DRC-2024-007099

CLIVE SITE
LETTER OF TRANSMITTAL

DATE: 10/4/2024
ATTN: LLRW
CC; Treesa Parker
Karen Kirkwood
RE: Transmittal 2024-073

Description of Documents Transmitted Qty

See attached for update to Mixed Waste Treatment.

CL-MT-PR-008 Rev 2 Managing Mixed Waste Treatments and Buildings 1

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Please replace your current procedure revisions with the documents within 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

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-MT-PR-008
Managing Mixed Waste Treatments and
Buildings
Revision 2
Authored By:
Brett Davis, MW Treatment Supervisor Date
Reviewed By:
Steve D. Gurr, Environmental Engineer and
Manager
Date
Approved By
Thomas A. Brown, Radiation Safety Officer
(RSO)
Date
Approved By
Brennon Dick , Operations Manager Date
Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation
Brett Davis Digitally signed by Brett Davis
Date: 2024.10.04 06:19:11 -06'00'
Digitally signed by Steve D. Gurr
Date: 2024.10.04 07:16:24 -06'00'
Digitally signed by Thomas Brown
DN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown,
E=[e-mail]
Reason: I am approving this document
Location: Clive
Date: 2024-10-04 07:35:37
Foxit PhantomPDF Version: 9.7.5
Thomas Brown
Brennon Dick Digitally signed by Brennon Dick
Date: 2024.10.04 08:34:34 -06'00'
Adobe Acrobat version: 2024.003.20112
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Revision 2

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Table of Content

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 ........................................................................................ 4
3.4 Document Control and Records .................................................................................. 4
4 REQUIREMENTS AND GUIDANCE .................................................................................. 4
5 ATTACHMENTS AND FORMS......................................................................................... 15
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1 PURPOSE AND SCOPE
1.1 Purpose
To verify that waste manifested into the facility conforms to the profile of the
waste and that all hazards associated with the waste are noted and managed
compliantly with all state and federal laws.
This procedure also describes development of Stabilization and Solidification
formulas and the management of the sample used in the process as well as fire
detection and suppression system inspections.
1.2 Scope
This procedure applies to Mixed Waste that will not meet Land Disposal
Restrictions.
2 REFERENCES
2.1 CL-SH-PR-150, Laboratory Chemical Hygiene Plan
2.2 State Issued Part B Permit, Attachment II-1-2-1, Approved Treatment Reagents
2.3 State Issued Part B Permit, Attachment II-1-3, Waste Stabilization Plan
2.4 CL-MD-PR-211, Mixed Waste Daily, Weekly and Monthly Inspections
2.5 CL-LB-PR-003, Sample Control
3 GENERAL
3.1 Definitions
3.1.1 Stabilization - The process of treating mixed wastes by chemical oxidation
or reduction, neutralization, or deactivation to reduce the leachability of
the hazardous constituents.
3.1.2 Land Disposal Restriction Certification (LDR) – Certification required to
accompany each Mixed Waste shipment. This certification identifies EPA
hazardous waste codes, constituents and Underlying Hazardous
Constituents, which may or may not meet Land Disposal Restrictions.
3.1.3 Underlying Hazardous Constituent (UHC) – Any constituent listed in 40
CFR 268.48, Table UTS—Universal Treatment Standards, except
fluoride, selenium, sulfides, vanadium, and zinc, which can reasonably be
expected to be present at the point of generation of the hazardous waste at
a concentration above the constituent-specific UTS treatment standards
3.1.4 High Risk Waste – Waste that contains hazards (e.g. D001, D002, D003,
lab packs, etc.) that may adversely react during waste processing and
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treatment activities.
3.2 Responsibilities
3.2.1 Operations Manager has the overall responsibility for this procedure.
3.2.2 Lead, MW Treatment is responsible for the overall implementation and
accuracy of this procedure.
3.2.3 Treatment Foreman/Operator is responsible for performing this procedure
to create treatment formulas.
3.2.4 Environmental Engineer is responsible for submitting treatment formulas
to the Division of Waste Management and Radiation Control (DWMRC),
for providing necessary notifications to accounting, and for assuring
treatability study sample disposition.
3.2.5 Manager, Health and Safety or designee is responsible for performing a
review of chemical constituents for high risk waste streams, and assist in
determining correct management practices during processing and/or
treatment.
3.3 Precautions and Limitations
3.3.1 Follow the PPE and other requirements posted on the appropriate RWP.
3.3.2 When working in the lab, follow the requirements in Reference 2.1,
Laboratory Chemical Hygiene Plan.
3.3.3 The Treatment Foreman/Operator shall check for heat generation and off
gassing when performing this procedure. If hazardous off-gassing is
suspected or detected, notify the safety department.
3.3.4 All waste samples received on site for treatability studies shall be treated
and disposed or returned to the generator within one year of arrival.
3.4 Document Control and Records
3.4.1 Attachment 5.2, Formula Development Form, shall be maintained in the
Mixed Waste Operating Record and transmitted to Document Control
within 90 days of completion.
4 REQUIREMENTS AND GUIDANCE
4.1 Compliance
4.1.1 The Waste Profile Record, Hazardous Waste Manifest, LDR and container
manifest (applicable to high-risk wastes), shall be reviewed prior to the
treatment of a hazardous waste shipment.
Note: This review shall include a verification that the
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treatment technology being employed is appropriate for
the waste codes listed in the profile, manifest, LDR,
and/or chemical constituents in each container.
4.2 Procedure
4.2.1 Complete the Shipment EPA Code Verification Checklist (Attachment
5.1) for each new shipment received, prior to treatment.
x Review the Hazardous Waste Manifest to ensure that the waste
codes listed match the waste codes on the Waste Profile Record.
Indicate “Yes” or “No.”
x Review the LDR to ensure that the waste codes listed match the
waste codes on the Hazardous Waste Manifest. Indicate “Yes” or
“No.”
x Review the LDR to ensure that the UHC’s listed match the UHC’s
on the Waste Profile Record. Indicate “Yes” or “No.”
x If applicable, ensure that the Deferred Chemical results match the
Treatability Sample base-line. Indicate “Yes” or “No.”
x Indicate whether the current treatment formula will be sufficient to
treat this waste.
x Is waste a High Risk Waste (eg. D001, D002, D003, Lab packs,
etc.)? Indicate “Yes” or “No.”
x Are there other hazards associated with treatment of waste that
need to be identified as High Risk Waste? Indicate “Yes” or “No.”
x If High Risk Waste, have the Environmental Engineer or designee,
the Lab chemist or designee, and the Manager, Health and Safety
or designee perform a review of each container contents to
determine safe handling practices. These reviews are to be
documented on the CL-MT-PR-008 F3 Shipment EPA High Risk
Approval checklist. Emails may be attached in place of signatures.
4.2.2 Upon completion, the Shipment EPA Code Verification Checklist or
Shipment EPA High Risk Approval Checklist shall be forwarded to the
Operations Manager, or designee for review.
4.2.3 The Operations Manager shall review the Shipment EPA Code
Verification Checklist or Shipment EPA High Risk Approval Checklist for
accuracy, completion and legibility, initial and date.
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4.2.3.1 Send completed forms to Document Control for filing in the
operating record within 90 days of completion.
4.3 Fire Systems at Mixed Waste
4.3.1 Compliance
4.3.1.1 Problems that may harm people or the environment, or items that
may lead to a problem, shall be noted as not acceptable, then
repaired and documented as outlined in the procedure below.
4.3.1.2 Problems that pose an imminent threat to human health or the
environment shall be corrected immediately. Other problems shall
be corrected within 72 hours of discovery unless a corrective
action plan is approved.
4.3.1.3 If the fire system is found to be inactive at any time, waste
operations are to cease in that area.
4.3.2 General
4.3.2.1 Annual inspections for the fire suppression system are documented
and filed in the operating record.
4.3.2.2 Items observed between scheduled inspections may be corrected
without formal documentation.
4.3.3 Process
4.3.3.1 Fire/Supply Water Tank Condition Assessment
4.3.3.1.1 Perform the following tank inspection on the fire
water tank at least once each calendar year, and at
least nine months later than the inspection for the
previous calendar year.
ƒ Visually inspect exposed standpipes for
leaks, corrosion, erosion, cracks and pitting.
Check “OK” if the tank is acceptable, “Fix”
if not acceptable.
ƒ Test cathodic protection of the tank using
current industry standard such as cathodic
protection potential meter. Check “OK” or
“Fix” and attach the results to the report..
ƒ Note any observations of unacceptable items
in the space for “REMARKS.”
ƒ Sign the form at the bottom of the page in
the “Inspector’s Signature” space and record
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the time and date in the space for the “Date.”
ƒ Test tank foundation integrity and secondary
containment integrity in addition to testing
for corrosion.
4.3.3.1.2 For unacceptable items, record how and when (date)
the problem was corrected in the space for “DATE
AND NATURE OF ANY REPAIRS OR OTHER
REMEDIAL ACTIONS.”
4.3.3.1.3 If a problem cannot be corrected within 72 hours (3
days), it will be tracked in the QA Condition
Reporting Program. The Manager, Waste Disposal
Operations will ensure these long-term problems are
corrected and documented.
4.3.3.1.4 Send completed inspection forms to the Document
Control Department for filing in the operating
record within 90 days of completion.
4.3.3.2 Fire Suppression System
4.3.3.2.1 Weekly and Monthly inspections shall be performed
by Compliance Inspector or by maintenance under
the direction of the Compliance Inspector, in
accordance with Reference 2.4, Mixed Waste Daily,
Weekly and Monthly Inspections.
4.3.3.2.2 Lead, Mixed Waste Treatment shall arrange
quarterly and/ or annual inspections by an
independent certified or qualified fire system
inspector.
4.3.3.2.3 Obtain a signed written report from the inspector
that documents the date and time of inspection, a
description of inspections performed, and results of
the inspection (acceptable or unacceptable). The
inspector shall record observations made for
unacceptable items.
ƒ For unacceptable items that can be corrected
within 72 hours (3 days), document how and
when (date) the problem was corrected in
the operating record. If a problem cannot be
corrected within 72 hours (3 days), notify
the Manager, Compliance and Permitting
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who will provide notification to the Director
of the Utah Division of Solid and Hazardous
Waste, prior to the completion of the 72
hours. A description of the problem and a
schedule of completion should be included
in that notification. The Manager, Waste
Disposal Operations will ensure these long
term problems are tracked and documented
through the Quality Assurance (QA)
Condition Reporting.
4.3.3.2.4 Send completed inspector’s reports to the Document
Control Office for filing in the operating record within 90
days of completion.
4.3.3.3 Monthly Preventative Maintenance
Note: These inspections and tests are performed
by Maintenance Personnel and are
tracked by Maintenance Department’s
MP2 Database. Completed work orders
shall be submitted to Manager, Waste
Disposal Operations for Review.
4.3.3.3.1 Fire Water Pump
ƒ Check Packing / Adjust as necessary (1-2
Drips per second)
ƒ Check inlet and outlet valves for leakage
ƒ Visually Inspect Piping and Connections
ƒ Exercise inlet and outlet valves for corrosion
control. Turn 5 to 6 turns and return to open
position
ƒ Add 2 pumps of grease in each bearing
cover
4.3.3.3.2 Jockey Pump
ƒ Inspect Pump for leaks
ƒ Exercise inlet and outlet valves for corrosion
control
Note: Pump shall be turned off when exercising valves.
4.3.3.3.3 Back Up Generator
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ƒ Record Hour Meter
ƒ Check Battery and Terminal for Corrosion
ƒ Check Engine Oil
ƒ Check coolant level and freeze protection
ƒ Test run the engine for 30 minutes
4.3.3.3.4 Fire Hydrant
ƒ Open Hydrant east of Mixed Waste
Operations Building (Bldg 33) and let flow
for 60 seconds and close.
ƒ Manually Turn off Fire Water Pump Switch
on the control panel in the Fire Water Pump
House and Reset to back to Auto Mode.
ƒ Reset Fire Alarm Panel in MW Treatment
Building. After testing the system will give
a “Trouble Mode” indication and resetting
the system should clear it. If not, contact
Maintenance for repair.
4.3.4 Stabilization and Solidification Formulas
4.3.4.1 General
4.3.4.1.1 The primary goal of treatment is to achieve the
applicable treatment standards or objectives. The
primary goal of solidification is to achieve a waste
form that passes PFLT. The secondary goal is to
achieve a final treatment residue, which may be
most easily managed. The desired physical form or
consistency of the treatment residue will be similar
to that of a loose, compactable soil. However, some
waste will have to be treated such that the treatment
residue will have physical properties similar to
concrete.
4.3.4.1.2 Conditions during the performance of this
procedure shall be as to replicate the full-scale
operation.
4.3.4.1.3 During treatment, water and reagents shall be added
to the waste in order to meet the applicable
treatment standards or objectives and to ensure a
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treated waste at a desired consistency.
4.3.4.1.4 If the sample requires size reduction in order to
optimize treatment, a grinder or other appropriate
device shall be used to reduce particle size of the
sample.
4.3.4.1.5 As a result of this procedure, information about the
following treatment parameters shall be developed:
ƒ The amount of water needed to make a
slurry.
ƒ Whether a pH adjustment is needed and how
to adjust the pH.
ƒ The composition and amount of treatment
reagents to be used.
ƒ The consistency of the post treatment
material.
4.3.4.1.6 The treatment formula is to be developed using the
information provided by the successful completion
of this procedure, then utilized in accordance with
Reference 2.3, Waste Stabilization Plan.
4.3.4.1.7 Practical application and field experience may be
used as part of the process for adjusting the
formulas. Justifications for adjustments shall be
documented in the remarks section of Attachment
5.2, Formula Development form.
4.3.4.1.8 Apparatus and Materials
ƒ Laboratory balance, with at least +/- 0.1g
readability.
ƒ pH Meter or pH Paper.
ƒ Beaker or container, glass or plastic
calibrated for volume, 200ml minimum.
ƒ Timing device (clock, watch, or timer).
ƒ Mixer/blender, with slow speed (Pro Line
model KSM5 or similar unit).
ƒ Stirring device (glass rod, spatula, etc.).
ƒ Volumetric measuring devices, glass or
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plastic (burets, pipettors, graduated
cylinders, beakers, or flasks).
ƒ Photo-ionization detector (PID).
ƒ Temperature meter.
ƒ Multi-gas meter.
4.3.4.2 Reagents
x Tap Water.
x Surfactants, various (i.e. detergents, wetting agents and
emulsifiers).
x Treatment reagents from those listed in Reference 2.2,
Approved Treatment Reagents.
x Technical grade acid and/or base to adjust pH.
x Materials to adjust the consistency of the treated waste which
may include:
x Perlite
x Diatomaceous Earth
x Natural clay
x Sand
x Gravel
x Soil
4.3.5 Process
Note: A treatment formula may involve introduction of the
water, waste, pH adjustments as necessary and reagents
in the order listed below or in an alternative order.
Treatment formulas may also involve preparatory and
follow-up steps with different reagents. The sequence of
reagents may be adjusted as necessary to account for
these considerations so long as the amounts and orders
of introduction to the treatment process (wastes, water,
reagents, and pH adjusting materials, when necessary)
are determined, performed, recorded and documented
properly on the Formula Development Form.
4.3.5.1 Weigh or establish a tare weight or mass of an empty beaker or
container.
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4.3.5.2 Place a minimum 100g waste sample into the container. Determine
the mass of the sample. Record the mass in grams.
4.3.5.3 Determine the volume of the sample. Record the volume in mls.
4.3.5.4 Place the sample into a beaker or slow speed mixer/blender.
4.3.5.5 Using a volumetric measuring device, add water (if necessary) to
the sample in small amounts and stir the sample-water solution
until a fluid slurry is created which is easily mixed.
4.3.5.6 Determine the amount of water added. Record this amount in mls.
4.3.5.7 Check the pH of this slurry using a pH paper or meter. If the pH
meter is used, a sample of the slurry may be taken and mixed with
an equal amount of water before measuring the pH. Record the
initial pH.
4.3.5.8 If the pH requires adjustment for compatibility with reagents or
other factors use approved reagents and record reactions and
adverse conditions.
4.3.5.9 Add treatment reagents as necessary.
4.3.5.9.1 Identify and record the composition and order of
addition of all treatment reagents used.
4.3.5.9.2 Prepare the treatment reagent(s) to be used for
addition to the waste or slurry. If more than one
reagent is to be used, a mixture may be made by
combining the appropriate amounts --OR-- the
reagents may be obtained and made ready for
appropriate addition to the slurry separately.
4.3.5.9.3 Add the selected treatment reagents to the slurry
and stir as needed until the slurry is solidified.
Record any observations or reactions noted between
the slurry and the treatment reagents. Record the
technique for adding the materials.
4.3.5.9.4 Determine the amount of treatment reagents added.
Record the amount in grams.
4.3.5.9.5 Determine the final volume of the treated material.
Record the amount in mls.
4.3.5.10 Free liquids consistency check.
4.3.5.10.1 Visually inspect the sample for the presence of free
liquids or run the Paint Filter Liquids Test (PFLT)
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on the treated waste.
4.3.5.10.1.1 If free liquids are present more
reagents are added.
4.3.5.10.1.2 If there are no free liquids, record.
4.3.5.11 Sample collection
4.3.5.11.1 Place the sample in an approved sampling
container. Label the sample with the following
information:
ƒ Contract number and formula designation
ƒ Date and time of the sample collection
ƒ Initials of the collector
4.3.5.11.2 Fill out a chain of custody and maintain in
accordance with Reference 2.5, Sample Control,
and deliver sample to Sample Control.
4.3.5.12 Analytical verification.
4.3.5.12.1 Analytical results showing the treatment standards
or objectives are met using this procedure shall be
obtained in order to establish a formula for use in
treatment. Additional screening methods may be
employed, but official analytical tests shall be
performed by a Utah Certified Laboratory.
4.3.5.13 Consistency adjustments.
4.3.5.13.1 If materials or other procedures are needed to adjust
the consistency of the material for disposal, add the
materials to the waste or carry out the procedures to
adjust the consistency of the waste. Record what
these adjustments are.
4.3.5.13.2 Record any observations or reactions during
consistency adjustments.
4.3.5.14 Quality Control.
4.3.5.14.1 Once a formula has been developed, a duplicate
must be completed as a comparison and precision
check for the items below. These precision
objectives require analysis of the treatment
standards. The duplicate must fit within the
following ranges:
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ƒ Mass of Sample: +/- 1%
ƒ Volume of water added: +/- 1%
ƒ Mass of reagents added: +/- 1%
ƒ Final volume of treated material: +/- 5%
ƒ Final mass of treated material: +/- 5%
4.3.5.15 Sample management
Note: Within one year of receipt, all samples
shall be disposed or returned to the
generator.
4.3.5.15.1 After receiving results demonstrating the treatment
formula is successful, the sample and associated
residues will be managed in one of the following
ways:
ƒ Combined with waste from the appropriate
generator Waste Stream;
ƒ Managed as EnergySolutions Created
Waste; or
ƒ Returned to the generator.
4.3.5.16 A copy of the Formula Development Form will be
forwarded to the Environmental Engineer.
4.3.5.16.1 The Environmental Engineer will review the
Formula Development Form for accuracy,
completion and legibility.
4.3.5.16.2 The Environmental Engineer will prepare a
document describing the proprietary treatment
formula and submit to the DWMRC. This submittal
shall include the following:
ƒ A cover letter describing the formula as
“Confidential”;
ƒ A list of reagents and ratios, in the order
added;
ƒ A description of the general formula
concept;
ƒ Safety and precautions;
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ƒ A step-by-step description of the treatment
process; and
ƒ An example Waste Treatment Formula and
Treatment Record Form.
5 ATTACHMENTS AND FORMS
5.1 CL-MT-PR-008-F1, Shipment EPA Code Verification Checklist
5.2 CL-MT-PR-008-F2, Formula Development Form
5.3 CL-MT-PR-008- F3, Shipment EPA High Risk Waste Approval form
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Attachment 5.1 - CL-MT-PR-008-F1, Shipment EPA Code Verification Checklist

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Attachment 5.2 - Formula Development Form CL-MT-PR 008 F2 Example

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Attachment 5.3 –
Shipment EPA High Risk Waste Approval Form CL-MT-PR-008 F3-Example

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