DRC-2015-001369 - 0901a068804f35c0

¥.\¥R( A SOLUTIONS
February 5, 2015 CD 15-0029
Mr. Rusty Lundberg DRC-2015-001369
Director
Utah Division of Radiation Control
195 North 1950 West
P.O.Box 144850
Salt Lake City, UT 84114-4850
Dear Mr. Lundberg:
In accordance with License Condition 16.F.i, EnergySolutions hereby requests Director approval
to receive non-aqueous liquids within waste stream 9105-05. The waste stream is primarily
debris for macroencapsulation treatment at the Mixed Waste Facility that may contain small
amounts of non-aqueous liquids. Non-aqueous liquids present are solvents, particularly
trichloroethylene.
Upon receipt, EnergySolutions will examine the waste and segregate out liquids from the debris.
The liquids will be treated by thermal desorption. Many hazardous waste codes area associated
with this waste; post-treatment analyses will confirm the waste is treated to Land Disposal
Restriction requirements prior to disposal. Liquid condensate generated through this treatment
will be shipped off-site to a permitted facility for further treatment and subsequent disposal. The
solid fractions from this treatment will be disposed in the Mixed Waste Landfill Cell.
The profile for waste stream 9105-05 is attached. Note that a conservative approach of
examining the upper bound of all nuclides in a single shipment will exceed Class A limits;
however, as stated in the Attachment B.5., Physical Properties, section of the profile, the
generator will review all shipments against Class A parameters and will not ship wastes that are
above Class a limits. This calculation is further checked by Clive personnel prior to the shipment
arriving at Clive. 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].
Timothy L. Orton, P.E.
Environmental Engineer and Manager
Enclosures
cc: Phil Goble, DRC (w/encl.)
Otis Willoughby, DSHW (w/encl.)
Subject: Radioactive Material License No. UT 2300249, Condition 16.F.i.
Non-aqueous Liquid Waste Stream 9105-05
Sincerely,
423 West 300 South, Suite 200 • Salt Lake City, UT 84101
www.energysolutions.com
Attachment 1
Waste Profile
ENERG\SOLVTIOyS EC-0230
Revision 6
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 docs not apply
1. GENERATOR INFORMATION
Generator Name Idaho National laboratory. DOR L:PA ID tt ID4890008952
Generator Contact Bruno Zovi Title MLLW Program Manager
Mailmc Address 850 Energy Dr.
Idaho Falls. ID 83401 Utah Site Access Permit ft 1110007102
Phone [phone] Faxi208)5S7-7803 Email James.ZovKSamwtp inl.com
Contractor Name Idaho Treatment Group Location of Waste (Citv. State) INI-ZScnville ID
Name & Title of Person Completing Form Kris Smith Phone [phone] Email Kris Smilh(S)amwlp inl.gov
2. WASTE STREAM INFORMATION
Waste Stream ID 9105-05 Waste Stream Name VTD Liquids / Mixed Wasle Debris with > 1% Liquid Slate of Origin ID_
Revision ^ Date 01/19/2015 Volume (ft1) 25.000 Delivery Date 2/15/2015
CHECK APPROPRIATE BOXES BELOW. Please verify the required forms requested below are completed and submitted wilh Ihe Radioactive
Waste Profile Record.
HAZARDOUS WASTE: Is the waste classified as hazardous waste as defined by 40 CFR 26 19
N D If NO, complete and attach the "Low-Level Radioactive Waste Certification Attachment"
Y Kl If YES, complete and attach the "Hazardous Wasle Certification Attachment" and check applicable box below
Has the waste been treated to meet applicable treatment standards per 40 CFR 268? YD N E
Is the waste to be treated by EnergySolutions9 Y H 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 19
Y El If YES, a current copy of a LLRW Compact Export letter authorizing export must be submitted if applicable This authorization is applicable
for non-DOE LLRW (i e , Mixed Waste, NORM/NARM, I le (2) material, and waste from DOE do not require a Compact Export Letter)
N • If NO, check appropriate box NORM/NARM • 1 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-2449
Y0 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 arc regulated for disposal per 40 CFR 7619
YD N Kl If Yes, complete and attach the "PCB Waste Certification" form (EC-98279)
ASBESTOS: Does the waste contain Asbestos Containing Material9
Y El N D 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 ofthe waste profile.
Page 1 of5
ENERGYSOLUTIONS
RADIOACTIVE WASTE PROFILE RECORD
EC-0230
Revision 6
B. WASTE PHYSICAL PROPERTIES & PACKAGE INFORMATION
1. GENERAL CHARACTERISTICS
Docs the waste contain free liquids? Y 13 ND If Yes. whal is the percent of free liquid by waste volume9 >1%
If Yes, is the liquid aqueous (water-based)'' Y El N El
Does the waste contain absorbent'' Y El ND Density range of the wasle 10 - 150 p/cc l~l lb/ft'El
List percentage of waste type by volume Soil 5% Concrete & Metal 43_% DAW 5Q% Resins % Sludge %
Other constituents and percentage by volume'' >l% liquid, both aqueous and non-aqueous (VTD) solvents such as TCP.
2. MATERIAL SIZE
Gradation of Material Indicate the percentage of waste material that would nass 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" 25.% 4" 25% l"20% 1/4" 12% 1/40" 5% 1/200" 5%
Does the waste stream contain oversize debris (l c , no dimension < 10 inches and any dimension > 12 fect)'' YD N El
If Yes, include a detailed description (i c . weight, size, drawings, etc ) ofthe oversize debris in the narrative of Section B 5
3. MOISTURE CONTENT
For soil or soil-like matenals. please use Std. Proctor Method ASTM D-698 lo determine the optimum moisture content The wasle material must
not exceed 3 percentage points above optimum moisture upon arrival at EnergySolutions' disposal facility unless approved by EnergySolutions
Optimum Moisture Content NA % al Maximum Dry Density (lb/ft1) NA
Average Moisture Content NA % Moisture Content Range NA% - NA%
4. WASTE SHIPPING & PACKAGING
Transportation Mode El Highway D Rail
Shipping & Container Packages El Drums* (S 85 gallons) El Boxes (S 100 ft') El Soft-Sided Bags (S 10 yd')
(Check all that apply)
D Intermodal El Scaland D Gondola" D 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 lo 12 5 fect in height as measured from the top ofthe rail to the
top ofthe railcar unless approved by EnergySolutions
5. NARRATIVE DESCRIPTION AND HISTORY OK WASTE
Please submit a narrative description and history ofthe 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
9105-05 RevO Page 2 of5
ENERGYSOII™VS
RADIOACTIVE WASTE PROFILE RECORD
EC-0230
Revision 6
Wasle Stream ID: 9105-05 Revision: 0
C RADIOLOGICAL INFORMATION
Date of Revision: 01/OS/201S
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. Docs the waste material contain accessible surfaces with contact dose rates greater than 500 mR/hr? YQ
1. Does the waste material contain any ofthe following isotopes: Aluminum-26, Berkelium-247, Calcium-41. Califomium-250.
Chlorine-36, Rhenium-187, Terbium-157, or Terbium-158? Y • NS
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.
Isotope
Ac-227
Am-241
Manifested Upper
Concentration
(pCi/g)
1.79E+02
7.00E+03
Weighted Avg
per Container
(pCi/g)
4.001--01
1.60E+03
Isotope
Manifested Upper
Concentration
(pCi/g)
Weighted Avg.
per Container
(pCi/g)
Am-243
Co-60
1.53E+00
1.00E+03
1.50E-01
1.68E-02
Cs-137
Eu-152
2.87 E+04
2.81 E+00
6.00E-02
1.4IE-0I
K-40
Np-237
4.97E+00
2.69E-01
2.90E+00
I.30E-01
Pu-238
Pu-239
Pu-240
Pu-241
Pu-242
7.95E+03
1.00E+04
1.54E+03
2.03E+04
2.00E-0I
7.00E+03
1.40E+03
I.30E+04
1.50E-0I
Ra-226
Sr-90
5.00E+02
3.16 E+03
1.60E-0I
7.00E-02
Th-232
U-232
U-233
U-234
U-235
U-238
I.00E+02
7.49E+00
I.62E+03
1.00E+04
6.75 E+02
1.50E+04
4.32E-0I
7.50E-0I
1.00E-01
2.30E-01
2.30E-01
5.00E+02
9105-05 RevO Page 3 of5
ENERGYSOLUTKXVS
RADIOACTIVE WASTE PROFILE RECORD
EC-0230
Revision 6
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.S.
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) NA Method 9045 Please provide the range ofthe pH analyses performed
PFLT NA Pass / Fail Method 9095 Nol 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 odor9 Y • N Kl 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.S.
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)
See D 2 Attachment
9105-05 RevO Hazardous Waste Certification Attachment Page 4 of 5
ENERGYSOLUTIONS EC-0230
Revision 6
3. UNDERYLYING 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)
None
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.
Worst Case Worst-Case
Concentration Other Concentration
(mg/kg unless noted Hazardous (mg/kg unless noted
as ma/L TCLP) Constituents as mg/L TCLP)
Other
Chemical
Constituents
None
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 ofthe 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)
NA
CERTIFICATION
I certify that sample results representative ofthe 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 arc 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 lo EnergySolutions I certify that
the waste does not contain any prohibited items listed in EnergySolutions' Radioactive Material License or RCRA Permit.
Generator's Signature Title:Waste Specialist Date: 01/19/2015
9105-05 RevO Hazardous Waste Certification Attachment Page 5 of 5
ATTACHMENT B.5
PHYSICAL PROPERTIES
Generator Name- INL for U.S. DOE Waste Stream ID: 9105-05
Revision #. 0 Revision Date: 01/19/2015
1. Process that generated the waste
The VTD Liquid/Mixed Waste Debris with Greater than 1 % liquid profile establishes bounding
parameters of waste generated as a result of activities at several facilities within the DOE Complex.
The wastes were shipped to and stored at the Idaho National Laboratory (INL) formally known as the
Idaho National Engineering and Environmental Laboratory (INEEL). The wastes were generated
from Decommissioning and Decontamination (D&D), facility modification, facility closure, materials
retrieval and equipment maintenance, and waste repackaging efforts. The waste associated with this
profile was originally generated at DOE facilities including, but not limited to, Rocky Flats, Mound
Facility, Bettis Laboratory, Battelle Columbus Lab and LNL. In July of 2010, AM WTP began
accepting waste from other DOE facilities for processing including but not limited to Hanford and
Las Alamos National Laboratory. Incoming waste is expected to be Transuranic Waste (TRU) and
will be shipped to WIPP however newly generated waste will be generated while handling this waste.
Hazardous waste codes have been updated to include any codes associated with incoming waste.
The INL's, AMWTP has performed characterization of the waste as part of the TRU process for
disposal at the Waste Isolation Pilot Project (WIPP). The wastes were originally believed to be
classified as TRU Wastes, however as a result of classification activities at the LNL, some waste has
been determined to be Low Level Mixed Waste (LLMW) meeting the definition of LLMW found in
the Low Level Radioactive Waste Policy Act, Public law 96-573.
The waste radionuclide concentrations have been reviewed against the requirements of the
classification tables found in Utah Administrative Code (UAC) R313-15-1008 and meet the
requirements as Class A Unstable waste for disposal at the EnergySolutions Bulk Waste Disposal
Facility located in Clive, UT.
The waste is packaged in metal, wood, and fiberglass containers. Containers are 55 gallon, 83 gallon,
85 gallon, and 100 gallon product drums. Box sizes include, but are not limited to BR-90's M-III/M-
rv* Bins, and SWB and half SWBs. The boxes and drums may not have DOT pedigree. If DOT
pedigree cannot be provided waste will be shipped in LP-l/IP-2 soft-sided bags or may also be placed
in LP-1 or IP-2 sealand/cargos containers for shipping purposes and will be removed from the
sealand/cargos for management at Clive.
2. Waste materials physical composition and characteristics
Waste shipped under profile 9105-05 will primarily be comprised of debris including, but not limited
to electrical components, lead shielding, concrete, laboratory debris, process piping and equipment,
and DAW (plastic sheeting, PPE, wood, paper, etc.). Containerized liquids, both aqueous and non-
aqueous, are expected to be present in volumes exceeding 1 % of the waste package disposal volume.
Newly generated debris will be characterized based on Acceptable Knowledge of the codes and
isotopes contaminating new gen waste, operational procedures, operational logs and visual
examination of the waste. RTR may also be used in rare cases to assist in characterization of new gen
waste. Primary waste will also be characterized utilizing visual examination. In addition to a
EC-0230 Attachment B.5
thorough review of historical documentation, each primary waste container has undergone processing
through a Real Time Radiography (RTR) system. RTR analyses with container specific content
descriptions have been completed for each container and will be made available to Energy Solutions
with the 5 day advanced notification. Every effort has been made to ensure waste characterization is
accurate and will provide EnergySolutions with the information necessary to safely and compliantly
manage this waste stream.
An example of RTR container analysis that will be made available to EnergySolutions is provided
below:
Containers NW J. RTR Review Comments
10000872 Overpacked FRP. electrical cable, rubber hose, scrap metal, glove boxes, metal tubing, sheet metal of lead in
glove box (~3"x 14"), electric motor. 3 lead bncks. pliers, metal trays, glass lab wear Cannot penetrate, ~ 2
gallons of liquid in the bagging within the waste , 1/4 cup liquid in plastic bottle, several areas of
containerized liquid (total 1 pint) Could not identify the aerosol can the operator called out Greg believes it is
actually a connection on the glove box
10001042 Cardboard Liner, plastic liner, scrap inetal tubing with littings, electrical boxes, drum rings, cloth, structural steel.
wood, electric motor Large steel object (electric motor00! in bottom comer could not be penetrated 20 ml
residual liquid in metal pipe
1 0001048 Cardboard, plastic sheeting, PPE, scrap metal, poly bottles, electrical cord, scissors, metal wire, metal pipes,
respirator cartridges. Large dense metal sealed container with ~ I gallon of liquid The impenetrable area
appears to be multiple layers of metal pipes, tins area encompasses the lower quarter of the box 2 cups liquid in
poly bottles and 2 tablespoons liquid in poly bottle. I cup liquid in bag pocket. 1/2 cup liquid in bag pocket
behind edge of dense piping.
Waste Management
The AM WTP has completed due diligence efforts to ensure identification and exclusion of waste
items that are not in compliance with EnergySolutions Waste Acceptance Criteria and applicable
licenses and permits. There remains, however, some small probability that non-conforming items
will be identified during sort and segregation operations. Should non-conforming items be identified,
AMWTP will be notified immediately and an alternate disposition path forward will be implemented.
Prior to waste processing, the RTR summary will be reviewed by EnergySolutions site personnel for
each container as necessary. The focus of the review will be to pre-identify items that may require
treatment other than macroencapsulation. These items may include:
Liquids: Most liquids are believed to be contained. Liquids, both aqueous and non-aqueous, will be
segregated for processing through the vacuum-assisted thermal desorption unit (VTD). VTD
condensate will be shipped off-site for incineration. VTD residues will be sampled and stabilized (if
necessary) prior to disposal.
Aerosol Cans: AK documentation indicates the potential presence of aerosol cans in this waste
stream. RTR provides an indication of whether or not the cans have been depressunzed. All aerosol
cans will be segregated and inspected for depressurization. Depressurized aerosol cans will be
managed as debris and macroencapsulated. Aerosol cans believed to be pressurized will be returned
to the LNL AMWTP, or be managed by Energy Solutions as appropriate.
Sealed Sources: AMWTP recognizes that EnergySolutions is prohibited from the receipt of sealed
sources. Every effort has been made to ensure sources are not present in this waste stream. However,
as a legacy waste there exists a very small potential that physical segregation activities reveals the
EC-0230 Attachment B.5
presence of a source. Should a source be identified, AMWTP is to be immediately contacted and
arrangements will be made for return shipment to the INL.
Incidental Soils/Sludges: Incidental (<5% by volume) soils or sludges will not be segregated from
the debris waste stream. Soils or sludges present in appreciable volumes (>50% per waste container)
will be segregated, sampled, and stabilized (if required).
PCB Items: PCB items will not be shipped in the 9105-05 profile but rather another EnergySolutions
profile specifically established for the management of PCBs.
Lead Acid Batteries: Lead acid batteries may be found within debris boxes and will need to be
removed and drained by Energy Solutions.
The following may be present in the waste and requires special labeling and handling.
Asbestos: Debris waste may contain small volumes of friable asbestos in the form of D&D waste.
Suspected asbestos waste will be properly packaged and containers will be properly marked and
labeled.
Beryllium: A percentage of containers will be labeled with Beryllium stickers. The concentration of
Beryllium in the containers is known to be less than 2 ug/g, as was measured at AMWTP. AMWTP
monitors for Beryllium due to the acceptable knowledge documentation but has never had to control
worker environments from an IH perspective due to Beryllium measurements in the waste.
AK Debris Constituents:
Most of the low-density debris material is organic in that it is a chemical compound that contains
carbon (blotter paper, plastics, cotton cloth).
Low-density hazardous debris is comprised of the following:
• Plastic materials (polyethylene, polyurethane, and PVC) primarily used for radioactive
contamination control purposes (bags, sheets, tubing, HEPA ventilation duct), and
personnel protective equipment (PPE-bubble hoods, booties, shoe covers)
• PPE - Tyvek, cloth anti-contamination clothing, rubber, latex and neoprene gloves, leather
gloves, respirator cartridges, rubber boots
• Miscellaneous - Masslin wipes, terry towels, blotter paper, duct tape, filters, cotton, tools
and equipment, scrap metal
• Graphite molds and cores
• Plexiglas and Benelex materials
• Blacktop (asphalt, concrete, dirt and sand)
• Fire brick and insulation materials
• Filter media and CWS Filters
• Leaded rubber gloves and aprons, bricks, sheets, etc.
• Wood - pieces of dimensional lumber, plywood, used pallets.
Organic constituents are typically associated with various EPA listed waste numbers applied to
the debris. The listed waste codes are applicable to the debris enveloped by this waste stream
because it has come in contact with listed organic waste contaminants. See Attachment D.2. for a
list of the applicable EPA hazardous waste numbers.
EC-0230 Attachment B.5
Inorganic Constituents:
Lead is suspected to be present in the form of standard 2"x 4"x 8" brick or pieces of brick, lead
blankets enclosed in plastic, lead wool, lead plates and sheets, lead shot, and various molded lead
configurations to conform to the shape of pipes, valves, and other components for the purpose of
radiological shielding.
Metal debris items consist of generic stainless and carbon steel shapes and sizes, pieces of chain,
nuts and bolts, brass, bronze, cadmium plates and sheet, copper, leaded cable, fuel racks with
cadmium sheeting or filters with cadmium plated metal housings.
5. Radiological and chemical characterization methods
The waste containers have been characterized for radionuclide content by direct method measurement
utilizing WIPP certified spectral gamma measurement techniques. The spectral gamma
measurements for all containers in this waste stream have identified nuclides below the lower limit of
detectibility for the instrumentation and geometry utilized.
While it is not possible to define an accurate radiological source term for individual drums that fall
below the LLD of the NDA instrumentation, it is possible to define an aggregate radiological source
term for a defined waste stream.
The method used to define such a source term is based on the simple summation of the gamma ray
spectra associated with the NDA measurements of the individual drums in the waste stream. This
composite spectrum is then analyzed using the same algorithms that are applied to the individual
measurements. This method provides a means to determine the radiological content of the entire
waste stream; the radiological content of the individual containers may then be estimated based on the
assumption that the radiological source term is evenly distributed throughout the waste stream.
The advantage of this approach is that the composite spectrum represents a significantly longer data
acquisition time than is practical on an individual container basis. This increase in the effective data
acquisition time results in significantly improved counting statistics. This allows for a determinate
measurement of the radiological source term for the waste stream. A description of the spectral
summation methodology is provided as an attachment to this profile.
The LLD for an NDA measurement is defined as; The LLD is that level of radioactivity, which, if
present, yields a measured value greater than the critical level with a 95% probability, where the
critical level is defined as that value which measurements of the background will exceed with 5%
probability.1 It turns out that the LLD is entirely due to the quality of the counting statistics, and, as a
rule of thumb the LLD corresponds to a measurement for which the uncertainty, due to counting
statistics, is approximately 30%. The radionuclide distribution comes from two sources depending on
the original generator of the waste. Waste covered by this profile was generated during the
development of radioactive sources for the production of heat for conversion to electric power (Heat
Source Plutonium - HSP) and waste generated for the production of nuclear weapons (Weapons
Grade Materials - WGM).
1 Contact-Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant, DOE/WIPP-
02-3122 Rev. 3.0
EC-0230 Attachment B.5
Nuclides that are not identifiable, by the use of gamma ray spectroscopy, were scaled using scaling
factors developed from the expected nuclide distribution identified in the respective AK document.
Any waste stream, per AK document, that identifies the presence of Cs-137 will also carry the
appropriate Sr-90 contribution based on a one to one scaling.
Chemical content determinations are made by review of available AK documentation. Each waste
stream has been subject to an extensive document review and has been characterized as having a
chemical constituent, if in the processes that generated the waste involved the use of an identified
chemical constituent.
In many cases, materials were identified during the inspection of the waste materials at the LNL
AMWTP. If during the inspection processes a hazardous material identification was made, the
appropriate hazardous waste code was applied to the container. An example of this is, a waste code
applied to a waste container after head gas measurement confirmed the presence of a volatile organic.
Basis for determining manifested radionuclide concentrations
The methodology that will be used to develop radionuclide activities that are entered on the manifest
will utilize a nuclide distribution for Weapons Grade Materials and/or Heat Source Plutonium
Materials. The nuclide distribution is developed by utilizing the actual nuclide activity or LLD for
the detection system and establishing an average nuclide concentration. This concentration is then
multiplied by the net weight of the waste materials to establish the total manifested activity for the
given waste volume.
Nuclides that were identified in a small number of containers will be identified in those specific
containers. An example of those nuclides are U-233, which was identified in approximately seven
containers will be manifested in those containers.
The concentration value of each container will be determined using the appropriate nuclide
distribution model. This method should provide a conservative radionuclide concentration for a given
container.
In some cases, both nuclide distributions will be utilized for a single container. These containers will
be those that contain "Super Compacted" drums from multiple generators and placed into the same
large over pack container. In these cases, the individual compacted drum will be characterized and
the total contents will be added together to obtain the final waste activities.
The nuclide distribution for HSP generated waste is Pu-238 (80% to 83.5%), Pu-239 (13.8% to
16.5%), Pu-240 (2.0% to 3.05%), Pu-241 (0.39% to 0.8%) and Pu-242 (0.08% to 0.2%).
The nuclide distribution for WGM is Pu-238 (.01 to .05%), Pu-239 (92.8% to 94.4%), Pu-240 (4.85%
to 6.5%), Pu-241 (0.3% to 1%) and Pu-240 (0.005% to 0.06%). This source term may also contain a
small amount of Enriched Uranium (enrU) contaminated waste. The distribution of nuclides
associated with the enrU is Th-231 (<0.001%), Th-234 (< 0.001%) U-234 (~ 0.1%), U-235 (90% to
93%), U-236 (-0.4%) and U-238 (-5.3%) There could also be a small amount of Depleted Uranium
(depU) contaminated waste identified in this waste stream. The nuclide distribution for depU is Th-231
(<.001%), Th-234 (< 0001%), U-234 (<.0001%), U-235 (~. 02%) and U-238 (99.8%).
Other isotopes that have been identified in the WGM waste stream include small quantities of fission
products that were added due to research and development activities at the initial generator sites.
EC-0230 Attachment B.5
Natural occurring isotopes have also been identified in the waste materials during analysis. These
isotopes include Th-232, Ra-226 and K.-40.
New gen pallets were generated for shipment on New Gen 8 campaign. Pallets would not fit into the
assay unit. Source term was determined by determining the surface activity and applying it across the
surface area of the pallets and /or the average concentration distributed according to the waste mass,
as appropriate.
Basis of non-hazardous or hazardous waste determinations
a. Listed Hazardous Waste:
The EPA listed hazardous waste codes associated with this campaign are as follows: F001, F002,
F003, F004, F005, F006, F007, F009, P030, P098, P099, P106, U003, U103, U108, U134 and
U151. These codes originate from listed waste that has come in contact with the debris addressed
in this waste stream. This determination is based upon knowledge of the parent waste streams and
processes involved in the generation of the waste, and are documented by the applicable
Acceptable Knowledge Documents identified in the reference section. The application of these
listed hazardous waste codes is per the "Contained-In Rule" 261.3(f)(2). No appreciable
concentrations of solvents or other listed hazardous wastes (per respective hazardous waste code)
are expected.
Containers that have containerized liquids and are subject to U134 EPA Hazardous Waste Code
will not be shipped to Energy Solutions for treatment and/or disposal. Containers that do not
have containerized liquids and have been assigned the U134 EPA Hazardous Waste Code
because of possible contact with Hydrofluoric Acid could be shipped to Energy Solutions for
treatment and/or disposal.
Containers that have containerized powders and are subject to P098, P099 and PI06 EPA
Hazardous Waste Codes will not be shipped to Energy Solutions for treatment and/or disposal.
Containers that do not have containerized powders and have been assigned the P098, P099 and
PI 06 EPA Hazardous Waste Code because of possible contact with potassium cyanide, potassium
silver cyanide and sodium cyanide could be shipped to Energy Solutions for treatment and/or
disposal.
Attachment D.2. provides a list of the hazardous waste codes.
b. Characteristic Hazardous Waste:
The waste contains various metallic lead items, cadmium metal pieces, residues from various
metal handling and chemical operations. The waste was also generated through the
decontamination and decommissioning efforts of the various facilities. The EPA waste code
numbers are: D001, D002, D004, D005, D006, D007, D008, D009, DO 10, DOI 1, DOI 8, DO 19,
D021, D022, D026, D027, D028, D029, D030, D031, D032, D033, D034, D035, D036, D037,
D038, D039, D040, and D043 and applied based upon knowledge of the material itself and/or
historical handling and clean up from the handling of such materials as discussed herein. D001 is
also applicable when a container is noted as having an aerosol can present. The aerosol can will
be separated from the debris and treated appropriately.
EC-0230 Attachment B.5
The low-density debris is declared to exhibit the toxicity characteristic for lead, cadmium,
chromium, arsenic, barium, and mercury. The D006 and D008 EPA waste numbers are typically
declared for the low density debris because it was used in or around processes where it was
known to have come in contact with lead and cadmium metal, or was exposed to lead or cadmium
in the form of small particles, oxides, or pigments. In addition, data (TCLP, EP Toxicity, and
Total Metals) from historical sampling and analysis efforts and additional process knowledge
information supports declaration of EPA waste numbers D002 (corrosive - batteries), D004
(arsenic), D005 (barium), D007 (chromium), D009 (mercury - low mercury subcategory), DO 10
(selenium) and DOI 1 (silver). When container contents warrant regulatory subcategories they
will be applied appropriately (i.e. batteries will receive a "Radioactively contaminated cadmium /
mercury battery category'' and elemental lead will receive the "'Radioactive Lead Solids
Subcategory".
Some of the debris in this campaign may have come in contact with waste carrying the following
characteristic codes: DOI8 (Benzene), DOI9 (Carbon Tetrchlonde), D021 (Chlorobenzene), D022
(chloroform), D026 (Cresol Mixtures), D027 P-Dichlorobenzene, D028 (1,2-Dichloroethane),
D029 (1,1-Dichloroethylene), D030 -2,4-Dinrtrotoluene, D031 (Heptachlor), D032
(Hexachlorobenzene), D033 (Hexachlorobutadiene ), D034 (Hexachlorobutadiene), D035
(Methyl ethyl ketone), D036 (Nitrobenzene), D037 (Pentachlorophenol) D038 (Pyridine ),
D039 (Tetrachloroethylene), D040 (trichloroethylene) and D043 (Vinyl Chloride). This debris
consists of gloves, bag cutters, parts of plastic liners and PPE. Codes are applied based on the
potential of the debris to come in contact with waste.
In summary, application of characteristic EPA waste numbers is based primarily upon process
knowledge of the material itself (e.g. metallic lead, cadmium, silver or lead solder) as
documented in Acceptable Knowledge documents identified in Section 10, References. Waste
numbers applied to the low-density debris is also based upon process knowledge of the debris and
are declared based upon that knowledge as described above. Historical data exists that supports
declaration of the EPA waste numbers for these items but in some cases is specific processes
(PPE generated while handling lead or cadmium, discarded leather gloves) and is used generically
to support declaration of EPA waste numbers.
8. Treatment Processes, if applicable
The debris waste stream has not been subject to treatment processes. Some items are identified for
segregation prior to treatment to ensure proper treatment in compliance with the Land Disposal
Restrictions.
9. Information requested in other sections of this form
a. Special Nuclear Materials
The waste contains Special Nuclear Materials (SNM) in solid physical form. The SNM are in the
metal oxides with a very small fraction (<1%) as metal nitrate form. The wastes were generated as
a result of nuclear weapons production or heat source production operations.
The SNM isotopes are distributed through the waste essentially uniformly as contaminated debris
materials. There are no discrete objects or point source materials within the waste matrix containing
SNM.
EC-0230 Attachment B.5
The document "Determination of Radioisotopic Content in TRU Waste Based on Acceptable
Knowledge" AMWTP-RPT-TRUW-07 is the basis for determination ofthe SNM content ofthe
wastes. Each container of waste has received nuclide identification by WLPP certified spectral
gamma measurement techniques. Nuclides that are not identifiable by the use of gamma ray
spectroscopy were scaled using scaling factors developed from the expected nuclide distribution
defined in the respective AK documentation.
The LLD for an NDA measurement is defined as; The LLD is that level of radioactivity, which, if
present, yields a measured value greater than the critical level with a 95% probability, where the
critical level is defined as that value which measurements of the background will exceed with 5%
probability. It turns out that the LLD is entirely due to the quality of the counting statistics, and, as a
rule of thumb the LLD corresponds to a measurement for which the uncertainty due to counting
statistics is approximately 30%. Gram concentrations are developed by utilizing specific activity
calculations for the identified nuclides applied to the waste mass. In many cases, gram quantities
have been verified by neutron analysis of the containers. The debris waste stream containers are
expected to contain less than 10 grams of fissionable materials.
10. REFERENCES:
a. AMWTP-RPT-TRUW-05, Current Rev., Waste Matrix Code Reference Manual
b. AWMTP-RPT-TRUW-07, Current Rev., Determination of Radioisotopic Content in TRU Waste
Based on Acceptable Knowledge
c. AMWTP-RPT-TRUW-12, Current Rev., AMWTP Waste Stream Designations
d. AMWTP-RPT-TRUW-l 3, Current Rev., Acceptable Knowledge Document for LNL Stored
Transuranic Waste - Mound Plant Waste
e. AMWTP-RPT-TRUW-56, Current Rev., Acceptable Knowledge Document for LNL Stored
Transuranic Waste - Rocky Flats Plant
f. AMWTP - TRUW-30, Current Rev., Acceptable Knowledge Summary for Supercompacted
Debris Waste (BN510)
g. AMWTP-TRUW-04, Current Re., Acceptable Knowledge for Battelle Columbus Laboratories
Building JN-4 Plutonium Laboratory
h. AMWTP-RPT-TRUW-83, Current Rev. Acceptable Knowledge Summary for Supercompacted
Debris (BN510.1)
l. EDF-0775, Engineering Design File, Mixed Low Level Waste Debris Characterization , K.A.
Smith
j. AMWTP-RPT-TRUF-92, Acceptable Knowledge Document for Select Idaho National
Laboratory (LNL) Facilities
k. An NDA Technique for the disposition of Mixed Low Level Waste at the Advanced Mixed
Waste treatment Project, M.J. Clapham, J.V. Seamans
EC-0230 Attachment B.5
Attachment D.2 to Waste Profile 9105-05 Rev 0
This revision is submitted to include newly generated containers, characterization established based on a
new revision of RPT-TRUW-12. New codes are a result of waste shipped to AMWTP for processing. As a
result ofthe process activities new gen waste codes are assumed to be contaminated with all codes of
associated primary waste.
Hazardous Waste Codes and Treatment Standards (40 CFR 268)
EPA Hazardous
Waste Code
Description, Constituent of Concern or Subcategory Treatment Standard
D00I lgnitable RORGS:CMBST: or POLYM
D002 Corrosives & (Batteries) MACRO
D004 Arsenic MACRO
D005 Barium MACRO
D006 Cadmium MACRO
D006 Radioactively Contaminated Cadmium Containing Batteries MACRO
D007 Chromium (Total) MACRO
D008 Radioactive Lead Solids MACRO
D008 Lead MACRO
D008 Lead Acid Battery RLEAD
D009 Low Subcategory Mercury MACRO
D009 High Subcategory Mercury MACRO
D009 Radioactively Contaminated Mercury Containing Batteries MACRO
D010 Selenium MACRO
D011 Silver MACRO
D018 Benzene MACRO
D019 Carbon Tetrachloride MACRO
D021 Chlorobenzene MACRO
LX)22 Chloroform MACRO
D026 Cresol Mixtures (o-, m-, p-) MACRO
D027 P-Dichlorobenzene MACRO
D028 1,2-Dichloroethane MACRO
D029 1,1 -Dichloroethylene MACRO
D030 2,4-Dinitrotoluene MACRO
D031 Heptachlor MACRO
D032 Hexachlorobenzene MACRO
D033 Hexachlorobutadiene MACRO
D034 Hexachloroethane MACRO
D03S Methyl ethyl ketone MACRO
D036 Nitrobenzene MACRO
D037 Pentachlorophenol MACRO
D038 Pyridine MACRO
D039 Tetrachloroethylene MACRO
D040 Trichloroethylene MACRO
D043 Vinyl chloride MACRO
F001 1,1,1 -Trichloroethane MACRO
FOOT 1,1,2-Trichloro-1,2,2-tjjfluoroethanc MACRO
F001 Carbon Tetrachloride MACRO
F001 Methylene Chloride MACRO
F001 Tetrachloroethylene MACRO
F001 Trichloroethylene MACRO
F001 Trichlorofluromethane MACRO
9105-05 Rev 0
EPA Hazardous
Waste Code
Description, Constituent of Concern or Subcategory Treatment Standard
F002 1,2-dichlorobenzcne MACRO
F002 1,1,1 -Trichloroethane MACRO
F002 1,1,2-Trichloroethane MACRO
F002 1,1,2-Trichloro-1,2,2-trifluoroethane MACRO
F002 Carbon Tetrachloride MACRO
F002 Methylene Chloride MACRO
F002 Tetrachloroethylene MACRO
F002 Chlorobenzene MACRO
F002 Trichloroethylene MACRO
F002 Trichlorofluromethane MACRO
F003 Acetone MACRO
F003 1-butanol MACRO
F003 Cyclohcxanone MACRO
F003 Ethyl Benzene MACRO
F003 Ethyl Ether MACRO
F003 Methanol MACRO
F003 Methyl Isobutyl Ketone MACRO
F003 Xylenes - mixed isomers MACRO
F004 Cresols MACRO
F004 Nitrobenzene MACRO
F005 2-Ethoxyethanol MACRO
FOOS 2-Nitropropane MACRO
FOOS Benzene MACRO
FOOS Carbon Disulfide MACRO
F005 Isobutanol (Isobutyl Alcohol) MACRO
F005 Methyl Ethyl Ketone MACRO
F005 Pyridine MACRO
F005 Toluene MACRO
F006 Electroplating Sludges MACRO
F007 Cyanides Plating Bath Solutions MACRO
F009 Chromium (Total) MACRO
F009 Cyanides Cleaning Bath Solutions MACRO
P030 Cyanides (soluble salts and complexes) MACRO
P098 Potassium Cyanide MACRO
P099 Potassium Silver Cyanide MACRO
P106 Sodium Cyanide MACRO
U003 Acetonitrile MACRO
UI03 Dimethyl sulfate MACRO
U108 1,4-Dioxane MACRO
U-134 Hydrogen Fluoride MACRO
U151 Mercury MACRO
The basis of characterization for this waste stream is founded on the definition of debris per 40 CFR §268.2 (g). In particular,
"A mixture of debris that has not been treated to the standards provided by § 268.4S and other material is subject to the
regulation as debris if the mixture is comprised primarily of debris, by volume based on visual inspection."
These hazardous waste codes are applicable to waste forms that meet the definition of hazardous debris and may be treated in
accordance with the alternative treatment standards for hazardous debris, 40 CFR 268.45.
9105-05 Rev 0
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: 9105-05 Manifest No.
ENERGYSOLUTIONS
1. Check applicable category below for the waste stream:
Uranium
Enrichment
Percent
Weight Percent
of Chemicals
in 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:
ISI a. Concentrations of SNM in individual waste containers do not exceed the applicable values listed in the
above table and SNM isotope concentrations listed in Table 1.
El b. The SNM is homogeneously distributed throughout the waste or the SNM concentrations in any
contiguous mass of 600 kilograms (1,323 lbs) do not exceed on average the specified limits. (Based on
process knowledge or testing).
c. Except as allowed by Condition 1, the waste does not contain "pure forms" of chemicals containing
carbon, 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, magnesium
carbonate, magnesium fluoride, bismuth oxide, etc. do not contain other elements. (Based on process
knowledge or testing).
£3 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 ofthe total weight ofthe
waste. (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 waste
meets 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, uranyl
potassium carbonate, and uranyl sulfate. (Based on process knowledge or testing).
153 f. For containers of liquid waste with more than 600 kilograms of waste, the total activity (pCi) of SNM
in the manifested container does not exceed the SNM concentration in the above table or Table 1 times
600 kilograms of waste (based on process knowledge or testing). For example, the maximum activity
of Pu-239 in any manifested container of liquid waste is 6.0 mCi (6.0E+09 pCi) as shown below:
10,000 f x 600,000g = 6.0X109 pCi = 6.0mCi Pu-239
Page I of2
ENERGYSOLUTIONS
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)
Measurement
Uncertainty
(pCi/g) Radionuclide
Maximum
Concentration
(pCi/g)
Measurement
Uncertainty
(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 identify
the uranium chemical composition.
b. Provide a general description of how the waste was characterized (including the volumetric extent of
the waste, and the number, location, type, and results of any analytical testing), the range of SNM
concentrations, 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 SNM
must be uniform, or other information supporting spatial distribution.
^ d. Describe the methods to be used to determine the concentrations on the manifests. These methods
could 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: 1 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.
Kris A. Smith Waste Specialist 1/19/2015
Authorize d)S ignature Printed Name Title Date
Page 2 of2
Attachment 2
Non Aqueous Liquid Assessment
EN ERGYSOLUTIONS
MEMORANDUM
Date:
To:
From:
Subject:
February 5, 2015
Vern Rogers
Tim Orton
Non Aqueous Liquid Assessment
Waste Stream 9105-05
The purpose of this memo is to evaluate Waste Stream 9105-05 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 9105-05 is primarily debris for macroencapsulation treatment, but also
contains non-aqueous liquids (solvents, primarily trichloroethylene) that need to be
segregated from the debris and managed separately. The Clive Facility will remove non-
aqueous liquids as they are found and manage them through the thermal desorption
system. Condensate generated from this treatment will be sent off-site for incineration;
solid material will be disposed in the Mixed Waste Landfill Cell.
For this review, the MSDS for trichloroethylene was examined. A description of the
hazards identified follow.
Trichloroethylene
Trichloroethylene is moderately stable under normal conditions, decomposing
very slowly to phosgene, hydrochloric acid, and dichloroacetic acid. This
decomposition is accelerated by direct sunlight, excessive heat, and moisture. As
such, trichloroethylene should be transported apart from open flame sources and
kept under standard environmental conditions, away from the heat of the sun.
Other than the slight acceleration in decomposition, trichloroethylene does not
423 West 300 South, Suite 200 • Salt Lake City, Utah 84101
[phone] • Fax [phone] • www energysolutions com
react with water. Trichloroethylene has no measurable flash point and is not
flammable under most conditions - high temperature and a strong flame would be
required to reach flammability limits. The autoignition temperature for
trichloroethylene under normal situations is approximately 420 °C (-788 °F).
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 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.
423 West 300 South, Suite 200 • Salt Lake City, Utah 84101
[phone] • Fax [phone] • www energysolutions com