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4.3 Debris with Non-RCRA Metals from Cleaning and Maintenance Activities This waste is in the form of solids containing non-RCRA metals that are generated from miscellaneous cleaning and maintenance activities. In 2010, 1475 pounds of this waste was in the form of debris from miscellaneous cleanup and maintenance activities and included 320 pounds of cooling tower sludge removal. In 2006, 12,632 pounds of this waste was mostly generated from cleaning and maintenance decommissioning of research facilities and some was generated from cleaning of cooling towers. This waste was expected to be reduced through better waste prevention practices and continuous improvements in facility operations. 4.4 Spent Deionization Resins for SLAC Closed -Loon Low -Conductivity Cooling Water System In 2006, spent ion exchange resin waste totaled 1,124 pounds. In 2010, 300 pounds of ion exchange resins were generated and categorized under CWC 132 (Aqueous solutions with metals). The change in CWC was due to the water and sludge that accompanied the resins. Because of the condition of the presence of sludge, it was not feasible to cleanly drain off the water. This waste would be similar to CWC 181 waste if the water were drained. Ion exchange resins are installed in-line as part of SLAC's closed-loop, Low - Conductivity Cooling Water (LCW) system. LCW is used to cool sections of the two- mile linear accelerator and other research equipment. The LCW is initially produced from potable water using a front-end deionization system and the ion exchange resins of this system are recycled with an outside water services vendor. This closed-loop cooling system is constructed of copper tubing and heat exchangers, releasing copper ions that are in tum removed by the in-line ion exchange resins. In-line ion exchange resins are strategically used to polish or remove copper ions from the LCW as it goes through the closed-loop cooling system. The use of LCW and copper heat exchange equipment is essential to controlling the operation of the accelerator and associated equipment. The decrease in waste resins between 2006 and 2010 was in part due to increased recycling of resins with an off-site contractor and due to reduce loading of copper on the in-line ion exchange resins. Resins are shipped to a permitted off -recycling facility and returned to SLAC for reuse. In the past, resins were shipped off for disposal. The two- mile accelerator operates at a lower heat duty since SLAC has changed from a high- energy physics laboratory to a multi-purpose laboratory. The lower heat duty results in less removal of metals from the LCW by the ion exchange resins. 4.5 Experimental Enuinment Repair/Ungrade and Removal Generating Beryllium or RCRA Metals Waste (RCRA Contaminated Debris and Non - Debris) In 2006, SLAC generated 317 pounds of this waste (310 pounds of beryllium copper waste and 7 pounds of other RCRA metals waste), and in 2010, SLAC generated 417 pounds of this waste (146 pounds of beryllium copper waste and 271 pounds of other RCRA metals waste). Some experimental apparatus use beryllium copper alloys and some operational and experimental activities generate small quantities of debris with other RCRA metals (other than lead) to support electronic operations. 4.6 Acid and Alkaline Debris In 2010, 1,134 pounds of the acid debris waste stream was coded under CWC 513. (Note: This waste quantity was extracted from the 2010 data but not included in the 8,421 -pound total of CWC 181 mentioned earlier because it was listed under a non -major waste stream, CWC 513, in 2010). This was less than the 1,987 pounds reported in 2006. The majority of this waste is in the form of containers for which there are limited recycling options. For LLNL 4.7 Batteries, Engineering Waste and Other Onerations In the 2007 SB 14 plan, the flowchart illustrating CWC 181 waste for LLNL (Figure 9) was incorrectly shown as "CWC 181 Environmental Restoration Process Flow Diagram for Ground Water Treatment Unit Scale Removal Operations". The section narrative indicates that the CWC 181 wastes were generated from various facility service operations, batteries and Engineering shop operations. The total CWC 181 waste was stated as 30,626 lbs in the 2007 SBI 4 Plan, however of that, no single process generated a sufficient quantity of waste to meet the S1314 reporting threshold of greater than 5% of the total waste stream. The largest single CWC 181 waste stream in 2006 was 6,648 lbs of batteries. Batteries are now collected and managed as universal waste and are sent for recycling. Over 120,000 lbs of small and large batteries were recycled during Fiscal Year 2010, resulting in no hazardous waste generated from battery disposal. The remaining waste reported in 2006 was from many different locations and dissimilar processes, and was not addressed. Although a total of 22,507 lbs of CWC 181 waste was generated during 2010, it was generated through various small processes such as lab trash, lumber, filters and sandblast. Each of these waste streams contributed between 1200 and 8000 lbs, and comprised only September 1, 2011 SB 14 Report 17 September 1, 2011 SB 14 Report