Exhibit_D_Appendix_D-19_Energy_Solutions_WAC.pdf

EnergySolutions Clive Facility October 2015

Bulk Waste Disposal and Treatment Facilities Revision 10

Waste Acceptance Criteria

EnergySolutions Clive, Utah

Bulk Waste Disposal and Treatment Facilities

Waste Acceptance Criteria Revision 10

(Includes Class A LLRW, Mixed Waste, and 11e.(2) Disposal Embankments)

RFP-0000297

Bulk Waste Disposal and Treatment Facilities ii Revision 10

Waste Acceptance Criteria

TABLE OF CONTENTS

SECTION 1 INTRODUCTION

1.1 PURPOSE

1.2 SCOPE

1.3 RESPONSIBILITIES

SECTION 2 SITE AND FACILITY DESCRIPTION

2.1 SELECTION OF THE CLIVE DISPOSAL SITE LOCATION

2.2 LICENSES, PERMITS, AND AUTHORIZATIONS

2.3 SITE LOCATION AND ACCESS

2.4 DISPOSAL AND TREATMENT FACILITIES

2.5 ALARA CRITERIA FOR THE BULK WASTE AND TREATMENT FACILITIES

SECTION 3 WASTE CRITERIA

3.1 ACCEPTABLE RADIOACTIVE WASTES

3.1.1 Class A Low-Level Radioactive Waste

3.1.2 NORM/NARM Waste

3.1.3 Class A Mixed Low-Level Radioactive Waste

3.1.3.1 Acceptable Hazardous Waste Codes

3.1.3.2 LDR Compliant Mixed Waste

3.1.3.3 Mixed Waste Requiring Treatment

3.1.4 11e.(2) Byproduct Material

3.1.4.1 Radionuclide Concentration Limits

3.1.4.2 Acceptable Forms of 11e.(2) Byproduct Material

3.1.4.3 Certification of 11e.(2) Byproduct Material

3.1.4.4 Shipping Paperwork for 11e.(2) Byproduct Material

3.1.5 Special Nuclear Material

3.1.5.1 Condition 1 – Percent Enrichment of Uranium-235

3.1.5.2 Condition 2 – Specified Limits for Waste Containing SNM

3.1.5.3 Condition 3 – Characterization of Waste Containing SNM

3.1.5.4 Condition 4 – Generator’s Certification

3.1.6 Uranium Shipments

3.1.6.1 Depleted Uranium

3.1.6.2 Manifested Uranium Shipments

3.1.7 Radium-226 Waste

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3.1.8 Bulk Shipments of Alpha Emitting Radionuclide Waste

3.1.9 Waste Containing Hot Particles

3.1.10 Polychlorinated Biphenyl (PCB) Radioactive Waste

3.1.10.1 PCB Remediation Waste

3.1.10.2 PCB Bulk Product Waste

3.1.10.3 PCB Articles

3.1.10.4 PCB Containers

3.1.10.5 PCB Oils

3.1.11 Dioxins and Furans

3.1.12 UCNI and Export Controlled Waste

3.1.13 Chelating Agents

3.1.14 Asbestos and Beryllium

3.1.15 Lab Packs

3.1.16 Reactive Metal Waste

3.1.17 Battery Management

3.2 ACCEPTABLE FORMS OF RADIOACTIVE WASTE

3.2.1 Soil or Soil-Like Wastes

3.2.2 Debris

3.2.2.1 Standard Size Debris

3.2.2.2 Oversize Debris and Large Components

3.2.3 Gaseous Waste

3.2.4 Waste Containing Free Liquids

3.3 PROHIBITED RADIOACTIVE AND MIXED WASTE

SECTION 4 WASTE ACCEPTANCE PROCESS

4.1 WASTE PROFILING PROCESS

4.2 WASTE CHARACTERIZATION

4.3 RADIOACTIVE WASTE PROFILE RECORD

4.3.1 Generator and Waste Stream Information

4.3.2 Waste Physical Properties and Packaging

4.3.3 Radiological Information

4.3.4 Chemical Composition and Hazardous Waste Evaluation

4.3.5 Special Nuclear Material Exemption Certification Form

4.3.6 PCB Waste Certification Form

4.4 TREATABILITY AND SOLIDIFICATION STUDY SAMPLES

4.5 WASTE PROFILE REVIEW AND APPROVAL

4.6 NOTICE TO TRANSPORT

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SECTION 5 SHIPMENT SCHEDULING AND MANIFESTING

5.1 GENERATOR SITE ACCESS PERMIT

5.2 SHIPPING CHECKLIST

5.3 5 WORKING-DAY ADVANCED SHIPMENT NOTIFICATION

5.4 SHIPPING PAPERWORK

5.4.1 Instructions for the Uniform LLRW Manifest Forms 540, 541, and 542

5.4.2 Electronic Submittal of the Uniform LLRW Manifest

5.5 90-DAY SHIPPING FORECAST

SECTION 6 PACKAGING AND TRANSPORTATION

6.1 COMPLIANCE WITH TRANSPORTATION REGULATIONS

6.2 WASTE PACKAGING GUIDELINES

6.2.1 Bulk Packaging

6.2.2 Non-bulk Packaging (Disposal Containers)

6.3 HIGHWAY TRANSPORTATION

6.4 RAIL TRANSPORTATION

6.5 RELEASE OF SHIPPING CONVEYANCES

APPENDIX A CONTACT INFORMATION

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SECTION 1

INTRODUCTION

1.1 PURPOSE

EnergySolutions has developed this Bulk Waste Disposal and Treatment Facilities – Waste Acceptance

Criteria (BWF WAC) document to assist waste generators and their contractors by providing information about the capabilities and requirements of EnergySolutions’ Clive, UT disposal and treatment facilities.

EnergySolutions is authorized to receive:

Class A Low-Level Radioactive Waste (LLRW)

NORM/NARM

Class A Mixed LLRW (i.e., radioactive and hazardous)

11e.(2) Byproduct Material

PCB Radioactive, and

Other various forms and types of radioactive wastes

The BWF WAC provides information on EnergySolutions’ waste acceptance processes including:

Waste characterization and profiling, Pre-shipment sampling and analysis, Waste packaging, transportation and delivery, Waste receipt, verification sampling and acceptance, and

Waste treatment and disposal

These waste acceptance criteria collectively pertain to the Bulk Waste and Treatment Facilities which are described in detail below. EnergySolutions new online Customer Portal website allows users to enter all of the waste profiling information, schedule requests for shipments, and validation of uploaded manifests.

The BWF WAC does not apply to EnergySolutions’ Containerized Waste Facility (CWF). Please refer to the CWF WAC which can be downloaded from the Customer Portal at EnergySolutions’ website at www.energysolutions.com.

1.2 SCOPE

Numerous state and federal agencies regulate the management, transportation, treatment and disposal of radioactive and hazardous materials. This document provides guidance on EnergySolutions’ waste acceptance process and should be used in conjunction with current copies of EnergySolutions’ licenses, permits and applicable state and federal regulations. These licenses, permits, and regulations take precedence over any information contained in this document. Generators may request variances from the

BWF WAC on a case-by-case basis. EnergySolutions will evaluate such requests and provide written notification to the generator if the variance is approved. In some cases, a variance may require state or federal regulatory approval.

Links to EnergySolutions’ governing licenses and permits may be found at the Customer Portal on the EnergySolutions’ website at www.energysolutions.com. In addition, Appendix A of this document contains a list of contact information for both EnergySolutions and the State of Utah. For additional information, Bulk Waste Disposal and Treatment Facilities 2 Revision 10

Waste Acceptance Criteria representatives of EnergySolutions’ Technical staff are available to answer any questions and can be contacted at (801) 649-2000.

1.3 RESPONSIBILITIES

The generator is responsible to characterize, classify, schedule, manifest, package and transport waste shipments to EnergySolutions’ disposal facility in accordance with the BWF WAC, licenses, permits, and applicable state and federal regulations. For waste classification, generators must have in place a quality control program to ensure compliance with the waste classification requirements. The generator or authorized representative must complete and submit a Radioactive Waste Profile Record to

EnergySolutions for review and approval prior to shipment. Additional forms and certifications may also be required such as the Special Nuclear Material Exemption Certification, the PCB Waste Certification, and the Land Disposal Restriction Notification and/or Certification. Section 4 details the waste profiling process. The generator or authorized representative should be available to resolve issues that arise associated with waste shipments.

EnergySolutions is responsible to safely and compliantly receive, treat (if applicable), and dispose of waste shipments in accordance with all applicable permits, licenses, and regulations. EnergySolutions will provide disposal and/or treatment certificates upon request from the generator. In addition, EnergySolutions will contact the generator to resolve non-conforming waste shipments or discrepancies with the contractual terms and conditions associated with the receipt and management of waste shipments.

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SECTION 2

SITE AND FACILITY DESCRIPTION

2.1 SELECTION OF THE CLIVE DISPOSAL SITE LOCATION

The initial selection of the EnergySolutions disposal site location dates back to the late 1970s when the

Department of Energy (DOE) and the State of Utah began the cleanup of an abandoned uranium mill site.

The VITRO mill site, located in central Salt Lake City, was one of the first sites cleaned up under the DOE

Uranium Mill Tailings Remediation Action (UMTRA) Program.

The DOE investigated 29 sites to identify the safest permanent disposal site for these materials. After eight years of characterization and evaluation of several sites, the DOE selected the Clive site located in Utah’s

West Desert approximately 75 miles west of Salt Lake City. The site’s remote location, low precipitation, naturally poor groundwater, and low-permeability clay soils were some of the attractive qualities of the area.

From 1984 to 1988, the VITRO tailings were relocated to Clive and placed in an above-ground disposal cell.

Since acquiring land adjacent to the VITRO disposal embankment and obtaining a disposal license, the vision of EnergySolutions’ Clive facility has been to provide a private disposal option for material from cleanups and generators of radioactive waste in separate disposal embankments similar to those used for DOE’s

VITRO project. The Clive site has received waste from cleanups carried out across the country including projects by the Environmental Protection Agency (EPA), Department of Energy (DOE), Department of

Defense (DOD), utilities and other commercial entities. The initial disposal license was for Naturally

Occurring Radioactive Material (NORM). Since 1988, EnergySolutions’ Radioactive Material License

(RML) has been amended several times, expanding the types of radioactive materials to include Class A low-level radioactive waste (LLRW), in addition to NORM.

2.2 LICENSES, PERMITS, AND AUTHORIZATIONS

EnergySolutions is permitted, licensed, and authorized to receive, treat, and dispose Class A LLRW, NORM/NARM, Class A Mixed LLRW, 11e.(2) Byproduct Material, Special Nuclear Material based on concentration limits, Polychlorinated Biphenyl (PCB) Radioactive Waste, and PCB Mixed Waste in accordance with the following documents. These documents are available for viewing at the

EnergySolutions Customer Portal at www.energysolutions.com.

Radioactive Material License (RML) Number UT 2300249, as amended

Class A LLRW as defined in Utah Administrative Code R313-15-1009

Class A Mixed LLRW (radioactive and hazardous)

NORM/NARM

Special Nuclear Material (concentration-based limits)

11e.(2) Byproduct Material License Number UT 2300478, as amended

11e.(2) Byproduct Material as defined by the Atomic Energy Act, as amended

State-Issued Part B Permit Number UTD982598898, as amended

Storage, treatment, and disposal of Mixed Waste

Authorizes disposal of specific types of PCB regulated waste in the LLRW and Mixed Waste disposal facility, depending upon the type and concentration of PCBs present in the waste

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[note that this authority has been transferred from the Groundwater Discharge Permit to the

RCRA Part B Permit] Special Nuclear Material (SNM) Exemption Order issued by the NRC, as amended

Authorizes receipt, storage, treatment, and disposal of waste containing SNM based on concentration limits rather than mass limits

TSCA Coordinated Approval and TSCA Shredding Approval issued by the EPA Region 8, as amended

Authorizes the receipt, management, and disposal of PCB Radioactive and PCB Mixed Waste

(40 CFR Part 761)

Section 3 details the various waste types and waste forms that are acceptable at EnergySolutions. Waste streams that are subject to multiple regulations must meet the requirements for each applicable regulation.

2.3 SITE LOCATION AND ACCESS

EnergySolutions’ operations are conducted on and adjacent to Section 32, Township 1 South, Range 11 West, SLM, Tooele County, Utah. The facility is about 75 miles west of Salt Lake City and about three miles south of Interstate 80, Exit 49. The site is conveniently accessed by both highway and rail transportation.

The disposal site mailing address is:

EnergySolutions LLC

Clive Disposal Site Interstate 80, Exit 49

Clive, UT 84029 (84083 if using Fed Ex)

Phone: (801) 649-2175

EnergySolutions receives waste shipped via bulk truck, containerized truck, enclosed truck, bulk railcars, rail boxcars, and rail intermodals. The transportation access allows EnergySolutions to operate throughout the entire year. The disposal site is accessed by the Union Pacific Railroad at EnergySolutions’ private siding. EnergySolutions uses more than ten miles of track and three locomotives for railcar management. The covered railcar thaw shed, rotary dumper, and railcar decontamination facilities allow for the efficient unloading, decontamination and return of rail shipments.

2.4 DISPOSAL AND TREATMENT FACILITIES

The design and operation of the EnergySolutions disposal site provides a long-term disposal solution with a minimal need for active maintenance after closure. EnergySolutions uses an above-ground engineered disposal cell. The design of these cells is patterned after DOE and EPA specifications for the VITRO disposal embankment. Each licensed disposal embankment meets or exceeds the applicable regulatory requirements.

Figure 2-1 shows the locations of EnergySolutions’ waste treatment, disposal, and operations areas at the

Clive facility. Clive waste operations are managed as three facilities:

“Bulk Waste Facility” (BWF) – including Mixed Waste, LARW, 11e.(2) and Class A LLRW

“Containerized Waste Facility” (CWF) – located within the Class A LLRW area

“Treatment Facility” (TF) – located in the southeast corner of the Mixed Waste area

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Figure 2-1. EnergySolutions’ Disposal and Treatment Facilities

Bulk Waste Facility

Waste shipped for direct disposal that is compliant with the ALARA Criteria described below is managed at EnergySolutions’ Bulk Waste Facility (BWF). Such waste is either removed from the container or filled with a grout-like mixture to minimize void spaces. Waste that is removed from the shipping container is typically compacted into soil lifts. For disposal in a bulk soil lift, debris must be less than 10 inches in at least one dimension and no longer than 12 feet in any dimension. Debris items that exceed this size limit are disposed of using grout in a different disposal area within the BWF. Waste is directly disposed at the Class A LLRW, Mixed Waste, or 11e.(2) disposal embankments. Bulk containers (e.g., intermodals, gondolas, etc.) and non-bulk containers (e.g., drums, boxes, etc.) are acceptable for receipt at the BWF.

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The Bulk Waste Facility (BWF) includes the following disposal embankments and structures:

Class A LLRW and NORM disposal embankment

11e.(2) Byproduct Material disposal embankment

Mixed Waste disposal embankment for LDR compliant solid waste

Intermodal unloading facility for unloading and staging bulk waste shipments for disposal

Railcar Rotary Dump facility for unloading and staging bulk waste shipments for disposal

Rail Wash Facility for decontamination, surveying, and releasing of railcars

Container Wash Facility for decontamination, surveying and releasing of bulk containers

Containerized Waste Facility

Waste shipped for direct disposal exceeding EnergySolutions’ ALARA Criteria is managed at the Containerized Waste Facility (CWF). Waste must be packaged in disposal containers (e.g., drums, boxes, liners, etc.) instead of bulk containers (e.g., intermodals, gondolas, etc.) for shipments to the CWF since

EnergySolutions will not remove such waste from its container due to the elevated dose rates. Please refer to EnergySolutions’ CWF WAC for information on shipping waste to the CWF.

Shipments to the CWF typically are shipped in a shielded transportation package such as a cask as illustrated in Figure 2-2.

Figure 2-2. Cask Shipment to the CWF

Treatment Facility

Waste shipped to EnergySolutions for treatment or liquid solidification/verification prior to disposal is managed at EnergySolutions’ Treatment Facility. The Treatment Facility is shown in Figure 2-1 as “TF”.

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The Treatment Facility is designed for radioactive waste that requires treatment for RCRA constituents and for liquid radioactive wastes requiring solidification prior to disposal. EnergySolutions’ Mixed Waste treatment and solidification capabilities include:

Chemical Stabilization – Including oxidation, reduction, neutralization and deactivation.

Amalgamation – For the treatment of elemental mercury.

Macroencapsulation – For the treatment of radioactive lead solids, RCRA metal-containing batteries and hazardous debris.

Liquid Solidification – For the solidification of radioactively contaminated liquids such as aqueous solutions, oils, antifreeze, etc. to facilitate land disposal. Mixed waste liquids can also be treated and solidified at the Treatment Facility.

Vacuum Thermal Desorption (VTD) of Organic Constituents - For the thermal segregation of organic constituents from wastes including wastes with PCBs. Waste containing PCB liquids is also acceptable for VTD treatment. Liquids will require solidification prior to processing through the system. The organic liquid condensate generated in the VTD process must be treated prior to final disposal. The non-liquid waste residue will be further treated for metal contaminates (if required) and disposed at the Mixed Waste embankment.

Debris Spray Washing – To remove contaminants from applicable hazardous debris.

Each of these treatment technologies are discussed in further detail in Section 3.1.3.

The Treatment Facility includes open and covered waste storage areas for storing, sampling, and staging Mixed Waste shipments, including the following buildings and areas:

Mixed Waste Operations Building

Mixed Waste Treatment Building

Liquids Storage Building

Mixed Waste storage, staging and sampling areas

2.5 ALARA CRITERIA FOR THE BULK WASTE AND TREATMENT FACILITIES

EnergySolutions has implemented an “As Low As Reasonably Achievable” (ALARA) Criteria to minimize worker exposures. The ALARA Criteria is not a license condition but is used as the primary distinction between waste that is acceptable for direct disposal at the BWF and CWF. Wastes with higher dose rates exceeding the ALARA Criteria are disposed at the CWF where waste packages are directly disposed without sampling and actual waste handling. Conversely, wastes with dose rates less than the ALARA Criteria may be disposed at the BWF since the waste is sampled and, in most cases, removed from the shipping container.

As shown in the table below, these ALARA Criteria define allowable external contact dose rates and loose surface contamination limits for waste managed at the BWF.

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External Contact Dose Rate

Removable Surface Contamination

On Exterior Surfaces of Debris

< 200 mR/hr on manifested container

< 500 mR/hr on external, accessible surfaces of waste in container

< 80 mR/hr on contact of unshielded container with resin

< 500 dpm α/100 cm

< 50,000 dpm β,/100 cm

External Contact Dose Rate Limits

The external contact dose rate limit of 200 mR/hr applies to the manifested container (e.g., drums/boxes on a flatbed truck or enclosed van, bulk containers such as intermodals, sealands, cargo containers, etc.).

For example, if drums or boxes are shipped in a bulk container, such as an intermodal, and the intermodal is manifested as the strong, tight container, then the external contact dose rate of 200 mR/hr applies to the intermodal and not to the drums or boxes inside the intermodal. The drums and boxes in this case would be considered waste and must not contain any item with dose rates exceeding 500 mR/hr on the external, accessible surfaces of the item.

The dose rate for debris items such as pipes should only be measured on the exterior surfaces and on the plane surface of the opening of the pipe to demonstrate compliance with the ALARA Criteria. For example, the internal pipe surfaces may exceed the 500 mR/hr dose limit only if the surface plane to the opening of the pipe is less than 500 mR/hr. Shield plates used to cover the opening of the pipe should not be used solely to lower the dose rates below the criteria since EnergySolutions is required to remove or penetrate into the debris items to fill internal voids with grout material.

Another example is DAW placed into 55 gallon drums and compacted into pucks. The dose rate criteria apply to the external surfaces of the puck itself and not to the DAW inside the puck.

Resin External Contact Dose Rate Limits

Unless approved in writing by EnergySolutions, resins must be shipped in disposal containers such as drums, boxes, liners, etc. to the BWF for grouting if the container is compliant with the ALARA Criteria .

Resins shipped to the BWF must be shipped under a Waste Profile specific for resins unless specifically approved in writing by EnergySolutions. Resins with dose rates that exceed these limits must be disposed at the CWF.

Removable Surface Contamination Limits

The same ALARA principles apply to the removable surface contamination limits. The main concern is controlling loose contamination on the exterior surfaces of debris items removed from the container.

Fixatives may be applied to the debris items to reduce the removable contamination levels below the specified limits.

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Requests for Exceptions

Requested exceptions to the ALARA Criteria are evaluated on a case-by-case basis. For example, Mixed

Waste exceeding the ALARA Criteria will be evaluated since the CWF cannot accept Mixed Waste for disposal. Generators must provide radiation and contamination surveys of the container and/or waste item when requesting approval to exceed the ALARA Criteria. Dose rate measurements at one foot from the waste should be provided on the radiation survey. The transportation mode and manifested package information should also be included with the request. The generator must receive written approval for exemptions to the ALARA Criteria prior to shipment of the waste.

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SECTION 3

WASTE CRITERIA

3.1 ACCEPTABLE RADIOACTIVE WASTES

The type, form, and quantity of LLRW, NORM, 11e.(2) byproduct material, and mixed waste that

EnergySolutions can receive for treatment and disposal is governed by the various licenses and permits under which EnergySolutions operates. EnergySolutions has been issued an Agreement State Radioactive Material License (License #UT 2300249, as amended) by the Utah Division of Waste Management and Radiation

Control (DWMRC). This license authorizes EnergySolutions to receive Class A LLRW, NORM, and

NARM waste. EnergySolutions has been issued a separate license (License number UT 2300478, as amended) to receive and dispose of uranium and thorium mill tailings byproduct material as defined by section 11e.(2) of the Atomic Energy Act of 1954, as amended.

The DWMRC issued EnergySolutions a State-Issued Part B Permit (EPA ID Number UTD982598898, as amended) to treat and dispose of hazardous waste which is also contaminated with LLRW, NORM, or

NARM wastes (mixed waste). Early in 1999, EnergySolutions received a Permit modification which authorized the receipt and disposal of PCB Radioactive and PCB Mixed wastes. In 2002, EnergySolutions received a TSCA Coordinated Approval from the EPA to expand PCB receipt and disposal options. The

TSCA Coordinated Approval has been subsequently expanded to include additional types of PCB radioactive and PCB mixed wastes.

3.1.1 Class A Low-Level Radioactive Waste

EnergySolutions Clive facility is authorized to receive Class A Low-Level and Mixed Low-Level Radioactive Waste. These wastes must be classified in accordance with the requirements of the Utah

Administrative Code (UAC) R313-15-1009, Classification and Characteristics of Low-Level Radioactive

Waste. Utah rule R313-15-1009 is similar to the NRC Waste Classification requirements in 10 CFR 61.55 with the addition of Radium-226. Generators must have in place a quality control program to ensure compliance with the waste classification requirements and prepare and retain with manifest documentation a record documenting the generator’s waste classification analysis. Shippers and generators should also review

NRC IE Bulletin No. 79-19 to ensure compliance with applicable training requirements in managing LLRW.

The information provided below is a summary of the waste classification regulations and how generators must classify their LLRW prior to shipment to the Clive facility. Further guidance is provided in NRC’s “Branch Technical Position on Concentration Averaging and Encapsulation”, as amended (BTP). All generators shipping LLRW to the Clive facility must comply with the NRC’s BTP as specified in Condition

16 of the Radioactive Material License. Utilization of the BTP for purposes of waste classification concentration averaging requires written approval from EnergySolutions Technical staff. Please contact EnergySolutions to assist and support the evaluation of these determinations.

Determination of waste class involves two considerations. First, consideration must be given to specific long-lived radionuclides listed in Table I of UAC R313-15-1009. Second, consideration must be given to specific short-lived radionuclides listed in Table II of UAC R313-15-1009. The waste is Class A if the radionuclides listed in either Table I or Table II are not present in the waste. Both tables are provided below.

The concentration limits for determining waste class are given in curies per cubic meter with the exception of the following Table I radionuclides which are given in nanocuries per gram: alpha-emitting

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Waste Acceptance Criteria transuranic radionuclides with a half-life greater than five years, Pu-241, Cm-242, and Ra-226. The following bullets outline the steps for determining waste class per R313-15-1009.

Classification Tables from UAC R313-15-1009

Table I

Radionuclide Ci/m nCi/g

C-14 8

C-14 (act) 80

Ni-59 (act) 220

Nb-94 (act) 0.2

Tc-99 3

I-129 0.08

Alpha-emitting transuranics

> 5 year half-life 100

Pu-241 3,500

Cm-242 20,000

Ra-226 100

When the waste does not contain any radionuclides listed in either Table I or II, it is Class A.

When the concentration does not exceed 0.1 times the value in Table I, the waste is Class A.

When the concentration exceeds 0.1 times the value in Table I, but does not exceed the value in Table I, the waste is Class C. EnergySolutions is not authorized to receive Class B and Class C waste.

For wastes containing mixtures of radionuclides listed in Table I, the total concentration shall be determined by the sum of fractions rule as illustrated in the example below.

When the waste does not contain any of the radionuclides listed in Table I, classification shall be determined based on the concentrations shown in Table II.

Table II

Radionuclide

Column 1 Ci/m

Column 2

Column 3

Total of all radionuclides <

5 year half-life

700 * *

H-3 40 * *

Co-60 700 * *

Ni-63 3.5 70 700

Ni-63 (act) 35 700 7,000

Sr-90 0.04 150 7,000

Cs-137 1 44 4,600

* There are no limits established for these radionuclides in Class B or C wastes. Practical considerations such as the 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 II determine the waste to be Class C independent of these radionuclides.

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When the concentration does not exceed the value in Column 1 of Table II, the waste is Class A.

When the concentration exceeds the value in Column 1 but does not exceed the value in Column 2 of

Table II, the waste is Class B.

When the concentration exceeds the value in Column 2 but does not exceed the value in Column 3 of

Table II, the waste is Class C.

For wastes containing mixtures of the radionuclides listed in Table II, the total concentration shall be determined by the sum of fractions rule.

For waste material that contains more than one radionuclide, the waste must be classified by applying the sum of fractions rule described in UAC R313-15-1009(1)(g). This rule states:

“For determining classification for waste that contains a mixture of radionuclides, it is necessary to determine the sum of fractions by dividing each radionuclide’s concentration by the appropriate limit and adding the resulting values. The appropriate limits shall all be taken from the same column of the same table. The sum of fractions for the column shall be less than 1.0 if the waste class is to be determined by that column.”

The following examples demonstrate the application of the sum of fractions rule in determining waste class.

EXAMPLE #1: A generator has one 55 gallon container of soil contaminated with plutonium-238, radium-226, uranium-234, uranium-235, uranium-238, cesium-137, and strontium-90. The density of the soil is 1.6 g/cm and is used to convert concentration units from pCi/g to Ci/m

. The radionuclide concentration in the container is as follows:

Container

Concentration (pCi/g)

Container

Concentration (Ci/m

Table I

Class A

Concentration

Limit (pCi/g)

Table II

Class A

Concentration

Limit (Ci/m

Pu-238 3,000 4.8 E-03 10,000 - -

Ra-226 6,000 9.6 E-03 10,000 - -

U-238 5,000 8.0 E-03 - - - -

U-235 1,100 1.8 E-03 - - - -

U-234 5,000 8.0 E-03 - - - -

Sr-90 5,000 8.0 E-03 - - 0.04

Cs-137 8,000 1.3 E-02 - - 1

* The soil density (1.6 g/cm3) is used to convert from pCi/g to Ci/m3.

The sum of fractions rule is applied to the container according to the radionuclides listed in Table I and II as follows:

Table I: 010.9 040.1

030.6

030.3

E

E

Table II: 011.2 000.1

023.1

020.4

030.8

E

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Based on the sum of fractions rule, the waste in this container is determined to be Class

A waste (i.e., 90 percent of the Class A limit for Table I radionuclides). This container is acceptable for disposal at EnergySolutions since it meets the sum of fractions rule.

The uranium radionuclides are not included in the sum of fractions calculation since these radionuclides are not included in Table I or II of R313-15-1009.

EXAMPLE #2: A generator has one 55 gallon container of Dry Active Waste (DAW) contaminated with americium-241, technetium-99, europium-155, colbalt-58, and cesium-135. The density of the DAW is 0.25 g/cm and is used to convert Table II units from pCi/g to Ci/m

. The radionuclide concentration in the container is as follows:

Container

Concentration (pCi/g)

Container

Concentration (Ci/m

Table I Class A

Concentration

Limit (pCi/g)

Table II Class A

Concentration

Limit (Ci/m

Am-241 6,000 1.5 E-03 10,000 - -

Tc-99 900,000 2.3 E-01 0.3 Ci/m

Eu-155 150,000 3.8 E-02 - - 700

Co-60 100,000 2.5 E-02 - - 700

Cs-135 500,000 1.3 E-01 - - - -

* The DAW density (0.25 g/cm3) is used to convert from pCi/g to Ci/m3.

The sum of fractions rule is applied to the container according to the radionuclides listed in Table I and II as follows:

Table I: 004.1 010.3

013.2

030.6

E

Table II: 050.9 020.7

025.2

020.7

028.3

E

Based on the sum of fractions rule, the waste in the DAW container exceeds the Table I Class A concentration limit and would not be acceptable at EnergySolutions. Note that

Cs-135 is not included in the sum of fractions calculation since this radionuclide is excluded in Table I or II of R313-15-1009.

Waste Classification Labels on Packages

All waste packages containing LLRW, including Mixed LLRW, must be labeled either “Class A

Unstable” or “Class AU” and appropriately marked in Block 16 of the Uniform Low-Level

Radioactive Waste Manifest Form 541. There are no State or Federal regulations that prescribe the size or color of the classification labels. The Utah DWMRC, however, requires that each package be labeled with a minimum of 0.5-inch lettering in contrasting color (refer to the

“Generator Site Access Permit Enforcement Policy - Utah Division of Radiation Control”, as amended). This requirement also applies to bulk packaging (e.g., intermodals, gondolas, etc.).

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LLRW Compact Export Approval

EnergySolutions’ Clive disposal site is not classified as a LLRW compact site under the Federal Low-Level

Radioactive Waste Policy Act, as amended. Condition 9A of the Radioactive Material License requires generators to demonstrate that the LLRW has been approved for export to EnergySolutions prior to the initial shipment of waste. In cases where an initial export authorization comes with an expiration date, generators are responsible to ensure continuing export authorization prior to shipment. Approval is required from the

LLRW compact of origin, or for states unaffiliated, the state of origin. All waste shipments received at Clive that require compact export authorization must include a copy of the authorization letter included with the shipping documentation. This license condition only applies to non-DOE generators of LLRW and excludes mixed LLRW. In addition, the Clive facility is not authorized to receive LLRW from the Northwest

Compact. Please contact EnergySolutions for assistance in complying with this license condition.

3.1.2 NORM/NARM Waste

EnergySolutions’ Radioactive Material License allows receipt and disposal of Naturally Occurring or Accelerator-Produced Radioactive Material (NORM/NARM) and Technologically Enhanced NORM

(TENORM). NORM/NARM does not include Byproduct, Source, or Special Nuclear Material and generally contains radionuclides in the uranium and thorium decay series. Since NORM/NARM waste is not considered LLRW, the waste classification regulations do not apply. In addition, LLRW Compact approval is required for NORM/NARM waste exported from the Rocky Mountain Compact.

3.1.3 Class A Mixed Low-Level Radioactive Waste

EnergySolutions’ Clive facility is authorized to receive Class A Mixed Low-Level Radioactive Waste (Mixed

Waste) for (1) disposal, or (2) treatment and disposal. Mixed Waste is defined by EnergySolutions’ State- Issued Part B Permit (# UTD982598898) as:

Waste defined by the Low Level Radioactive Waste Policy Act, Public Law 96-573; this is radioactive waste not classified as high-level radioactive waste, transuranics waste, spent nuclear fuel, or byproduct material as defined by section 11e.(2) of the Atomic Energy Act, and contains hazardous waste that is either listed as a hazardous waste in Subpart D of 40

CFR 261 and/or exhibits any of the hazardous waste characteristics identified in Subpart C of 40 CFR 261, or hazardous waste which also contains naturally occurring radioactive materials.

In accordance with 40 CFR 268.7, and by requirement of the State-issued Part B Permit, a Land Disposal

Restriction Notification and/or Certification must accompany each shipment of Mixed Waste. This includes former hazardous wastes that have been treated to remove the Hazardous Waste Codes.

3.1.3.1 Acceptable Hazardous Waste Codes

The specific EPA Hazardous Waste Codes that may be received by EnergySolutions are identified in its

Statue-Issued Part B Permit. A copy of this permit may be found at the Customer Portal tab on the

EnergySolutions’ web site: www.energysolutions.com . The following Utah Hazardous Waste Codes are not acceptable at EnergySolutions: F999 and P999.

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3.1.3.2 LDR Compliant Mixed Waste

Mixed Waste must be analyzed to determine if treatment is required prior to disposal. Mixed Waste that is determined to be compliant with the Land Disposal Restriction (LDR) treatment standards specified in 40

CFR 268 may be directly disposed in EnergySolutions’ Mixed Waste disposal embankment, or under certain circumstances, may be transferred to the LLRW embankment for disposal. EnergySolutions is required to verify LDR compliance for all Mixed Waste streams prior to disposal.

3.1.3.3 Mixed Waste Requiring Treatment

EnergySolutions’ Clive facility may also receive Mixed Waste that requires treatment in order to comply with

LDR treatment standards. EnergySolutions is approved under the State-Issued Part B Permit to operate a mixed waste treatment facility. Mixed Waste that is not LDR compliant may be treated by EnergySolutions using one of the following treatment technologies or methods:

Chemical Stabilization, Oxidation, Reduction, Neutralization, and Deactivation

Macroencapsulation of hazardous debris or radioactive lead solids

Debris Spray Washing

Thermal Treatment of Organics including PCBs

Mercury Treatment (Amalgamation)

Chemical Stabilization

Chemical stabilization involves the addition of approved chemical reagents in accordance with a waste-specific treatment formula and is performed in mixers at EnergySolutions’ Treatment Facility. Formula additions of waste, reagents, and water involve the following chemical processes to chemically bind contaminants to reduce their ability to leach from the waste.

Stabilization (STABL)

Deactivation (DEACT)

Neutralization (NEUTR)

Oxidation (CHOXD)

Reduction (CHRED)

Formula development may also be applied to Mixed Waste with very low levels of organic contaminants that require chemical destruction in order to meet total concentration based standards versus a leach standard as determined by the Toxicity Characteristic Leaching Procedure (TCLP) test. Mixed Waste requiring chemical stabilization may be sized and homogenized using various equipment including shredders, vibrating screens, and mixers. In order to evaluate chemical compatibility with the stabilization treatment process, generators shipping waste with Hazardous Waste Codes D001, D002, or D003 must provide a list of specific chemicals in each container with the shipping paperwork.

Macroencapsulation of Hazardous Debris and Radioactive Lead Solids

Mixed Waste consisting of hazardous debris may be macroencapsulated in accordance with the “Alternative

Treatment Standards for Hazardous Debris” as specified in 40 CFR 268.45. Figure 3-1 illustrates macroencapsulation of hazardous debris using pozzolanic material. Treatment of hazardous debris via macroencapsulation must meet the following criteria:

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Waste Acceptance Criteria

“Macroencapsulation of hazardous debris requires application of surface coating materials such as polymeric organics (e.g., resins and plastics) or use of a jacket of inert inorganic materials to substantially reduce surface exposure to potential leaching media” (40 CFR 268.45).

In order for hazardous debris to qualify for this alternative treatment, the waste must comply with the debris definition in 40 CFR 268.2(g).

“Debris means solid material exceeding a 60 mm particle size that is intended for disposal and that is: A manufactured object; or plant or animal matter; or natural geologic material. However, the following materials are not debris: Any material for which a specific treatment standard is provided in Subpart D, Part 268, namely lead acid batteries, cadmium batteries, and radioactive lead solids;

Process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludges, or air emission residues; and intact containers of hazardous waste that are not ruptured and that retain at least 75% of their original volume. A mixture of debris that has not been treated to the standards provided by § 268.45 and other material is subject to regulation as debris if the mixture is comprised primarily of debris, by volume, based on visual inspection” (emphasis added).

Figure 3-1. Macroencapsulation of RCRA Hazardous Debris

Therefore, packaged waste subject to macroencapsulation (MACRO) may contain other material that does not meet the debris definition (e.g., paint chips, scale, etc.) to the extent that the mixture is “comprised primarily of debris”. Consistent with the ALARA principle, this definition provides generators with flexibility in managing waste streams requiring treatment without having to sort and segregate non-debris items prior to treatment. However, as noted in 40 CFR 268.2(h), “deliberate mixing of other hazardous material with debris to change its treatment classification (i.e., from waste to hazardous debris) is not allowed under the dilution prohibition in § 268.3.”

Radioactive Lead Solids (RLS) are another type of hazardous waste that requires treatment via macroencapsulation. Radioactive Lead Solids include, but are not limited to, all forms of lead shielding and other elemental forms of lead. There are no size criteria for RLS unlike the 60 mm particle size requirement for hazardous debris. As such, smaller forms of RLS such as lead shot or fines require macroencapsulation prior to disposal.

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EnergySolutions’ MACRO treatment capability accommodates any size or weight of hazardous debris, thus enabling the generator to reduce the amount of time and cost associated with preparing waste packages for shipment. Generators with large debris over 20,000 pounds requiring macroencapsulation will provide the following information to EnergySolutions for review during the waste acceptance process: drawings, photographs, dimensions, weight, description of access ports to internal voids, radiological dose rate and contamination levels, and loading plans.

Debris Spray Washing

Debris Spray Washing is another alternative treatment option utilized by EnergySolutions to treat hazardous debris. High pressure water is sprayed at the debris surface to remove hazardous constituents to a “clean debris surface”. This treatment technology is best if used on non-porous debris such as metal. ‘‘Clean debris surface’’ criteria are specified in 40 CFR 268.45:

“Clean debris surface means the surface, when viewed without magnification, shall be free of all visible contaminated soil and hazardous waste except that residual staining from soil and waste consisting of light shadows, slight streaks, or minor discolorations, and soil and waste in cracks, crevices, and pits may be present provided that such staining and waste and soil in cracks, crevices, and pits shall be limited to no more than 5% of each square inch of surface area.”

Thermal Treatment of Organics (including PCBs)

Mixed Waste streams contaminated with organic hazardous constituents are among the most difficult waste streams to treat. The LDR treatment standards are expressed in terms of total organic concentrations (i.e., mg/kg) versus TCLP concentration based standards. As such, treatment of organic contaminated waste streams requires either destruction or removal of the organic constituent from the waste. Several organic contaminants carry the CMBST (combustion) technology-based treatment standard; the EnergySolutions’

Vacuum-assisted Thermal Desorption (VTD) unit has been demonstrated and approved by the EPA to meet this standard.

EnergySolutions utilizes the VTD system to process organic-contaminated waste streams including those containing PCBs. Waste containing PCB liquids is also acceptable for VTD treatment. PCB capacitors (leaking small PCB capacitors and light ballasts as well as large PCB capacitors) may also be processed through VTD. These wastes require size reduction prior to treatment and EnergySolutions has regulatory authority (through the EPA-administered TSCA Coordinated Approval) to shred PCB capacitors prior to treatment.

To meet permit requirements, generators are requested to identify the presence of asphalt or crude oil in profiled VTD waste streams.

Mixed Waste streams are heated in the VTD system at sufficient temperatures to volatize the organic constituents which are then condensed and collected as a liquid. The thermally treated residue is then sampled to verify LDR compliance. In some cases, the treatment residue will require additional treatment to stabilize hazardous metals prior to disposal. The organic liquid condensate will require further treatment to comply with LDR treatment standards.

Mercury Treatment

Elemental mercury contaminated with radioactive materials must be treated via amalgamation per

40 CFR 268.40. Amalgamation of elemental mercury involves the mixing of reagents with the mercury to

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Waste Acceptance Criteria produce a non-liquid, semi-solid amalgam that reduces the potential emissions of elemental mercury vapors to the air. The Utah DWMRC also requires the amalgamation treatment to reduce the leachability of elemental mercury to below the characteristic concentration limit of 0.2 mg/L TCLP. This requirement applies to amalgamated mercury treated at either EnergySolutions’ Treatment Facility or treated at another facility and shipped to EnergySolutions for disposal. Generators may ship elemental mercury contaminated with radioactive materials to EnergySolutions for treatment and disposal.

EnergySolutions is also capable of treating both Low (< 260 ppm Hg) and High Mercury Subcategory waste streams (≥ 260 ppm Hg). Waste streams containing Low Subcategory Mercury must be treated to less than

0.025 mg/L TCLP mercury. The EPA requires High Mercury Subcategory waste streams be treated thermally by incinerating (IMERC) or retorting (RMERC). EnergySolutions has received a site-specific treatment variance from the Utah Solid and Hazardous Waste Control Board to treat High Mercury Subcategory waste streams via stabilization instead of IMERC or RMERC. Consequently, waste streams containing High Subcategory Mercury are treated via stabilization and analyzed post-treatment to ensure the

TCLP mercury results are less than 0.2 mg/L.

Hazardous debris that is contaminated with mercury may be macroencapsulated in accordance with the

“Alternative Treatment Standards for Hazardous Debris” as specified in 40 CFR 268.45. Elemental mercury must be removed from hazardous debris to the maximum extent practical including, but not limited to, draining pumps, hoses, pipes, etc. and wiping excessive mercury from external surfaces.

3.1.4 11e.(2) Byproduct Material

EnergySolutions is licensed by the Utah DWMRC to receive and dispose of 11e.(2) byproduct material as defined by the Atomic Energy Act, as amended. 11e.(2) byproduct material is defined as the tailings or waste produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content. Shipments of 11e.(2) waste will be managed and disposed of in a separate disposal embankment specifically licensed and designed for this material.

3.1.4.1 Radionuclide Concentration Limits

EnergySolutions may accept 11e.(2) byproduct material with an average concentration in any transport vehicle (truck or railcar) not to exceed 4,000 pCi/g for natural uranium or for any radionuclide in the Radium- 226 series, 60,000 pCi/g for Thorium-230, or 6,000 pCi/g for any radionuclide in the thorium decay series.

EnergySolutions’ 11e.(2) Byproduct Material License does not require a sum of fractions calculation. The concentration limits are based on the average concentration of the 11e.(2) byproduct material over the transport vehicle upon receipt and not each individual container on the transport vehicle.

3.1.4.2 Acceptable Forms of 11e.(2) Byproduct Material

In addition to soil and soil-like 11e.(2) byproduct material, EnergySolutions may accept 11e.(2) contaminated debris. The generator must certify in the Radioactive Waste Profile Record that the debris was either generated during the cleanup of an 11e.(2) facility or is an integral part of the operations of extraction or concentration of uranium or thorium.

All debris must be less than 10 inches in at least one dimension and no longer than 12 feet in any dimension.

Debris that exceeds this size limit (e.g., 11e.(2) oversize debris) is not acceptable for disposal under the

11e.(2) license. Generators with 11e.(2) contaminated debris that are unable to size the debris prior to shipment must contact EnergySolutions’ Customer Service representative to make necessary arrangements for EnergySolutions to size the debris upon receipt.

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Waste Acceptance Criteria

Shipments of 11e.(2) byproduct material containing free liquid will be considered nonconforming and managed in accordance with EnergySolutions’ 11e.(2) license.

3.1.4.3 Certification of 11e.(2) Byproduct Material

EnergySolutions requires that each generator or owner certify in writing that the waste is 11.e(2) byproduct material as defined by the Atomic Energy Act, as amended. Specifically, the generator or owner must certify that the waste materials are tailings or waste produced by extraction or concentration of uranium or thorium from any ore processed primarily for its source material content. The generator or owner must also certify that the waste material does not contain any other radioactive waste or hazardous waste. The generator or owner must provide the following information as it relates to the 11e.(2) byproduct material:

License under which the waste was processed

Licensee that was issued the license

License issue and/or expiration date

Issuing agency

Type of license

Volume of tailings

The generator or owner must attach to the certification a list of all radiological and non-radiological constituents in the waste and the maximum and average concentrations of such constituents. EnergySolutions will perform an independent verification as to the accuracy of the information contained in the certification.

3.1.4.4 Shipping Paperwork for 11e.(2) Byproduct Material

Although 11e.(2) byproduct material is specifically excluded from the definition of Low-Level Radioactive

Waste; EnergySolutions requires that all shipments be manifested using the Uniform Low-Level Radioactive

Waste Manifest (NRC Forms 540 and 541).