DRC-2025-002639

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 8/18/2025 ATTN: LLRW
CC; Karen Kirkwood Treesa Parker RE: Transmittal 2025-047
Description of Documents Transmitted Qty
See attached list for updates to Mixed Waste Disposal. CL-MD-PR-300 Rev 7 Onsite Waste Management 1
------------------------------------------------------------------------------------------------------------ Please replace your current procedure revisions with the documents within this Transmittal. You are not required to sign any documents to verify receipt of this distribution. However, you should make every effort to ensure that your copy of the License is current. FROM: EnergySolutions Document Control Clive Facility

CL-MD-PR-300

Onsite Waste Management
Revision 7

Authored By:

Steve D. Gurr, Environmental Engineer and
Manager
Date
Reviewed By:

Brett Davis, Lead, Mixed Waste Treatment Date
Approved By:
Thomas A. Brown, Radiation Safety Officer (RSO) Date
Approved By:

David F. Booth, General Manager, Clive

Date

Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation

Steve D. Gurr Digitally signed by Steve D. Gurr
DN: dc=com, dc=energysolutions, ou=North America, ou=Users,
ou=CLUT, cn=Steve D. Gurr, email=[e-mail]
Date: 2025.08.12 09:42:01 -06'00'
Brett Davis Digitally signed by Brett Davis
Date: 2025.08.12 10:09:52 -06'00'
Thomas Brown Digitally signed by Thomas Brown
Date: 2025.08.14 07:01:42 -06'00'
Digitally signed by David F Booth
DN: C=US, O=EnergySolutions, CN=David F Booth, E=[e-mail]
Reason: I am approving this document.Location: NA
Date: 2025-08-17 12:54:40
Foxit PhantomPDF Version: 9.7.5David F Booth
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Table of Contents

1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose........................................................................................................................... 3
1.2 Scope............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 3
4 REQUIREMENTS AND GUIDANCE .................................................................................. 7
4.1 Compliance .................................................................................................................... 7
4.2 Waste Accumulation ..................................................................................................... 9
4.3 Universal Wastes ......................................................................................................... 13
4.4 Used Oil ........................................................................................................................ 14
4.5 ECW Requirements .................................................................................................... 14
5 ATTACHMENTS AND FORMS......................................................................................... 17

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1 PURPOSE AND SCOPE
1.1 Purpose
This procedure provides guidance for the accumulation and management of
wastes at the Clive Facility.
1.2 Scope
This procedure describes the different types of hazardous wastes generated at the
Clive Facility and their proper disposition in accordance with state and federal
regulations. This procedure also describes compliant methods for the
accumulation of these wastes in 90-day and satellite accumulation containers.
This procedure does not address contact LLRW generated outside the Mixed
Waste facility, i.e., PPE, decontamination liquids, etc.
2 REFERENCES
2.1 CL-CH-PR-250, Decontamination Procedure
2.2 CL-MD-PR-211, Mixed Waste: Daily, Weekly & Monthly Inspections
2.3 State-issued Part B Permit
2.4 Radioactive Material License UT2300249
2.5 Utah Administrative Code (UAC) R315-262, Hazardous Waste Generator
Requirements
2.6 UAC R315-273, Standards for Universal Waste Management
2.7 UAC R315-15, Standards for the Management of Used Oil
2.8 CL-WT-PR-001, Facility Waste Tracking
3 GENERAL
3.1 Definitions
3.1.1 90 Day Container - Containers used to accumulate Hazardous Waste for a
regulated period of 90 days.
3.1.2 Aerosol Can – A container with a total capacity no more than 24 ounces of
gas under pressure and is used to aerate and dispense any material through
a valve in the form of a spray or foam.
3.1.3 Antifreeze – An ethylene glycol or propylene glycol-based mixture that
lowers the freezing point of water and is used as an engine coolant.
3.1.4 Battery – A device consisting of one or more electrically connected
electrochemical cells which is designed to receive, store, and deliver
electric energy.
3.1.5 Combustible Material – Defined in 40 CFR 173 and 40 CFR 261 as a
liquid with a flashpoint greater than 140 ºF and less than 200 ºF or a solid
material that is capable of igniting and burning (e.g., wood, paper).
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3.1.6 Container - A portable device, in which material is stored, transported,
treated, disposed, or otherwise handled (B-25, B-12, C-21, 85-gal, 55- gal,
etc.).
3.1.7 EnergySolutions Created Waste (ECW) - Waste generated from onsite
operations including decontamination, used PPE, used oil, Vacuum
Thermal Desorption (VTD) secondary waste streams, etc. The following
are the ECW streams along with brief descriptions (historic waste streams
that are no longer generated have been designated INACTIVE in this list):
• Waste Stream 01 - Sludge from On-Site Generated Liquids
• Waste Stream 02 - On-Site Generated Liquids, including mixed
waste leachate, on-site laboratory liquid wastes, and mixed waste
decontamination liquids.
• Waste Stream 03 - (INACTIVE as of April 20, 2015) - Non-
contact PPE and Miscellaneous Debris, including non-contact
waste (such as wood, metal banding, etc.).
• Waste Stream 04 (INACTIVE AS OF September 3, 2015) -
Hazardous Waste Requiring Treatment, including wash pad waste,
baghouse dust, treatment decontamination residues, solid sample
waste, and on-site laboratory solid wastes.
• Waste Stream 05 - Debris for MACRO.
• Waste Stream 06 (INACTIVE as of April 5, 2013) -
Radioactively Contaminated Oil.
• Waste Stream 07 - Liquid and Sludge from the Mixed Waste
Pond (This waste stream is only used as a tracking mechanism for
the annual pond sludge sampling required in Condition II.D.4. of
reference 2.3).
• Waste Stream 08 (INACTIVE as of April 7, 2011) - VTD
Condensate.
• Waste Stream 09 - VTD TSCA Condensate.
• Waste Stream 10 (INACTIVE as of April 5, 2013) - VTD
Wastewater.
• Waste Stream 11 - VTD Processed Material; e.g., VTD Waste
Requiring Stabilization Treatment.
• Waste Stream 12 (INACTIVE as of April 7, 2011) - VTD
Secondary solids, including carbon filters, particulate filters, and
decontamination products.
• Waste Stream 13 (INACTIVE as of March 15, 2012) - Non-
Radioactive Hazardous Waste, generated outside the radiological
controlled area.
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• Waste Stream 14 (INACTIVE as of March 15, 2012) -
Hazardous Oil.
• Waste Stream 15 (INACTIVE as of March 15, 2012) - Residual
Elemental Mercury.
• Waste Stream 16 (INACTIVE as of March 15, 2012) - Non-
Hazardous Used Antifreeze.
• Waste Stream 17 (INACTIVE as of March 15, 2012) – Spent
Flammable Solvents.
• Waste Stream 18 – Waste for VTD Treatment.
• Waste Stream 19 – High Risk Waste.
• Waste Stream 20 – LLRW-Destined Used Oil.
• Waste Stream 21 – RCRA Empty Container Tracking (Not Waste
– Waste Stream issued for EWIS tracking purposes only).
• Waste Stream 99 – Empty Container Tracking (Not Waste -
Waste Stream issued for EWIS tracking purposes only).
3.1.8 Flammable Material – Defined in 40 CFR 173 and 40 CFR 261 as a liquid
with flashpoint less than 140 ºF or a solid that is self-reactive, pyrophoric,
water reactive, or a DOT oxidizer (defined in 40 CFR 173.127) and/or
burns vigorously when ignited.
3.1.9 High Risk Waste – Waste that contains hazards (e.g. D001, D002, D003,
Lab packs, etc.) that may adversely react during waste processing and
treatment activities. High Risk Waste may also include any waste that
requires additional data or other information in order to determine
appropriate management of the waste.
3.1.10 Lamp – The bulb or tube portion of an electric lighting device.
3.1.11 Mercury-containing Equipment – A device or part of a device, including
thermostats, but excluding batteries and lamps, that contains elemental
mercury integral to its function.
3.1.12 Non-Contact - Personal Protective Equipment or other material that does
not come in contact with hazardous waste or materials.
3.1.13 Operator – For satellite accumulation management, the operator of the
process generating the waste is the EnergySolutions Clive Facility.
3.1.14 Out of Service Date (O.O.S.) – The date on which Polychlorinated
Biphenyl (PCB) items were removed from service. This date is provided
by the generator or is the date the waste arrives at the Clive Facility.
3.1.15 Pesticide – Any substance or mixture of substances intended for
preventing, destroying, repelling, or mitigating any pest, or intended for
use as a plant regulator, defoliant, or desiccant.
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3.1.16 RCRA Empty Container – Defined in 40 CFR 261.7 as a container from
which all waste has been removed using commonly employed removal
practices and retains no more than one inch of residue on the bottom; or no
more than 3% by weight of the total capacity of the container if the
container is 110 gallons or less, or 0.3% by weight of larger containers.
3.1.17 Satellite Accumulation - Containers, not to exceed 55 gallons, used for
accumulation of hazardous waste near the point of generation. For acutely
hazardous waste, the container may be no greater than one quart.
3.1.18 Universal Waste – Described in reference 2.6 as the following widely
generated hazardous wastes: batteries, pesticides, mercury-containing
equipment, lamps, antifreeze, and aerosol cans.
3.1.19 Used Oil - Oil that has been refined from crude or synthetic oil and has
been used and as a result of such use is contaminated by physical or
chemical impurities. Used oil loses its designation as used oil once it is
transferred to ECW.
3.1.20 Electronic Waste Tracking System – An electronic waste tracking system
used to track the current status of waste upon receipt through storage,
treatment, and disposal.
3.2 Responsibilities
3.2.1 Operations Manager has responsibility for the overall implementation and
accuracy of this procedure excluding updating the Waste Profile Record.
3.2.2 Environmental Engineer is responsible for updating each of the active
ECW Waste Profile Records in accordance with this procedure. The
Environmental Engineer is also responsible for reviewing waste
information to assign ECW waste stream to generated waste and provide
cautions and guidance on management of the waste. The Environmental
Engineer also reviews regulatory changes and updates this procedure
when rules are modified.
3.2.3 Lead, Mixed Waste Treatment is responsible for reviewing waste
information and, in consultation with the Environmental Engineer,
assigning ECW waste stream to generated waste. The Lead, Mixed Waste
Treatment shall ensure that qualified personnel implement this procedure.
3.2.4 The Waste Tracker and Lead, Mixed Waste are responsible for
maintaining EnergySolutions Created Waste using the Waste Tracking
System and the 90-Day Container Tracking Log (Attachment 5.1) and
assigning tracking numbers to onsite generated waste containers as they
are created.
3.2.5 Facility Managers and Leads are responsible for the daily management of
onsite generated waste containers and to ensure that facility operators are
trained to identify EnergySolutions Created Wastes and Universal Wastes.
3.2.6 Facility Operators are responsible for performing the operations required
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in this procedure including assigning the correct tracking numbers to
newly generated waste and for discerning the different types of waste and
their appropriate management.
3.2.7 Maintenance Personnel are responsible for the management of used oil
generated site-wide.
3.3 Precautions and Limitations
3.3.1 When uncertain as to whether a waste should be managed as a High Risk
Waste, consult with the Environmental Engineer or Lead, Mixed Waste
Treatment prior to managing the waste.
3.3.2 Personnel shall follow the requirements (including necessary PPE) of the
appropriate RWP or, in the case of High Risk Waste, as directed by the
Operations Manager, or designee.
3.3.3 Personnel shall exercise caution when opening and closing containers in
order to avoid pinch points.
3.3.4 Unless specifically authorized by the Operations Manager, flammable
material shall not be processed through a shredder.
3.4 Document Control and Records
3.4.1 The 90-Day Container Tracking Log (Attachment 5.1) shall be transmitted
to Document Control annually.
4 REQUIREMENTS AND GUIDANCE
4.1 Compliance
4.1.1 Up to 55 gallons may be accumulated in Satellite Accumulation
containers, provided that:
4.1.1.1 The container remains in good, strong-tight condition.
4.1.1.1.1 If the container holding the hazardous waste is not
in good condition, or if it begins to leak, the waste
shall be transferred to a container that is in good
condition.
4.1.1.2 The container is made of or lined with materials that will not react
with, and are otherwise compatible with, the hazardous waste to be
stored.
4.1.1.3 Control of Satellite Accumulation Containers.
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4.1.1.3.1 Satellite Accumulation Containers within the
restricted area are controlled by access control to the
restricted area.
4.1.1.3.2 Satellite Accumulation Containers outside the
restricted area are controlled by locating them within
designated fenced areas that are locked when
EnergySolutions personnel are not present.
4.1.1.4 The container shall be kept closed except when adding or
removing waste.
Note: For the aerosol can puncturing station
containers, the cap over the can puncturer must
be pushed down onto the opening when not in
use.
4.1.1.5 Satellite Accumulation Containers shall be labeled as described in
Section 4.2.5.4.
4.1.2 90-day containers may be designated and used to accumulate waste
provided that the following conditions are met:
4.1.2.1 The container holding hazardous waste shall always be closed,
except when it is necessary to add or remove waste.
4.1.2.2 The container shall be inspected weekly in accordance with
reference 2.2.
4.1.2.3 The container is labeled as described in Section 4.2.5.3.
4.1.2.4 The container has an accumulation start date.
4.1.2.5 The container’s accumulation end date will not exceed 90 days
after the accumulation start date.
4.1.2.6 The container has a 90-day tracking number.
4.1.3 Special Requirements for Incompatible Wastes.
4.1.3.1 Incompatible wastes are not to be placed in the same container.
4.1.3.2 Used containers that may have previously contained waste that is
incompatible with waste being placed in the container will be
decontaminated in accordance with reference 2.1 prior to use for
onsite waste.
• If no incompatible material is suspected, the container need only
be “RCRA Empty” prior to use for onsite waste.
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4.1.3.3 Containers holding hazardous waste that may be incompatible with
any waste or material accumulated nearby will be separated from
the other waste or materials (distance, walls, pallets, sump areas,
etc.).
4.1.4 Each active ECW stream will be re-characterized at least annually. Waste
Profile Records (WPR) may be updated more often as deemed necessary.
4.1.5 In accordance with Condition 15.A. of reference 2.4, prior to treatment all
onsite generated waste will be evaluated, based on knowledge of the
technology to be used for treatment/processing, to ensure the resultant
processed waste is neither Class B nor Class C waste. This evaluation will
be documented in the ECW waste profile record or with the treatment
paperwork.
4.1.6 The quantity of used oil stored within the restricted area prior to being
transferred to ECW shall not exceed 1,000 gallons.
4.1.7 Waste that contains PCBs shall have an Out-of-Service (OOS) date added
to the label. The OOS date shall be the date PCB waste was first placed in
the container.
4.1.8 The Lead, Mixed Waste Treatment, or designee shall be informed prior to
the transfer of any waste to a permitted Mixed Waste storage area.
4.1.9 If waste is left in a tank after operating hours, the tank will be labeled as
described in Section 4.2.5.5.
4.2 Waste Accumulation
4.2.1 Onsite generated hazardous wastes shall be accumulated and managed
within permitted Mixed Waste storage areas, within 90-day containers, or
within satellite accumulation containers.
Note: Wastes with a liquid component shall be stored in
secondary containment.
4.2.2 Permitted Mixed Waste storage areas are described in reference 2.3.
4.2.3 90-Day Container Management
4.2.3.1 Obtain a suitable container (B-25, B-12, C-21, 85-gal, 55- gal,
etc.). The container shall have good physical integrity (i.e. working
clamps or closure devices, no holes or ruptures, and a lid that fits
over the container without gaps).
4.2.3.2 If needed, decontaminate the container in accordance with
reference 2.1.
4.2.3.3 Fill out the 90-Day Container Tracking Log as follows:
4.2.3.3.1 FACILITY OPERATOR: Record name (print)
under this column.
4.2.3.3.2 90 DAY TRACKING NUMBER: 90-day tracking
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number must be assigned in numerical order.
Record the next 90-day tracking number in 9D0000
format. Use only one container for each tracking
number.
Note: 90-day tracking number shall
appear on the label for the
container recorded in the 90-Day
Container Tracking Log
(Attachment 5.1).
4.2.3.3.3 LOCATION: Record the specific area(s) where the
container is located.
4.2.3.3.4 WASTE DESCRIPTION: Record the expected
contents for the container in question.
4.2.3.3.5 CONT. TYPE: Record the type of container that
will be used (B-25, B-12, C-21, 85-gal, 55- gal,
etc.)
4.2.3.3.6 EMPTY WEIGHT: Use the empty container
weights provided on the 90-Day Container Tracking
Log (Attachment 5.1), or if needed, weigh the
container prior to filling.
4.2.3.3.7 ACCUMULATION START DATE: Record the
date that the container will begin accumulating
waste.
Note: If transferring waste from one 90-
day container to another, the
accumulation start date is the
earliest date.
Note: If PCBs are disposed in the
container, the accumulation start
date is also the PCB Out of Service
Date.
4.2.3.3.8 ACCUMULATION END DATE: This date will not
exceed 90 days after the accumulation start date.
Note: Count actual days to get this
number. Do not assume that the
same date three months later is the
correct date.
4.2.3.3.9 FULL WEIGHT: Record the gross weight of the
container when full or upon expiration of the 90
days.
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4.2.3.3.10 NET WEIGHT: Subtract the empty weight from
the full weight and record the remainder.
4.2.3.3.11 DATE TRANS: Record the date the waste was
transferred to a permitted Mixed Waste storage area
and assigned a Bates number.
4.2.3.3.12 FINAL REVIEW SIGNATURE AND DATE:
Upon Completion of items 4.2.3.3.1 - 4.2.3.3.11, a
final review will be conducted by the Operations
Manager, to check for the following items:
4.2.3.3.12.1 Accuracy of the information
• The 90-day accumulation time is not exceeded.
• There is up to 90-days between the accumulation
start & end date recorded in the 90-Day Container
Tracking Log (Attachment 5.1).
4.2.3.3.12.2 Completeness
• Must have signature and date.
• Blanks filled in or N/A to prevent unauthorized
additions with one line, initials, and date.
• Black or Blue ink
• Legible penmanship
4.2.3.4 Label the 90-day container in accordance with Section 4.2.5.3.
4.2.3.5 When a 90-day container has reached its capacity or accumulation
end date, the container shall be transferred to a permitted Mixed
Waste storage area.
Note: Containers that reach capacity shall be
transferred to a permitted Mixed Waste
storage area within 3 days. Containers
that are at their accumulation end date
shall be transferred to a permitted Mixed
Waste storage area that same day.
4.2.4 Satellite Accumulation Container Management
4.2.4.1 Obtain a suitable container less than or equal to 55 gallons, or no
more than one quart for acutely hazardous waste, with a lid capable
of remaining in place in the event that the container is tipped over.
4.2.4.2 Place the containers at or near the point of generation of the waste.
4.2.4.3 Label the container as described in Section 4.2.5.4.
4.2.4.4 When a satellite accumulation container reaches its capacity, it
shall be emptied into a container on a permitted Mixed Waste
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storage area or into a 90-day container.
4.2.4.4.1 The accumulation start date for satellite
accumulation waste is the date it is removed from
the satellite accumulation container.
4.2.4.4.2 If PCBs are disposed in the container, the
accumulation start date is also the PCB Out of
Service Date.
4.2.5 Labeling Containers
4.2.5.1 Labels will be visible for inventory and tracking purposes.
4.2.5.2 Containers on permitted Mixed Waste storage areas shall be
labeled with the following information:
4.2.5.2.1 Date of waste generation
4.2.5.2.2 Tracking number (i.e., Bates Number)
4.2.5.2.3 The words “Hazardous Waste”, if applicable
4.2.5.2.4 Reactivity Group Numbers (RGNs)
4.2.5.2.5 90-day container number, if applicable
4.2.5.2.6 PCB label and Out of Service Date, if applicable
4.2.5.3 90-day containers shall be labeled with the following information
at the time they are created:
4.2.5.3.1 The words “Hazardous Waste”
4.2.5.3.2 Accumulation start date
4.2.5.3.3 Accumulation end date
4.2.5.3.4 Brief description of the waste
4.2.5.3.5 90-day tracking number
4.2.5.3.6 PCB label, if applicable
4.2.5.3.7 An indication of the hazards of the contents by
characteristics (i.e., ignitable, corrosive, reactive, toxic), or
standard label (e.g., NFPA diamond, hazard
communication pictograms).
4.2.5.4 Satellite Accumulation Containers shall be labeled with the
following information at the time they are created:
4.2.5.4.1 The words “Hazardous Waste”
4.2.5.4.2 An indication of the hazards of the contents by
characteristics (i.e., ignitable, corrosive, reactive, toxic), or
standard label (e.g., NFPA diamond, hazard
communication pictograms).
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4.2.5.4.3 PCB label, if applicable
4.2.5.5 Tanks which have waste left in them after operating hours shall be
labeled with the following information:
4.2.5.5.1 The words “Hazardous Waste”
4.2.5.5.2 An indication of the hazards of the contents by
characteristics (i.e., ignitable, corrosive, reactive, toxic), or
standard label (e.g., NFPA diamond, hazard
communication pictograms).
4.2.5.5.3 PCB label, if applicable
4.3 Universal Wastes
4.3.1 The following wastes are universal wastes:
• Batteries as defined in 3.1.4;
• Pesticides as defined in 3.1.15;
• Mercury-containing equipment as defined in 3.1.11;
• Lamps as defined in 3.1.10;
• Antifreeze as defined in 3.1.3; and
• Aerosol cans as defined in 3.2.1.
4.3.2 Lead-acid batteries that are recycled are not Universal Wastes and not
subject to this procedure.
4.3.3 Antifreeze that is recycled is not a Universal Waste and is not subject to
this procedure.
4.3.4 All personnel will be trained annually on the identification of Universal
Wastes in the workplace.
4.3.5 All personnel should identify potential Universal Wastes present within
their work locations.
4.3.6 When Universal Wastes are taken out of service, they are to be discarded
as a hazardous waste and managed as an appropriate ECW stream (see
Section 4.5).
4.3.7 Aerosol cans that are no longer in use (out of service) are considered a
hazardous waste until they are punctured.
4.3.7.1 There are five satellite accumulation can puncturing stations on
site:
• On the south side of the LLRW Operations building, inside the
Restricted Area;
• Inside the rotary building;
• Inside the Mixed Waste Operations Building bay;
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• On the north side of the maintenance shop inside the Restricted
Area; and
• In the maintenance bay of the outside maintenance shop.
4.3.7.2 Aerosol cans taken out of service shall be punctured immediately.
Unless they are stored in secondary containment at Mixed Waste
they may not be stored in the out of service condition.
4.3.7.3 After the can has been punctured and the contents emptied into the
satellite accumulation container, the empty carcass may be
disposed as a non-hazardous solid waste.
4.3.8 No additional documentation is required for this process.
4.4 Used Oil
4.4.1 Used oil regulations are detailed in reference 2.6.
4.4.2 There is no accumulation time limit for used oil
4.4.3 Containers used to collect used oil must be in good condition (e.g., no
severe rusting, structural defects, deterioration, leaks, etc.).
4.4.4 Used oil container will be stored in secondary containment.
4.4.5 Containers for used oil collection will be labeled “Used Oil” and have an
appropriately marked NFPA diamond.
4.4.6 Only used oil, as defined in 3.1.19, will be accumulated in containers
labeled “Used Oil”.
4.4.6.1 All other liquid waste generated (e.g., antifreeze, solvents, etc.)
will be segregated in separate containers, labeled as to their
contents, and managed accordingly.
4.4.7 The Lead, Mixed Waste Treatment, or designee, shall be informed when
used oil containers are complete and ready for transfer to the Mixed Waste
Facility.
4.5 ECW Requirements
4.5.1 After a container has been transferred to a permitted Mixed Waste storage
pad, or no more waste is going to be added to a container on a permitted
Mixed Waste storage pad, Facility Operators shall visually inspect and
note the contents of the container.
4.5.2 The Facility Operator will determine a waste stream for the container(s)
using the following process:
4.5.2.1 If the waste is sludge from evaporation tanks, it will be ECW-01.
4.5.2.2 If the waste is laboratory liquids, or any other liquids from mixed
waste leachate, mixed waste run-off, mixed waste
decontamination, or groundwater monitoring purging, the liquid
may be placed directly into an evaporation tank, mixed waste
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decontamination pad tank, or surface impoundment without
obtaining a tracking number.
4.5.2.3 If the waste is non-contact debris, it will be disposed directly in the
Mixed Waste Landfill Cell, tracking as ECW is not necessary.
4.5.2.4 If the waste is contact debris, it will be ECW-05.
4.5.2.5 If the waste is used oil, the following will occur:
4.5.2.5.1 When transferred to Mixed Waste, the Lead, Mixed
Waste Treatment will be informed and containers of
used oil will be delivered to the Mixed Waste
Operations Building.
4.5.2.5.2 The oil will be ECW-20 and no longer considered
used oil.
4.5.2.5.3 Every container of ECW-20 oil will be sampled and
analyzed for radiological parameters, Total Organic
Halogens (TOX), flashpoint, total arsenic,
cadmium, chromium, lead, and PCBs.
4.5.2.5.3.1 The results of the analysis will be
compared to Table 1 in reference 2.6
and to a total PCB standard of two
(2) mg/kg.
4.5.2.5.3.2 If results do not meet all of the
criteria in Section 4.5.2.5.3.1, the
Environmental Engineer will review
the data and assign appropriate
management for the oil.
4.5.2.6 If the waste is condensate from VTD, it will be ECW-09.
4.5.2.7 If the waste is known to be contaminated with high concentrations
of organic compounds (e.g., sample returns) or was generated by
VTD (e.g., activated carbon filter media), it will be ECW-18.
4.5.2.8 For all other ECW, a description of the waste will be provided to
the Environmental Engineer and Lead, Mixed Waste Treatment for
review.
4.5.2.8.1 The Environmental Engineer and Lead, Mixed
Waste Treatment will review the waste description
and history of the waste together and, if necessary,
will physically examine the waste prior to making a
determination on the designation of the waste.
4.5.2.8.1.1 This review will specifically address
whether the waste has the potential
to create an additional hazard if
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introduced into a waste management
unit or mixed with other wastes.
4.5.2.8.1.2 The review will also address whether
items added to the waste in previous
waste processing (including PPE), or
the waste container itself, may create
a hazard in future waste management
(e.g., shredding).
4.5.2.8.1.3 The review will designate whether
the waste contains flammable
material.
4.5.2.8.2 Based on this review, the waste may be designated
ECW-05, ECW-18, or ECW-19.
4.5.2.8.3 Waste designated ECW-19 will have further
analytical performed as necessary to determine
appropriate management.
4.5.2.8.3.1 After additional information is
received, the ECW-19 waste may be
treated or disposed as ECW-19, or
may be changed to an appropriate
ECW stream.
4.5.2.8.3.2 Waste remaining ECW-19 for
management will have special
precautions as prescribed by the
Environmental Engineer and Lead,
Mixed Waste Treatment.
4.5.2.8.4 During this review process, if it takes more than one
day, the container(s) will be labeled “HOLD” with
the date of waste generation, the words “Hazardous
Waste”, and a brief description of the waste.
4.5.3 Once the ECW stream is determined, the Waste Tracker and/or Lead,
Mixed Waste Treatment will assign the next available EnergySolutions
“shipment” tracking number from the electronic waste tracking system.
Note: Each tracking number may consist of a single container,
or multiple containers depending on what is generated.
4.5.4 The Facility Operator will then complete a Daily Operations Working
Record (CL-WT-PR-001 F3 in reference 2.8) to create a shipment with the
tracking number.
4.5.5 The Facility Operator will label the container(s) as described in Section
4.2.5.2 and place the container(s) into an appropriate storage area.
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5 ATTACHMENTS AND FORMS
5.1 CL-MD-PR-300-F2, 90-Day Container Tracking Log - Example

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Attachment 5.1 - CL-MD-PR-300-F2, 90-Day Container Tracking Log – Example

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