DRC-2025-002462

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
August 1, 2025 CD-2025-154
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 9825-04 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 9825-04.
Waste Stream 9825-04 consists of shipboard maintenance waste including: Neolube, adhesives,
sealants, coatings, etc. The waste within this profile includes Hazardous waste codes D001 (Deactivation), D002 (Corrosivity) and D004-D011 (Metals). The waste will be treated by thermal desorption (VTD) and will be disposed of in the Mixed Waste Landfill Cell.
The profile for Waste Stream 9825-04 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 [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:
Charleston, SC
Jeisha Alayon
757-396-9469 [e-mail]
9825-04 Liquid Mixed Waste for Thermal Treatment
0 7/31/2025 1.000E2 ft^3
8
8
8
8
8
8
8
Joint Base Charleston-Weapons(NPTU)/Charleston, SC SC8170022620
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 %
8 100
8
8
100
100 100 100 100 100 100
8
N/A
8
8 8
1.1 g/cc0.9 g/cc
N/A
N/A N/A N/A
Liquid solution
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
AG-110M
C-14
CO-58
CO-60
CS-134
CS-137
FE-55
H-3
I-129
MN-54
NB-94
NI-59
NI-63
SB-125
SR-90
TC-99
ZN-65
4.850E2
1.210E3
1.540E4
8.090E4
3.230E1
3.230E2
8.090E4
2.760E3
1.620E-2
6.470E3
1.620E1
6.470E1
6.470E3
4.040E2
1.620E1
3.230E1
6.470E2
4.000E1
1.200E2
1.500E2
8.100E2
3.230E0
3.200E0
8.100E1
2.800E2
1.000E-2
6.500E2
1.000E0
6.000E1
6.500E2
4.000E0
1.600E0
3.000E0
6.470E1
9825-04 0 7/31/2025
Physical Properties Narrative

This Liquid Waste Stream consists of the following wastes:

This waste is generated as a result of shipboard maintenance work or the analysis of radioactive
liquid samples at NPTU.
Neolube, adhesives, sealants, coatings, resins with a flash point less than 140°F (D001).
General information
NNSY utilizes process knowledge to identify the radiological properties of waste. The process
knowledge involves the use of scaling factors to identify the isotopes and their associated activities.
Activities were determined by multiplying the measured Co-60 activity by specific isotope factors.
Co-60 activity by specific isotope factors. Co-60 is the primary radionuclide of concern for Naval
Ship and shipyard operations. The highest C0-60 specific activity determined for all like waste
generated at NNSY is 6000 pCi/g.

NNSY packages it's waste in double polyethylene and/or polyurethane bags.

NNSY containerizes its waste within <=85-gallon drums for shipment. NNSY will palletize drums for
shipment.

This is used pure products with SDS provided.

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 beenlisted. 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
See SDS
N/A
8 See SDS See SDS
D001 IGNITABILITY N/A
D002 Not Specified N/A
D004 Not Specified N/A
D005 Not Specified N/A
D006 Not Specified N/A
D007 Not Specified N/A
D008 Not Specified N/A
D009 Not Specified N/A
D010 Not Specified N/A
D011 Not Specified N/A
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
None
None
Jeisha Alayon eb250eef-aa3a-4bed-b2b4-959536b77ad7 7/31/2025
N/A
Attachment 2
Non Aqueous Liquid Assessment

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
M E M O R A N D U M
Date: August 1, 2025
To: Vern Rogers
From: Steve Gurr
Subject: Waste Stream 9825-04
Non Aqueous Liquid Assessment

The purpose of this memo is to evaluate Waste Stream 9825-04 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 9825-04 consists of shipboard maintenance wastes including: Neolube,
adhesives, sealants, coatings, etc. The waste within this profile includes Hazardous waste codes D001 (Deactivation), D002 (Corrosivity) and D004-D011 (Metals). From the profile description, the waste may be categorized into three categories for this review: Neolube (Isopropanol), Paints/Enamels, and epoxy adhesives. Safety Data Sheet (SDS)
representing these three categories of material were reviewed with the following
information obtained:

Neolube (Isopropanol)

The SDS for Neolube No. 1 was examined for this review. The chemical name for Neolube is “Graphite in Isopropanol”. This product is a mixture of >50% Isopropanol and <5% Graphite. Neolube is flammable liquids and vapors with a flashpoint of 52 °F. It has a vapor density greater than air (heavier). The
boiling point is 35 °C. Neolube is not reactive and is chemically stable under
normal conditions of storage and use. Reactive or incompatible material would only occur with strong oxidizers.

Paint/Enamel
Several different paint and enamel SDSs were examined for this review. These products are a mixture of >25% Light Aliphatic Hydrocarbons, between 10-25% Calcium Carbonate, Titanium Dioxide <3%, and many other ingredients
<1% of the overall weight. The paints contain flammable liquids and vapors

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
with a flashpoint of 102 °F. It has a vapor density greater than air (5.0). The boiling point is 298 °F. The paints are not reactive and are chemically stable under normal conditions of storage and use. Reactive or incompatible material would only occur with oxidizers.

Epoxy Adhesives These products are generally a mixture containing approximately 35% benzyl
alcohol, 50-60% amines, and nonylphenol. The SDS for the product calls it a
corrosive spray-on epoxy surfacer. The product is combustible, but not flammable; with a flashpoint of 200 °F. The liquid is slightly heavier than water with a specific gravity of 1.02 and is not reactive with water. The product is stable and will not polymerize to hazardous products. Incompatible
materials include strong oxidizers, acids and alkalis. If the material were to
burn, its decomposition products include carbon monoxide, carbon dioxide, oxides of nitrogen, aldehydes, and ammonia.

All waste containers will remain 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.