Import & Export License Application for Diversified Scientific ...Diversified Scientific Services, Inc. (DSSI) requests, under 10 CFR 110.20 (a)(2), the issuance of a specific import

I

Diversified Scientific Services, Inc.

657 Gallaher Road * Kingston, TN 37763 * (423) 376-0084 e FAX (423) 376-0087

AD0234-97 Sent Via Federal ExpressNo. 3353250644

July 23, 1997 .

Mr. Ronald D. Hauber , OODirector for Non-Proliferation, Exports & Multilateral Relations'! • ) • .

Office of International ProgramsU.S. Nuclear Regulatory Commission11555 Rockville PikeRockville, MD 20855

Re: Application for a Specific License to Import/Export Radioactive Waste

Dear Mr. Hauber:

Diversified Scientific Services, Inc. (DSSI) requests, under 10 CFR 110.20(a)(2), the issuance of a specific import license to receive radioactivelycontaminated waste from Ontario, Canada for processing. Additionally, DSSIrequests the issuance of a specific export license to return to the generator theradioactive solids associated with processing the imported material.

DSSI operates an Industrial Boiler Facility for the treatment of liquid waste. DSSIis permitted to receive this material and to perform this treatment under RCRAPart B Permit Number TNHW-024 issued by the Tennessee Division of SolidWaste Management and Radioactive Materials License Number R-73014-K98issued by the Tennessee Division of Radiological Health.

This process completely destroys the original waste. The DSSI air pollutioncontrol system captures particulate matter and neutralizes the acid forminggasses generated during combustion of the waste. The salts from neutralizationand boiler ash associated with this waste will then be returned to the generator.

0

Prior to making the first shipment of radioactive material to DSSI for processing,Ontario Hydro will provide written assurance from the appropriate Canadianauthorities confirming Ontario Hydro's authorization to accept return receipt oftheir material, processed or unprocessed.

O.j :1 l~tj 1SWT 66

* Printed on recycled paper


657 Gallaher Road • Kngston, TN 37763 * (423) 376-0084 * FAX (423) 376-0087

AD0234-97, Page 2Mr. Ronald D. HauberJuly 23, 1997

As required by 10 CFR 110.31, the following attachments are enclosed insupport of this license application:

Attachment AInformation required by 10 CFR 110.32 for an import license

Attachment BInformation required by 10 CFR 110.32 on an NRC Form 7 for an export license

Attachment CInitial $5,000.00 application fee in accordance with 10 CFR 170.31

Additionally, a letter from Ontario Hydro concerning their ability to receive solidsfrom DSSI generated from processing their liquid is also attached as follows:

Attachment DOntario Hydro letter from H. Morrison dated June 27, 1997

Thank you for your consideration in this matter. If you have any questions orrequire any additional information, please do not hesitate to contact me at(423) 376-8712.

Sincerely,

z im R. SelphDSSI Radiation Safety Officer

Attachments

CC: Dr. J.P. Kraznia, Ontario Hydro TechnologiesMr. Roger Perry, TN DEC, Division of Radiological Health

1 Printed on recycled paper

, Diversified Scientific Services, Inc.

657 Gallaher Road * Kingston, TN 37763 * (423) 376-0084 * FAX (423) 376-0087


ATTACHMENT A

Import License Application


Import License Application / / O • q •' ,

The following information is provided, as required by 10 CFR 110.32, to supportthe application for a specific license to import radioactive waste.

Name and Address of Applicant

Diversified Scientific Services, Inc. (DSSI)657 Gallaher RoadKingston, Tennessee 37763

TN Radioactive Material License No. R-73014-K98'

Name and Address of Supplier

Ontario Hydro TechnologiesPickering Nuclear DivisionP.O. Box 160Pickering, Ontario LlV 2R5

Country of Origin

Canada

Name and Address of Intermediate Consignees

There are no intermediate consignees. The waste will be shipped directly toDSSI for processing and the resultant solids will be shipped directly back.

Dates of Proposed First and Last Shipment

First Shipment - August, 1997Last Shipment - Continuous business from date of authorization

AD0234-97, Attachment APage 1 of 2

Material Description

The radioactive wastes to be imported from Ontario Hydro Technologies aretypically liquid, used oil and/or other combustible materials containing primarilyH-3 and C-14, mixed fission product radionuclides, and other contaminants. Thewaste is generated during the normal course of business by the nuclear powerutility. Only waste authorized by our RCRA Permit, our Radioactive MaterialsLicense, and the Used Oil Regulations (40 CFR 279),will be imported.

The anticipated maximum quantity of waste is 5X10 6 kilograms per year. Theanticipated maximum quantity of radioactivity is approximately 1000 Ci of H-3and C-14 and 10 Ci of mixed fission product radionuclides per year. The wastesto be shipped to DSSI under this license will be destroyed and not disposed.Therefore the classification described in 10 CFR 61.55 is not applicable.

In accordance with 49 CFR 171.12a, the material shall be transported inaccordance with Canadian and U.S. transportation regulations. The material willmost likely be transported by exclusive use tractor trailer or tank truck to DSSIas Radioactive LSA or an exempt quantity.

The material was generated during the last 20 years from routine maintenanceof machines and machine shop work. The generator has a regulatorily drivenreason to dispose of this waste prior to August 31,1 997 and there is no permittedoutlet for it in Canada.

After the waste has been processed, the resultant solids will be returned to thegenerator in Canada for storage.

AD0234-97, Attachment APage 2 of 2


657 Gallaher Road * Kngston, TN 37763 * (423) 376-0084 * FAX (423) 376-0087


ATTACHMENT B

NRC Form 7, Export License Application


- 1 ---- - - - - - -- API~ROVEO BY 0MB: NO. 3150-0027NRC FOR(3-94)10CFR 110

tM 7

o

U.S Nuclear Regulatory Commission

APPLICATION FOR LICENSE TO EXPORTNUCLEAR MATERIAL AND EQUIPMENT

APPROVED BY OMS: NO. 3150-0027EXPIRES: 3-31-97

ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REouEST: 1.7HOURS. THIS MANDATORY SUBMITTAL IS REVIEWED TO ENSURE THAT THE APPLICABLE STATUTORY,REGULATORY. AND POLICY CONCIDERATIONS ARE SATISFIED. FORWARD COMMENTS REGARDINGBURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (T-4 F33). U.S.NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-SOO1, AND TO THE PAPERWORKREDUCTION PROJECT (3150-00271. OFFI(;E OF MANAGEMENT AND BUDGET. WASHINGTON, DC 2O503.

(See Instructions on Reverse)1. APPLICANTS a. DATE OF APPLICATION [ b. APPLICANT'S REFERENCE 2. NRC

USE - 4- 7/23/97 AD0234-97 USE-4

3. APPLICANT'S NAME AND ADDRESS ..t:.:......... ..... .. ................a. NAMEDiversified Scientific Services, Inc. material)

4. SUPPLIER'S NAME AND ADDRESS(Complete if applicant is not supplier of the

b. STREET ADDRESS (Facility Site) a. NAME

657 Gallaher Road Same as Number 3c. CITY T d. STATE e. ZIP CODE b. STREET ADDRESSKingston Tennessee 37763f. TELEPHONE NUMBER (Area Code - Number - Extension) c. CITY d. STATE e. ZIP CODE423 - 376 - 00845. FIRST SHIPMENT 6. FINAL SHIPMENT 7. APPLICANT'S CONTRACTUAL a. PROPOSED. LICENSE 9. U.S. DEPARTMENT OF ENERGY

SCHEDULED SCHEDULED DELIVERY DATE EXPIRATION DATE CONTRACT NO. (If Known)8/97 On-Going before August 31,1997 Maximum length allowed N/A

10. ULTIMATE FOREIGN CONSIGNEE .:= .. 11. ULTIMATE END USE .... .......:.a. NAME (Include plant of facility name)Ontario Hydro Technologies Return solid material from processing liquids fromb. STREET ADDRESS (Facility Site) - - Ontario Hydro toP e N Station for storage.Ric~kerinigNuzlersttýfien Lt- IC~ e Si n~ T ~ "I 1c. CITY T'; V••'6•-'7 d. COUNTRY

fh Ontario Canada Ila. DATE REQUIRED August 31,199712. INTERMEDIATE FOREIGN CONSIGNEE I -~: .. .iii:i!ii:;~!:!!!!!::•!•!ii:iii:•:i:!~~:i::iiiE•i; .1....:3.... ......... EDIATE.. .... .S ....i~~~ii~iiiii•~i:~i:!~i:ii~!i!i••:ii•ii:

12. ~ ~ ~ ~ ~ ~ ~ ~ ' INEMEIT FOEGOSGE A 13. INTERMEDIATE END USE .5OD

a. NAMEN/A N/A

b. STREET ADDRESS (Facility Site)

c. CITY d. COUNTRY13a. DATE REQUIRED

14. INTERMEDIATE FOREIGN CONSIGNEE :.:15. INTERMEDIATE END USE 1

a. NAMEN/A N/A

b. STREET ADDRESS (Facility Site)

c. CITY d. COUNTRY15a. DATE REQUIRED

16. COM 17, DESCRIPTION 18.MAX ELEMENT 19. MAX. 20. MAX ISOTOPE 21.CODE (include chemical and physical form of nuclear material; give WEIGHT WT. % WEIGHT UNIT

dollar value of nuclear equipment and components)........................ DSSI's combustion process completely destroys. -

....... ...... .... the original waste liquids. The DSSI air pollution N/A N/A N/A '4'-/Acontrol system captures particulate matter and - C)

.iii neutralizes the acid forming gasses generated -during combustion of the waste. The salts from

...... . neutralization and boiler ash associated with this

............ waste will be the material returned to thegenerator. The radionuclides returned will be .primarily mixed fission products with an annual

activity of less ten (10) curies. The waste doesnot contain Source Material or Special NuclearMaterial.

22. COUNTRY OF ORIGIN - 23 COUNTRY OF ORIGIN - SNMI 24. COUNTRIES WHICH ATTACHSOURCE MATERIAL WHERE ENRICHED OR PRODUCED SAFEGUARDS (if known)

N/A N/A N/A25. ADDITIONAL INFORMATION ON CONDIGNEES, END USES, AND PRODUCT DESCRIPTIONN (Use separate sheet if necessary)See DSSI Letter AD0234-97 dated July 23, 1997 to the U.S. NRC regarding an application for a specific license toimport/export radioactive waste.

f26. The applicant certifies that this application is prepared in conformity with Title 10, Code of Federal Regulations, and that all information in this applicationis correct to the best of his/her knowledge. 1 .

27. AUTHORIZED OFFICIAL Ia. SIGNATURE, b. TITLE DSSI Radiation Safety OfficerNRC FORM 7(3 -94)- -

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657 Gallaher Road • Kingston, TN 37763 * (423) 376-0084 * FAX (423) 376-0087

AD0234-97:,.-Page 5Mr. Ronald D. HauberJuly 23, 1997

ATTACHMENT C

Application Fee

Cýe C4 5 3 In OVIP- 1

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657 Gallaher Road • Kngston, TN 37763 * (423) 376-0084 * FAX (423) 376-0087


ATTACHMENT D

Ontario Hydro letter dated June 27, 1997


Box 1540, Tiverton, Ontario NOG 2T0Telephone (519) 361-2673

MEMORANDUM ?;?- e0-W 7

J. KRASZNAIPrinciple Research Engineer/ScientistTechnology Services DivisionKKR 230

97-06-27

FILE: WO-03463 (T5)

Ash from the Destruction of Radioactive Liquid at DSS1

We were asked if we would accept ash from the destruction of radioactivelycontaminated liquid if that material was destroyed at a U.S. facility such as that operated by DSSI.

Our facility is licensed to accept radioactive materials "produced at nucleargenerating stations or other facilities currently or previously operated by Ontario Hydro". It istherefore essential that you are able to demonstrate that the ash we receive is the ash which arosefrom the radioactive materials generated at Ontario Hydro facilities. If this can be demonstrated,and if the ash meets our Waste Acceptance Criteria (attached), then we can accept if for storageat Radioactive Waste Operations Site #2.

If the ash is sent to us we would prefer to receive it in a B25 box, although newcarbon steel drums are an acceptable alternative if quantities do not warrant the use of B25's.

H. MorrisonU Manager

Waste Management Services Dept.Nuclear Waste & Environment Services Div.KMombourquette/pb

Att.

cc: K. Mombourquette

n:\wmsmg r\memo\destruct. doc

06/27/97 13:54 ea 003

WASTENWESD WAC-01 Page I of 4

ACCEPTANCE CRITERIA

REV 5

WASTE ACCEPTANCE CRITERIA

WAC-01

BNPD RADIOACTIVE WASTEOPERATIONS SITE 2

ABSTRACT OF REVISION:

New format.Definitions expanded.General information expanded.Added waste classification and packaging criteria.Reorganized specific criteria into "Normal" and "Non-standard" wastes.Reorganized criteria for standard low and intermediate level waste.Revised packaging criteria for contaminated oil.

Revised by: Verified by: Authorized by: IG. Cleland K. MomboUrquette H. Morrison,

Date: Date: ii Date:

97-04 " . ,, t 7

06/27/97 13:55 00[a 004

TABLE OF CONTENTS

1.0 PURPOSE

2.0 SCOPE

3.0 GOVERNING POLICY

4.0 RESPONSIBILITIES

5.0 DEFINITIONS

6.0 GENERAL INFORMATION

6.1 Telephone Numbers6.2 Normal Hours of Operation6.3 Holidays6.4 Pre-Shipment Requirements6.5 Shipment Prior Notification6.6 Pickup and Offloading Schedule6.7 Drivers Check-In Procedure6.8 Delays6.9 Retrievability of Stored Material6.10 Equipment Storage

7.0 MEASUREMENT CRITERIA

7.1 Volume Measurement7.2 Mass Measurement7.3 Dose Rate Measurement7.4 Activity Measurement

8.0 NON-RADIOLOGICAL CRITERIA

9.0 WASTE CLASSIFICATION AND PACKAGING CRITERIA

9.1 Station Processing and Handling9.2 Streaming and Characterization9.3 Classification9.4 Packaging9.4.1 General9.4.2 Care and Use of Packages9.4.3 Labelling9.4.4 Contamination Control9.4.5 Tritium Control

06/2-7/97 13:55 0@ oo5

TABLE OF CONTENTS CONT'D.

9.4.6 Free-Standing Liquid9.5 Waste Tracking9.6 Transportation9.7 Documentation

10.0 ACCEPTANCE OF NORMAL WASTES

10. 1 Procedure10.2 Criteria for Exempt Waste10.3 Criteria for Low Waste10.3.1 LLW Incinerable10.3.2 LLW Compactible10.3.3 LLW Non-Processible10.3.4 Tritiated LLW10.3.5 Carbon-14 Contaminated10.3.6 Iron-55 Contaminated10.3.7 Reject Drums10.3.8 HT Contaminated TRF Waste10.4 Criteria for Intermediate Level Waste10.4.1 Small Filter and IX Columns10.4.2 Core Components10.4.3 Bulk Ion Exchange Resin10.4.4 Large Heat Exchangers for In-ground Container IC-HX Storage10.4.5 Miscellaneous Bulky Items10.4.6 High Activity Particles10.5 Other Hazardous Waste10.5.1 Scintillation Fluids10.5.2 Animal Carcasses

11.0 ACCEPTANCE OF NON-STANDARD WASTES

11.1 Procedure11.2 Criteria for Liquids11.3 Criteria for Interim Storage of Oil11.4 Criteria for Solidified Liquids11.5 Criteria for Interim Storage of Contaminated Tooling11.6 Criteria for Fuel Flea Contamination

06/27/97 13:56 e 9006

TABLE OF CONTENTS CONT'D.

12.0 EXCLUSIONS (UNACCEPTABLE WASTE)

12.1 Waste Origin12.2 Waste Form12.2.1 Liquids12.3 Radiological Content12.3.1 Recognizable Used Fuel Fragments12.4 Non-Radiological Content12.5 Exclusions with Respect to Safeguards and Physical Security

13.0 NON-COMPLIANT WASTES

14.0 WASTE AUDITS

15.0 REFERENCES

06/27/97 13:562007

1.0 PURPOSE

2.0

2.1

The purpose of this document is to establish criteria for:

a) accepting radioactive waste at the BNPD Radioactive WasteOperations Site 2 (RWOS), and

b) excluding wastes and waste forms not allowed under the existingoperating licence; that represent an unacceptable risk or cost forRWOS operations; or that represent unacceptable risk or cost forfuture disposal operations.

SCOPE

These criteria apply to all radioactive waste offered for shipment to thenreceived at the BNPD Radioactive Waste Operations Site 2 (RWOS).

These criteria apply to waste produced in nuclear generating stations andother facilities currently or previously operated by Ontario Hydro, consistingof materials which are contaminated with fission and/or activation products,or have become radioactive as a result of neutron activation, or may containnatural radionuclides and/or actinides. These wastes can be categorized intosolid waste and liquid waste.

GOVERNING POLICY

- Waste Acceptance at BNPD Radioactive Waste Operations Site,NWESD Policy WMSD 1.57

Waste Acceptance at BNPD Radioactive Waste Operations Site,NWESD Procedure WMSP-03460-1

Only wastes and waste forms described in the RWOS Safety Report (orby prior agreement with the AECB) can be accepted at RWOS.

Periodically, wastes will arise at the generating stations that are notdescribed in this Waste Acceptance Criteria. Shippers may still shipthese wastes to RWOS by prior agreement with WMSD.

3.0

Revised by: Verified by:, Authorized by:

G. Cleland K. Mombourquett• "• H. Morrison

Date: Date: Date:97-04 _1__ _/0 S f(

06/27/97 13:57 -- _ __ _008

NWESD WAG-al Page 2 of 21WASTE ACCEPTANCE CRITERIA

REV 5

Waste Acceptance Criteria will clearly state acceptable waste forms, wastetracking requirements, waste segregation requirements, lists of excludedmaterials, waste package requirements, waste characterisation requirementsand limits on radiological and chemical contents.

WMSD reserves the right to make changes and/or additions to the wasteacceptance criteria at any time.

Prior acceptance of a non-conforming or "special" waste form does not

constitute blanket acceptance of that waste form for future shipments.

4.0 RESPONSIBILITIES

The final determination of acceptability shall be made by the Manager ofWMSD, or authorised designate.

4.1 The Manager, Waste Management Services Department, NWESD isaccountable for these Waste Acceptance Criteria.

Hugh Morrison, Manager (ext. 3389)

4.2 The Operations Co-ordinator is responsible for the day to day operations ofRWOS. Arrangements for normal wastes are made through Planning.Arrangements for non-standard wastes are made through the Operations Co-ordinator.

George Macdonald, Operations Co-ordinator (ext. 3201)Vein Fry, Planner (ext. 3207)

4.3 Technical support, including long range planning, for RWOS is theresponsibility of the Technical Superintendent - Waste Operations Technical.

Keith Mombourquette, Technical Superintendent (ext. 4844)Gregg Cleland (ext. 3205)Mike Garamszeghy (ext. 4084)Mark Billington, Incineration (ext. 5859)Ed Nicholls, Waste Tracking (ext. 4082)

06/.27/97 13:57 %Y 200a9

5.0 DEFINITIONS

Where practical, definitions are consistent with those in the most recentedition of the IAEA Radioactive Waste Management Glossary:

Waste Acceptance Criteria (WA C); those criteria relevant to acceptance ofwaste packages for handling, processing, storage and disposal.

Waste is held at the BNPD Radioactive Waste Operations Site bysecuring it in a safe form and posting signs listing the known hazards.

Waste. Characterization is the determination of the physical, radiological,chemical and biological properties of waste to establish the need forfurther processing and/or decide on the appropriate method of storage ordisposal.

Waste Form is the waste- in its physical and chemical form after treatmentand/or processing (resulting in a solid product) prior to packaging by the.shipper. The waste form is a component of the waste package.

.Waste Package is the combination that includes the waste or waste formand any container(s) and internal barriers (e.g. liner) prepared inaccordance with the requirements for handling, transportation, storageand/or disposal.

Waste Segregation is the activity of separating, or keeping separate,waste according to its radiological, chemical and/or physical properties.

Waste Tracking is the process of identifying and recording where andwhen wastes originate at the station and their Movements until delivery toRWOS for conditioning and/or placement into storage inventory.

E~xempt Waste: waste that is released from regulatory control becausethe associated radiological hazards are negligible.

Low and Intermediate Level Waste: waste that the radionuclideconcentration or quantity is above the clearance levels established by theregulator (AECB), but with a radionuclide content and thermal powerbelow those of high level waste (e.g., used fuel). Low and intermediatelevel waste may also be separated into short lived and long lived wastes.

06/27/97 13:58 0Z0o10

For the purposes of these waste acceptance criteria only, the followingdistinction is made:

a) Low level waste is dominated by short lived fission and/oractivation products in concentration and quantity such that thecontact gamma dose rate on the waste form is less than 1 rem/h.The alpha, beta and tritium concentrations and the potential forgross contamination or high activity particles are so low that theradiation protection of waste handlers is dominated by concerns forgamma over the following twenty years.

b) Intermediate level waste is all other low and intermediate levelwaste.

6.0 GENERAL INFORMATION

6.1 Telephone Numbers

Telephone contacts are as follows:

Normal Wastes: Waste Operations Planner (Vem Fry) at (702) 3207 or(519) 361-3201.

Non-standard wastes: Waste Operations Co-ordinator (George Macdonald)at (702) 3201 or (519) 361-3201.

Other Waste Operations personnel can be contacted at the numbers listed inSection 4.

The WVRF operator can be contacted at (702) 4009 or (519) 361-4007 at alltimes. This is a ulast resort" contact.

Facsimile transmission can be made as follows:

Manager, Technical Superintendent & Operations Co-ordinator(519) 361-4345

Waste Operations Technical (519) 361-3223

Waste Operations Planning, Field Office and Operator (519) 361-5846

Waste Operations Radiation Control (519) 361-3994

06/2,7/97 13:58 V @1011

6.2 Normal Hours of Operation

RWOS is staffed on a continual basis, however, most operating personnel,as well as their supervision, technical and planning support work weekdaysbetween 0730 hand 1600 h.

6.3 Holidays

Those statutory holidays listed in the OH fiscal calendar.

6.4 Pre-Shipment Requirements

For normal wastes, contact the Waste Operations Planner.

For non-standard wastes or unusually large volumes of wastes resultingfrom major operating or maintenance programs, early involvement ofWaste Operations' staff is recommended. This ensures that thenecessary storage capacity, equipment and skilled labour are in place.Contact the Waste Operations Coordinator.

6.5 Shipment Prior Notification

Prior notification is required for non-standard wastes, as well as for somenormal wastes if listed in the acceptance criteria.

6.6 Pickup and Offloadinq Schedule

Waste pickup is arranged through WMSD Planning (ext. 3207). Most off-sitewastes can be picked up within three (3) working days. Most on-site wastescan be picked up within on (1) working day. Alternate arrangements arepossible, however a surcharge may be applied at the discretion of theOperations Co-ordinator.

6.7 Drivers Check-In Procedure

Drivers are required to check in at RWOS as part of transport regulationsand/or RWOS procedure.

6.8 Delays

Delays may occur due to weather, packaging problems and rarely due topriority problems. Contact Waste Operations Planning if turnaround timeis a concern.

06/2-7/97 13:59 V' ___ __ __ __ _ -- 012__

6.9 Retrievability of Stored Material

Radioactive waste must be packaged and stored in a manner that permitsits safe retrieval for subsequent disposal. This is reflected in the followingacceptance criteria.

6.10 Equipment Storage

Contaminated tooling can be accepted for interim storage per applicablecriteria, Section 11.5. Other storage requests are treated as non-standardrequests, Section 11.

7.0 MEASUREMENT CRITERIA

7.1 Volume Measurement

Waste volumes are measured in cubic meters.

7.2 Mass Measurement

Mass is measured in kilograms. Weight is measured in pounds or tons.

7.3 Dose Rate Measurement

Dose rate is measured in mrem/h and rem/h.

7.4 Activity Measurement

Activity is measured in Cures.

8.0 NON-RADIOLOGiCAL CRITERIA

Reserved for future criteria.

9.0 WASTE CLASSIFICATION AND PACKAGING CRITERIA

9.1 Station Processing and Handling

Processible wastes shall not be pre-treated at the shipper's site in a mannerwhich will interfere with the operation of the WVRF processing equipment(e.g. pre-compaction of waste at source is not permitted).

Shippers must have "Likely Clean" and "Presumed Active" programs thatstrive to divert as much exempt waste as practical away from RWOS. Lowlevel waste that is needlessly "contaminated" with exempt waste representsan unacceptable burden to Ontario Hydro and its future ratepayers.

06/27/97 14:00 Z013

9.2 Streaming and Characterization

The eventual disposal of low and intermediate level wastes received atRWOS can only be accomplished if the characteristics (radiological,chemical and physical) are known (measured or estimated with reasonableaccuracy). In order to avoid the necessity of measuring the characteristics ofeach waste form, it is necessary to identify typical waste streams then applygood waste management practice, reasonable assumptions, and source termdata to achieve good waste characterization estimates.

Criteria will be developed and applied in the future to achieve this.

9.3 Classification

Wastes shall be segregated at the generating site into "Incinerable","Compactible" and "Non-Processible" categories according to thesegregation criteria established by WMSD. Refer to Appendix A.

9.4 Packaging

9.4.1 General

All wastes shall be shipped in containers/packages approved by the WMSDOperations Co-ordinator or authorised designate. A catalogue (WAC-02) ofstandard radioactive waste containers/packages is available from WMSD.

All wastes shall be packaged to prevent the spread of radioactivecontamination and to protect personnel from radiation and other hazardsduring handling of the wastes.

Radioactive waste must be packaged in a manner that allows it to beshipped, unloaded and stored without unacceptable risk to public andworker safety.

Solid LLW shall be packaged in 60 L clear polyethylene black striperadioactive waste bags (OH MatCode # 223A1685). Bulky items may bepackaged in 80 L clear black stripe radioactive waste bags (223A8853). Allbags shall be sealed with duct tape using the following colour codes:

Carbon-14 (C-14) Blue tape (# 995A1 101)TRF Elemental Tritium Red tape (# 995A4104)Iron-55 (Fe-55) Brown tape (# 995A1 094)"Normal wastes" Yellow tape (# 995A3712)

Sharp items which may puncture bags shall be double bagged. Wherepractical, sharp edges should be covered with duct tape or other suitableprotection.

06/27/97 14:00 0... • 14

Bags shall normally have a maximum weight of 25 lbs (11.5 kg), and in nocase greater than 40 lbs (18.1 kg).

All bagged wastes shall be shipped to the RWOS in containers supplied byWMSD (currently 1 m3 yellow corginers). Blue (C-14), red (TRF) and brown(Fe-55) colour coded wastes shal ipped in separate containers. Theyshall not be mixed with normal (yellow coded) wastes. Containers with blue,red or brown coded wastes shall be clearly marked with a similar colourcoded stripe on at least two sides and the top.

9.4.2 Care and Use of Packages

Waste packages (i.e., flasks) owned by the waste generator must bemaintained and inspected under a quality program that assures theirstructural and shielding integrity, and cleanliness. Nuts and bolts must beeasily removable and flanges not seized (e.g. coated with anti-seizecompound). The gross weight must be clearly marked on the package. Inaddition, the weight of any removable portion (such as lids or shielding plugs)must be clearly marked on that part.

Re-usable waste packages must be provided with suitable lifting connectionsfor the package as a whole, the lid, and the waste contained in the package.All lifting connections shall be achievable using standard tools withoutexposing the waste handler to any elevated radiation fields or beams.

All bolts and other closure devices on re-usable waste packages owned bythe waste generator which must be opened for removal of the waste shall bemaintained in good working order by the waste generator.

Disposable waste packages must be provided with suitable liftingconnections for the package. All lifting connections shall be achievablewithout exposing the waste handler to any elevated radiation fields or beams.All non-standard lifting tackle required for handling non-standard packagesmust be supplied by the waste generator.

9.4.3 Labelling

All additional non-radioactive hazards associated with a waste shipment shallbe clearly marked on the containers and on the shipping documents (e.g.,radioactive asbestos).

9.4.4 Contamination Control

Packaging must be selected to control contamination during handling(loading, transport and unloading) and be readily decontaminated ifnecessary.

06/27/97 14:01 V 9015

9.4.5 Tritium Control

Packaging must be selected to control tritium during handling (loading,transport and unloading).

9.4.6 Free-Standing Liquid

Waste packages/containers shall not contain any free standing water. (e.g.,interstitial water in dewatered IX resin is acceptable, flooded resin is notacceptable).

Re-usable waste packages must be free of loose contamination and liquids

inside and outside.

9.5 Waste Tracking

Waste tracking is an important element of lifecycle management of low andintermediate level waste. Shippers must have the capability to track wastefrom point of origin (station pick-up point) until placement into shippingpackages. If bar coding technology is used, it should be compatible withIntermec technology.

9.6 Transportation

Additional restrictions based on transport regulations may apply to thepackaging and shipment of waste from the generator's site to the RWOS.The Transport Co-ordinator at each facility should be consulted to assist thewaste generator.

9.7 Documentation

All waste shipments received at the RWOS must be accompanied bycomplete documentation. For all shipments, this includes, as a minimum anapproved Radioactive Materials Shipment Advice form (OH form # 820459 -external to BNPD site) or Transfer Permit (Conditional or Standing, fromwithin BNPD site). Additional documentation is listed, where required, underthe specific requirements for each waste type.

10.0 ACCEPTANCE OF NORMAL WASTES

10.1 Procedure

Normal procedure is to apply these acceptance criteria and makearrangements through WMSD Planning.

06/'27/97 14:01 olZ0

10.2 Criteria for Exempt Waste


10.3 Criteria for Low Level Waste

10.3.1 LLW Incinerable

Incinerable wastes shall have a maximum dose rate of 60 mremnh on contact

with the unshielded bag.

Incinerable waste shall be packaged in clear radioactive waste bags unlessotherwise specified. The bags shall be closed with tape. Bags with holes, orthat contain sharp objects, shall be double bagged. Bagged waste mustweigh less than 40 lbs.

Bags shall not contain visible liquids (oils, water, paint).

Bags shall have a maximum tritium level of 100 MPCa.

Dry incinerable wastes may be packaged in cardboard boxes with overalldimensions of less than 2 ftx 2 ft x 2 ft (60 cm x 60 cmx 60 cm). The boxmust weigh. less than 40 ibs. and be labelled as to contents.

Large incinerable items (such as scaffolding planks and plywood) must be

cut into pieces with a maximum dimension of 2 ft (60 cm) and bagged.

10.3.2 LLW Compactible

Compactible wastes shall have a maximum dose rate of 200 mremnh oncontact with the unshielded bag.

Compactible waste shall be packaged in clear radioactive waste bags unlessotherwise specified. The bags shall be closed with tape. Bags with holes, orthat contain sharp objects, shall be double bagged. Bagged waste mustweigh less than 40 lbs.



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10.3.3 LLW Non-Processible

Low level non-processible waste is all low level waste that is neitherincinerable nor compactible.

Low level non-processible waste shall have a maximum contact dose rate of1R/h.

Low level non-processible waste shall be packaged in clear radioactivewaste bags unless otherwise specified. The bags shall be closed with tape.Bags with holes, or that contain sharp objects, shall be double bagged.Bagged waste must weigh less than 40 lbs.



Large non-processible items may be packaged in WMSD suppliednon-processible. waste containers ("blue bins"). In such cases, the wasteand/or container shall be sealed to prevent the spread of contamination. Theexterior of the container shall be free of any loose contamination. The ratedweight capacity of the "blue bin" shall not be exceeded.

HEPA filters may be packaged in suitable cardboard boxes (such as the oneswhich contained the replacement filters). Where the potential for loosecontamination exists, the filter and/or box shall be sealed in a suitable plasticbag.

Large non-processible items may be packaged in "blue bins", provided thatthe unshielded dose rate on the container does not exceed 1 rem/h oncontact with any surface of the container. "Blue bins" containing C-14,elemental tritium or Fe-55 wastes shall be colour coded with a tape stripeaccording to 9.4.1.

Some non-processible wastes, such as solidified liquids and wastes with ahigh potential for loose contamination, may be packaged in 205 Lnon-processible radioactive waste drums ("black drums" such asOH MatCode # 223A4625 or 223A1 790). The drums shall be sealed and thecontents of the drum shall be clearly marked on the side of the drum. Wheresix or more drums are to be shipped, the drums shall be shipped on WMSDsupplied drum. racks ("bale racks" - OH MatCode # 599A6700), six per rack.

If scrap (previously used) drums are used, they must be in good condition(e.g., leak tight, rust free). In addition, any old markings which are notappropriate for the new waste form shall be completely covered over withopaque paint. (e.g., do not leave words like '•Waste Oil" stencilled on a drumwhich actually contains metal shavings.)

06/27/97 14:03 V1 [oa01

NOTE: The use of drums for routine non-processible waste is severelydiscouraged due to in-efficient storage. (A rack of six drumswith a capacity of 1.2 m3 of waste occupies 3.4 m 3 of storagespace).

10.3.6 Iron-55 Contaminated

Iron-55 (Fe-55) contamination is present'to varying degrees during Bruce Afuel channel maintenance. When Fe-55 is identified by Bruce A as being ahazard in low level waste, the following is required:

Contact the Operations Co-ordinator (3201) PRIOR to transferring the Fe-55contaminated waste.

Unless agreed to otherwise by the Operations Co-ordinator, Fe-55 waste isto be transferred to RWOS on weekdays during dayworker hours.

Incinerable Fe-55 waste must be double bagged, marked with brown tape(T1 .1) and shipped in 1 cubic meter containers clearly marked "FE-55INCINERABLE WASTE".

Fe-55 contaminated compactible waste is treated as non-processible.Non-processible Fe-55 waste must be packaged as follows:

- caulk all joints of a "blue bin" with silicone caulking compound- line the bin with plastic sheeting and cover and seal the plastic with

duct tape- cover the blue bin by strapping on a 1/2 inch thick plywood sheet- mark the bin "FE-55 NON-PROCESSIBLE WASTE"

10.3.7 Reject Drums

All reject drums shall be free of liquids and sludge inside and free of loosecontamination on the outside.

The maximum contact dose rate on any surface of the drum shall be lessthan 1 rem/h. If the dose rate exceeds this limit, the drum must bedecontaminated prior to shipment to the RWOS.

Reject drums which may contain loose contamination on the inside, andcannot be sealed (for example due to deformation of the drum) shall besealed in a suitable plastic bag.

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10.3.8 HT Contaminated TRF Waste

Metallic waste with high levels of surface elemental tritium shall be packagedas follows:

a) double bag components in polyethylene, minimise the void volume,b) heat seal in a metallic foil bag, and place into a steel drum,c) backfill void space with moist vermiculite, or other absorbent,d) contain in a 1 cm thick sealed high density polyethylene salvage

overpack (Enpac) labelled 'TRF ELEMENTAL TRITIUM WASTE.

Tritiated oils, limited to 1000 Ci per package, shall be packaged as follows:

a) absorbed on sawdust (or other oil absorbent),b) place in a steel drum,c) contain in a 1 cm thick, sealed high density polyethylene salvage

overpack (Enpac)

The HDPE salvage overpack might have to be further contained in a qualifiedcontainer for transportation purposes.

10.4 Criteria for Intermediate Level Waste

All waste with greater than 1 rem/h gamma contact shall be consideredIntermediate Level Waste. All filters and IX columns used for cleanup ofsystems with long half life radionuclides or with the potential for alpha and/orhigh activity particles, are considered to be intermediate level waste. Forexample, fuel bay filters are considered to be intermediate level waste at lowdose rates.

10.4.1 Small Filters and IX Columns

All waste containers for Type 3 wastes (such as filter drip cans, disposablefilter vessels and shutoff rod liners) shall be designed for storage in an IC- 8or equivalent storage structure. Except for 3 m3 IX resin liners (seeSection 10.4.3) and similar packages, the maximum OD for the wastecontainers is 20 inches (51 cm). Oversized wastes with OD up to 22 inches(56 cm) can be accepted as non-standard waste for tilehole storage (11.0).

All waste packages must be designed for bottom unloading into IC-1 B's in amanner that controls the descent of the waste, contains loose contamination,and limits dose rates to less than 300 mrem/h during storage operations.

IX columns must be sealed. Small filters must be contained in a sealedcontainer or a competent drip can.

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REV 5

10.4.2 Core Components

All waste packages must be designed for bottom unloading into IC-1 8's in amanner that controls the descent of the waste, contains loose contamination,and limits dose rates to less than 300 mrem/h during storage operations.

Full length core components can be stored in specially adapted IC-1 8's.Such operations generally require long lead times and special equipment.Please contact the WMSD Waste Operations Technical Supt. during theearly planning stages for the job for detailed requirements on a case by casebasis.

10.4.3 Bulk Ion Exchange Resin

Bulk ion exchange (IX) resins must be packaged in containers approved byWMSD. The standard containers for resins are "4 m3 Low Level ResinContainer" (OH MatCode # 599A6735 for storage of resins with a contactdose rate of less than I rem/h in Low Level Storage Buildings) and "3 m3

Resin Liner" (OH MatCode # 599B6406 for storage of resins in the IC-1 8's).Bulk resin containers are normally obtained by contacting the WMSDOperations Co-ordinator.

All penetrations on the resin containers must be sealed with suitablethreaded metal plugs.

The resin containers must be de-watered to less than 1 % free standing waterprior to shipment to the RWOS.

The 3 m3 resin liner must be loaded into the transportation flask usingapproved procedures to ensure that the lifting lug remains accessible.

The 3 m3 resin liner must be free of loose contamination and water on theoutside.

10.4.4 Large Heat Exchangers for In-Ground Container IC-HX Storage

These criteria apply to large heat exchangers only. Contact WMSD todiscuss the suitability and preparation of individual heat exchangers forstorage as inground heat exchangers (IC-HX) as follows:

All heat exchangers shall be dry on both the tube side and shell side, andfree of loose contamination on the exterior of the shell.

All heat exchangers shall have a minimum wall thickness of 3/8" (1 cm). Allpenetrations in the outer shell shall be sealed with welded caps with aminimum thickness of 3/8".

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NWESD WAC-01 Page 15 of 21WASTE ACCEPTANCE CRITERIA

REV 5

All heat exchangers shall be coated with a suitable corrosion protection-- ' coating (such as coal tar epoxy, or equivalent approved by the WMSD

Operations Co-ordinator).

All heat exchangers shall be vacuum leak tested to -6 psig (-42 kPag) andholding the vacuum for a minimum of 30 minutes, as indicated on a vacuumgauge connected to both the shell side and tube side. The leak test is to bedone before the coating is applied. All leaks must be located and repairedusing welded caps. After a successful vacuum test, the heat exchangers areto be backfilled with nitrogen.

All heat exchangers shall have the weight and maximum dose rate stencilledon the side.

All heat exchangers shall have suitably designed lifting lugs to allow liftingand rotation from horizontal to vertical.

A quality inspection check sheet must accompany the shipment describingweld quality control, leak testing and corrosion protection.

All heat exchangers destined for IC-HX storage shall be provided with a leaktest port consisting of a 3/4" NPS pipe which penetrates both the shell andtube side, and extends approximately 4 ft (1.2 m) above the top of the heatexchanger when raised to a vertical orientation. The leak test line shall beprovided with a ball valve at the upper end. The ball valve shall be cappedwith a suitable pipe plug. A similar vent line, open at both the top and bottom(no valve) is to be attached to the exterior of the heat exchanger shell andprotrude to the same height as the leak test line. The vent line shall be fittedwith a U-bend at the upper end to prevent the ingress of precipitation.

An inspection / test report (OH form 241547) must be completed and

forwarded to WMSD Technical.

10.4.5 Miscellaneous Bulky Items

The existing storage facility at RWOS are designed for specific waste formgeometries. Miscellaneous bulky items are treated as non-standard wastes(11.0).

10.4.6 High Activity particles

Waste containing known high activity particles are considered non-standard(11.0).

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NWESD WAC-01 Page •16 of 21WASTE ACCEPTANCE CRITERIA

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10.5 Other Hazardous Waste

10.5.1 Scintillation Fluids

Liquid scintillation fluid vials must'be packaged in a manner suitable forincineration. The currently recommended method is to put the vials in a 20 L(5 gal) white polyethylene pail (OH MatCode # 22320704). The lid of the pailmust be sealed in place with duct tape. The pail must be clearly marked ascontaining liquid scintillation vials, such as with OH MatCode # 822C4276radioactive liquid scintillation fluid labels. Waxed cardboard boxes may alsobe used, subject to the size and weight restrictions given in T1.6.

10.5.2 Animal Carcasses

Biological wastes (such as animal carcasses from OH Technologies) shall besealed in air tight incinerable containers, such as 20 L (5 gal) polyethylenepails (OH MatCode # 22320704). The pail lids shall be sealed with duct tapeand the containers shall be clearly marked as containing biological wastes forimmediate incineration.

11.0 ACCEPTANCE OF NON-STANDARD WASTES

11.1 Procedure

Radioactive waste types not specifically mentioned in this document shallonly be shipped to the RWOS with prior approval from the WMSDOperations Co-ordinator or authorised designate. This is accomplished bycompleting OH Form 821032 "Notification of Non-Routine Radioactive WasteShipment". An approved copy of the form must accompany the shipment.

11.2 Criteria for Liquid

With prior approval and prior notification, absorbed liquids that are suitablypackaged, may be accepted for immediate incineration. Other criteria forLLW Incinerable (10.3) may also apply.

I-0 6 /ý7 / 9 7 14:06 6 •023

11.3 Criteria for Interim Storage of Oil

Radioactive waste oil is accepted for interim storage only. Thegenerator is responsible for the full costs once a suitableprocessing technique is implemented..

All shipments of radioactive oils require the PRIOR approval of the WVMSDOperations Co-ordinator. The shipper.must senda copy of the radiologicaland chemical analyses to the RWOS Operations Co-ordinator prior to theshipment. The analyses must confirm that the oil meets the criteria listed inRO.2.

The oil shall meet the following chemical and radiological criteria:

- no decantibie water- total PCB- total Chlorine- total Lead- total Cadmium- Flash point- Tritium< 9.59 x 10"2 Ci/L- Gross beta/gamma

< 50 ppm< 20000 ppm< 300 ppm (see also RO.4)< 0.5 ppm>610 C

< 3.14 x 10"4 Ci/L

The oil must also be non-explosive, non-flammable, non-corrosive andnon-toxic. It may, however, be combustible. Oil which fails to meet one ormore of the above criteria is NOT acceptable for storage.

Drums of oil with a lead concentration greater than 5 ppm must be labelled

with:

LEACHATE TOXIC - LEAD

Oil must be contained in new, leak free drums with a "bung" type closure(such as OH MatCode # 223A3190). The drums shall be stencilled with:

RADIOACTIVE WASTE OIL

Each drum shall also be stencilled with a serial number corresponding to theradiological and chemical analysis sample numbers used for RO.3.

Where six or more drums of oil are to be shipped, the drums shall be shippedon drum racks ("bale racks" - OH MatCode # 599A6700), six per rack, Emptyracks are available from the Operations Co-ordinator.

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NWESD WAC-01 Page 18 of 21ýTE ACCEPTANCE CRITERIA

5

11.4 Criteria for Solidified Liquids

Liquids wastes must be solidified by a method approved by WMSD.Requests for approval of a new (or non-standard) solidification method mustbe made to the WMSD Operation's Co-ordinator in writing PRIOR to theperforming of the solidification operation.

All shipments of solidified liquids must be accompanied by an approved"Solidified Liquid Waste Record" (OH form #820939), along with detailedchemical and radiological analyses of the solidified liquid. The form must beapproved by the WMSD Operations Co-ordinator PRIOR to shipment of thesolidified liquid waste to the RWOS.

The liquids shall be completely solidified, with no free standing liquid.

The solidified liquid must be in a container approved by WMSD. Requestsfor approval of a new (or non-standard) container must be made to theWMSD Operations Co-ordinator in writing PRIOR to the performing of thesolidification operation. All containers shall be provided by the wastegenerator.

11.5 Criteria for Interim Storage of Contaminated Toolinq

ISO marine freight containers (cargo containers) are used for interim storage

of slightly contaminated tooling, not for storage of wastes as follows:

Standard 20 ft ISO marine freight containers are normally used, howeverother similar containers can be used with PRIOR approval by WMSD. Thecontainers are stored outdoors, so temperature sensitive equipment shouldnot be included in such containers.

The shipper provides the container, loads it, inventories it, locks it andarranges for it to be shipped to the RWOS.

All loads in the container shall be suitably constrained against shifting undertransport or lifting conditions.

The maximum external radiation field for storage is 2.5 mrem/h @ 1 m. Allmaterials inside the container shall be decontaminated to a level of less than5000 cpm of loose contamination.

The shipper must include a completed "Storage of Cargo Containers" form(BNPD form # BF-743) showing the load distribution along with a detailedinventory listing with the shipping documents.

ai'06/ 27 /97 14:07 V' 0025

.11.6

12.0

12.1

WMSD will periodically require the owners of contaminated tooling to justifyits continued interim storage. A charge will be applied at that time.

Criteria for Fuel Flea Contamination

Wastes contaminated with fuel fleas are acceptable only with prior approvalby WMSD.

EXCLUSIONS (UNACCEPTABLE WASTE)

Wastes shall not contain any recognisable fuel fragments.

Waste OriQin

Wastes are unacceptable if produced in a location other than in a nucleargenerating station and other facilities currently or previously operated byOntario Hydro.

Waste Form

Liquids

Liquid wastes other than scintillation fluids (10.5.1), contaminated oil (11.3)and absorbed liquids (11.2) are unacceptable.

Aqueous liquid wastes are not accepted for storage at the RWOS. Allaqueous liquids must be solidified at the generating site by an approvedmethod prior to shipment to the RWOS.

Waste packages/containers shall not contain any free standing water. (e.g.,interstitial water in dewatered IX resin is acceptable, flooded resin is notacceptable).

Gases

Compressed gases are unacceptable.

12.2

12.2.1

12.2.2

12.3

Gaseous waste is unacceptable.

RadioloQical Content

Recognizable Used Fuel Fragments12.3.1

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""iiNWESID WAC-01 Page 20 of 21


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12.4 Non-Radiological Content


.13.0 NON-COMPLIANT WASTES

Whenever waste is received at RWOS that unexpectedly does not meetthe WAC, then, in order of preference:'

a) the waste will be held in its existing form or package awaitingspecial tooling and / or handling procedures, or

b) the waste will be held and the shipper will be requested to supplyadvisor(s) who are familiar with the waste form and its package, or

c) the waste will be returned to the shipper to be made into anacceptable form and/or packaged acceptably.

Surcharges may be applied in these situations as per service levelagreements or negotiations between WMSD and the shipper.

14.0 WASTE AUDITS

WMSD performs waste audits on a regular basis. When access is requiredto the stations, arrangements will be made in advance with approval of thestation involved. Some audits will be conducted at RWOS on incomingwaste. All audits will be conducted according to approved WMSCD procedure.All non-conformances and findings will be reported to the shipper.

15.0 REFERENCES

BNPD Radioactive Waste Operations Site 2 Operating LicenceAECB-WFOL-314 and current reference documents

- BNPD Radioactive Waste Operations Site 2 Safety Report- Ontario Hydro Radiation Protection Regulations, Part 1- Radioactive Waste Operations: Operating Policies & Principles,

01911.1.

NWESD Radiation Protection Procedures, 09071

Waste Acceptance at BNPD Radioactive Waste Operations Site, NWESD

Policy WMSD 1.57, Revision 0, August 1996

Waste Acceptance at BNPD Radioactive Waste Operations Site, NWESDProcedure WMSP-03460-1, Revision 0, August 1996

"..06/27/g7 14:08 '' [ 027

Packaging of Low & Intermediate Level Waste - Catalogue of WMSDSupplied Packages, NWESD WAC-02, Rev. 1, February 1997

14:08 1& o028

APPENDIX A

LOW LEVEL WASTE

INCINERABLE COMPACTIBLE NON-PROCESSIBLEMaximum Dose Rate: Maximum Dose Rate: Maximum Dose Rate:60 mrem/hr contact 200 mrem/hr contact 1 rem/hr at 30 cm

Paper & Paper Towel Comfo Respirator Filters Heavy Gauge Metal i.e. I-beams,Tyvek Coveralls, Booties, Light Gauge Metals angle iron, plate metal, etc.

and Hoods Welding Rods Metal Components i.e. pipe,Plastic Booties Metal Cans flanges, valves, etc.Plastic Bottles Insulation Concrete and Cement BlocksWood (2'x2') Ventilation Filters Floor Sweepings, Dust Bane,Cardboard Air Hoses Stay Dry, etc.Mop Heads -dry and damp Mop Buckets and Presses ToolsSmears/Filter Paper Electric Cable (<1/41) Electric Cables (>1/4")Cloths Lathe Turnings Wire Cables and SlingsRope and Nylon Slings Metal FilingsFloor Buffing Pads GlassSafety Shoes Plastic Suits (Mark IllyV)Browns RubbersCotton Gloves Vicraft Hoods

Rubber Gloves

NOTES:

(1) All waste is to be bagged/wrapped such that the size and weight do notexceed the following:

Maximum Weight:Maximum Size:

25 lbs or 11.5 kg2x2.2.' or 60cm x 60cm

(2) No liquids are to be present, I.e. oils, water, paint, etc. Special precautions should be taken to avoidsending paint cans and similar type containers which are partially full.

(3) For C14, Fe55, and TRF waste, the following should be performed:

- identify the individual bags by using different colour tape

C14Fe55RF

Blue tapeBrown tapeRed tape

- segregate the waste into two categories: incinerable and non-processible.All compactible waste to be treated as non-processible.

Documents

Import & Export License Application for Diversified Scientific ...Diversified Scientific Services, Inc. (DSSI) requests, under 10 CFR 110.20 (a)(2), the issuance of a specific import