12/22/98
Operations Department
WASTE CONTROL SPECIALISTS LLC
TREATING MIXED WASTE IN THE PERMACON

1.0 PURPOSE AND SCOPE
This procedure was prepared to provide guidelines for the treatment of mixed waste in the Permacon. Radioactive wastes treated to achieve a RCRA LDR standard or to meet the disposal facility's requirements, will be processed according to this procedure.

Waste treatment activities done under this procedure will occur in the Permacon equivalent structure unless an alternate location is approved by the Radiation Safety Officer.

2.0 EQUIPMENT AND MATERIALS

Treatment reagents:

Acids

Alkaline

Reducing Agents

Oxidizing Agents

Minerals

Pozzolans

Precipitation Clay

Synthetic Clay

Activated Clay

Others

Hand Tools

Containers

Mixers

3.0 PROCEDURE

3.1 PREREQUISITES

3.1.1 Radiation Work Permit (RWP)

Note: the RWP will be issued by the Radiation Safety Department. Issues regarding personal

protection will be coordinated with Heaith & Safety or Environmental Department.

3.1.2 Recipe of treatment reagents, mixing requirements and waste ratios.

The amount of reagents, mixing instructions, and waste ratios will be provided in the form of a

recipe report by the Laboratory.

3.2 PRECAUTIONS AND LIMITATIONS

3.2.1 All personal protective equipment requirements will be addressed in, and all work will be done under, the provisions of an approved RWP.

3.2.2 Radiation Safety Technicians will monitor operations performed under this procedure for radioactive materiais protection and control.

3.3 INSTRUCTIONS

3.3.1 Track the movement of waste into and out of the processing area on the "Load Tracking" or "Treatment Batch Tracking" forms.

3.3.2 Waste Treatment:

1. Obtain recipe from the laboratory.

2. Transfer necessary equipment, reagents and waste containers into the Permacon

equivalent structure.

3. The Radiation Safety Department will verify that proper radiation protection measures

are in place.

4. Treat the waste according to the written recipe.

5. Acquire a grab sample of the treated waste. Mark this sample and prepare it for transfer to the laboratory.

6. Record weight and volume of material added and/or finai weight and volume of the waste.

7. Close the waste containers.

8. Secure the work area and stop work.

9. Radiation Safety will perform exit surveys.

10. Submit the sample(s) to the laboratory for treatment verification.

11. Transfer the waste containers to a storage location if appropriate.

12. Release the waste as treated only after authorization from the Lab Manager and Compliance Manager.

13. Retreat the waste if it fails the specified treatment standards by following the above steps in this section.

Note: WCS is the generator of all treated waste destined for off-site shipment. The generator status is only relevant for the waste tracking requirements promulgated under RCRA and TNRCC regulations.

4.0 RECORDS
Records created as a result of this procedure are quality assurance records and will be maintained in accordance with the Records Management Plan. These records include but are not limited to analytical data used to verify treatment, waste tracking sheets, survey data, RWPs, etc.

5.0 REFERENCES
Radiological Control Manual