HomeMy WebLinkAboutDRC-2024-007092
CLIVE SITE
LETTER OF TRANSMITTAL
DATE: 10/1/2024
ATTN: LLRW
CC; Treesa Parker
Karen Kirkwood
RE: Transmittal 2024-070
Description of Documents Transmitted Qty
See attached for update to Mixed Waste Treatment.
CL-MT-PR-108 Rev 3 Draining and Flushing of PCB Items 1
------------------------------------------------------------------------------------------------------------
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Electronic documents, once printed, are uncontrolled and may become outdated.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-108
Draining and Flushing of PCB Items
Revision 3
Authored By:
Brett Davis MW Treatment Supervisor Date
Reviewed By:
Curtis Kirk, Director, Quality Assurance Date
Approved By
Thomas A. Brown, Radiation Safety Officer Date
Approved By
Brennon Dick, Operations Manager Date
Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 2 of 9
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 .............................................................................................................. 3
3.3 Precautions and Limitations ........................................................................................ 4
3.4 Document Control and Records .................................................................................. 4
4 REQUIREMENTS AND GUIDANCE .................................................................................. 4
5 ATTACHMENTS AND FORMS........................................................................................... 7
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 3 of 9
1 PURPOSE AND SCOPE
1.1 Purpose
To provide the method for draining and flushing PCB transformers, hydraulic
machines, and electrical equipment in accordance with 40 CFR 761 prior to
disposal in the Mixed Waste landfill at the Clive Facility.
1.2 Scope
This procedure applies to EnergySolutions personnel who will be involved in
draining and flushing PCB transformers, hydraulic machines, and electrical
equipment at the Clive Facility.
Note: Revisions to this procedure may include revising the TSCA
Coordinated Approval and shall be coordinated with the
Environmental Engineer.
2 REFERENCES
2.1 CL-MT-PR-400, Waste Solidification
2.2 40 CFR 761 – Polychlorinated Biphenyls (PCBs) Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions
2.3 CL-MT-PR-007, Solidification and Stabilization with Reagents
2.4 State-Issued Part B Permit, Attachment II-1-10, Management of Waste
Containing Polychlorinated Biphenyls (PCBs)
2.5 CL-SH-PR-500, Emergency Response Plan
2.6 CL-MT-PR-009, Waste Sorting, Sizing and Repackaging
3 GENERAL
3.1 Definitions
3.1.1 Catch Basin - A container used to collect drained oil and solvent from
PCB items during the draining/flushing process.
3.1.2 PCB Item - Any transformer, hydraulic machine, or electrical equipment
that deliberately or unintentionally contains or has as a part of it any PCB
or PCBs. This definition excludes capacitors.
3.2 Responsibilities
3.2.1 Manager, Operations has responsibility for the overall implementation and
accuracy of this procedure.
3.2.2 Lead, MW Treatment or Treatment Foreman is responsible for
conducting required pre-operationa1 briefings.
3.2.3 Treatment Operator is responsible for performing daily activities required
for implementation of this procedure.
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 4 of 9
3.2.4 Environmental Engineer is responsible for making notification
determination in case of spill. In addition, the Environmental Engineer
shall coordinate revisions of this procedure with the TSCA Coordinated
Approval.
3.3 Precautions and Limitations
3.3.1 Operations shall be conducted in accordance with the appropriate
Radiation Work Permit.
3.3.2 PCB items may be heavy and awkward, use two people or a piece of
equipment to assist any time movement is required.
3.3.3 Spills outside secondary containments require implementation of
Contingency Plan in accordance with Reference 2.5, Emergency Response
Plan. Notifications may include Environmental Protection Agency (EPA),
Office of Solid Waste (OSW). Environmental Engineer will make the
notification determination.
3.3.4 Industrial Hygienist shall be contacted for PPE and atmospheric sampling
requirements associated with draining/flushing PCB items.
3.4 Document Control and Records
3.4.1 The Transformer/Hydraulic Machine Draining & Flushing Record
(Attachment 5.1) shall be transmitted to Document Control within 90 days
upon completion.
3.4.2 The Overpack / Repack Operation Record, CL-MT-PR-009-F1, of
Reference 2.6 shall be used as a record of the PCB item draining process.
4 REQUIREMENTS AND GUIDANCE
4.1 Compliance
4.1.1 The Treatment Lead shall provide and document a pre-operational briefing
for all employees involved in the operation prior to performing the job, in
accordance with Reference 2.3.
4.1.2 The solvent (diesel) used in the flushing process and oil shall be collected
and managed in accordance with Reference 2.1 Waste Solidification,
prior to Thermal Desorption.
4.1.3 Transformers with ≥ 500 ppm PCBs are required to be flushed with
solvent which complies with 40 CFR 761.60(b)(1)(B) (i.e. diesel) in
accordance with this procedure, prior to disposal.
4.1.4 Hydraulic machines with ≥ 1,000 ppm PCBs are required to be
decontaminated or flushed with solvent which complies with 40 CFR
761.60(b)(1)(B) (i.e. diesel) in accordance with this procedure, prior to
disposal.
4.1.5 Electrical equipment, other than transformers and hydraulic machines, do
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 5 of 9
not require solvent flushing, regardless of the PCB concentration.
4.1.6 The catch basin selected shall be sized to contain at least 120% of the
volume of the PCB item.
4.2 Procedure
Note: A Treatment Operator is responsible for performing steps
4.2.1 – 4.2.6.
4.2.1 Pumping PCB oil From PCB Items
4.2.1.1 Prior to transfer of PCB oil, PCB item shall be placed on
the catch basin.
4.2.1.2 PCB Items without drain plug or valve shall be pumped
into a suitable container and the liquid shall be managed as
PCB liquids in accordance with Reference 2.1, Waste
Solidification.
4.2.2 Draining of PCB Items
4.2.2.1 A grate shall be placed over the opening of the catch basin,
in a manner to let liquid flow through, into the catch basin.
Note: The grate shall be wrapped in plastic if it
is to be reused later and labeled PCB, if
the grate is to be disposed it shall be
rinsed with solvent (diesel fuel) prior to
disposal.
4.2.2.2 Each PCB item shall be placed on top of the grate then
openings made to adequately drain liquid.
4.2.2.2.1 Each transformer or hydraulic machine drained
shall have a sample collected of liquid as it is being
drained and tested for PCB concentration. A unique
sample identifier shall be given to each sample,
which correlates to the respective transformer.
4.2.2.2.2 A sample of the liquid drained from PCB items
other than transformers or hydraulic machines is not
necessary.
Note: PCB items that are similar to each
other shall be grouped together
and drained into the same catch
basin.
4.2.2.3 Each PCB item shall be rotated as needed to help the liquid
drain into the catch basin.
4.2.2.4 Once the PCB item is completely drained, it will be placed
in a container pending analytical for disposal or additional
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 6 of 9
solvent flushing.
4.2.2.4.1 Transformers with a PCB concentration greater than
500 ppm shall be flushed in accordance with section
4.2.3 below.
4.2.2.4.2 Hydraulic machines with a PCB concentration
greater than 1,000 ppm shall be wiped down in
accordance with section 4.2.4 below.
4.2.2.5 Documentation of the containers managed / PCB items
flushed and the amounts of PCB liquids generated shall be
as described in reference 2.6.
Note: Volumes shall be documented in the
Notes Section of the Overpack / Repack
Operation Record, CL-MT-PR-009-F1, of
Reference 2.6.
4.2.3 Flushing of Transformers
4.2.3.1 The transformer shall be opened if not already.
4.2.3.2 If the transformer has surficial PCB contamination, it shall
be decontaminated as a piece of movable equipment as
described in 40 CFR 761.79(c)(2) prior to disposal.
4.2.3.3 The transformer shall be completely filled with diesel fluid.
4.2.3.4 Record the start time and date on the
Transformer/Hydraulic Machine Draining & Flushing
Record (Attachment 5.1).
4.2.3.5 Allow the transformer to sit for at least 18 hours.
4.2.3.6 Completely drain the transformer and record the date / time
of the draining and quantity drained on the
Transformer/Hydraulic Machine Draining & Flushing
Record (Attachment 5.1).
4.2.3.7 Add a sufficient amount of absorbent material to the
drained transformer to ensure no free liquids are present.
4.2.3.8 The catch basin shall be labeled and managed as part of the
generator’s waste and shall be managed in accordance with
Reference 2.1, Waste Solidification:
4.2.3.8.1 The catch basin shall include a PCB out of service
date. This date shall be the oldest date of all PCB
items that were drained into the catch basin.
4.2.3.9 Complete the Transformer/Hydraulic Machine Draining &
Flushing Record (Attachment 5.1). The reviewer shall
initial that the document is complete, accurate and legible.
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 7 of 9
The Transformer/Hydraulic Machine Draining & Flushing
Record (Attachment 5.1) shall then be forwarded to
Document Control in accordance with Section 3.4.1 of this
procedure.
4.2.4 Decontaminating/Flushing Hydraulic Machines
4.2.4.1 If the hydraulic machine has a reservoir that contained PCB
liquids greater than 1,000 ppm, it shall be filled and flushed
similar to a transformer as described in section 4.2.3 of this
procedure.
4.2.4.2 If the hydraulic machine has surficial PCB contamination,
it shall be decontaminated as a piece of movable equipment
as described in 40 CFR 761.79(c)(2) prior to disposal.
4.2.4.3 A rag shall be saturated with diesel fuel.
4.2.4.4 Use the saturated rag to swab contaminated surfaces of the
hydraulic machine.
4.2.4.5 Allow the surface to dry.
4.2.4.6 Any residual liquids from this operation should be managed
with the original drained liquid.
Note: Wipe downs shall be documented on the
Observation/Comments section of
Attachment 5.1, Transformer/Hydraulic
Machine Draining & Flushing Record.
5 ATTACHMENTS AND FORMS
5.1 CL-MT-PR-108-F1, Transformer/Hydraulic Machine Draining & Flushing
Record - Example
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 8 of 9
ATTACHMENT 5.1- CL-MT-PR-108-F1
Transformer/Hydraulic Machine Draining & Flushing Record - Example
CL-MT-PR-108-F1
Revision 0
Transformer/Hydraulic Machine Draining & Flushing Record
Date:
Tracking No.:
Solvent Type:
Generator Transformer # /
Container # Hydraulic Machine# Start Date / Time End Date / Time Qty (lbs)
1. / /
2. / /
3. / /
4. / /
5. / /
6. / /
7. / /
8. / /
9. / /
10. / /
Observations / Comments:
Operator Signature: Reviewer Initials:
Date: Date:
Page _____ of _____
CL-MT-PR-108
Draining and Flushing of PCB Items Revision 3
Non-Proprietary Page 9 of 9