DRC-2015-001368 - 0901a068804f35bf

ENERGYSOLUTIONS
DRC-2015-001368
February 5,2015 W CD15-0028
Mr. Rusty Lundberg
Director BhoEfVED
Utah Division of Radiation Control
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850 . : D UALITY
Subject: Radioactive Material License No. UT 2300249, Condition 16.F.i.
Non-aqueous Liquid Waste Stream 9509-24
Dear Mr. Lundberg:
In accordance with License Condition 16.F.i, EnergySolutions hereby requests Director
approval to receive non-aqueous liquids within waste stream 9509-24. The waste stream is
primarily debris for macroencapsulation treatment at the Mixed Waste Facility that may
contain small amounts of both aqueous and non-aqueous liquids. Non-aqueous liquids
present are expected to be used and hydraulic oils. From the "Derived-From" rule, many
codes are associated with this waste; however, the generator has certified that the non-
aqueous liquids will meet all required treatment standards.
Upon receipt, EnergySolutions will examine the waste and segregate out liquids from the
debris. The liquids will be sampled and analyzed to confirm they are below treatment
standards. After confirmation that the liquids are below treatment standards, they will be
solidified and disposed in the Mixed Waste Landfill Cell. If results show the liquids are
above treatment standards, the generator will be notified and a treatment plan developed.
The profile for waste stream 9509-24 is attached. In addition to the profile, an evaluation of
potentially harmful gases vapors or fumes associated with the waste is included.
Should there by any questions please contact me at [phone].
Sincerely,
Timothy L. Orton, P.E.
Environmental Engineer and Manager
Enclosures
cc: Phil Goble, DRC (w/encl.)
Otis Willoughby, DSHW (w/encl.)
423 West 300 South, Suite 200 • Salt Lake City, UT 84101
www.energysolutions.com
Attachment 1
Waste Profile
EN ERGYSQLUTIONS 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
Generator Name DOE Portsmouth EPA ID tf OH7890008983
Generator Contact James Fontaine Title Waste Disposition Manager
Mailing Address PO Box 548
Piketon. Ohio 45661 Utah Site Access Permit ft 1104 006 580
Phone [phone] Fax [phone] Email lames fontaineiaifbports com
Contractor Name Fluor B&W Portsmouth Location of Waste (Citv. State)' Piketon. Ohio
Name & Title of Person Completing Form James Fontaine Phone. [phone] Email lames fontain(a)fbports com
2. WASTE STREAM INFORMATION
Waste Stream ID 9509-24 Waste Stream Name. MLLW Debns With Free Liquids For Macro State of Origin OH
Revision. 4 Date- 01/08/2015 Volume (ft3). TBD Delivery Date. On-going
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 El 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 Q
Is the waste to be treated by EnergySolutions'' 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 El 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 1 le (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
ND If NO, check appropriate box NORM/NARM • I le (2) Byproduct Material • Other:
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 El 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?
YD N El If Yes, complete and attach the "PCB Waste Certification" form (EC-98279)
ASBESTOS: Does the waste contain Asbestos Containing Material7
Y El 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 Section B 5 of the waste profile '
Page 1 of 5
ENERGYSOLUTIONS 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 liquids9 (>1%) ND if Yes, what IS the percent of free liquid by waste 20%
If Yes, is the liquid aqueous (water-based)'' Y El Ng]
Density range of the
Does the waste contain absorbent'' Y El N • waste 9-110 g/cc • lb/ft' B
Concrete &
List percentage of waste type by volume Soil 10% Metal 10% DAW 20% Resins 0% Sludge J0%
Other constituents and percentage by volume'' 50% RCRA Debris
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" 90% 4" 90% 1"30% 1/4" 10% 1/40" 2% 1/200" I %
Does the waste stream contain oversize debris (i.e, no dimension < 10 inches and any dimension > 12 feet)? Y Q N El
If Yes, include a detailed description (i e, weight, size, drawings, etc) of the oversize debris in the narrative of Section B 5
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 NA% at Maximum Dry Density (lb/ft3)- NA
Average Moisture Content. NA % Moisture Content Range 0% - 20%
4. WASTE SHIPPING & PACKAGING
Transportation Mode. El Highway • Rail
Shipping & Container Packages El Drums* (< 85 gallons) El Boxes (< 100 ft3) • Soft-Sided Bags (< 10 yd3)
(Check all that apply)
• Intermodal • Sealand • Gondola** • Box Car
Other This waste stream may include drums up to 110 gallons capacity
'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 Materia] Safety Data Sheets associated with the waste as applicable
• Information requested in other sections of this form
9509-24 Rev 4 Page 2 of 5
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
Waste Stream ID: 9509-24 Revision: 4 Date of Revision: 01/08/2015
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? YQ N O
2. Does the waste material contain any of the following isotopes: Aluminum-26, Berkelium-247, Calcium-41, Californium-250,
Chlorine-36, Rhenium-187, Terbium-157, or Terbium-158? Y • N
3. Please list the following information for each isotope associated with the waste. Provide an explanation in the narrative description
of Section B.5 if the waste contains localized "hot spots" or elevated concentrations that significantly exceed the upper
concentration range If additional space is needed, provide an Attachment C.3 to this profile record formatted as below.
Manifested Upper Weighted Avg. Manifested Upper Weighted Avg.
Isotope Concentration per Container Isotope Concentration per Container
(pCi/g) (pCi/g) (pd/g) (pCi/g)
Tc-99 800000 3500
U-238 16500 5000
U-236 500 2
U-235 1900 500
U-234 38000 1000
Th-234 16500 5000
NP-237 500 50
Pu-238 500 50
U-232 500 50
Pa-231 500 50
Pu-239 500 50
Am-241 500 50
Pu-242 500 50
Th-230 500 50
Pa-233 500 50
Th-228 500 50
Pu-241 500 50
Th-232 500 50
9509-24 Rev 4 Page 3 of 5
ENERGYSOLUTIONS 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 Section B.5.
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
pH (Liquid only) Method 9045 Please provide the range of the pH analyses performed.
PFLT Fail 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 El If Yes, color' ; odor:
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 Attachment D.2 to this profile record formatted as below. Include a
description of hazardous waste determinations and any variances, exclusions, etc. in the narrative requested in Section B.5.
EPA HW
Codes
Description,
Constituent of Concern,
or Subcategory
F001 Trichloroethylene
D006 Cadmium
D008 Lead
D009 Mercury
Various
Treatment Standard
(mg/kg unless noted as
mg/L TCLP or
Technology Code)
6 mg/kg
0.69 mg/L
0.69 mg/L
Alternative Debris Standards, See Section B.S
0.15 mg/L
MACRO
Worst-Case
Concentration
(mg/kg unless noted
as mg/L TCLP)
9.63 mg/kg
12 mg/L
2100 mg/L
0.22 mg/L
NA
9509-24 Rev 4 Hazardous Waste Certification Attachment Page 4 of 5
EmRGYSOLUTIONS 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 Attachment D.3 to this profile record formatted as below.
Underlying Hazardous Treatment Standard (mg/kg unless noted as Worst-Case Concentration
Constituents mg/L TCLP or Technology Code) (mg/kg unless noted as mg/L TCLP)
NA
D. 4. OTHER CHEMICAL CONSTITUENTS
List any other chemical constituents of concern (e.g., PCDs, chelating agents, etc.) and worst-case concentrations. If additional
space is needed, provide an Attachment D.4 to this profile record formatted as below.
Worst Case Worst-Case
°tner Concentration Other Concentration
Chemical (mg/kg unless noted Hazardous (mg/kg unless noted
Constituents as mg/L TCLP) Constituents as mg/L TCLP)
5. LABORATORY CERTIFICATION INFORMATION
B 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 contajnany prohibitedjlems listed in EnergySolutions' Radioactive Material License or RCRA Permit.
Generator's Signature:
9509-24 Rev 4
Title:Waste Disp. Manager Date:01/26/20159+-
Hazardous Waste Certification Attachment Page 5 of 5
ATTACHMENT B.5
PHYSICAL PROPERTIES
Generator Name: U.S. Department of Enerpy/FBPorts Waste Stream ID: 9509-24
Revision #: 4 Revision Date: 01/08/2015
REVISION 4 - REVISED TO ADD RADIONUCLIDES AND TO ADD NON AQUEOUS LIQUIDS (OILS)
Revision 3 - This profile is being revised to allow for macro-encapsulation treatment of wastes that may contain
asbestos.
Revision 2 - This profile is being expanded to include waste that is generated as a result from clean-up and D&D
operations at the Portsmouth facility. The waste includes general debris consisting of DAW, PPE, concrete, plastic,
wood, PVC pipe, absorbent, bag filters, hand pumps, sand, etc. All of these waste are contaminated with RCRA
constituents. The waste requires treatment prior to disposal at EnergySolution's Mixed Waste Facility. The waste is
> 50% RCRA debris
Process knowledge and sampling and analysis are used to perform chemical characterization of the waste. Listed
codes may be assigned where F001 - F005 hazardous constituents are suspected. The waste may also include
characteristic codes of D003 thru D008, D009 (<260 mg/kg), DO 10 thru D043.
Please delete the reference to the Characterization Narrative for Mixed LLW Listed F001 PPE/Debris and Bag
Filters.
Please delete the SNM concentration references below and refer to the Radiological Information Section C of the
profile.
The enrichment for this profile does not exceed 10%.
Items to include in this attachment as applicable:
Revision 1 - Added the toxic metals that were identified by analysis of aqueous liquid from one of the containers.
The metals added are Cadmium, Lead and Mercury.
Please refer to the attached Characterization Narrative for Mixed LLW Listed F001 PPE/Debris and Bag Filters.
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
For waste streams with SNM, please include the information requested in items 3a through 3d of the SNM
Exemption Certification (form EC-0230-SNM) including:
• How the waste was generated
• Physical forms in the waste
• Uranium chemical composition (if applicable) - The uranium present in this waste is assumed to be in the
form of uranium oxides.
• How the waste was characterized
The range of SNM concentrations - U-235 ranges from zero to 0.27 pCi/g
• Analytical results with error values
9509-24 Rev 4 01/08/2015 Page I of2 EC-0230 Attachment B.5
ATTACHMENT B.5
PHYSICAL PROPERTIES
Spatial distribution uniformity of SNM - the SNM is assumed to be uniformly distributed throughout the
waste.
Determination of manifested concentrations - based on volumetric sampling and analysis and using the
highest observed activity concentrations.
For waste streams containing PCBs regulated for disposal, please provide a description of the PCB waste categories
listed on the PCB Waste Certification form (EC-98279) - PCBs are not associated with this material, as confirmed
by sampling and analysis.
This waste stream may contain both Friable and non-friable asbestos
Friable Asbestos will be managed, marked, and labeled in accordance with 40 CFR 61 Subpart M
9509-24 Rev 4 01/08/2015 Page 2 of2 EC-0230 Attachment B.5
Attachment 2
Non Aqueous Liquid Assessment
EN ERI,\SOLUTIONS
MEMORANDUM
Date:
To:
From:
Subject:
February 5, 2015
Vern Rogers
Tim Orton
Non Aqueous Liquid Assessment
Waste Stream 9509-24
The purpose of this memo is to evaluate Waste Stream 9509-24 for compliance with
Radioactive Material License conditions 16.B and 16.C. EnergySolutions intends to treat
the liquids associated with this waste stream by solidifying at the Mixed Waste Facility
and disposing at LLRW. 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 9509-24 is an existing waste stream that is primarily debris for
macroencapsulation treatment, but also contains liquids that need to be segregated from
the debris and managed separately. Previous liquid associated with this waste stream
were aqueous; in the current revision (Rev. 4), non-aqueous liquids are being added to the
profile. The non-aqueous liquids are in the form of oils, typically used oils and hydraulic
oils. All of the liquids are certified by the generator to be non-RCRA hazardous. The
Clive Facility will remove liquids found, analyze them for hazardous contaminants, and
treat or solidify prior to disposal in the Mixed Waste Landfill Cell.
MSDSs have been reviewed of both used oil and hydraulic oil for this analysis. A
description of the hazards identified follow.
Used Oil
The auto ignition temperature for used oil is 500 - 800 deg F dependent upon
the amount of volatile components present. The tlash point is >350 deg F.
Although the tlash 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
423 West 300 South, Suite 200 • Salt Lake City, Utah 84101
[phone] • Fax [phone] • www energysolutions com
EN I:RG\SOLUTIONS
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 MSDS for used oil does not state any incompatibilities with
water and it is considered stable under standard conditions.
Hydraulic Oil
Several different hydraulic oil and dielectric fluid MSDSs were examined for
this review. These liquids generally consist of paraffin petroleum solvents,
phosphorous compounds (phosphates and phosphorodithioic acids), and zinc
salts. The auto ignition temperature for hydraulic oils ranges from 600 to 1100
deg F. The flash point ranges from 350 to 700 deg F (higher for fire resistant
high temperature hydraulic fluids). Nevertheless, this material should not be
transported next to open flame sources, or subjected to excessively hot
conditions under standard environmental 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 nitrogen, sulfur, and phosphorous.
All waste containers will remained 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 MSDS information described above, this waste stream is
not capable of generating toxic gases, vapors or fumes in quantities that are hannful 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.
423 West 300 South, Suite 200 • Salt Lake City, Utah 84101
[phone] • Fax [phone] • www energysolutions com