment.
H. Special Nuclear Material
The liquids and sludges to be shipped under this waste profile will typically be homogenous.
However, some containers may have both liquids and sludges in which case mass balance
calculations will be performed to determine total Special Nuclear Material (SNM) present or
conservative assumptions will be used in calculations from analytical results to total SNM quantities.
The chemical form of uranium will be U3O8, UO2F2 or other non-soluble forms of uranium oxide.
Other chemical forms may exist in trace quantities.
Depending upon results of characterization for each subpopulation of this waste stream, there will be
a range of uranium concentrations and U-235 enrichment. However, most packages contain less
than 15 g U-235. Uranium-235 enrichment typically ranges from <0.5% to 20%, with samples
containing lower concentrations of uranium typically showing higher enrichment due to more
laboratory uncertainty at the low uranium concentrations. Therefore, each package is specifically
evaluated to determine which SNM Exemption condition is applicable.
The control and tracking of SNM is conducted in accordance with United Cleanup Oak Ridge, LLC
(UCOR) (Rev. 6) procedure PROC-SE-1360, Nuclear Materials Transactions, which implements the
requirements of DOE Order 474.1A, Control and Accountability of Nuclear Materials. Shipments are
released only after a Nuclear Material Transaction Report (DOE/NRC-741) is issued by UCOR.
I. Neutron Moderators
Beryllium or other highly effective neutron moderators may be present in negligible concentrations.
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
SW-846 Analytical Methods
3B
pH (Liquid only): Method 9045 Please provide the range of the pH analyses performed.
PFLT: 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? Y N If Yes, color: ; odor:
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 treatmentand indicate “Former” in the second column. Worst-case concentrations only need to be provided for concentration basedtreatment standards. If additional space is needed, provide an attachment to this profile record formatted as below. Include adescription of hazardous waste determinations and any variances, exclusions, etc. in the Waste Profile narrative.
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)
Hazardous Waste Certification Attachment
<2 to >12.5
8
D002 Not Specified N/A
D004 Not Specified 1.120E1 mg/LTCLP
D005 Not Specified 5.000E2 mg/LTCLP
D006 Not Specified 1.300E0 mg/LTCLP
D007 Not Specified 7.590E1 mg/LTCLP
D008 Not Specified 1.300E2 mg/LTCLP
D009 HIGH HG > 260 PPM 1.130E3 mg/kg
D009 ELEMENTAL N/A
D009 LOW HG < 260 PPM mg/kg
D010 Not Specified 1.000E1 mg/LTCLP
D011 Not Specified 5.000E1 mg/LTCLP
D023 Not Specified 2.880E2 mg/kg
D026 Not Specified 2.880E2 mg/kg
D027 Not Specified 2.880E2 mg/kg
D030 Not Specified 2.880E2 mg/kg
D032 Not Specified 2.880E2 mg/kg
D033 Not Specified 2.880E2 mg/kg
ADDITIONAL HAZARDOUS WASTE CODES AND TREATMENT STANDARDS
ATTACHMENT
EPA HW Codes Description,Constituent of Concern,
or Subcategory Treatment Standard Worst-Case Concentration
D034 Not Specified 2.880E2 mg/kg
D035 Not Specified mg/kg
D036 Not Specified 2.880E2 mg/kg
D037 Not Specified 2.880E2 mg/kg
D042 Not Specified 2.880E2 mg/kg
D043 Not Specified 9.000E-1 mg/kg
F039 BENZENE 2.000E-1 mg/kg
F039 1, 1-DICHLOROETHANE 2.000E-1 mg/kg
F039 1, 1-DICHLOROETHYLENE 9.000E-2 mg/kg
F039 METHYL ISOBUTYL KETONE 2.000E-1 mg/kg
F039 ACETONE 3.000E-1 mg/kg
F039 CHLOROETHANE 6.000E0 mg/kg
F039 CYCLOHEXANONE 4.000E-1 mg/kg
F039 METHANOL 6.000E0 mg/kg
F039 METHYLENE CHLORIDE 1.000E-1 mg/kg
F039 TETRACHLOROETHYLENE 8.000E-1 mg/kg
F039 TOLUENE 2.000E-1 mg/kg
F039 VINYL CHLORIDE 9.000E-1 mg/kg
F039 BARIUM 5.000E1 ppm
CL-WM-PR-001 F2 (EC-0230)
Revision 9
3.UNDERLYING HAZARDOUS CONSTITUENTS (40 CFR 268.48)
List all underlying hazardous constituents (UHCs) and treatment standards. Include UHCs that have been removed throughtreatment. Worst-case concentrations only need to be provided for concentration based treatment standards. If additionalspace is needed, provide an attachment to this profile record formatted as below.
Underlying Hazardous
Constituents Treatment Standard (mg/kg unless noted as mg/L TCLP or Technology Code) Worst-Case Concentration (mg/kg unless noted as mg/L TCLP)
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 formatted as below.
Other
Chemical
Constituents
Worst Case
Concentration (mg/kg unless noted as mg/L TCLP)
Other
Hazardous
Constituents
Worst-Case
Concentration (mg/kg unless noted as mg/L TCLP)B
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 form.
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 toEnergySolutions and to qualified laboratories for the analytical results reported herein. I further certify that the waste described inthis record is not prohibited from land disposal in 40 CFR 268 (unless prior arrangements are made for treatment atEnergySolutions) and that all applicable treatment standards are clearly indicated on this form. I also certify that the informationprovided on this form is complete, true, and correct and is accurately supported and documented by any laboratory testing asrequired by EnergySolutions. I certify that the results of any said testing have been submitted to EnergySolutions. I certify thatthe waste does not contain any prohibited items listed in EnergySolutions’ Radioactive Material License or RCRA Permit.
Signature: Signature Key: Date:
Hazardous Waste Certification Attachment
8
1, 2, 4-TRICHLOROBENZENE mg/kg
1,2,3,4,6,7,8,9- OCTACHLORODIBENZO-P-DIOXIN (OCD mg/kg
1,2-DICHLOROBENZENE mg/kg
1,4-DICHLOROBENZENE mg/kg
2, 3, 4, 6-TETRACHLOROPHENOL mg/kg
2, 4, 5-TRICHLOROPHENOL N/A
2, 4, 6-TRICHLOROPHENOL mg/kg
2, 4-DICHLOROPHENOL mg/kg
2, 4-DINITROPHENOL mg/kg
Nitrate ppm
Citric Acid N/A
Hexalene glycol N/A
Michael Kane 03e3b4c5-7314-468a-b1ae-0d3f27e5a54c 11/15/2024
ADDITIONAL UNDERLYING HAZARDOUS CONSTITUENTS ATTACHMENT
Underlying Hazardous Constituents Treatment Standard Worst-Case Concentration
2, 6-DINITROTOLUENE mg/kg
2,4-DIMETHYL PHENOL mg/kg
2-CHLORONAPHTHALENE mg/kg
2-CHLOROPHENOL mg/kg
3,3-DICHLOROBENZIDINE mg/kg
4, 6-DINITRO-O-CRESOL mg/kg
4-BROMOPHENYL PHENYL ETHER mg/kg
4-CHLORO-3-METHYL PHENOL mg/kg
ACENAPHTHENE mg/kg
ACENAPHTHYLENE mg/kg
ALPHA-BHC mg/kg
ANILINE mg/kg
ANTHRACENE mg/kg
ANTIMONY mg/kg
BARIUM mg/kg
BEMZ(A)ANTHRACENE mg/kg
BENZO (A) PYRENE mg/kg
BENZO (B) FLUORANTHENE mg/kg
BENZO(GHI)PERYLENE mg/kg
BENZO(K)FLUORANTHENE mg/kg
BERYLLIUM mg/kg
BIS (2-CHLOROETHYL) ETHER mg/kg
BIS(2)CHLOROETHOXY)METHANE mg/kg
BIS(2-CHLOROISOPROPYL)ETHER mg/kg
BIS-(2-ETHYLHEXYL)PHTHALATE mg/kg
BUTYL BENZYL PHTHALATE mg/kg
CHLOROACETALDEHYDE mg/kg
CHROMIUM mg/kg
CHRYSENE mg/kg
DI-N-BUTYL PHTHALATE mg/kg
DI-N-OCTYL PHTALATE mg/kg
DI-N-PROPYLNITROSAMINE mg/kg
DIBENZ (A, H) ANTHRACENE mg/kg
DIETHYL PHALATE mg/kg
DIMETHYL PHTHALATE mg/kg
DIPHENYLAMINE mg/kg
FLUORANTHENE mg/kg
FLUORENE mg/kg
HEXACHLOROCYCLOPENTADIENE mg/kg
INDENO (1,2,3-C,D) PYRENE mg/kg
LEAD mg/kg
M-DICHLOROBENZENE mg/kg
MERCURY-ALL OTHERS mg/kg
N-NITROSODIMETHYLAMINE mg/kg
NAPHTHALENE mg/kg
NICKEL mg/kg
O-NITROANILINE mg/kg
O-NITROPHENOL mg/kg
P-CHLOROANILINE mg/kg
P-NITROANILINE mg/kg
P-NITROPHENOL mg/kg
PCB mg/kg
PHENANTHRENE mg/kg
PHENOL mg/kg
PYRENE mg/kg
SILVER mg/kg
THALLIUM mg/kg
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: Manifest No.
1.Check applicable category below for the waste stream:
√
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)
< 10 % ≤ 20 % ≤ 1 % ≤ 1,900 ≤ 285
Unlimited ≤ 20 % ≤ 1 % ≤ 1,190 ≤ 179
Unlimited Sum of both ≤ 45 % of waste by weight ≤ 680 ≤ 102
Unlimited Unlimited Unlimited ≤ 26 ≤ 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 toallow 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 theabove table and SNM isotope concentrations listed in Table 1.
b.The SNM is homogeneously distributed throughout the waste or the SNM concentrations in anycontiguous mass of 600 kilograms (1,323 lbs) do not exceed on average the specified limits. (Based onprocess knowledge or testing).
c.Except as allowed by Condition 1, the waste does not contain “pure forms” of chemicals containingcarbon, 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, magnesiumcarbonate, magnesium fluoride, bismuth oxide, etc. do not contain other elements. (Based on processknowledge 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 thewaste. (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 wastemeets 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, uranylpotassium carbonate, and uranyl sulfate. (Based on process knowledge or testing).
f.For containers of liquid waste with more than 600 kilograms of waste, the total activity (pCi) of SNMin the manifested container does not exceed the SNM concentration in the above table or Table 1 times600 kilograms of waste (based on process knowledge or testing). For example, the maximum activityof Pu-239 in any manifested container of liquid waste is 6.0 mCi (6.0E+09 pCi) as shown below:
239-PumCi 6.0pCi9X100.6000,600000,10 gpCi ==× g
9720-36
8
8
8
8
8
8
8
8
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).
a.Provide a description of how the waste was generated, list the physical forms in the waste, and identifythe uranium chemical composition.
b.Provide a general description of how the waste was characterized (including the volumetric extent ofthe waste, and the number, location, type, and results of any analytical testing), the range of SNMconcentrations, and the analytical results with error values used to develop the concentration ranges.
c.Describe the process by which the waste was generated showing that the spatial distribution of SNMmust be uniform, or other information supporting spatial distribution.
d.Describe the methods to be used to determine the concentrations on the manifests. These methodscould include direct measurement and the use of scaling factors. Describe the uncertainty associatedwith 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 onthis form is complete, true, and correct and is based on process knowledge, physical observations, or approvedlaboratory testing. I also certify that sampling and radiological testing of waste containing SNM was performedin accordance with EnergySolutions’ Radioactive Material License and that any supporting documentation andanalytical results have been submitted to EnergySolutions.
Signature Name Signature Key Date
8
8
8
8
Michael Kane 03e3b4c5-7314-468a-b1ae-0d3f27e5a54c 11/15/2024

matrix.
The waste does not include pure forms of the chemicals likely to increase the reactivity of the
characterizationpurposes.
andsludge phases, either a mass balance or the higher analytical result will be used for
beused to determine manifested radionuclide concentrations. For populations with both aqueous
Laboratory analytical data associated with each subpopulation of aqueous liquids and sludges will
radionuclides isconfirmed routinely through characterization efforts at the individual sites.
addition, fission andactivation products are common on the DOE-ORR. The presence of these
transuranic (TRU)radionuclides with moderate half-lives: Np-237, Pu-238, and Pu-239. In
commonlyrecognized are the uranium isotopes (in oxide form) and their daughter products,
nuclearweapons components, and chemical processing. The principal radionuclides that are
beengenerated from the diffusion cascade, reactor research, manufacture and assembly of
During more than forty years of operations on the DOE-ORR, various radioactive wastes have
SNM Attachment - 3.B
may exist in trace quantities.
uranium will be U3O8, UO2F2 or other non-soluble forms of uranium oxide. Other chemical forms
confirmed routinely through characterization efforts at the individual sites.The chemical form of
activation products are common on the DOE-ORR. The presence of these radionuclides is
radionuclides with moderate half-lives: Np-237, Pu-238, and Pu-239. In addition, fission and
are the uranium isotopes (in oxide form) and their daughter products, transuranic (TRU)
components, and chemical processing. The principal radionuclides that are commonly recognized
from the diffusion cascade, reactor research, manufacture and assembly of nuclear weapons
than forty years of operations on the DOE-ORR, various radioactive wastes have been generated
primarily generated as a result of the cleanout of sumps, basins and similar structures.During more
area cleanouts (Rev. 2) (past and current)and laboratories (Rev. 3)at these facilities; and is
demolition (D&D) activities; and routine maintenance and operations,including chemical storage
result of residuals from on-site waste treatment operations; RCRA closures; decontamination and
Security Complex, and the Oak Ridge National Laboratory (ORNL). The waste is generated as a
Technology Park (ETTP) (which is the former the K-25 Gaseous Diffusion Plant), Y-12 National
Department of Energy – Oak Ridge Reservation (DOE-ORR) including the East Tennessee
This mixed low-level waste (MLLW) material may originate from any of the facilities at the
SNM Attachment - 3.A

backup informationfor each shipment.
container of waste.This comparison is made through a spreadsheet calculation which is part of the
Co-60, Sr-90,and Cs-137 will be compared against the values of Table 2, Column 1 for each
present, are atconcentrations less than 0.1% of Table 2, Column 1 values. Concentrations of H-3,
Characterizationdata will show that Ni-63 and radionuclides with half-lives less than 5 years, if
Table 1values. For radionuclides in Table 2, activated metal are not present in this waste.
I-129,transuranics, Pu-241, and Cm-242, if present, are at concentrations at or below 0.1% of the
Activatedmetals are not present in this waste. Characterization data will show that C-14, Tc-99,
therequirements of 10 CFR 61.55 for Nuclear Regulatory Commission (NRC) Burial Class A.
The radioisotope content of each container will be evaluated to ensure that each meets
SNM Attachment - 3.D
total SNM quantities.
(SNM) present or conservative assumptions will be used in calculations from analytical results to
which case mass balance calculations will be performed to determine total Special Nuclear Material
(uniform SNM spatial distribution). However, some containers may have both liquids and sludges in
The aqueous liquids and sludges to be shipped under this waste profile will typically be homogenous
SNM Attachment - 3.C
Attachment 2
Non Aqueous Liquid Assessment

299 South Main Street Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ www.energysolutions.com

M E M O R A N D U M

Date: November 18, 2024
To: Vern Rogers
From: Steve Gurr
Subject: Waste Stream 9720-36 – Non Aqueous Liquid Assessment

The purpose of this memo is to evaluate Waste Stream 9720-36 for compliance with Radioactive Material License conditions 16.B and 16.C. License conditions 16.B and 16.C 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 Chemistry [IUPAC] standard temperature and pressure) apply.
Waste Stream 9720-36 consists of Mixed Low Level Waste (MLLW) liquids, sludges, and solids for stabilization treatment. The oil waste consists of 1 drum of 10% oil, 90% water being added to the waste profile as Revision 7. The waste was sampled and analyzed and found to be characteristically hazardous for several semi-vol contaminates
and UHC’s. A Safety Data Sheet (SDS) for used oil has been reviewed 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 SDS for used oil does not state any incompatibilities with
water and it is considered stable under standard conditions.

299 South Main Street Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ www.energysolutions.com
All waste containers will remain closed during transport and storage and will only be opened for management within controlled environments where incompatible material 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. It is not considered water reactive, nor does it appear unstable or explosive under standard temperature and pressure.