DRC-2018-003681 - 0901a068807f553d

ENERGY SOLUTIONS
1:W.-2.10 IS- 00 366(
April 19, 2018 CD18-0081
Mr. Scott T. Anderson
Director
Utah Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, Utah 84114-4880
Subject: Radioactive Material License Numbers UT2300249 and UT2300478
Response to Module 13 Inspection, Liquids Management
Dear Mr. Anderson,
In a letter dated April 12, 2018, the Division of Waste Management and Radiation
Control provided results of Health Physics Compliance Evaluation Inspection Module 13,
Liquids Management. Within that letter, the Division noted two observations that
required attention. Herein, EnergySolutions provides responses and corrections to these
two observations.
Observation 1: The Mixed Waste Treatment Lead was using an outdated (April 4,
2003) listing of approved treatment reagents.
EnergySolutions Response: The Mixed Waste Treatment Lead had an uncontrolled
copy of the reagent list in a folder in his office; however, the currently approved revision
(dated May 27, 2016) is available to all employees via the intranet that can be reached on
any site computer. The Mixed Waste Treatment Lead has been reminded to use this
resource rather than the uncontrolled printed copy in his office.
Observation 2: Radioactive Waste Profile Record B.1. for waste stream 9105-01 "VTD
Liquids / Mixed Waste Debris" indicates that the waste does not contain free liquids
<1%. However, the same section shows the waste contains "other constituents and
percentages by volume" of "liquid, both aqueous and non-aqueous (VTD)" at "2%."
EnergySolutions Response: Both the profile and shipping paperwork of previously
received shipments for 9105-08 was reviewed. Previous revisions of the profile had the
"other constituents and percentages by volume" category blank and was recently changed
to 2% in response to a request from an internal reviewer. However, the generator has
stated that liquids are very low in this waste and the historical liquid volume is <1%.
This profile was revised again and the volume of liquids in the "other constituents and
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
\ ERG Y SOLUTIONS
Mr. Scott T. Anderson
CD18-0081
April 19, 2018
Page 2 of 2
percentages by volume" category corrected to 1%. A copy of applicable pages of this
revised profile is attached.
Should there be any questions regarding this response, contact me at 801-649-2144.
Sincerely,
Timothy L. Orton, P.E.
Environmental Engineer and Manager
cc: Don Verbica, DWMRC
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted Based on my inquiry of the person or persons who manage the
system, or those persons responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete I am aware that there are significant penalties for submitting false information, including the possibility of fine and nnpnsonment for knowing
violations
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www energysolutions.com
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
A. GENERATOR AND WASTE STREAM INFORMATION
GENERAL: Complete this fonn for one waste stream. Contact Energysolutions at [phone] if you have any questions while completing this form.
Please indicate "N/A" if a category does not apply
1. GENERATOR INFORMATION
Generator Name. DOE, Idaho National Laboratory/AMWTP EPA ID ID4890008952
Name of Person Cornplete Form: Kris Smith
Phone [phone] Email [e-mail]
Location of Waste (City, State): Scoville, ID
2. WASTE STREAM INFORMATION
Waste Strearn ID: 9105-01 Waste Stream Name: VTD Liquids / Mixed Waste Debris
Revision. 8 Date: 4/14/2016
CHECK APPROPRIATE BOXES BELOW. Please verify the required forms requested below are completed and submitted with the Radioactive
Waste Profile Record.
HAZARDOUS WASTE: Is the waste classified as hazardous waste as defmed by 40 CFR 261?
NEl lf NO, complete and attach the "Low-Level Radioactive Waste Certification Attachment"
Y If YES, complete and attach the "Hazardous Waste Certification Attachment" and check applicable box below.
Has the waste been treated to meet applicable treatrnent standards per 40 CFR 268? Y D N [0
Is the waste to be treated by EnergySolutions? Y N
LOW-LEVEL RADIOACTIVE WASTE: Is the radioactive waste defmed as Low-Level Radioactive Waste in accordance with the Low-Level
Radioactive Waste Policy Amendments Act of 1985 or m DOE Order 435.1?
Y [0 If YES„ a current copy of a LLRW Compact Export letter authorizmg export must be submitted if applicable. Cornpact export approval is not
required for DOE-generated or lle.(2) waste streams. Case by case export approval for mixed waste and NORM may be required based on generator's
governing Compact requirements, contact Energysolutions Technical Services staff for additional guidance.
N D If NO, check appropnate box• NORM/NARM El 11e.(2) Byproduct Matenal El Other:
SPECIAL NUCLEAR MATERIAL: Does the waste stream contain material with uranium ennched in U-235 or any of the following radionuclides.
U-233, Pu-236, Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, Pu-243, or Pu-244?
Y N If Yes, complete and attach the "SNM Exemption Certification" fonn (EC-0230-SNM). Supportmg statements, analytical results, and
documentation must be included with the submittal.
PCB WASTE: Does the waste contain Polychlonnated Biphenyls (PCB) that are regulated for disposal per 40 CFR 7617
Y I=1 N [11 If Yes, complete and attach the "PCB Waste Certification" form (EC-98279).
ASBESTOS: Does the waste contain Asbestos Containing Matenal?
Y li N Ej If Yes, Asbestos Contammg Material must be managed m accordance with applicable federal regulations. Provide a detailed
description of the waste contammg asbestos in the Waste Profile narrative
ENERGYSOLUTIONS CL-WM-PR-001 F2 (EC-0230)
Revision 9
RADIOACTIVE WASTE PROFILE RECORD
B. WASTE PHYSICAL PROPERTIES & PACKAGE INFORMATION
1. GENERAL CHARACTERISTICS
Does the waste contain free liquids? (>1%) Y D N DE If Yes, what is the percent of free liquid by waste %

If Yes, is the liquid aqueous (water-based)? Y N
Density range of the waste: 1 0 — '150 Ibtft^3
Does the waste contain absorbent? Y IE N
concrete & A A
List percentage of waste type by volume: Soil 5 % Metal % DAW 50 % Resins % Sludge ° %
other liquid, both aqueous and non aqueous (VTD) Other 1 % Other constituents and percentage by volume?
2. MATERIAL SIZE
Gradation of Matenal: Indicate the percentage of waste matenal that would pass throuah the followmg grid sizes. For example, 95% of the
matenal would pass through a 12" square, 90% passes through a 4" square, 80% passes through a 1" square, etc.
35 25 % 20 ox, 1/4,, 1 0 % _1/40" 5 % 1/200" 5 %
Does the waste stream contain oversize debns (i.e., no dimension < 10 inches and any dimension > 12 feet)? Y N
If yes, include a detailed description (i.e., weight, size, drawmgs, etc.) of the oversize debns m the Waste Profile narrative.
3. MOISTURE CONTENT
For soil or soil-like matenals, please use Std. Proctor Method ASTM D-698 to determine the optimum moisture content The waste matenal must
not exceed 3 percentage pomts above optnnurn moisture upon arrival at EnergySolutions' disposal facility unless approved by Energysolutions.
Optimum Moisture Content: N/A % at Maximum Dry Density (1b/ft3)• N/A
Average Moisture Content: N/A Moisture Content Range: N/A N/A% -
4. WASTE SHIPPING & PACKAGING
Transportation Mode. [KI Highway Rail
Shipping & Container Packages: Drums* 85 gallons) Boxes 100 ft3) EI Soft-Sided Bags 10 yd3)
(Check all that apply)
lntennodal Sealand ID Gondola** 1:1 Box Car
Other:
*Palletized drums are preferred by the disposal site. Please specify in the "Other" field if drums will not be palletized.
**Dnnensions of gondola railcars must be between 48 to 65 feet in length and 8.5 to 12.5 feet in height as measured from the top of the rail to the
top of the railcar unless approved by EnergySolutions.
5. NARRATIVE DESCRIPTION AND HISTORY OF WASTE
Please submit a narrative description and history of the waste as an attachment to the Radioactive Waste Profile Record. This
attachment should include the following:
• Process that generated the waste
• Waste material physical composition and characteristics
• Radiological and chemical characterization method
• Basis for determining manifested radionuclide concentrations
• Description and amounts of absorbents, if applicable
• Basis of non-hazardous or hazardous waste determinations
• Treatment processes, if applicable
• Product information or Material Safety Data Sheets associated with the waste as applicable
• Information requested in other sections of this form