Exhibit_D_Appendix_D-9_WCS_Genarator_Handbook.pdf

FWF Generator Handbook

Issued – 8-28-15 Page i Revision 4

Low-Level Radioactive Waste Disposal

Andrews, Texas

Federal Waste

Disposal Facility

(FWF)

Generator Handbook

Issued – 8-28-15 Page ii Revision 4

Table of Contents

1.0 Overview

2.0 Definitions

3.0 Overview of Waste Acceptance Process

4.0 Step 1: Generator Certification

4.1 Generator Certification Packet Submittal

4.2 Onsite Generator Audits

5.0 Step 2: Waste Profile and Waste Classification

5.1 ELITE Software Registration

5.2 Limitations

5.2.1 License Volume and Curie Limitations

5.2.2 Chelating agents

5.2.3 Free liquids

5.2.4 Void Space/Head Space

5.2.5 Void Filling/Solidification Agents

5.2.6 Waste Packaging

5.2.7 Waste Class

5.2.8 Containerized Waste Form

5.2.9 Waste Stability Requirements

5.2.10 Transportation

5.2.11 Prohibited Wastes Types

5.3 Pre-Shipment Samples (Soil & Soil-Like Waste)

5.4 Laboratory Accreditation

5.5 DSHS Shipper and Transporter Registration

6.0 Step 3: Waste Shipment Request

6.1 Pre-Shipment Notifications

6.1.1 Advanced Shipment Notification to TCEQ

6.1.2 Advanced Shipment Notification to DSHS

6.1.3 Neutron Sealed Sources

6.1.4 Nationally Tracked Sources As Defined In 10 CFR §20.1003

6.1.5 Lead Used For Radiation Shielding Purposes

6.2 Shielded Shipping Cask Configuration

6.3 Shipping Document Information

6.3.1 NRC Form 540 Block 5, Shipper I.D. Number

6.3.2 NRC Form 540 Block 5, Shipment Number

6.3.3 NRC Form 540 Block 5

6.3.4 NRC Form 540 Block 8

6.3.5 NRC Form 540 Block 9, Consignee

6.3.6 NRC Form 540 Block 11, U.S. Department of Transportation Description ...14

6.3.7 NRC Form 541 Block 4, Shipment ID Number

6.3.8 NRC Form 541 Block 15, Concentration

6.3.9 UHWM Block 8, Designated Facility

6.3.10 UHWM Block 13, Waste Codes

6.3.11 UHWM Block 14, Special Handling Instructions

6.3.12 NRC Form 741 Reporting Identification Symbol (RIS)

6.3.13 NRC Form 741 Block 9, Receiver Data

6.3.14 NRC Form 741 Block 23a, Manifest Number

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6.3.15 NRC Form 741 Block 24, Total Gross Weight

6.3.16 NRC Form 741 Block 25, Total Volume

6.3.17 DSHS Shipper and Transporter Registration Number(s)

7.0 Step 4: Waste Shipment Approval

7.1 WCS-Specific Waste Package Marking

7.2 Pre-Arrival Documentation

8.0 Step 5: Waste Shipment Verification

8.1 Non-Compliant Waste or Waste Shipments

8.2 TCEQ Resident Inspector

9.0 General Site Information

9.1 Operational and Business Hours

9.1.1 Audits and Tours

9.1.2 Viewing Waste as it is Received and Disposed

9.2 Demurrage

9.3 Decontamination of Vehicles and Reusable Containers

9.4 Customer Service Contact Information

9.5 Transportation Requirements

9.5.1 Selection of a Transporter

9.5.2 Prohibited Items

9.5.3 Site Access

9.5.4 Upon Arrival at the WCS Facility

9.5.5 Transporter Insurance Requirements

Appendix 1 – Generator Path to Disposal Appendix 2 – Waste Stream Restrictions Appendix 3 – Additional Criteria for Specific Waste Streams

Sealed Sources & Special Form Radioactive Material

Biological, Pathogenic or Infectious Waste Radioactive Gases Large Components Bulk Waste in Reusable Packages

Thorium and Uranium Wastes Bulk Waste Containing Friable Asbestos ……………………………………………26

Appendix 4 – Use of Shielded Shipping Casks Liners in Lift Bags Grappable Liners Liners with Slings TN-RAM Cask and Liners Other Configurations in Shielded Shipping Casks Type B Cask Authorized User Information

Appendix 5 – Hazardous, Biological, Pathogenic, or Infectious Waste Packaging Appendix 6 – NRC Form and UHWM Examples Appendix 7 – Waste Verification Requirements References

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Table of Tables Table 1 – 30 TAC §336.362 Appendix E, Table I, Class A and C Waste - Long Lived Isotopes . 6 Table 2 – 30 TAC §336.362 Appendix E, Table II, Class A, B and C Waste - Short Lived

Isotopes Table 3 – Radiological Release Standards of Vehicles and Reusable Containers

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Acronyms and Abbreviations

AASHTO American Association of State Highway and Transportation Officials ALARA As Low As Reasonably Achievable

ASTM American Society for Testing and Materials atm Atmospheres

CFR Code of Federal Regulations cm Centimeter

CRCPD Conference of Radiation Control Program Directors

CWF Compact Waste Disposal Facility

DOE Department of Energy DOT U.S. Department of Transportation

DSHS Texas Department of State Health Services

DU Depleted Uranium

ELITE Electronic Inventory Tracking Engine EPA Environmental Protection Agency

FWF Federal Waste Disposal Facility

GTCC Greater than Class C

HCD High Container Dose ICSS Integrated Customer Service Specialist

ID Identification

IHTS Irradiated Hardware Transfer System

IP Industrial Package LC Large Component

LDR Land Disposal Restrictions

LLRW Low-Level Radioactive Waste

LLMW Low-Level Mixed Waste µCi Microcurie

MCC Modular Concrete Canister mrem/hr Millirem per hour

MSDS Material Safety Data Sheet NA Not Applicable nCi/g nanocurie per gram

NELAC National Environmental Laboratory Accreditation Conference

NMMSS DOE / NRC Nuclear Materials Management & Safeguards System NRC Nuclear Regulatory Commission pCi/g picocurie per gram

PPE Personal Protective Equipment

QA/QC Quality Assurance/Quality Control Rem/hr Rem per hour

RCRA Resource Conservation and Recovery Act

R&D Research and Development

RIS Reporting Identification Symbol RML Radioactive Materials License

SNM Special Nuclear Material

TAC Texas Administration Code

TCEQ Texas Commission on Environmental Quality THSC Texas Health and Safety Code

UHWM Uniform Hazardous Waste Manifest

TLLRWDCC Texas Low Level Radioactive Waste Disposal Compact Commission aka Texas Compact Commission ULLRWM Uniform Low Level Radioactive Waste Manifest

WAP Waste Acceptance Plan

WCS Waste Control Specialists LLC

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1.0 OVERVIEW

The purpose of this document is to promote efficient utilization of WCS by the federal government and its contractors (i.e., generators). This handbook provides guidance and specific criteria for waste acceptance at the FWF in compliance with WCS licenses, permits, and procedures.

WCS has two LLRW disposal facilities; the Compact Waste Disposal Facility (CWF) and the Federal Waste Disposal Facility (FWF). The CWF accepts commercial LLRW that is generated in a host state or party state or LLRW that is not generated in a host state or party state, but has been approved for importation to the state by the Texas Compact Commission. The FWF accepts

LLRW and Low Level Mixed Waste (LLMW) that is the responsibility of the Federal government under the LLRW Policy Act as amended by the LLRW Policy Amendments Act of

1985 (Department of Energy (DOE) waste, U.S. Navy vessel decommissioning waste, government atomic weapons Research and Development (R&D), testing or production waste, excluding Greater than Class C). The focus of this Generator Handbook is on the FWF.

2.0 DEFINITIONS

2.1 Bulk Waste in Reusable Packages

Waste that is not disposed in the DOT container that it is shipped in, and is not placed in a Modular Concrete Canister (MCC) for disposal. Bulk waste is acceptable for disposal in the

FWF, if it is Class A and has a dose rate of <100 mrem at 30 cm.

2.2 Cask Waste

This waste category consists of any waste that must be shielded to meet shipping requirements, any waste shipped in Type A, Type IP-2 DOT cask or Type B Nuclear Regulatory Commission (NRC) cask regardless of dose rate, and any container with a dose rate greater than 1 Rem/hr at the surface of the unshielded container.

2.3 Containerized Waste

Waste that is received in a container and the container is placed in an MCC for disposal.

Containerized waste can be bulk or non-bulk as long as the container fits inside the MCC.

Dimensions of the standard sized MCCs are listed in Section 5.2.6.

2.4 Electronic Inventory Tracking Engine (ELITE)

A web-based database used by customers to submit profiles and shipment requests online. The same database is used by WCS to approve profiles and shipment requests as well as maintain inventory and disposal information. WCS requires that all profiles and shipment requests be submitted through this database.

2.5 Federal Waste

LLRW and LLMW that is the responsibility of the Federal government under the LLRW Policy Act as amended by the LLRW Policy Amendments Act of 1985 [i.e., Department of Energy waste, U.S. Navy vessel decommissioning waste, government atomic weapons research and development, testing, or production, excluding Greater than Class C waste (GTCC)].

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2.6 Head Space

Head space is the empty volume of a waste container between the top of the waste and the top of the waste package. The term head space is used, as opposed to void space, when the waste type has minimal interstitial space within the waste in the container (e.g., resin, soil, sludge, compacted debris, etc.).

2.7 High Container Dose Rate Waste (HCD)

This waste category consists of all unshielded, containerized wastes, where 90% or more of the containers have a dose rate between 100 mrem/hr @ 30 cm and 1 Rem/hr at the surface of the container. Containerized wastes that would otherwise fall into the containerized soil or containerized debris categories, but will not be opened due to specific health and safety issues will be managed in the same manner as HCD wastes.

2.8 Large Component (LC)

Any equipment or large item that will not fit into a standard MCC and other waste for which disposal within an MCC may not be desirable.

2.9 Modular Concrete Canister (MCC)

Cylindrical or rectangular reinforced concrete canister that when properly filled with waste and grout meets the stability requirements found in 30 Texas Administrative Code (TAC)

336.362(b)(2) and conforms to the TCEQ regulatory requirements of retrievability. See Section

5.2.6 for more information.

2.10 Source Material

Uranium or thorium, or any combination thereof, in any physical or chemical form; or ores that contain, by weight, 0.05% or more or uranium, thorium, or any combination thereof. Source material does not include special nuclear material.

2.11 Void Space

Void space is the empty volume of a waste container including the space between the top of the waste and the top of the waste package, and the interstitial space within the waste in the container. The term void space is used, as opposed to head space, when the waste type has more than minimal interstitial space between the waste pieces in the container (e.g., debris, irradiated hardware, filters, etc.).

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3.0 OVERVIEW OF WASTE ACCEPTANCE PROCESS

See Appendix 1 – Generator Steps to Disposal for an additional graphic.

4.0 STEP 1: GENERATOR CERTIFICATION

All generators must be certified by WCS in accordance with our Quality Assurance (QA) Generator Certification Program prior to sending waste to WCS for disposal. For DOE sites with multiple contractors/subcontractors, the contractor that has primary responsibility for waste management should go through the certification process. Other contractors/subcontractors at the same DOE site will be able to utilize another contractor’s certification if the certified contractor’s waste management procedures are utilized for the various waste management activities. Any entity that provides information upon which the classification and/or the characterization of a waste is based, or handles the waste prior to shipment to the WCS facility will be included in the generator certification process. For example, if a DOE prime contractor uses a subcontractor to perform waste management activities the processes and procedures for the subcontractor will be included in the review during the generator certification process to ensure those operations are sufficient to meet the requirements of the WCS license.

The certification process begins with completion and submittal of a generator certification packet. WCS suggests that the generator or customer submit this information as early as possible to ensure approval well in advance of the desired shipping date. WCS will accept generator certification packets without a signed contract but will generally not give final approval of the generator certification until an executed contract is in place.

Each generator certification packet may be associated with multiple waste profiles, one profile for each waste stream the generator proposes to ship to WCS. Onsite audits will be conducted as required in Section 4.2. Approved generators will receive a generator certification identification number valid for 12 months. The generator certification identification number must be renewed through the generator certification process on an annual basis. The WCS QA department will normally contact the generator 90 days in advance of the certification expiration to start the renewal process.

Only generators with an approved generator identification number will be authorized to ship waste to the FWF. The generator’s certification identification number is required on all documentation and correspondence to WCS regarding waste disposal at WCS LLRW disposal facility.

Generators who ship wastes to the FWF that do not meet regulatory requirements or otherwise result in the occurrence of a major discrepancy will be designated as non-compliant (see Section

8.1 for definitions of minor, moderate, and major discrepancies). WCS will suspend the generator identification number of any generator designated as non-compliant. Generators found to be non-compliant must apply for re-certification by resubmission of the generator certification packet. The resubmitted packet must be revised to reflect measures taken to prevent the

Step 4:

Waste shipment approval

Step 1:

Generator certification

Step 2:

Waste profile approval

Step 3:

Waste shipment request

Step 5:

Waste shipment verification

Issued – 8/28/15 Page 4 Revision 4 reoccurrence of the violation that resulted in the non-compliance. Non-compliant generators are also required to undergo the site audit process to qualify for re-certification. See Section 8.1 for additional information on non-compliant waste and waste shipments.

4.1 Generator Certification Packet Submittal

Each generator shall submit a generator certification packet to WCS to obtain certification. The generator certification packet must contain documentation of all of the following programs as applicable:

The waste classification/characterization program, including sampling and analytical procedures and frequencies, quality assurance/quality control procedures, procedures for documenting free liquids and void space, procedures for verification of Land Disposal Restriction (LDR) status (for LLMW), and procedures for verification that LLRW is not hazardous

The program for determining the presence or absence of chelating agents, and, where chelating agents are present or potentially present, the methodologies for establishing a conservative upper bound for the typical concentration of chelating agents in each waste, and the basis upon which the methodologies provide a conservative upper bound of chelating agent concentrations

The process control program identifying the procedures and systems in place to maintain consistency in the generating process and resultant wastes (required only when process knowledge is used in characterizing a waste)

The waste packaging and shipping program

The personnel training program applicable to persons responsible for all component steps in performing waste classification, characterization, packaging, and shipping

Records concerning their relevant compliance history. This includes results of regulatory inspections and compliance audits and resolution of any alleged non-compliant conditions or practices that would impact the generator’s waste program

4.2 Onsite Generator Audits

All FWF generators will be required to undergo an onsite audit. This audit will encompass verification and review of the generator’s waste classification, characterization, chelating agent documentation, packaging, shipping, and other programs, practices, and records associated with waste generating activities.

WCS will develop an audit plan for each generator to be audited. The plan will include audit procedures and/or checklists that reflect specific elements of the programs submitted in the generator certification packet to determine compliance with applicable licenses, permits, plans and procedures. The following activities may be conducted by an auditor as part of the generator site audit:

Observe or verify onsite waste handling procedures, including transfer, storage, processing, packaging, and shipment preparation procedures

Interview personnel with direct and supervisory responsibility for waste classification/characterization and waste handling

Observe or verify the actions taken to ensure that wastes shipped to the LLRW facilities meet each waste acceptance criterion (absence or quantity of free liquids, void space in containers, Issued – 8/28/15 Page 5 Revision 4 non-hazardous waste determinations for LLRW, LDR compliance for LLMW, etc.)

Observe or verify the performance of measurements, analyses, calculations, or other methods used to classify and characterize radioactive waste

Review records documenting use of chelating agents and the basis for the generator’s waste profile information regarding chelating agents

Review radioactive waste characterization records for waste shipments made during the previous year, regardless of the facility to which it was shipped, including, as applicable, process knowledge documentation. The number of shipments reviewed is typically a small sampling of the past year’s shipments, but is at the discretion of the auditor.

5.0 STEP 2: WASTE PROFILE AND WASTE CLASSIFICATION

A waste profile must be completed in ELITE for each authorized waste stream or appropriate combination of authorized waste streams that a generator intends to ship for disposal at the FWF.

Any section not applicable on the form must be marked as “Not Applicable” or “NA.” WCS will not accept blank input fields. Combining authorized waste streams will be evaluated on a case by case basis and approval will be determined based on similarities of the required waste acceptance verification requirements and the operational handling and disposal processes. See additional discussion in Section 5.1 for additional guidance. In addition to completing the form in ELITE and attaching any supporting documentation, the generator is required to attach a signed copy of the printed profile from ELITE prior to hitting the “Submit” button.

The generator is encouraged to include information in the profile related to container processing and handling. For example, it is helpful to include in Section 2 of the Profile, Process Generating Waste, notice if the waste meets the void space requirement (see 5.2.4). Similarly, in

Section 6, in the text box to list DOT Packing Types, it is helpful to note if there any special considerations related to package loading or unloading. Attachments may also be uploaded as needed to upload any other relevant information about the waste, packaging, or shipment practice.

The completed waste profile and supporting documentation must allow WCS to demonstrate that the waste is compliant with regulatory requirements along with license and permit conditions applicable to the LLRW disposal facility. The completed profile form provides an overview of the waste stream and its physical, chemical, and radiological characteristics. The following radionuclides are required to be placed on a waste profile when present:

Enriched U-235, enriched U-233, Pu-239, and Pu-241 [Special Nuclear Material (SNM)]

Radionuclides that are required to be listed in accordance with the latest version of NUREG/BR-0204, Instructions for Completing NRC's Uniform Low-Level Radioactive

Waste Manifest.

Radionuclides that are required to be listed in accordance with 49 Code of Federal

Regulations (CFR) Part 173.433(c)(2)

Radionuclides that affect the dose rate of a package or shipment

Uranium and/or thorium considered source material

In addition, the subsequent shipping documentation must include only radionuclides that were previously identified on the approved waste profile. Consequently generators should consult

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NUREG/BR-0204 for guidance on other radionuclides that should be identified on the waste profile (e.g. hard to detect isotopes below the limits of detection).

Analytical data and/or documentation of process knowledge are submitted with the waste profile.

The data must be accompanied by an identification of the analytical method used for each parameter or constituent reported, and by QA/QC results. The generator must employ analytical methods approved by recognized entities (i.e., EPA, DOE, ASTM, or AASHTO) for waste analyses supplied with the waste profile whenever possible. The generator may conduct analyses via other industry-accepted methods as necessary to classify and characterize the waste;

however, the need to use these other methods must be documented by the generator. Refer to Section 5.4 for additional information on laboratory selection.

The generator may use process knowledge to characterize waste in completing the waste profile, as long as there is reasonable assurance that this approach can be correlated by bounding or other relationships to actual measurements or known quantities. Process knowledge alone may be sufficient to adequately characterize a waste (e.g., spill cleanup residues from a previously characterized waste; containers that have been emptied of their prior contents where the composition of the prior contents is known). Process knowledge may include use of scaling factors to develop inferred concentrations of radionuclides based on measured concentrations of other radionuclides or radionuclide material accountability. Documentation of the generator’s process control program will be required if process knowledge will be used in characterizing a waste stream that is a routinely-generated waste resulting from a commercial or industrial process.

For other waste streams, including demolition wastes and other debris, the generator must thoroughly document the basis for classification and characterization of the waste stream and include any pertinent analytical data or known composition information for chemical and radioactive materials with which the waste materials may have been in contact.

The generator’s waste profile and supporting documentation, in conjunction with the information in the generator’s certification packet, must demonstrate reasonable assurance that the waste is correctly classified as Class A, Class B, or Class C in accordance with the waste classification tables in 30 TAC §336.362, Appendix E, as summarized in the Waste Classification Table 1 and 2 below; that any and all hazardous characteristics and constituents have been identified; and that the concentration of any chelating agents have been conservatively established. The combined documentation must include the methodology used to classify/characterize the waste and the basis upon which the classification and characterization was established and demonstrate that the basis for classification/characterization is adequate and appropriate.

Generators are required to re-certify the waste profile information on an annual basis or when the process generating a waste or the characteristics of a waste changes from the information presented in the current waste profile. A new waste profile must be submitted to WCS for review and approval prior to scheduling additional shipments of the waste.

Table 1 – 30 TAC §336.362 Appendix E, Table I, Class A and C Waste - Long Lived Isotopes

Radionuclide Class A Limit Class B Limit Class C Limit

C-14 0.8 Ci/m³ 1 Ci/m³ 8 Ci/m³

C-14 in Activated Metals 8 Ci/m³ 1 Ci/m³ 80 Ci/m³

Ni-59 in Activated Metals 22 Ci/m³ 1 Ci/m³ 220 Ci/m³

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Radionuclide Class A Limit Class B Limit Class C Limit Nb-94 in Activated Metals 0.02 Ci/m³ 1 Ci/m³ 0.2 Ci/m³

Tc-99 0.3 Ci/m³ 1 Ci/m³ 3 Ci/m³

I-129 0.008 Ci/m³ 1 Ci/m³ 0.08 Ci/m³

Alpha-emitting transuranic radionuclides with half-lives greater than five (5) years 10 nCi/g 1 nCi/g 100 nCi/g

Pu-241 350 nCi/g 1 nCi/g 3,500 nCi/g

Cm-242 2,000 nCi/g 1 nCi/g 20,000 nCi/g

Ra-2262 10 nCi/g 1 nCi/g 100 nCi/g

There are no limits established for these radionuclides in Class B wastes 2 This isotope is not listed in the classification tables in 10 CFR Part 61 but is required by the state of Texas to be included in classification determination

Table 2 – 30 TAC §336.362 Appendix E, Table II, Class A, B and C Waste - Short Lived Isotopes

Radionuclide Class A Limit Class B Limit Class C Limit Total radionuclides with half-lives less than five (5) years 700 Ci/m³ 3 Ci/m³ 3

Ci/m³

H-3 40 Ci/m³ 3 Ci/m³ 3

Ci/m³

Co-60 700 Ci/m³ 3 Ci/m³ 3

Ci/m³

Ni-63 3.5 Ci/m³ 70 Ci/m³ 700 Ci/m³

Ni-63 in Activated Metals 35 Ci/m³ 700 Ci/m³ 7,000 Ci/m³

Sr-90 0.04 Ci/m³ 150 Ci/m³ 7,000 Ci/m³

Cs-137 1 Ci/m³ 44 Ci/m³ 4,600 Ci/m³ 3 There are no limits established for these radionuclides in Class B or C wastes. Practical considerations such as effects of external radiation and internal heat generation on transportation, handling, and disposal will limit the concentrations for these wastes. These wastes shall be Class B unless the concentrations of other radionuclides in Table 2 determine the waste is Class C independent of these radionuclides.

For the purpose of the Federal Waste Facility, WCS is authorized to accept for disposal, waste which is handled, treated, packaged, or characterized in accordance with applicable Department of Energy orders, policies, and procedures. Waste class applies when the waste is manifested for transport, regardless if a waste class has been assigned on the manifest documents. NRC waste classification shall apply and shall be limited to Class A, B, and C.

5.1 ELITE Software Registration

WCS has developed a web-based database, named ELITE that is used by customers to submit profiles and shipment requests online. The same program is be used by WCS to approve profiles and shipment requests as well as maintain inventory and disposal information. WCS requires that all profiles and shipment requests be submitted through this website. Users will have the ability to create profiles and shipment requests as well as attach all necessary supporting documentation.

Generators using LowTrack™, eMWaste

TM

(Attention IT), RADMAN™ (WMG Inc.), or ISIP

(DW James Consulting) can upload electronic NRC Forms 540, 541 or 542 into ELITE at the time of shipment request. Generators using NAC Reporter™ (NAC International) or other software to generate an unclassified NMMSS-readable NRC Form 741 data file may transmit the data to WCS electronically in addition to the hardcopy accompanying the manifest.

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WCS suggests that each generator register for an ELITE account early in the generator certification process to expedite the process. A physical signature from an authorized agent of the generator will still be required on all forms and manifests. Please contact WCS for more details and assistance.

5.2 Limitations

Some of the limitations below are also captured in Appendix 2 – Waste Stream Restrictions

5.2.1 License Volume and Curie Limitations

Federal LLRW volumes shall not exceed a total of 26,000,000 cubic feet of waste with a total decay corrected quantity of radioactivity not to exceed 5,600,000 curies, and of the total volume 8,100,000 cubic feet can be containerized waste with a total quantity of radioactivity of containerized waste not to exceed 5,500,000 curies.

5.2.2 Chelating agents

Limited to 8% by weight for each waste stream (e.g., profile)

5.2.3 Free liquids

Must not exceed 1% of the volume in containerized waste (WCS can dewater/absorb free liquid in non-bulk waste as an additional service upon receipt when requested)

No free liquids may be present in bulk waste

Absorbents used to absorb free liquids must be non-biodegradable and capable of absorbing the liquids

Liquids must be solidified in sufficient absorbent material to absorb twice the volume of liquid

5.2.4 Void Space/Head Space

This requirement is for containerized waste only

Must be reduced to the extent practicable

LLRW can have no more than 15% void space/headspace

LLMW can have no more than 10% void space/headspace

NOTE: WCS may request an exemption from TCEQ for to allow disposal of LLRW with > 15% void space/headspace if meeting the requirement presents ALARA or other safety or technical concerns. Contact WCS if exception to the 15% void space requirement is needed.

5.2.5 Void Filling/Solidification Agents

Void filling/solidification agents are required to be non-biodegradable. Two examples are vermiculite and concrete. There is not an approved list of void filling/solidification agents.

NOTE: WCS has the ability to dewater/void fill containers to meet the free liquids and/or void space/head space criteria for containers shipped directly to the FWF prior to disposal. Contact your WCS Business Development representative to ensure proper contracts are in place for this service

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5.2.6 Waste Packaging

Each package or container shall only contain one approved profiled waste stream. See

Section 5.0 for combining approved waste streams in a single profile

Packages should weigh 10,000 lbs or less unless special arrangements have been made.

Drums exceeding 1,000 lbs must be palletized and banded unless alternate arrangements are made with WCS

All containers transported on public roads to WCS are required to meet the applicable requirements of the Texas Department of State Health Services (DSHS) and DOT regulations (49 CFR)

Cardboard, fiberboard, and wood boxes are prohibited

Except for bulk waste in reusable containers and Large Components, waste packages must fit into a MCC. WCS has two standard types of MCCs:

Cylindrical: 6’ 8” D x 9’ 2” H (internal dimension)

Rectangular: 9’ 6” L x 7’ 8” W x 9’ 2” H

5.2.7 Waste Class

The FWF is authorized to receive containerized Class A, Class B, and Class C (as defined in 30 TAC §336.362) LLRW & LLMW and bulk Class A LLRW and LLMW in reusable packages with a dose rates of <100 mrem/hr at 30 centimeters.

5.2.8 Waste Form

Containerized debris and bulk debris in reusable packages must contain greater than 50% debris

Containerized soil and soil-like and bulk soil in reusable packages must contain less than 50% debris

5.2.9 Waste Stability Requirements

The MCC disposal structure provided by WCS will provide the stability required for radioactive waste in accordance with 10 CFR 10 CFR §61; therefore, the waste or the waste form as shipped to WCS is not required to meet stability requirements.

All Class B and C, and HCD Class A waste will be placed in an MCC.

5.2.10 Transportation

Transportation by highway and rail are acceptable means for delivery of waste to the FWF.

5.2.11 Prohibited Wastes Types

Waste streams not specifically authorized by the license or with physical, chemical, and radiological characteristics not evaluated in the license application

Waste of international origin [THSC §401.207(0)]

Greater than Class C (GTCC) waste

Naturally-occurring radioactive material (NORM) waste including oil & gas NORM

Byproduct material waste [11.e(2)]

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High-level radioactive waste

Uranium hexafluoride

Waste capable of generating toxic gases, vapors, or fumes (excluding radioactive gases)

Waste readily capable of detonation or of explosive decomposition or reaction at normal pressures and temperatures or of explosive reaction with water

Waste containing transuranic nuclides in concentrations greater than 100 nCi/g

Municipal solid waste

Liquid waste that is not stabilized or not solidified

Explosive materials

Pyrophoric material that has not been properly stabilized

Putrescible waste

LLMW containing RCRA codes F020, F021, F022, F023, F026, and F027 (Dioxins & Furans)

Waste that is NOT considered Federal Waste.

5.3 Pre-Shipment Samples (Soil & Soil-Like Waste)

Pre-shipment samples are required during the profile approval process for soil and soil-like waste streams that are < 100 mrem/hr @ 30 cm. WCS will contact the generator when a pre-shipment sample is required and what the requirements are for providing the pre-shipment sample to WCS.

NOTE: Do not send pre-shipment samples unless specifically requested by WCS.

5.4 Laboratory Accreditation

Analytical data from samples measured by a laboratory can only be accepted if the laboratory is National Environmental Laboratory Accreditation Conference (NELAC) accredited by the Texas

Laboratory Accreditation Program operated by the TCEQ or the data are exempt from the NELAC-accreditation requirement under one of the following criteria [30 TAC §25.6]:

The laboratory is an on-site or in-house environmental testing laboratory that o is inspected at least every three years by the executive director, o is located in another state and accredited or periodically inspected by that state, or o gets inspected at least every three years by the executive director and is performing work:

for another company with a unit located on the same site, or without compensation for a governmental agency or a charitable organization.

The lab is accredited under federal law, including certification by the United States Environmental Protection Agency to provide analytical data for decisions relating to compliance with the Safe Drinking Water Act. TCEQ has interpreted this to include DOE on-site labs that are subject to DOECAP audits as labs that are operating under federal law.

The lab supplies analytical data necessary for emergency response and the required analytical data are not otherwise available from an environmental testing laboratory that is accredited by the TCEQ or federal law.

The lab supplies analytical data for which the commission does not offer accreditation (i.e., Issued – 8/28/15 Page 11 Revision 4 in-situ gamma spectroscopy).

A list of laboratories accredited by the TCEQ and the accredited analytical methods is available at www.tceq.state.tx.us/assets/public/compliance/compliance_support/qa/txnelap_lab_list.pdf.

5.5 DSHS Shipper and Transporter Registration

All entities appearing as either Shippers (generators) or as Carriers (transporters) on NRC Form

540 must be registered with DSHS prior to disposal in Texas. Shippers and transporters must submit documents described in DSHS Regulatory Guide 2.19, Guide for Submission of

Documents and Fees by Low Level Radioactive Waste Shippers and Transporters, to DSHS at least fourteen (14) days prior to the first shipment departure.

WCS maintains a current list of DSHS-approved shippers and transporters for disposal of LLRW in Texas. Registration for shippers is valid for up to ten (10) years, and registration for transporters must be renewed annually at the time of insurance renewal. WCS will not approve shipment requests from entities without current DSHS registration. Registration assistance is available from WCS’ Customer Service Department and from DSHS.

6.0 STEP 3: WASTE SHIPMENT REQUEST

Each shipment of waste to WCS must be pre-approved. Once a generator has completed generator certification, and has an approved profile from WCS, then the generator can request to make a shipment to WCS using ELITE.

The generator must fill out a Waste Shipment Request form in ELITE and submit the completed form along with an advanced copy of the shipping documents that will accompany the shipment at least 5 business days in advance of the requested delivery date. A list of required documentation, as applicable, is listed below:

NRC Form 540/541/542 Uniform Low Level Radioactive Waste Manifest (ULLRWM)

NRC Form 741/742 Nuclear Transaction Form

US EPA Form 8700-22, Uniform Hazardous Waste Manifest (UHWM)

Land Disposal Restriction (LDR) notification(s)

Asbestos Record of Shipment PCB Continuation Sheet

When completing the shipping request in ELITE, under the Attachments tab in the Customer

Remarks section, it is helpful for the generator to list relevant information about the shipment.

For example note if the waste meets the 15% void space requirement (see 5.2.4). This section can also be used to note that dewatering/void fill services are required (see 5.2.5), or to note that dewatering/void fill is not required and to note the date of dewatering. Similarly, it is helpful to note if any special considerations relating to the loading and unloading of the packages. (See 5.2.6)

6.1 Pre-Shipment Notifications

6.1.1 Advanced Shipment Notification to TCEQ

In addition to the notification to WCS, every waste shipment will require WCS to notify TCEQ five (5) business days prior to shipment departure for verification and tracking purposes.

http://www.tceq.state.tx.us/assets/public/compliance/compliance_support/qa/txnelap_lab_list.pdf

Issued – 8/28/15 Page 12 Revision 4

6.1.2 Advanced Shipment Notification to DSHS

Five (5) business days prior to shipment departure, each shipper shall notify DSHS providing a copy of the waste manifest and the date of shipment. WCS performs the DSHS notification on behalf of the shipper, unless the shipper requests otherwise. The notification may be submitted by facsimile to (512) 834-6690, email to Jennifer.Ludwig@dshs.state.tx.us and ray.fleming@dshs.state.tx.us or to:

US Mail: Texas Department of State Health Services

Radioactive Material Licensing – MC 2835 P.O. Box 149347

Austin, TX 78714-9347

UPS/FedEx: Texas Department of State Health Services (512) 834-6688 Radioactive Material Licensing – MC 2835

ATTN: Ray Fleming 8407 Wall St

Austin, TX 78714

6.1.3 Neutron Sealed Sources

The generator must notify WCS and TCEQ of the intent to ship a neutron sealed source. The notification must consist of telephone and written notification prior to the five day advanced notification. The notification needs to include the following information:

Isotope

Activity

Form of the source

Description of the packaging utilized

Radiological data

Requested date of arrival

NOTE: A copy of the Neutron Sealed Sources notification must accompany the shipment.

6.1.4 Nationally Tracked Sources As Defined In 10 CFR §20.1003

Prior to shipping, the generator must provide WCS and TCEQ the following information:

Generator’s name, shipping address, radioactive material license number, and name of individual preparing the reported information

The manufacturer, model, and serial number of the source, or if not available, other information to uniquely identify the source

The radioactive material in the source and the current activity in Becquerels (Bq) and Curies

(Ci). The activity reported must be the same as the activity that will be listed on the shipment manifest

The date the source strength is reported

The requested shipping date and estimated arrival date

The waste manifest number and the waste disposal container number mailto:Jennifer.Ludwig@dshs.state.tx.us mailto:ray.fleming@dshs.state.tx.us

Issued – 8/28/15 Page 13 Revision 4

6.1.5 Lead Used For Radiation Shielding Purposes

6.1.5.1 Contaminated lead or lead that will be considered part of the waste stream as D008

Waste streams that will be shielded with contaminated lead will be considered mixed waste and subject the RCRA disposal requirements found in 40 CFR Part 268.

6.1.5.2 Non-Contaminated Lead used for shielding purposes only

If a customer is using non-contaminated lead as part of the package for the sole purpose of shielding and will not characterize the waste stream as hazardous for lead (D008), prior approval from WCS is required. This approval must be obtained during the profile approval process and prior to request for shipment. Generators must provide the following information with the profile submittal:

Type of lead used (sheet, block, pig, etc.)

Amount of lead used (in pounds) and a graphic depiction of its location and configuration within the package that will support WCS’ dose modeling

Container type and size

Description of the waste requiring shielding including waste classification

Approximate external dose rate prior to shielding

External dose rate after shielding

6.2 Shielded Shipping Cask Configuration

Include cask model and cask loading configuration information in the shipment request, specifically if the liner will be in a lift bag, retrievable with a grapple or retrievable with slings.

For liners with slings, specify if the slings are wire or synthetic.

NOTE: Refer to APPENDIX 4 for additional shielded shipping cask configuration information.

6.3 Shipping Document Information

See Appendix 4 – NRC Form & UHWM Examples for illustration of the WCS-specific entries to

NRC Forms 540, 541, 542 and 741 and the Uniform Hazardous Waste Manifest (UHWM) described below.

6.3.1 NRC Form 540 Block 5, Shipper I.D. Number

Enter the certified generator’s nine (9) character generator certification number assigned by

WCS in Block 5 of NRC Form 540.

6.3.2 NRC Form 540 Block 5, Shipment Number

It is optional to enter either data determined by the shipper or the ELITE shipment number in

Block 5 of NRC Form 540.

6.3.3 NRC Form 540 Block 5

It is optional to enter either data determined by the shipper or the five (5) character DSHS Shipper Registration number assigned by DSHS in Block 5 of NRC Form 540, under the shipper’s address and to the left of the shipment number.

Issued – 8/28/15 Page 14 Revision 4

6.3.4 NRC Form 540 Block 8

The manifest number is typically assigned by the generator. WCS encourages the use of the following format:

FWF-XXXX-##, where XXXX is the four digit profile number, and ## is a sequential number.

6.3.5 NRC Form 540 Block 9, Consignee

Enter WCS as the consignee exactly as shown below in Block 9 of NRC Form 540.

Waste Control Specialists LLC

Federal Waste Disposal Facility Contact – Tom Hannah 9998 W. State Hwy. 176 Phone – (432) 525-8500

Andrews, TX 79714

6.3.6 NRC Form 540 Block 11, U.S. Department of Transportation

Description

Enter your waste profile number in parentheses after your proper shipping name.

6.3.7 NRC Form 541 Block 4, Shipment ID Number

Enter the certified generator’s nine (9) character generator certification number assigned by WCS in Block 4 of NRC Form 541.

6.3.8 NRC Form 541 Block 15, Concentration

WCS requests that generators list the concentration of each isotope in picocuries per gram

(pCi/g) in Block 15 of NRC Form 541. If this is not possible, upload an Excel® spreadsheet with pCi/g information for each row of isotopic data on NRC Form 541 as an attachment to the

ELITE shipment request.

6.3.9 UHWM Block 8, Designated Facility

Please enter WCS as the designated facility exactly as shown below in Block 8 of UHWM.

Waste Control Specialists LLC EPA ID – TXR000075788

Federal Waste Disposal Facility 9998 W. State Hwy. 176

Andrews, TX 79714

(432) 525-8500

6.3.10 UHWM Block 13, Waste Codes

In addition to entering EPA hazardous waste codes, enter the 8-character Texas Waste Code in two adjacent blocks on the same row, if space permits.

6.3.11 UHWM Block 14, Special Handling Instructions

The waste profiles for each line item must be specified in Block 14. The identification number of the shipping container for bulk containers should be entered. The rail equipment number and corresponding intermodal equipment number(s) must be entered.

Issued – 8/28/15 Page 15 Revision 4

6.3.12 NRC Form 741 Reporting Identification Symbol (RIS)

WCS’ unclassified Reporting Identification Symbol (RIS) for the FWF is VAD. Generators using NAC Reporter™ (NAC International) or other software to generate an unclassified

NMMSS-readable NRC Form 741 data file may transmit the data to WCS electronically in addition to the hardcopy accompanying the manifest.

6.3.13 NRC Form 741 Block 9, Receiver Data

It is optional to enter WCS’ address and Texas radioactive materials license number, R04100.

6.3.14 NRC Form 741 Block 23a, Manifest Number

WCS requires customers to list the ULLRWM and UHWM number(s) in the miscellaneous box on the DOE/NRC Form 741/741A.

6.3.15 NRC Form 741 Block 24, Total Gross Weight

Enter the gross weight of the disposed waste rounded to the nearest whole kilogram from Form

541. Do not include the weight of reusable shipping containers that will not be buried (i.e., Type

A and B shielded casks).

6.3.16 NRC Form 741 Block 25, Total Volume

Enter the volume of the disposed waste rounded to the nearest whole cubic foot from Form 541.

Do not include the external volume of reusable shipping containers that will not be buried (i.e., Type A and B shielded casks).

6.3.17 DSHS Shipper and Transporter Registration Number(s)

DSHS shipper and transporter registration number(s) is not required on the shipping documents.

If included, it is suggested to enter it in Block 5 of Form 540, under the shipper’s address and to the left of the shipment number.

7.0 STEP 4: WASTE SHIPMENT APPROVAL

WCS will review the Waste Shipment Request form and the associated shipping documentation.

WCS will work with the generators to promptly process and approve or resolve any discrepancies or address any concerns associated the with the shipment request.

Once WCS is satisfied with the shipping documentation and has approved the delivery of the shipment, WCS will provide the generator with a Waste Shipment Approval form. This form will contain the scheduled date and time for delivery of the shipment. This form is WCS’s indication to the generator that they are authorized to ship the waste for disposal at the FWF.

NOTE: WCS will not approve a shipment request unless both the

Shipper and Carrier on NRC Form 540 hold current DSHS registration.

7.1 WCS-Specific Waste Package Marking

Each package, except for Cask Waste, must be marked with the information specified below:

Generator name (as listed on the associated profile)

Waste profile number associated with the container (one waste profile per container)

Manifest number

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Generator’s unique package ID number

Gross weight of container in pounds

NOTE: Based on As Low As Reasonable Achievable (ALARA) principles, generators may make arrangements with WCS to convey this information in a different manner.

7.2 Pre-Arrival Documentation

Provide electronically to DL_WCS_Shipping_Docs@wcstexas.com on or before the day of departure:

Final manifest documents if there are changes from the ELITE submission

Driver(s) name as it appears on their commercial driver license (CDL) and driver’s cell phone number

Notification if the vehicle will arrive with waste or freight not for disposal in the FWF (i.e., brokered shipment on a “milk run”)

Pre-shipment departure radiological survey of the vehicle

Waste container radiological surveys including fixed and removable contamination and the maximum dose rate at one (1) foot for each item

Cask shipments only, provide:

o Radiological survey of the empty cask, including fixed and removable contamination data and dose rate information o Maximum contact dose rate on the exterior of the closed primary lid of the loaded cask for ALARA planning

8.0 STEP 5: WASTE SHIPMENT VERIFICATION

Waste verification will be performed on incoming shipments. The method and frequency will depend on the type of waste. See Appendix 5 - Waste Verification Requirements for additional details.

The following wastes are excluded from intrusive sampling or inspection due to ALARA and health and safety concerns and will be treated as high container dose rate waste during the generator certification and waste verification processes:

Waste that could release radon or tritium gas upon opening

Waste that could release fine, dispersible radioactive particulates upon opening (e.g., ash)

Biohazard waste

Waste with sharps from any source

8.1 Non-Compliant Waste or Waste Shipments

Non-compliant waste containers or shipments will be addressed on a case by case basis through the WCS discrepancy resolution process

There are three types of discrepancies:

Minor discrepancy - Discrepancies that do not affect the safe and appropriate management of the waste in accordance with license conditions and regulatory requirements, and do not result in a nonconformance between the waste shipment and the mailto:DL_WCS_Shipping_Docs@wcstexas.com

Issued – 8/28/15 Page 17 Revision 4 waste profile. (e.g. Department of Transportation (DOT) marking or labeling discrepancies)

Moderate discrepancy - Discrepancies that would not normally result in a non-compliance with license conditions, but may have minor regulatory impacts. (e.g. a waste form that is otherwise compliant with the license and permits and would require a profile modification with minimal impacts to operations)

Major discrepancy - Discrepancies identified that could result in a non-compliance with license conditions and/or regulatory requirement that has the ability to adversely affect members of the general public, site employees and/or the environment; to include discrepancies between the characteristics of the shipped waste and the waste profile that are indicative of substantive differences (i.e. wastes that are different in type from that profiled)

Generator certification status will be affected by repeatedly sending discrepant waste or waste shipments to WCS. Minor or Moderate discrepancies that are addressed by the generator in a timely manner to the satisfaction of WCS do not usually affect the generator’s current status although points may be assessed..

If the generator chooses, WCS has the capability to mitigate some discrepancies at the adjacent processing facility.

8.2 TCEQ Resident Inspector

The TCEQ resident inspector may inspect every waste shipment and manifest received at the disposal facility for proper classification and characterization prior to waste acceptance.

As part of the TCEQ inspection process, the TCEQ reserves the right to inspect manifests, waste shipments, and conduct visual inspections and external exposure rate surveys, as well as any other inspection deemed necessary by the TCEQ

Waste shipment packaging may be inspected for damage or compromised container integrity by the TCEQ

All waste shipment inspections shall be conducted in accordance with the TCEQ resident inspector inspection procedures

Waste class verification may also be performed by the TCEQ resident inspector(s) upon receipt prior to acceptance through inspection procedures

9.0 GENERAL SITE INFORMATION

9.1 Operational and Business Hours

Normal business hours for the facility are Monday…