DRC-2018-006501 - 0901a06880864a1b

Div of Waste Management
and Radiation Control
JUL 0 3 2018 CLIVE SITE
LETTER OF TRANSMITTAL DRC-2018 -00().501
DATE: 06/14/2018
ATTN: Don Verblea DWMRC
CC; Treesa Parker
Karen Kirkwood
RE: Transmittal 18022
Description of Documents Transmitted Qty
See attached for an update to Container Handling;
CL-CH-PR-250 Rev 4, Decontamination Procedure F4 Revision ONLY
Please replace your current procedure revisions with the documents with in this
Transmittal.
You are not required to sign any documents to verify receipt of this distribution.
However, you should make every effort to ensure that your copy of the License is
current.
FROM: EnergySolutions
Document Control
Clive Facility
ENERGYSOLUTIONS CL-CH-PR-250
Decontamination Procedure
Revision 4
Chance Spradling
Jun 12 2018 8:28 AM Authored By:

COS1811

Chance Spradling, Lead, Container Decon and Date
Storage
Reviewed By:
Curtis Kirk Jun 12 2018 9:12 AM
Curtis Kirk, Quality Assurance Manager Date
Thomas Brown
Jun 12 2018 9:27 AM Approved By

COSI811

Thomas A. Brown, Radiation Safety Officer Date
(RSO)
Approved By
Brian Beynon Jun 14 2018 9:29 AM

Brian Beynon, Operations Manager Date
El Non-Proprietary El Proprietary
O Restricted Information
O Safeguards Information
0 Sensitive Security Information
CI New
O Title Change E Revision
O Rewrite
0 Cancellation
Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-CH-PR-250
Decontamination Procedure Revision 4
Table of Contents
1 PURPOSE AND SCOPE 3

1.1 Purpose 3

1.2 Scope 3
2 REFERENCES 3
3 GENERAL 3

3.1 Definitions 3

3 .2 Responsibilities 4

3.3 Precautions and Limitations 5

3.4 Records 5
4 REQUIREMENTS AND GUIDANCE 6
5 ATTACHMENTS AND FORMS 8
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CL-CH-PR-250
Decontamination Procedure Revision 4
1 PURPOSE AND SCOPE
1.1 Purpose
The purpose of this procedure is to provide consistent guidelines for operation of
the Decontamination Facilities, which include the Intermodal Container Wash
Facility (ICWF), Track 4 Wash Facility, and Mixed Waste Wash Pad/Bay.
1.2 Scope
This procedure applies to all EnergySolutions personnel who will be involved in
the operation of the listed facilities. This procedure does not apply to
decontamination at the Rotary Dump Wash Facility.
2 REFERENCES
2.1 ES-SH-PR-110, Hazardous Energy Control
2.2 ES-SH-PR-105, Fall Protection
2.3 29 CFR 1926.1053, "Ladders"
2.4 ES-QA-PR-005, Records
2.5 ES-SH-PR-106, Personal Protective Equipment
2.6 CL-SH-PR-100, Clive Health and Safety Program
2.7 CL-LD-PR-020, Management and Disposal of LLRW, and 1le.(2) and Mixed
Waste
2.8 Appendix J, Ground Water Quality Discharge Permit BAT Performance
Monitoring Plan.
2.9 Appendix K, Ground Water Quality Discharge Permit BAT Contingency Plan.
2.10 CL-CH-PR-252, Incoming Shipment Inspecting and Sampling
2.11 CL-RS-PR-115, Radiological surveys
3 GENERAL
3.1 Definitions
3.1.1 BAT — Best Available Technology: The application of design, equipment,
work practice, operation standard, or combination thereof, at a facility to
effect the maximum reduction of a pollutant achievable by available
processes and methods taking into account energy, public health,
environmental and economic impacts and other costs.
3.1.2 ICWF- Acronym used throughout this procedure in place of Intermodal
Container Wash Facility.
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CL-CH-PR-250
Decontamination Procedure Revision 4
3.1.3 Free Liquids — Any liquid(s) that separate from the solid portion of a
waste.
3.1.4 Pressure Wash System — A high-pressure water spray system consisting of
pump, high-pressure hose, spray nozzle and associated piping. It is
engineered to provide a continuous jet spray for decontamination of
railcars and other equipment.
3.1.5 Identification (ID) Label — Labels affixed to each container that are used
to identify the waste material and that an inspection has been completed.
Other information may also be included on the label to assist field
personnel in handling of the container.
3.1.6 Mud Box — A container, such as a B-25 box or similar dimensions, used to
contain sludge removed from the sump for storage and/or transport to
disposal.
3.1.7 Sump Sludge — a precipitated semi-solid matter produced during the
decontamination of containers. This sump sludge shall be managed as
onsite-generated waste.
3.1.8 Tripod — Mobile steel structure used as bracing underneath an intermodal
door to secure the door open during work activities inside the container.
3.1.9 Wheel Chocks — Positive pressure stops that are placed on the wheel to
prevent movement.
3.1.10 Mixed Waste Contaminated Areas — The areas at Mixed Waste that
contain possible surface contamination of mixed waste. These areas
include the MW Landfill Cell, Wash Pad, Wash Bay, and the Treatment
Building.
3.1.11 Polychlorinated Biphenyl's (PCB's): As defined in 40 CFR 761.61
through 64.
3.1.12 PCB Wipe: A cloth wipe soaked in Hexane used to determine removable
PCB contamination on a container.
3.1.13 Triple Rinse - Consists of rinsing three times using water or a solvent
capable of removing contaminants.
3.2 Responsibilities
3.2.1 The Operations Manager has overall responsibility for the implementation
of this procedure.
3.2.2 The Lead, Container Decon and Storage is responsible for coordinating
decontamination activities with the Foreman or designee, supplying
personnel equipment necessary to perform their duties in a safe and
compliant manner.
3.2.3 The Foreman or designee is responsible for:
• Maintenance and upkeep of wash guns, and all other equipment
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CL-CH-PR-250
Decontamination Procedure Revision 4
used in the decontamination facilities.
• Facilitating the return of containers for rail and truck shipments.
• Ensuring decontamination personnel perform all job function
activities safely and compliantly.
• Compliance with procedures
3.2.4 The Decontamination Personnel are responsible for the actual washing of
the boxes and the clean-up of the decontamination facilities.
3.2.5 The Radiation Safety Technicians (RST) shall ensure the radiological
release criteria are met after decontamination operations and the RWP
requirements are followed.
3.2.6 The Maintenance Department is responsible for the maintenance and
upkeep of the pumps and pressure washers used in the decontamination
facilities.

3.3 Precautions and Limitations
3.3.1 Personnel involved in the washing and decontamination of
containers/equipment in the listed facilities shall be qualified or under
direct supervision of a qualified operator, and have received training on
the proper safe use of all equipment used.
3.3.2 The Foreman or designee shall ensure daily pre-operational inspection of
the facility in use, is performed prior to decontamination operations.
3.3.3 If any discrepancies are found, the Foreman or designee shall note the
discrepancy on the Pre-Operational Checklist, and then contact the
Maintenance Department when necessary for repairs.
3.3.4 Operation of the wash facilities shall be stopped in the event of a failure or
elimination of any safety device (e.g. guards, shields, covers, control
switches, etc.)
3.3.5 When washing railcars, decontamination personnel shall enter or exit
using caution, and maintaining three point contact.

3.4 Records
3.4.1 The Facility Pre-Operational Checklist CL-CH-PR-250 F 1 shall be
completed daily, and then reviewed by the Manager, Container
Management or designee. The completed document will be transmitted to
document control within 45 days.
3.4.2 The Triple Rinse Verification Document CL-CH-PR-250 F2 shall be
completed monthly, and then reviewed by the Manager, Container
Management or designee. The completed document will be transmitted to
document control within 45 days.
3.4.3 The Mud Box/Site Generated Waste Container Inspection Form CL-CH-
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CL-CH-PR-250
Decontamination Procedure Revision 4
PR-250 F3 shall be completed as necessary, and then reviewed by the
Operations Manager or designee. The completed document will be
transmitted to document control within 45 days.
3.4.4 The Container Return Inspection Checklist CL-CH-PR-250 F4 shall be
completed daily and then reviewed by the Operations Manager or
designee. The completed document will be transmitted to document
control within 45 days of review.
4 REQUIREMENTS AND GUIDANCE
4.1 Safety
4.1.1 Personnel shall wear the appropriate Personal Protective Equipment (PPE)
as defined in the RWP and in accordance with Reference 2.5, Personal
Protective Equipment and applicable JHA(s)
4.1.2 Work performed on or around rail such as in the Rail Decon Facilities
shall be done in accordance with Reference 2.6, Clive Health and Safety
Program.
4.1.3 Personnel shall notify their supervisor immediately if an unsafe condition
or practice is observed.
4.1.4 Prior to washing containers mounted upon a transport trailer, the Decon
Operator shall ensure the trailer is secure to prevent movement.
4.1.5 When washing Intermodal containers that have a tailgate or door that lifts
up, the Foreman or designee shall ensure:
• Equipment shall carefully lift tailgate/door while all other
employees stand clear.
• Tripod and or adequate support shall be positioned under
tailgate/door. Personnel positioning tripod/support shall at no time
be in the swing area of the tailgate/door
4.2 Compliance
4.2.1 Prior to changing waste types (i.e. 1le.(2) to Class A or Class A to
11e.(2)), all vehicles and equipment used shall be inspected and labeled in
accordance with Reference 2.7, Management and Disposal of LLRW, and
lle.(2) and Mixed Waste.
4.2.2 When removing sludge from the sump or cleaning the bays after
decontaminating 11 e. (2) Waste type containers, the sludge and other
removed material shall be placed in a container that is appropriately
labeled for the waste type.
4.2.3 A container, which previously held hazardous waste, shall be RCRA
empty prior to reuse with a different waste stream, and triple rinsed before
use other than inside the Mixed Waste Facility.
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CL-CH-PR-250
Decontamination Procedure Revision 4

4.3 Procedure
4.3.1 Prior to beginning work, the Decon Foreman or designee shall perform an
initial visual inspection of the facility to ensure it complies with the
requirements outlined in Reference 2.8, Appendix J, Ground Water
Quality Discharge Permit BAT Performance Monitoring Plan.
4.3.2 During the inspection or at any time during operations, if a BAT failure is
detected, the Decon Foreman or designee shall follow the action outlined
in: Reference 2.9, Appendix K of the Ground Water Quality Discharge
Permit BAT Contingency Plan.
4.3.3 A formal BAT inspection will be performed each day in accordance with
Reference 2.8, Appendix J, Ground Water Quality Discharge Perrnit BAT
Performance Monitoring Plan.
4.3.4 Equipment or containers that have come in direct contact with open Mixed
Waste or non-lined containers that contained Mixed Waste shall be triple
rinsed before leaving the Mixed Waste area.

4.4 Decontamination Process
4.4.1 The Decon Foreman or designee shall verify the status of each
conveyance.
4.4.2 The decontamination personnel may use a pressure wash system for
decontamination of railcars and other equipment.
Note: Although utilizing the pressure washer is the preferred
method for decontaminating, alternate methods to
include but not limited to hand wiping, grinding,
scrubbing, gritblasting, and sandblasting can be
utilized. Appropriate JHA's and RWP's shall be
followed when performing this work.
4.4.3 Determined PCB contaminated waste containers are containers: where the
liner has been breached and residual contamination on the surface exceeds
10 ug/100 cm^2.
4.4.4 When PCB decontamination is required, this shall be completed before
radiological decontamination.
4.4.5 Select a solvent used that demonstrates the ability to remove PCB's.
Examples of solvents that may be used are Diesel Fuel, N-Hexane, etc.
4.4.6 All solvents, absorbent pads, etc. used to decontaminate PCB's shall be
collected and solidified. Disposal methods for PCB decon waste is to be
approved by the Environmental Engineer.
4.4.7 Collect a PCB wipe, in accordance with CL-CH-PR-252, Incoming
Shipment Inspecting and Sampling procedure and submit to the lab for
analysis. If results are passing, remove PCB labels.
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CL-CH-PR-250
Decontamination Procedure Revision 4
4.4.8 The RST shall ensure the radiological release criteria are met after
decontamination operations.
4.4.9 Roll up all hoses.
4.4.10 All containers shall be processed and released in accordance with
Container Return Inspection Checklist.
5 ATTACHMENTS AND FORMS
5.1 CL-CH-PR-250-F1, Decon Facility Pre-Operational Checklist
5.2 CL-CH-PR-250-F2, Triple Rinse Verification
5.3 CL-CH-PR-250-F3, Mud Box/Site Generated Waste Container Inspection Form
5.4 CL-CH-PR-250-F4, Container Return Inspection Checklist
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Decontamination Procedure
CL-CH-PR-250
Revision 4
Attachment 5.1 — Decon Facility Pre-Operational Checklist
ENERGY SOLUTIO/VS CL-CH-PR-250 Fl
Decontamination/Wash Facility Pre-Onerational Checklist
Intennodal Container Wash Facility 0 Rail Wash Facility 0 Other:
OK FIX
Verify the components are securely mounted and all guards, shields,
and covers are in place
Examine all components for damage and wear
Check oil level
Verify that fire extimuishers are present and current
Verify that eye wash station is present
Inspect area for any objects that could become airborne during
operation. Evaluate the potential for injury
Check system, including hoses, for leakage
Inspect secondary containment
If components have been subject to freezing conditions, thaw before
operation.
Inspect facility for holes/cracks and exterior walls for signs of
leakage.
Comments:
Person performing checklist:
Signature Date/time
Print name:
Wash Facility Foreman or designee:
Signature Date/time
Print narne:
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Description of Vehicle,
Container, Tank m.
Equipment
Serial
Number or
Box Number
Decontamination
Inspectors Signature Time Date
CL-CH-PR-250
Decontamination Procedure Revision 4
Attachment 5.2 — Triple Rinse Verification
FALMASOLII770M
Triple Rinse Verification Document
Form CL-C1I-PR-250 F2 Rev. 0
Decon/wash Location:
Reviewer Initials/Date:
Page 1 of
Electronic documents. once printed. are uncontrolled and may become outdated. Refer to the intraweb or the document conirol authority for the current revision.
Non-Proprietary Page 10 of 13
Facility:
Fill Line <2/3 Full Absorb. Added Inspection Label uspectoo InflaIi Date Box ID LH Secure Cannons
Decontamination Procedure
CL-CH-PR-250
Revision 4
Attachment 5.3 — Mud Box/Site Generated Waste Container Inspection Form
CL-CH-PR-250 F3
Revision 0 ENERGYSOLUTIONS
Mud Box/Site Generated Waste Container Inspection Form
Manager, Contemn. Handhng Review
Signature Date
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Decontamination Procedure
CL-CH-PR-250
Revision 4
Attachment 5.4 — Container Return Inspection Checklist
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Decontamination Procedure
CL-CH-PR-250
Revision 4
DOCUMENT SUMMARY FORM
Please provide the following information for new/revised documents.
Forward the completed form, approved document, and electronic file, to Document Control.
Document No.: CL-CH-PR-250 Revision No.; 5
Title: Container Return Checklist
Special Status (i.e. Restricted; SSI; etc.):
If special status is applicable, please note any special distribution/handling requirements:
None
Summary of changes (if this is a revision):.
Added line 16
Lid inspections. Inspect for: Crack, hardware, pin, hasp/clamp, security seal (as needed)
O Yes No This document requires evaluation per the requirements of a license. If yes, Ul attach evaluation results.
O Yes No This document requires regulatoiy agency approval before implementation. If yes, contact Document Control.
Distribution (or changes to distribution) for controlled copies of this document.
Source: ES-AD-PR-001, Rev.7, Document Preparation [Attachment 5.4]
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