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Radiation Safety Manual Blue Buttes Disposal Facility WM of North Dakota Energy Disposal Solutions, LLC E ½ Section 35, Township 151N, Range 96W McKenzie County, ND Version 1.0: 2020

Radiation Safety Manual Blue Buttes Disposal Facility

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Document Review This Radiation Safety Manual is annually reviewed. This manual will be updated as needed to address changing site conditions and identified hazards.

Version: Date: Revision: Prepared By:

1.0 05/24/20 Initial Draft Reice Haase, RSO (former HDR), and Tina Fricke


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Contents

Document Review .......................................................................................................................................... i

1 Scope and Purpose ............................................................................................................................. 1

2 Definitions ............................................................................................................................................ 1

3 Characteristics of Radiation ................................................................................................................ 3 3.1 Classifying Radiation ................................................................................................................. 4 3.2 Methods of Radioactive Decay ................................................................................................. 5 3.3 Measuring Radiation ................................................................................................................. 6

4 TENORM ............................................................................................................................................. 7 4.1 Radionuclides of Concern ......................................................................................................... 8

5 Biological Hazards ............................................................................................................................... 9 5.1 Factors Affecting Biological Hazards ........................................................................................ 9 5.2 TENORM Hazards .................................................................................................................. 10

6 Radiation Protection .......................................................................................................................... 11 6.1 Regulatory Requirements........................................................................................................ 12 6.2 Dosimetry ................................................................................................................................ 13 6.3 Facility Monitoring ................................................................................................................... 13

6.3.1 Radiation Exposure Surveys ...................................................................................... 14 6.4 Waste Characterization and Waste Acceptance ..................................................................... 14

6.4.1 Sampling Procedures ................................................................................................. 16 6.5 Training Requirements ............................................................................................................ 16 6.6 Personal Protective Equipment ............................................................................................... 18 6.7 Operational Procedures .......................................................................................................... 19

6.7.1 Decontamination ........................................................................................................ 20

7 Management of TENORM Waste ..................................................................................................... 20

8 Emergency Response ....................................................................................................................... 21

9 Recordkeeping .................................................................................................................................. 23

Tables

Table 1 Measuring Radiation ........................................................................................................................ 6 Table 2 Regulatory Limits ........................................................................................................................... 12 Table 3 Required Training........................................................................................................................... 18 Table 4 Emergency Response Contacts .................................................................................................... 23

Attachments

Attachment 1 EZ Profile


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1 Scope and Purpose This Radiation Safety Manual was developed to establish policy, programs, procedures, and guidelines to control risk and define required work practices. This document was developed in accordance with North Dakota Administrative Code (NDAC) 33-10-23-10 and the Conference of Radiation Control Program Directors’ (CRCPD) Suggested State Regulations for Control of Regulation (SSRCR): Part N “Regulation and Licensing of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM)”. This manual applies to all WM of North Dakota Energy Disposal Solutions, LLC (Waste Management) operating entities, employees, contractors, and subcontractors of Waste Management or its subsidiaries. Only those employees certified by training and acknowledgement of this Manual shall be designated as authorized users of TENORM materials at the Blue Buttes Disposal Facility.

2 Definitions For the purposes of this Radiation Safety Manual, all units described herein are standard American units. SI units are not referenced in this manual.

Activity (or Radioactivity): the measure of the rate of decay or disintegration, measured in curies (Ci) or picocuries (pCi).

As Low As Reasonably Achievable (ALARA): principle of radiation safety, the means of which is to undertake every reasonable effort to ensure radiation exposure is as low as possible.

Atom: the basic building block of the universe, consisting of protons, neutrons, and electrons.

Background Radiation: radiation present in the environment as naturally occurring terrestrial radiation, cosmic radiation, and radiation resulting from past atmospheric testing of nuclear devices. Background radiation does not include progeny or decay products of licensed materials.

Calibration: the adjustment of instrument measurement based on the establishment of the relationship between known values and instrument uncertainties.

Contamination: the presence of undesired radioactive materials, measured in counts per minute (CPM).

Control area: an area of restricted access designed to prevent exposure to radioactive material.

Curie (Ci): the unit of measure for radioactivity, defined as the radioactivity of one gram of Radium, or 37 billion decays per second.

Decay Chain: a series of radioactive isotopes resulting from the decay of a parent radionuclide into subsequent progeny or daughter isotopes.


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Dose: the measure of biological effects of radiation to living tissue, measured in Roentgen-Equivalent-Man (rem), or millirem (mrem).

Dosimeter: an instrument used to measure the dose of ionizing radiation, can include film badges or digital dose meters.

Element: a group of atoms sharing the same atomic number (number of protons).

Exposure: the measure of the rate of radiation travelling through the air, measured in Roentgen (R/hr) or microRoentgen (μR/hr).

Half-life: the amount of time required for a radionuclide to decay to half of its original activity.

Ionizing Radiation: radiation with sufficient energy to free an electron from an atom, causing biological harm.

Isotope: an atom of a particular element containing the same atomic number (number of protons), but a different atomic mass (number of electrons), which may be stable or radioactive.

Micro- (μ): a unit prefix which denotes a factor of one-millionth of a unit.

Milli- (m): a unit prefix which denotes a factor of one-thousandth of a unit.

Non-ionizing Radiation: radiation with sufficient energy to excite electrons, but insufficient energy to free an electron from an atom.

NORM: Naturally Occurring Radioactive Materials

Occupational Dose: the dose received during the course of employment, and does not include dose received from medical procedures or from natural background radiation.

Pico- (p): a unit prefix which denotes a factor of one-trillionth of a unit.

Progeny Products: a radionuclide resulting from the previous decay of a parent radionuclide.

Radiation: the release of energy as either energy waves or sub-atomic particles.

Radioactive Decay: the release of energy in the form of ionizing radiation as an unstable atom moves toward a stable state.

Radioactivity: the characteristic of unstable atoms releasing energy as they decay toward equilibrium

Radionuclide: an unstable atom which releases energy in the form of radiation as it decays toward a state of equilibrium.

Radiosensitivity: the measure of sensitivity to radiation exposure.

Rem: Roentgen-Equivalent-Man, the measure of absorbed dose considering relative biological effectiveness.

Roentgen: the measure of radiation exposure.

TENORM: Technologically Enhanced Naturally Occurring Radioactive Materials


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3 Characteristics of Radiation Radiation can be defined as the release of energy in the form of energy waves or sub-atomic particles as an atom decays to a state of equilibrium. Atoms are the basic building block of the universe, and consist of positively charged protons, negatively charged electrons, and neutrons, which have no charge. Atoms are classified by the number of protons and neutrons present, with varying amounts resulting in different chemical elements. Sometimes, an atom of a particular element may have a different amount of electrons which does not match the amount of protons, in which case it is classified as an isotope. For example, Ra226 and Ra228 are different isotopes of Radium.

Should an atom possess an unequal amount of protons and electrons, it will be unstable. Radionuclides are unstable atoms which will release energy in the form of radiation, or decay, until it reaches a stable state. Radioactive decay is the process by which these unstable atoms move toward stability. As it decays, a radionuclide may also decay into several unstable daughter elements or progeny products before reaching a state of stability.

A radioactive half-life is the amount of time it takes a radionuclide to decay to half of its original activity. Radionuclides have varying half-lives; for example, U238 has a half-life of 4.5 billion years, whereas Rn222 has a half-life of 3.8 days. It is important to note that after two half-lives, a radioactive source is not eliminated, but rather will be at ¼ the original activity. In theory, the radioactive source will never be completely eliminated.

Radiation can be either naturally occurring or man-made. Example of naturally occurring radiation are cosmic rays penetrating the earth’s atmosphere from space, radionuclides present in the soil and groundwater, and certain types of food. Man-made sources of radiation include nuclear medicine, consumer products, and industrial processes.

The average American receives a dose of 620 mrem every year, half of which is due to

naturally occurring background radiation. Medical procedures and medicine make up the vast majority of man-made exposures.


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3.1 Classifying Radiation Radiation is visualized by the Electromagnetic Spectrum, which classifies radiation as ionizing or non-ionizing. Ionizing radiation has sufficient energy to free an electron from an atom, changing its atomic structure and causing biological damage. Examples of ionizing radiation include x-rays, gamma rays, and some UV rays.

In contrast to ionizing radiation, non-ionizing radiation does not have sufficient energy to free an electron from an atom. Instead, it simply excites electrons and does not cause significant biological damage. Examples of non-ionizing radiation include microwaves, radio waves, and visible light.

Source: Atomic Energy Commission

Energy waves toward the right of the Electromagnetic Spectrum are more energetic, and waves toward the left of the spectrum are less energetic. Ionizing radiation is composed

of energy waves meeting or exceeding the energy of UV rays. Waves less energetic than UV rays are classified as Non-ionizing radiation.


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3.2 Methods of Radioactive Decay Radionuclides present at the Blue Buttes Disposal Facility exhibit three methods of radioactive decay:

Alpha decay involves the release of alpha particles, which consist of two protons and two neutrons. It is the most hazardous method of decay, but alpha particles can only travel a few inches, and are shielded by a piece of paper

Beta decay involves the release of beta particles, which consist of a single electron. Beta particles can travel several feet, and are shielded by a piece of plastic or clothing

Gamma decay involves the release of gamma rays, which are similar to x-rays. Gamma rays can travel much longer distances than alpha or beta particles, and require a thick material like lead or steel to shield. Gamma rays are not as hazardous as alpha or beta particles, however they have so much penetrating power that several inches of dense material like lead, or even a few feet of concrete may be required to stop them.


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3.3 Measuring Radiation Visible light and infrared radiation are the only types of radiation which can be perceived by human senses. If the entire Electromagnetic Spectrum were stretched from New York to Los Angeles, the length of the spectrum that could be perceived by human senses would only measure about 100 nanometers! Therefore, human senses cannot be relied on to detect ionizing radiation. Various instruments are used instead, depending on the target measurement. Radiation is measured in the following ways:

Table 1 Measuring Radiation

Measurement Definition Instrument Unit

Exposure Amount of radiation traveling through the air

Rate meter with scintillation wand

Roentgen or microRoentgen (μR/hr)

Dose Amount of radiation absorbed by a person

Dosimeter Roentgen-Equivalent-Man (rem) or millirem (mrem)

Radioactivity Amount of radioactive decay in a substance

Laboratory Analysis

Curie/gram (C/gram) or picocurie/gram (pCi/g)

Contamination Amount of ionization in a particular area

Rate meter with “pancake wand”

Disintegrations per minute (dpm)


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4 TENORM NORM is defined as Naturally Occurring Radioactive Materials. TENORM is defined as Technologically Enhanced Naturally Occurring Radioactive Materials, which are concentrated at levels higher than NORM due to man-made processes. The North Dakota Department of Environmental Quality defines TENORM (per CRCPD Part N, Sec. N.3) as “naturally occurring radioactive material whose radionuclide concentrations are increased by or as a result of past or present human practices”. TENORM does not include background radiation, “source material” or “byproduct material”. Generally, any material encountered at the Blue Buttes Disposal Facility which exceeds 5 pCi/g is considered TENORM.

TENORM occurs in the oil and gas industry as a result of drilling and producing oil and gas. As fluids are produced from subsurface formations, naturally occurring radionuclides precipitate out in the form of pipe scale. Once passed through the wellhead, radionuclides can also concentrate in the form of tank bottoms and sludge. Certain treating processes such as filtering, passing solids through a shaker, and using a centrifuge, can concentrate radionuclides and form TENORM. At the Blue Buttes Disposal Facility, incoming waste may include TENORM. TENORM is not expected to form as a result of processing at the facility.

The concentrations of radioactivity present in TENORM are so low, that full units of measurement are rarely used. Instead, TENORM is measured in fractions of a unit, which include:

• Milli (m) – one thousandth of a unit

• Micro (μ) – one millionth of a unit

• Nano (n) – one billionth of a unit

• Pico (p) – one trillionth of a unit

For example, TENORM is typically measured in pCi/g, which is one-trillionth of a Curie. To put that into perspective, a banana is about 3.5 pCi/g and filter socks containing TENORM are typically 30-50 pCi/g, whereas phosphate fertilizer used by farmers in North Dakota contains up to 600 pCi/g, and a source of pure Radium contains 1 Ci/g. About 35,000,000 bananas would need to be consumed at once to obtain a lethal dose of radiation!


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4.1 Radionuclides of Concern Radionuclides commonly associated with TENORM in the oil and gas industry include Radium-226 (Ra226), Radium-228 (Ra228), Radon-222 (Rn222), and Lead-210 (Pb210). These radionuclides are progeny products of Uranium and Thorium, which occur naturally in the earth’s crust. Ra226 and Ra228 are most commonly associated with produced water. Radium concentrations have also been correlated with TDS (Total Dissolved Solids); aquifers with higher TDS tend to have higher concentrations of Radium.1 In the Williston Basin, deeper formations like the Devonian Bakken or the Ordovician Red River tend to have higher TDS than shallower formations like the Mississippian Madison. Rn222 and Pb210 are commonly associated with natural gas production, and can be expected in pigging wastes, scrubbers, and natural gas lines.

Table 2 Radionuclides of Concern Radionuclide Description Hazards Half-Life Decay

Ra226 Solid which tends to follow produced water stream

Carcinogenic 1,600 years

Alpha

Ra228 Solid which tends to follow produced water stream

Carcinogenic 5.75 years Beta

Rn222 Odorless, colorless, and tasteless gas which tends to follows natural gas stream

Carcinogenic 3.8 days Alpha

Pb210 Solid which tends to follow natural gas stream

Damage to kidney, nervous system, and brain

22.3 years Beta

1 Szabo, Z. et al. “Occurrence and Geochemistry of Radium in Water from Principal Drinking-water

Aquifers of the United States”, Applied Geochemistry, 2012.


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5 Biological Hazards Ionizing radiation poses both external and internal hazards. External hazards include exposure to x-rays and gamma rays. Radionuclides commonly found in oilfield TENORM do not typically decay by emitting gamma rays. Therefore, external hazards resulting from TENORM exposure at the Blue Buttes Disposal Facility are unlikely to cause significant health risks to employees or the general public.

Internal hazards pose the greatest risk at the facility. Internal hazards include radionuclides which decay by emitting alpha and beta particles. Internal hazards are simple to mitigate, however. Common internal exposure routes include inhalation, and ingestion. Inhalation occurs when TENORM dust or particles are inhaled. Ingestion can occur when TENORM particles enter the mouth while eating, drinking, smoking, or applying cosmetics. Less common routes of internal exposure include absorption and injection. Absorption occurs when radionuclides are absorbed into the bloodstream through the eye membrane or an open wound. Injection can occur if radionuclides are pushed directly into the blood stream by a puncture wound.

The effects of radiation exposure include acute and chronic effects. Acute effects are immediate, short-term effects to high doses of radiation, and include radiation sickness and radiation burns. Acute effects require relatively high doses over a short period of time. For example, a dose of 15 rem will cause temporary sterility, and a dose of 100 rem will cause nausea and vomiting. A dose of 500 rem will cause death in about half of all people. Dose rates sufficient to cause acute effects are not likely at the Blue Buttes Disposal Facility due to the low levels of TENORM radioactivity.

Chronic effects are long-term effects to radiation exposure, and include biological tissue damage and cancer. Chronic effects are more likely if safe work practices are not followed.

5.1 Factors Affecting Biological Hazards Several factors can contribute to the hazards of radiation exposure. Certain cells within the body are radiosensitive, that is, they are more susceptible to the damaging effects of radiation exposure. In general, any rapidly reproducing cell can be expected to be radiosensitive. This includes bone marrow, lungs, white blood cells, reproductive organs, and unborn fetuses. Certain drugs and products can affect radiosensitivity. For example, smokers have an annual radiation exposure dose which is increased by up to 16 rem per year. Age can also affect radiosensitivity, as children and adolescents are more sensitive to the effects of radiation exposure than adults.

The method of radioactive decay can also affect the hazards of radiation exposure. Alpha particles are the most hazardous radioactive decay products associated with TENORM, but are also the easiest hazard to mitigate. Gamma radiation is the most difficult hazard to mitigate, but is the least hazardous decay product, and the least likely decay product associated with TENORM.


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A cell survival curve offers a visualization of the hazards of particular decay methods.

Note the steep curve indicated by alpha decay. This demonstrates that a dose of 500 rem of alpha particles would result in the death of 99.9% of all cells. Compare this to

gamma, which would require a dose of 1,500 rem to reach a similar amount.

5.2 TENORM Hazards Ra226 is considered the most hazardous TENORM radionuclide. Not only does it decay by emitting an alpha particle, it also has the longest half-life of 1,600 years. Ra228 does not have as long of a half-life (5.75 years), and emits a beta particle, but remains an internal exposure hazard. Radium is a bone seeker, and has been linked to the development of leukemia.

Rn222 is easily inhaled, but is also easily dispersed outdoors, and has a short half-life (3.8 days). Radon is linked to the development of lung cancer, and is the second leading cause of lung cancer in the United States behind smoking. Due to the nature of waste processing and disposal at the Blue Buttes Disposal Facility, radon is not anticipated to pose a major hazard to workers or the general public.

Pb210 also poses an internal radiation exposure hazard, in addition to its toxic side effects as a heavy metal. Due to its typical association with natural gas waste streams, it is not expected to be a common radionuclide found in waste accepted at the Blue Buttes Disposal Facility.

0.001

0.01

0.1

1

0 500 1000 1500 2000

Cel

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talit

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Dose (rem)

Cell Survival Curve

Alpha

Beta

Gamma


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6 Radiation Protection The main principle of radiation safety is ALARA (As Low As Reasonably Achievable). This involves taking every practicable measure to reduce radiation exposure to levels As Low As Reasonably Achievable. To achieve ALARA, engineering and administrative controls are implemented.

Engineering controls present at the Blue Buttes Disposal Facility include:

• Processing equipment is designed to prevent dry open-air mixing of TENORM waste. All mixing and agitation is conducted in a “wet process” as waste is slurrified, which prevents the generation of dust and prevents the spread of TENORM.

• Processing equipment is constructed from high-density materials which will effectively shield all alpha and beta particles as well as most gamma rays.

• The facility will be surrounded by a fence with signage to prevent unauthorized access. This will alert the general public to prevent from accidentally venturing into a TENORM area, and will deter trespassing.

Administrative controls present at the Blue Buttes Disposal Facility include:

• Access to the facility will be restricted to authorized personnel only. This will prevent accidental exposure or intentional vandalism from the general public.

• The facility will be monitored 24 hours a day. This will deter trespassing, prevent vandalism, and reduce the risk of equipment failure and accidental release of wastes.

• A radiation safety program will be implemented to identify and establish safe work practices.

• All employees will be trained in TENORM Awareness and TENORM Surveying prior to working with TENORM.

• All employees will be required to wear proper Personal Protective Equipment (PPE) to protect themselves from potential exposure.

• Employees will work in designated shifts to limit the time of potential exposure.

Three methods can be used to reduce or eliminate radiation exposure: Time, Distance, and Shielding. A limited time of exposure can reduce the dose received. Employees at the Blue Buttes Disposal Facility will conduct work in shifts to reduce exposure.

Distance is inversely proportional to radiation exposure. For example, a source with an exposure reading of 1000 µR/hr at one foot would read 1/4th as much at double the distance, and 1/9th as much at triple the distance. A few inches of distance can prevent alpha exposure and several feet can prevent beta exposure. Administrative and engineering controls are in place at the Blue Buttes Disposal Facility to prevent public access. This increases the distance between TENORM waste and the general public, and eliminates their risk of exposure. Long-term working tasks will also take place away from the TENORM waste to maintain distance between employees and sources of potential radiation exposure.


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Shielding involves the use of a barrier to absorb ionizing radiation, thereby reducing exposure. Alpha particles can be shielded by a piece of paper, whereas beta particles can be shielded by a piece of plastic or clothing. Gamma rays require a thick material like lead or steel for effective shielding. Engineering controls at the Blue Buttes Disposal Facility include the design of processing equipment which will effectively shield exposure from TENORM wastes. Additional controls in the form of required PPE will provide additional shielding to facility employees.

6.1 Regulatory Requirements Although there are no federal regulations specific to TENORM, several federal agencies regulate certain aspects of TENORM:

1. The U.S. Nuclear Regulatory Commission (NRC) regulates the safe use of radioactive materials

2. The U.S. Department of Transportation (DOT) regulates the transportation of TENORM exceeding 270 pCi/g of Ra226 and Ra228

3. The U.S. Environmental Protection Agency (EPA) regulates the cleanup, disposal, and release of TENORM to the environment

4. The Occupational Safety and Health Administration (OSHA) regulates hazardous materials in the workplace, including sources of ionizing radiation not regulated by the NRC

North Dakota is an NRC agreement state, which makes the State responsible for regulating TENORM. In North Dakota, TENORM is regulated by the North Dakota Department of Environmental Quality. General TENORM regulations are found in NDAC 33-10-23, whereas the landfill disposal of TENORM waste is found in NDAC 33-20-11.

Table 2 Regulatory Limits

Subject Limit Applicable Regulation

Exempt TENORM 5 pCi/g NDAC 33-10-23-04

Landfill Waste Disposal in North Dakota 50 pCi/g NDAC 33-20-11-01

Disposal of Contaminated Equipment 100 μR/hr NDAC 33-20-11-01

Exempt from DOT Regulations 270 pCi/g 49 CFR 173.433

Occupational Dose for Adults 5 rem/year 10 CFR 20.1201

Occupational Dose for Minors 500 mrem/year 10 CFR 20.1207

Occupational Dose for Pregnant Workers/Embryo

500 mrem/year 10 CFR 20.1208

Dose for General Public 100 mrem/year 10 CFR 20.1301

Unrestricted Release (Gamma Radiation) Shall not exceed background

NDAC 33-10-4.2


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6.2 Dosimetry Dosimetry is the measure of absorbed dose of radiation. Dosimeters are used to measure the dose absorbed by a person, and to ensure regulatory dose limits are not exceeded. Thermo-Luminescent Dosimeters (TLDs) will be used at the facility. TLDs will be provided by a licensed dosimetry service provider approved by the North Dakota Department of Environmental Quality. TLDs will be sent to the dosimetry service provider quarterly for reading.

“Area Dosimeters” will be placed at the entrance to the facility, at the truck offload area, and at the office. The purpose of the area dosimeters is to ensure public dose rates do not exceed 100 mrem/year. All employees of the facility will be issued personal TLDs. All readings will be made available to employees and the North Dakota Department of Environmental Quality, and will be recorded on a quarterly dosimetry report.

Employees will be required to wear their issued TLDs during the course of the work shift. TLDs will be returned to a designated storage area at the end of the shift, and will not be allowed off-site. One TLD will be designated as a “background dosimeter”, and will be kept in the storage area at all times to measure the background dose.

Each employee will be issued their own unique TLD. Sharing of TLDs will be prohibited. In the event a personal dosimeter is lost, the Radiation Safety Office (RSO) will be immediately notified, and a replacement will be secured as soon as possible. A maximum probable dose received by the employee during time worked without a dosimeter will be calculated based on the recorded dose of a co-worker conducting similar tasks. Lost or misplaced TLDs will be noted in the quarterly dosimetry report.

In the unlikely event a regulatory dose is exceeded, the following action plan will be implemented:

1. North Dakota Department of Environmental Quality will be notified.

2. Employee will be removed from work involving TENORM.

3. An investigation into the cause of the dose exceedance will be conducted.

4. Any deficiencies revealed by the investigation will be corrected in consultation with the North Dakota Department of Environmental Quality.

5. Results of the investigation and follow-up monitoring will be reported to the North Dakota Department of Environmental Quality.

6.3 Facility Monitoring Facility monitoring in the form of quarterly radiation surveys will be conducted to determine the amount of radiation exposure present at the facility.

Survey equipment will be present onsite for the screening of incoming waste streams. Equipment and vehicles used to transfer incoming waste will also be screened prior to leaving the facility. A truck washout station will be available onsite for decontamination. Rinsate will be collected and disposed of onsite via subsurface injection.

All incoming waste streams will be required to be accompanied by analytical data detailing the concentrations of total Ra226 and Ra228. Samples of incoming waste streams


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may be collected at the discretion of the facility operator to confirm the characterized radioactivity. Employees will be trained in the use of survey equipment and proper sampling procedures.

6.3.1 Radiation Exposure Surveys A general purpose Ludlum Model 3000 Rate Meter, Model 44-2 Sodium Iodide Scintillation Probe, and a Model 44-9 GM Pancake Detector will be kept at the facility. Survey equipment will be used to detect the presence of radioactive decay originating from contamination on personnel and equipment. Radiation survey equipment will be sent to Ludlum for calibration. Backup survey equipment will be available during calibration.

Quarterly facility surveys will be conducted by a qualified radiation surveyor. A general purpose rate meter and a gamma scintillation probe will be used to identify areas of radiation exposure exceeding background. Survey equipment will be calibrated and tested against a known source of Cs137 per the manufacturer’s instructions. Background levels will be determined prior to the survey. The scintillation probe will be held within 1 cm of the ground or equipment while surveying.

Quarterly surveying will involve the screening of facility equipment, the waste offload area, traffic corridors, and mobile equipment such as loaders and excavators. Quarterly surveys will enable the tracking of TENORM waste movement onsite, and will be used to identify areas of concern. Corrective actions may be developed based on the results of the quarterly surveys to eliminate the movement of TENORM wastes offsite.

All equipment with gamma exposure readings exceeding background will be labeled or tagged as follows: “Caution – TENORM may be present. Proper PPE required.” A designated TENORM storage area will be used to store TENORM-impacted equipment. Access to the TENORM storage area will be restricted to trained personnel only.

Prior to exiting the facility, all mobile equipment (excavators, loaders, etc.) will be surveyed. Equipment with loose exterior contamination exceeding background will be properly decontaminated prior to release.

6.4 Waste Characterization and Waste Acceptance All wastes processed or disposed of at the Blue Buttes Disposal Facility require a physical and chemical characterization. Incoming wastes will also be screened with radiation exposure equipment. In instances where TENORM is known or suspected, radiological analyses will be required. Waste Management’s waste profiling form, EZ ProfileTM, must accompany all incoming wastes. Wastes not accompanied by the EZ Profile will not be accepted. A copy of EZ Profile is included in Attachment 1.

The following procedures detail waste characterization and waste acceptance at the facility:

1. EZ Profile submittal is received from the generator or designated representative. EZ Profile submittal must include the following information:

a. Schematic or Flow Chart of Process Generating Waste

b. Description of Process Generating Waste


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i. List of products generated (if applicable)

c. Sampling Schematic or Map

i. Show how composite sample was generated

d. Sampling Description

i. Explain how composite sample was collected

e. Chemical analysis/Lab Report

f. Safety Data Sheet (SDS) (if applicable)

2. If the waste exhibits a radiation exposure reading greater than or equal to 10 μR/hr above normal background levels, the EZ Profile will need to include the following information:

a. Radiochemistry Analysis for TENORM Isotopes:

i. Ra226 and Ra228 analyzed by a North Dakota Department of Environmental Quality-approved laboratory in accordance with EPA Methods 900.0, 901.1, or approved equivalent

ii. Radiation exposure readings using a gamma scintillation probe expressed in μR/hr should be included

b. If radiochemistry data is missing, the EZ Profile is returned as incomplete and the waste is not accepted

3. The required chemical and radiological lab data will be reviewed for completeness and forwarded to the Waste Approvals Manager (WAM). After review, the WAM will decide if a determination can be made or if the results must be forwarded to the RSO for further review.

4. Any EZ Profile with demonstrated TENORM characteristics will require review and approval by the RSO.

5. The RSO will remain in contact with the Market Area Manager, the District Manager, and the Environmental Engineer while determining waste acceptance or rejection.

6. All EZ Profiles as well as final acceptance or rejection determinations will remain onsite and be made available for review upon request.


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6.4.1 Sampling Procedures Incoming wastes with a radiation exposure level which does not correlate with the level reported in the EZ Profile will be sampled for confirmation of radioactivity. The following procedures will be followed to ensure the safety of the sampler and the integrity of the sample:

1. Proper PPE will be donned prior to sample collection

2. Samples will be collected using clean, disposable sampling equipment, if possible. If disposable sampling equipment is unavailable or unsuitable for the sampled material, a dedicated sampling spade or shovel may be used if it has been properly decontaminated prior to use.

3. Sampled material will be placed in a non-leaking Ziploc bag or plastic container. Glass containers will not be used. The minimum amount of solids is one-quart, and the minimum amount of liquids is one-gallon.

4. Sample containers will be properly sealed and labeled.

5. Sampling equipment will be decontaminated after each sample with distilled water and a laboratory-grade detergent. Disposable sampling equipment will not be re-used.

6. A Chain of Custody for all the samples will be completed and signed by the Sampler.

7. Sample containers and the Chain of Custody will be placed in a hard-sided container and sealed with signed Custody Seals

8. Sample packages will be shipped to a North Dakota Department of Environmental Quality-approved laboratory via FedEx or UPS. Samples will not be shipped via USPS.

6.5 Training Requirements Training will be conducted by a certified Radiation Safety Officer. TrainND Northwest of Williston State College offers TENORM Awareness and TENORM Surveyor Training. These courses were designed and developed in consultation with the Health Department.

TENORM Awareness and TENORM Surveyor training courses can be combined in an 8-hour class, or can be split into two 4-hour classes. TENORM Awareness is required for all employees, including ancillary personnel. TENORM Surveyor is required for all employees who will work with or near waste, including plant operators and plant supervisors.

All employees will be trained prior to working at the facility. Only employees who successfully complete the training and pass the proficiency tests will be certified to work at the facility. The facility RSO will provide annual refresher training.


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TENORM Awareness training encompasses the following topics:

• Characteristics of Radiation

• NORM vs. TENORM

• Measuring Radiation

• TENORM in the Williston Basin

• Contamination

• Exposure Pathways

• Hazards of Exposure to Radiation

• Radiation Safety and Regulatory Requirements

• Transportation and Disposal of TENORM

• Components of the Radiation Safety Program

• Closed Book Proficiency Test (80% or higher required to pass)

TENORM Surveyor training will cover the following topics:

• Common Locations of TENORM

• Measuring TENORM

• PPE and Regulatory Requirements

• Radiation Detection Equipment Care, Calibration Checks, and Use

• Steps for Conducting a TENORM Survey

• Proper Survey Documentation

• Personnel Surveying

• Decontamination

• TENORM Sampling

• Practical Exam Including Demonstrated Meter Use (80% or higher required to pass)

At a minimum, the following training will be required for all employees and contractors at the Blue Buttes Disposal Facility:


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Table 3 Required Training

Training Operators Supervisors RSO

Emergency Response Procedures

Safe Work Practices and PPE

Hazards of Radiation Exposure

Sources of TENORM Contamination

TENORM Handling, Storage, and Disposal

Record-keeping

Radiation Dose Limits

TENORM Sampling and Surveying

Survey Equipment Car and Use

TENORM-impacted Equipment Procedures

Labeling and Documentation

Types of Laboratory Analyses

Survey Documentation

Surveying Plans and Schedules

Minimization of Liability

Biological Effects of Radiation Exposure

Radiation Protection and Dosimetry

Elements of a Radiation Safety Program

Licensing of Radiation Devices

Regulatory Agencies

Transportation of Radioactive Materials

Risk Communication

Workplace Auditing and Inspection

6.6 Personal Protective Equipment PPE is not considered a primary control measure for minimizing risk. The use of PPE is only considered after all other engineering and administrative control measures have been exhausted. PPE is considered a last line of defense, and is not intended to replace other control measures.

PPE required by all personnel conducting work at the Blue Buttes Disposal Facility include:

• Long-sleeved FRC Clothing

• Steel-toed Boots

• Chemical-resistant Gloves

• NIOSH-approved Safety Glasses

• NIOSH-approved Hardhat


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• Personal H2S Gas Monitor

The required PPE is intended to protect employees from a variety of hazards, including TENORM. Areas and processes where open sources of TENORM are anticipated include the unloading bays and the transfer of waste to the grinder. After passing through the solids grinder, TENORM will be in tanks and flow lines until disposal.

Using disposable PPE whenever practicable is a best practice which will be encouraged at the Blue Buttes Disposal Facility. The best decontamination is no decontamination, and disposing of PPE after each use eliminates the need for decontamination and prevents the spread of TENORM. If work near an open source of TENORM is necessary, disposable boot covers will be donned prior to entering the area. Boot covers are intended to protect boots from contamination, and will be disposed of prior to leaving the work area to prevent the spread of TENORM. Disposable gloves will be used when possible.

Non-disposable PPE which may have come in contact with TENORM will not be allowed to leave the work area, and will be decontaminated onsite. Washing equipment will be available onsite for this purpose. Employees who may have come in direct contact with TENORM will be screened using a scintillation wand prior to removal of PPE. Any PPE which cannot be decontaminated will be disposed of.

Visitors to the facility, including corporate staff, consultants, regulatory inspectors, auditors, and other third-party personnel will be provided with PPE. Additional PPE may be required if conditions warrant. The use of additional PPE will be at the discretion of the RSO.

6.7 Operational Procedures At the Blue Buttes Disposal Facility, inhalation and ingestion are expected to present the greatest risk of exposure. Due to the nature of the processing procedures at the facility, dust-generating activities will not be conducted. Engineering controls mitigate the risk of direct contact with TENORM. The greatest risk is presented as incoming waste is unloaded into the concrete bay.

To mitigate the risk of inhalation, the following procedures will be implemented:

• Waste transporters will be required to cover loads.

• Incoming waste will be unloaded directly into the concrete bay.

• Waste present in the concrete bay will be disturbed as little as possible. Any mixing conducted will be a “wet process”, which will not result in dust-generation.

• Waste will be transferred via pump.

• Once waste is transferred from the concrete bay, it will be placed in the grinder, transferred to slurry tanks, and transferred to agitated storage tanks.

• Waste will not be dried or solidified as part of the process. Rather, waste will be slurrified with produced water, preventing the generation of dust.


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Eating, drinking, smoking, and the application of cosmetics will be prohibited when working with an open source of TENORM to reduce the risk of ingestion. Good hygiene practices, such as thoroughly washing the hands and face after completing work tasks and prior to making contact with the face will be encouraged.

6.7.1 Decontamination Non-disposable PPE, clothing, and rags will be decontaminated by a licensed facility/contractor. Products used for decontamination will be laundered onsite or disposed of. Rinsate will be collected and disposed of onsite via the subsurface injection wells.

Equipment will be surveyed by trained personnel and decontaminated using standard cleaning methods, if necessary, prior to maintenance. Rinsate will not be allowed to runoff, and will be collected for disposal. Equipment with fixed contamination will only be decontaminated by a company licensed by the DEQ.

Care must be taken when washing the hands and face to avoid irritating the skin. Irritated skin could act as a potential route of exposure.

7 Management of TENORM Waste Wastes accepted by the Blue Buttes Disposal Facility will be slurrified and injected into two on-site injection wells. Should any waste remain which cannot be injected, it will be segregated for alternative disposal. Although North Dakota’s radioactivity limit for in-state disposal is 50 pCi/g, no landfills are currently approved to accept waste exceeding 5 pCi/g. Waste will be analyzed prior to disposal. Waste which cannot be injected will be disposed of at a North Dakota Department of Environmental Quality-approved in-state landfill, if possible. If the waste exceeds allowable limits, it will be disposed of at an approved out-of-state landfill.

Storage of TENORM waste unsuitable for injection will be temporary until final disposal is possible. In accordance with NDAC 43-02-03-19.2, TENORM waste will be placed in leak-proof, covered, and labeled storage bins. The TENORM storage area will meet the following requirements:

• TENORM waste and TENORM-impacted equipment will be stored in a sealed container and/or in a designated TENORM storage area.

• The TENORM storage area will be identified by signage designating it as such.

• Access to the TENORM storage area will be restricted to authorized personnel only.

• The TENORM storage area will be designed to prevent storm water runoff.

• An inventory of TENORM waste and impacted equipment within the storage area will be kept on file at the facility.

• Monthly inspections of the TENORM storage area will be conducted, noting the condition of the storage containers and/or equipment.

• Any storage containers found in poor condition will be immediately replaced.


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• Storage containers and equipment will be placed in a neat manner.

• Labels will placed in accessible locations so as to not require climbing amongst the stored waste to read.

• In the unlikely event used tubing is stored onsite, tubing ends will be plugged or capped.

• All TENORM-impacted PPE, rags, or other small tools and equipment will be stored in heavy gauge polyurethane containers or equivalent designated and labeled for such use.

Transportation of TENORM waste offsite will only be conducted by a transporter licensed and approved by the North Dakota Department of Environmental Quality.

8 Emergency Response In the event of an emergency, the priority will be the safety of employees and first responders. Immediate evacuation of the facility will occur if required. Employees will congregate at a pre-determined muster point for accounting. If all employees are not accounted for, first responders will be immediately notified.

Only if it is safe to do so, measures will be taken to contain the emergency and prevent its spread. This may include activating a kill switch for processing equipment, closing valves to isolate failed equipment, deploying containment booms, and locking out the main power source.

As TENORM does not pose a significant short-term health risk, priority will be given to concerns which are immediately dangerous to life and health (IDLH). Only after IDLH conditions have been addressed will TENORM response occur. The primary TENORM concern in the event of an emergency is release to the environment.

The Blue Buttes Disposal Facility has numerous engineering and administrative controls to mitigate impacts to the environment. For example, the facility will be monitored 24 hours a day. The following monitoring devices and procedures will also be used at the facility:

• SCADA2/automation alarms and shutdowns will be used on site.

• All tanks and the concrete offload pit/containment bin will include high-tank level alarms to alert facility personnel prior to overflow, radar indicated tank levels, and automated shutoff valves.

• There will be automated and manual ESD (emergency shutdown system) available at several locations across the facility. The system will have alarms and warning lights to indicate potential problems with the system, and there will be system redundancy with HMI (human-machine interface) touch screens and/or handheld tablets available at several locations across the facility.

2 SCADA=supervisory control and data acquisition


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• High-pressure injection lines will include high and low pressure alarms to alert facility personnel to potential failure. High pressure alarms will prevent the operation of flowlines at pressures exceeding the rated value, and low pressure alarms will indicate a potential release

• All pumps will be operated within manufacturer-recommended pressure ranges. Gaskets and seals will be replaced per the recommended maintenance schedule.

• Pumps will have automated and manual safety shutdown switches, high pressure shutdown, and suction and discharge monitoring.

• Daily site inspections will be conducted to note the integrity of tanks, pumps, flowlines, and equipment. If evidence of release is noted, the equipment will be isolated from the remainder of the facility and repaired.

• Four monitoring wells will be installed on the east side of the pad and two monitoring wells will be installed on the west side of the pad. The wells will be sampled semi-annually.

• Groundwater will be sampled for target analytes found in the waste streams. Should target analytes be discovered within the observation wells, the use of the concrete offload pits will cease until investigation of subsurface soils and remedial actions have been completed.

• A witness well will be installed under the mud truck offload pits as a means for leak detection. Pea gravel with a 6” perforated pipe and an underlying geocomposite layer in addition to a 60 Mil LLDPE liner would effectively convey any leaked material from the mud truck offload pits into the witness well.

• Secondary containment is included for the tank battery, SPU building, and slurry tank building. The SPU building, which has four tanks the containment bin, would have sufficient secondary containment to hold 110% of the volume of the tanks and containment bin. The slurry tank building would hold six slurry tanks and would also have secondary containment for 110% of the tank volume. Waste Management is pursuing a variance for secondary containment associated with the tank battery, which has 16 tanks, and is proposing less than 100% containment volume for that area. To compensate, they are implementing additional monitoring measures.

• A 2.5-foot high perimeter berm will surround the facility and prevent fluid runoff from leaving the site.

• Two storm water containment ponds will be present to collect runoff. Any accidentally released wastes will collect in the ponds and can be recovered before release to the environment.

In the unlikely event of an accidental release of TENORM, the North Dakota Department of Environmental Quality will be immediately notified. The area of impact will be delineated by a qualified TENORM surveyor. Risks to workers and the general public will be considered while drafting a Remedial Action Plan in consultation with the North Dakota Department of Environmental Quality. Confirmation sampling and radiation exposure surveying will be used to confirm the removal of impacted materials.


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Table 4 Emergency Response Contacts

Emergency Responders

McKenzie County Ambulance 911 or 701-842-6364

McKenzie County Healthcare Systems 701-842-3000

Watford City Fire Department 701-444-3516

McKenzie County Sheriff’s Department 701-444-3654

McKenzie County Emergency Manager 701-444-7483

Regulatory Agencies

North Dakota Department of Environmental Quality, Radiation Control Program

701-328-5166

North Dakota Industrial Commission, Oil and Gas Division 701-328-8020

US EPA Region 8 202-260-1358

WM of North Dakota Energy Disposal Solutions, LLCContacts

Johannes Kohn, RSO 701-609-3650

9 Recordkeeping The following records will be kept at the facility and will be made available to regulators upon request:

1. Waste characterization data

2. Monthly injection pressures and rates

3. Monthly waste inventory

4. Monthly TENORM storage area inspection report

5. Monthly facility inspection report

6. Quarterly dosimetry report

7. Quarterly radiation exposure survey

8. Annual facility report

A monthly inventory of incoming and outgoing waste will be maintained at the Blue Buttes Disposal Facility. Data included in the inventory include daily load volumes, waste generator, waste source, date received, and waste characterization data. In accordance with NDIC requirements, an annual report will be completed summarizing the following:

• Site schematic of the facility detailing all tanks and equipment

• Present inventory of fluids and solids

• Any releases or equipment failure

• Any facility modifications or process improvements completed or planned

• Any other information as required by the NDIC


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In addition to the above records, the following records will also be maintained at the facility:

• Records of major releases, and equipment failures

• Records of cleanup of impacted materials

• As-built drawing of the facility showing any modifications

• Safety Data Sheets (SDS)

• Radiation Safety Manual

• Corporate HSE Manual

• Storm Water Pollution Prevention Plan (SWPPP)

• Spill Prevention Control and Countermeasure Plan (SPCC)

• Any further information as requested by the NDDH or the NDIC


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Attachment 1: EZ ProfileTM

QUESTIONS? CALL 800 963 4776 FOR ASSISTANCERevised June 30, 2015

©2015 Waste Management

Requested Facility: Unsure Profile Number: Multiple Generator Locations (Attach Locations) Request Certificate of Disposal Renewal? Original Profile Number:

A. GENERATOR INFORMATION (MATERIAL ORIGIN)

1. Generator Name: 2. Site Address: (City, State, ZIP) 3. County: 4. Contact Name: 5. Email: 6. Phone: 7. Fax: 8. Generator EPA ID: N/A9. State ID: N/A

B. BILLING INFORMATION SAME AS GENERATOR

1. Billing Name: 2. Billing Address: (City, State, ZIP) 3. Contact Name: 4. Email: 5. Phone: 6. Fax: 7. WM Hauled? Yes No 8. P.O. Number: 9. Payment Method: Credit Account Cash Credit Card

C. MATERIAL INFORMATION

1. Common Name: Describe Process Generating Material: See Attached

2. Material Composition and Contaminants: See Attached

1.2.3.4.

Total comp. must be equal to or greater than 100% ≥100%3. State Waste Codes: N/A4. Color: 5. Physical State at 70˚F: Solid Liquid Other: 6. Free Liquid Range Percentage: to N/A 7. pH: to N/A 8. Strong Odor: Yes No Describe: 9. Flash Point: <140˚F 140˚–199˚F ≥200˚ N/A

D. REGULATORY INFORMATION1. EPA Hazardous Waste? Yes* No Code: 2. State Hazardous Waste? Yes No Code: 3. Is this material non-hazardous due to Treatment, Delisting, or an Exclusion?

Yes* No

4. Contains Underlying Hazardous Constituents? Yes* No5. From an industry regulated under Benzene NESHAP? Yes* No 6. Facility remediation subject to 40 CFR 63 GGGGG? Yes* No7. CERCLA or State-mandated clean-up? Yes* No8. NRC or State-regulated radioactive or NORM waste? Yes* No*If Yes, see Addendum (page 2) for additional questions and space.9. Contains PCBs? If Yes, answer a, b and c. Yes No a. Regulated by 40 CFR 761? Yes No b. Remediation under 40 CFR 761.61 (a)? Yes No c. Were PCB imported into the US? Yes No10. Regulated and/or Untreated Medical/Infectious Waste?

Yes No

11. Contains Asbestos? Yes No If Yes: Non-Friable Non-Friable – Regulated Friable

E. ANALYTICAL AND OTHER REPRESENTATIVE INFORMATION

1. Analytical attached Yes Please identify applicable samples and/or lab reports:

2. Other information attached (such as MSDS)? Yes

F. SHIPPING AND DOT INFORMATION

1. One-Time Event Repeat Event/Ongoing Business2. Estimated Quantity/Unit of Measure: Tons Yards Drums Gallons Other: 3. Container Type and Size: 4. USDOT Proper Shipping Name: N/A

G. GENERATOR CERTIFICATION (PLEASE READ AND CERTIFY BY SIGNATURE)By signing this EZ Profile™ form, I hereby certify that all information submitted in this and all attached documents contain true and accurate descriptions of this material, and that all relevant information necessary for proper material characterization and to identify known and suspected hazards has been provided. Any analytical data attached was derived from a sample that is representative as defined in 40 CFR 261 - Appendix 1 or by using an equivalent method. All changes occurring in the character of the material (i.e., changes in the process or new analytical) will be identified by the Generator and be disclosed to Waste Management prior to providing the material to Waste Management.

If I am an agent signing on behalf of the Generator, I have confirmed with the Generator that information contained in this Profile is accurate and complete.

Name (Print): Date:

Title:

Company:

Certification Signature

EZ Profile™



Only complete this Addendum if prompted by responses on EZ Profile™ (page 1) or to provide additional information. Sections and question numbers correspond to EZ Profile™.

Profile Number:

C. MATERIAL INFORMATIONDescribe Process Generating Material (Continued from page 1): If more space is needed, please attach additional pages.

Material Composition and Contaminants (Continued from page 1): If more space is needed, please attach additional pages.5.6.7.8.9.

Total composition must be equal to or greater than 100% ≥100%

D. REGULATORY INFORMATIONOnly questions with a “Yes” response in Section D on the EZ Profile™ form (page 1) need to be answered here.1. EPA Hazardous Waste a. Please list all USEPA listed and characteristic waste code numbers:

b. Is the material subject to the Alternative Debris standards (40 CFR 268.45)? Yes No c. Is the material subject to the Alternative Soil standards (40 CFR 268.49)? If Yes, complete question 4. Yes No d. Is the material exempt from Subpart CC Controls (40 CFR 264.1083)? Yes No If Yes, please check one of the following: Waste meets LDR or treatment exemptions for organics (40 CFR 264.1082(c)(2) or (c)(4)) Waste contains VOCs that average <500 ppmw (CFR 264.1082(c)(1)) – will require annual update.2. State Hazardous Waste Please list all state waste codes: 3. For material that is Treated, Delisted, or Excluded Please indicate the category, below: Delisted Hazardous Waste Excluded Waste under 40 CFR 261.4 Specify Exclusion: Treated Hazardous Waste Debris Treated Characteristic Hazardous Waste If checked, complete question 4.4. Underlying Hazardous Constituents Please list all Underlying Hazardous Constituents:

5. Industries regulated under Benzene NESHAP include petroleum refineries, chemical manufacturing plants, coke by-product recovery plants, and TSDFs. a. Are you a TSDF? If yes, please complete Benzene NESHAP questionnaire. If not, continue. Yes No b. Does this material contain benzene? Yes No 1. If yes, what is the flow weighted average concentration? ppmw c. What is your facility’s current total annual benzene quantity in Megagrams? <1 Mg 1–9.99 Mg ≥10 Mg d. Is this waste soil from a remediation? Yes No 1. If yes, what is the benzene concentration in remediation waste? ppmw e. Does the waste contain >10% water/moisture? Yes No f. Has material been treated to remove 99% of the benzene or to achieve <10 ppmw? Yes No g. Is material exempt from controls in accordance with 40 CFR 61.342? Yes No If yes, specify exemption: h. Based on your knowledge of your waste and the BWON regulations, do you believe that this waste stream is subject to treatment and control requirements at an off-site TSDF? Yes No6. 40 CFR 63 GGGGG Does the material contain <500 ppmw VOHAPs at the point of determination? Yes No7. CERCLA or State-Mandated clean up Please submit the Record of Decision or other documentation with process information to assist others in

the evaluation for proper disposal. A “Determination of Acceptability” may be needed for CERCLA wastes not going to a CERCLA approved facility.8. NRC or state regulated radioactive or NORM Waste Please identify Isotopes and pCi/g:

EZ Profile™ Addendum

!



Profile Number:

C. MATERIAL INFORMATION

Material Composition and Contaminants (Continued from page 2): If more space is needed, please attach additional pages.

10.11.12.13.14.15.16.17.18.19.20.21.22.23.24.25.26.27.28.29.30.31.32.33.34.35.36.37.38.39.40.

Total composition must be equal to or greater than 100% ≥100%

D. REGULATORY INFORMATION1. EPA Hazardous Waste a. Please list all USEPA listed and characteristic waste code numbers (Continued from page 2):

Additional Profile Information

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