DRC-2025-001949

299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
June 18, 2025 CD-2025-128
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 0856-55
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 0856-55.
Waste Stream 0856-55 consists of Electrical Transformers with liquid PCB oil inside. PCB
The waste is non-hazardous
and will require draining of the PCB oil and flushing in accordance with 40 CFR 761.60
(b)(1)(b). The oil and flush will be treated by thermal desorption (VTD) and the transformer
carcasses will be disposed of in the Mixed Waste Landfill Cell.
The profile for Waste Stream 0856-55 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.
10B12”%12B4”%14B1”%16B1/4"%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
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 .
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:Pass / Fail Method 9095 Not applicable for liquid radioactive waste streams.
2. 40 CFR 261.24 Table 1 – Contaminants of Toxicity Characteristic
Metals:Methods 6010 & *7470
Arsenic Chromium Selenium
Barium Lead Silver
Cadmium *Mercury
Organics, Pesticides/Herbicides:Methods 8081/*8151
Endrin oxaphene Chlordane
Lindane *2,4-D Heptachlor
Methoxychlor *2,4,5-TP Silvex
23BOrganics, Semi-Volatile:Method 8270
o-Cresol Hexachlorobenzene Pentachlorophenol
m-Cresol Hexachlorobutadiene Pyridine
p-Cresol Hexachloroethane 2,4,5-Trichlorophenol
Total Cresol Nitrobenzene 2,4,6-Trichlorophenol
2,4-Dinitrotoluene
151BOrganics, Volatile:Method 8260
Benzene 1,4-Dichlorobenzene Methyl ethyl keytone
Carbon Tetrachloride 1,2-Dichloroethane Tetrachloroethylene
Chlorobenzene 1,1-Dichloroethylene Trichloroethylene
Chloroform Vinyl Chloride
3.Was the waste at the point of generation a RCRA hazardous waste per 40 CFR 261? Y N
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 ttachment to this profile record formatted as below. Attach the
most recent chemical analytical results demonstrating compliance with applicable treatment standards.
If No, indicate “N/A” in Section D.3 below.
Low-Level Radioactive Waste Certification Attachment
CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
D. 3.
Former EPA HW Codes or
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)
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)
5. LABORATORY CERTIFICATION
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.
Signature::Date:
Low-Level Radioactive Waste Certification Attachment
CL-WM-PR-001 F4 (EC-98279)
Revision 4
PCB WASTE CERTIFICATION
Waste Stream ID: PCB/Radioactive Waste *PCB/Mixed Waste
The waste stream contains the following PCB categories (please check all that apply):
*PCB Transformers to be flushed by EnergySolutions
*Intact, non-leaking PCB Small Capacitors (including intact, non-leaking light ballasts with PCB
concentrations < 50 ppm in the potting material)
Drained PCB-
Drained PCB Containers (previously contained PCBs at concentrations < 500 ppm)
PCB Bulk Remediation Waste, as defined in 40 CFR 761.3:
Non-liquid cleaning materials and personal protective equipment waste at any concentration, as
described in 40 CFR 761.61(a)(5)(v)(A)
PCB Bulk Product Waste, as defined in 40 CFR 761.3
Plastics (such as plastic insulation from wire or cable: radio, television and computer casings; vehicle
parts; or furniture laminates); preformed or molded rubber parts and components; applied dried paints,
varnishes, waxes or other similar coatings or sealants; caulking; Galbestos; non-liquid building
demolition debris; or non-liquid PCB bulk product waste from the shredding of automobiles or
household appliances from which PCB small capacitors have been removed (shredder fluff). PCB
761.62(b)(1)(i)).
PCB Waste from Research & Development
Other:
* Any waste in groups marked with an asterisk must be disposed at EnergySolutions’ Mixed Waste disposal
embankment and requires the use of a Uniform Hazardous Waste Manifest.
** Each drained PCB Transformer with PCB concentra
of 40 CFR 761.60(b)(1)(i)(B) have been met. Flush Certifications must include, at a minimum:
A unique identification number for each PCB Item that was flushed;
The date that the flush was performed;
A statement that the flush was performed in accordance with regulation; and
A certified signature and date signed.
Provide a description of the PCB waste (including information to support the groups identified above) in the
Attachment B.5 narrative of the Waste Profile Record (EC-0230).
GENERATOR CERTIFICATION
I certify that the waste described on this form and accompanying documents were or shall be obtained using state
and EPA-approved sampling methods, as applicable. I certify that the PCB/radioactive waste or PCB/mixed waste
described on this form has not been diluted from a higher concentration in order to avoid any provision of specifying
a PCB concentration in accordance with 40 CFR 761. I certify that the waste does not contain any free-standing
liquids. I 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.
Signature Date
Attachment 2
Non Aqueous Liquid Assessment
M E M O R A N D U M
Date: June 18, 2025
To: Vern Rogers
From: Steve Gurr
Subject: Waste Stream 0856-55
Non Aqueous Liquid Assessment
The purpose of this memo is to evaluate Waste Stream 0856-55 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 0856-55 consists of Electrical Transformers with liquid PCB oil inside.
PCB concentrations are presumed to be -
hazardous and will require draining of the PCB oil and flushing in accordance with 40
CFR 761.60 (b)(1)(b). The oil and flush will be treated by thermal desorption (VTD) and
the transformer carcasses will be disposed of in the Mixed Waste Landfill Cell. The
waste does not carry any hazardous waste codes, only requiring management at the
Mixed Waste Facility due to PCB categories.
A worst-case assessment is made herein that the non-aqueous liquids are pure PCBs. The
following analysis of pure PCBs was performed using a Safety Data Sheet (SDS) for
PCBs.
PCBs
PCBs are fire resistant compounds that are not volatile at room temperature.
Their flash point is 284 degrees Fahrenheit or higher dependent upon the
chlorination level of the Aroclor product. Their fire point is 349 degrees
Fahrenheit or higher, also dependent upon the Aroclor chlorination level.
Despite these high temperature thresholds, PCBs should not be transported
next to open flame sources, or subjected to excessively hot conditions.
Exposure to excessive heat may create CO, CO2, HCl, phenolics, aldehydes
and other toxic combustion or decomposition products. It will therefore be
important to ensure that transport occurs under standard environmental
conditions. The SDS for PCBs does not state any incompatibilities with water
and it is considered very stable.
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. The waste is not
considered water reactive, nor is it unstable or explosive under standard temperature and
pressure.