DRC-2025-002023

299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
June 24, 2025 CD-2025-131
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 9083-18
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 9083-18.
Waste Stream 9083-18 consists of primarily Used Oil and Ultima Gold liquid scintillation fluid.
The non-aqueous liquids consist of high concentrations of metals and low concentrations of
organic compounds. The waste will be stabilized/solidified at the Mixed Waste Facility prior to
disposal.
The profile for Waste Stream 9083-18 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
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 (801) 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 .
:
:
:
:ID:
:
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
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"%18B1/40”%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 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 arrival at EnergySolutions’disposal facility unless approved by EnergySolutions.
Optimum Moisture Content: % at Maximum Dry Density (lb/ft
3):
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. 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
%
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 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 ttachment 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)
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 .
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 treatment
and indicate “Former” in the second column. Worst-case concentrations only need to be provided for concentration based
treatment standards. If additional space is needed, provide an ttachment to this profile record formatted as below. Include a
description of hazardous waste determinations and any variances, exclusions, etc. in the 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
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 through
treatment. Worst-case concentrations only need to be provided for concentration based treatment standards. If additional
space is needed, provide an ttachment 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 notedas 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 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 or RCRA Permit.
Signature::Date:
Hazardous Waste Certification Attachment
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 Chemicalsin 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 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 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 g
pCi g
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)
MeasurementUncertainty(pCi/g)Radionuclide
Maximum Concentration(pCi/g)
MeasurementUncertainty(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 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.
Signature Date
CL-WM-PR-001
The friable asbestos containing liquids are from pipes (containing friable asbestos) generating sodium
contaminated wash water. The friable asbestos will be packaged, marked, and labeled in accordance
with applicable federal regulations.
Attachment 2
Non Aqueous Liquid Assessment
M E M O R A N D U M
Date: June 24, 2025
To: Vern Rogers
From: Steve Gurr
Subject: Waste Stream 9083-18 – Non-Aqueous Liquid Assessment
The purpose of this memo is to evaluate Waste Stream 9083-18 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 9083-18 consists of primarily Used Oil and Ultima Gold liquid scintillation
fluid. The non-aqueous liquids consist of high concentrations of metals and low
concentrations of organic compounds. The waste will require Stabilization treatment
prior to disposal.
The Safety Data Sheet (SDS) for Used Oil and Ultima Gold were 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.
Ultima Gold
Ultima Gold consists of a mixture of non-hazardous chemicals and has a flash
point of 152 ºC, a boiling point of 290 ºC, and an ignition temperature of 500
ºC. The MSDS specifically states that the material will not self-ignite. The
specific gravity of Ultima Gold slightly less than water (0.960) and is soluble
in water (10 ppm). The product is stable and will not thermally decompose,
with the only incompatibility listed being strong oxidizers. If allowed to burn,
the only decomposition product listed is carbon monoxide.
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.