HomeMy WebLinkAboutDRC-2024-007073
CLIVE SITE
LETTER OF TRANSMITTAL
DATE: 09/27/2024
ATTN: LLRW
CC; Treesa Parker
Karen Kirkwood
RE: Transmittal 2024-067
Description of Documents Transmitted Qty
See attached for update to Administration.
CL-AD-PR-030 Rev 12 LLRW Export Approval 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Electronic documents, once printed, are uncontrolled and may become outdated.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-AD-PR-030
LLRW Export Approval
Revision 12
Authored By:
Nick Clarke, Compliance and Licensing Specialist
II
Date
Reviewed By:
Justin Lee, Manager, Shipping & Receiving Date
Approved By:
Thomas A. Brown, Radiation Safety Officer
(RSO)
Date
Approved By
Vern C. Rogers, Director, Regulatory Affairs Date
Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation
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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 .............................................................................................................. 5
3.3 Precautions .................................................................................................................... 6
3.4 Limitations ..................................................................................................................... 6
3.5 Records........................................................................................................................... 6
4 REQUIREMENTS AND GUIDANCE ................................................................................. 6
5 ATTACHMENTS AND FORMS.......................................................................................... 7
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1 PURPOSE AND SCOPE
1.1 Purpose
To describe operational requirements used to document verification that only
waste having approval from the Compact/State of original generation, as required
by Condition 9.A of Radioactive Material License UT2300249 (RML) is accepted
for disposal.
1.2 Scope
Each original waste generator is responsible for compliance with their respective
compact/state radioactive waste disposal requirements. Waste processors are
responsible for providing Clive with their proof of compliance with compact/state
radioactive waste export requirements for all waste process inputs. This procedure
identifies Approval to Export document requirements used to comply with RML
Condition 9.A.
2 REFERENCES
2.1 CL-CW-PR-202, Generator Certification
2.2 CL-QA-PR-005, Quality Assurance Records
2.3 CL-SR-PR-041, Incoming Radioactive Waste Shipment Acceptance
2.4 CL-WM-PR-001, Waste Profile Acceptance Process
2.5 Northwest Interstate Compact on Low-Level Radioactive Waste Management,
Third Amended Resolution and Order, May 2006, Olympia, Washington.
2.6 Northwest Interstate Compact on Low-Level Radioactive Waste Management,
Resolution Clarifying the Third Amended Resolution and Order, 12 May 2008,
Olympia, Washington.
2.7 Low-Level Radioactive Waste Policy Amendments Act of 1985 (Public Law 99-
240)
2.8 Utah Division of Waste Management and Radiation Control, Radioactive Material
License, UT 2300249 (RML)
2.9 Utah Division of Waste Management and Radiation Control, Manifest
Requirements for Low-Level Radioactive Waste (LLRW) Processors, 22 March
2012.
3 GENERAL
3.1 Definitions
3.1.1 11e.(2)Waste - Tailings or wastes produced by the extraction or
concentration of uranium or thorium from ore processed primarily for its
source material content.
3.1.2 Approval to Export (ATE) - A written document, commonly identified as
a “permit” or “petition”, issued by a Compact or State, within which waste
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was originally generated, authorizing the disposal of the low-level
radioactive waste at EnergySolutions’ Clive facility.
3.1.3 Blanket Approval - A Compact or Unaffiliated State policy that does not
require a generator to acquire a specific ATE document to ship radioactive
waste to EnergySolutions’ Clive facility for disposal.
3.1.4 Case-by-Case - A Compact or Unaffiliated State that requires a specific
ATE document to dispose of radioactive waste at Clive’s disposal facility;
and does not have a blanket approval allowing shipment for disposal of
LLRW to EnergySolutions.
3.1.5 Compact - Interstate agreement designed to establish and administer a
common radioactive waste disposal policy for radioactive waste generated
within the member States.
3.1.6 DOE Wastes - LLRW wastes produced by the U.S. Department of Energy.
3.1.7 Low-level Radioactive Waste (LLRW) - Radioactive waste that is not;
• Classified as high-level radioactive waste, transuranic waste, or
spent nuclear fuel.
• 11e.(2) wastes.
• Discrete surface wastes resulting from uranium solution extraction
processes.
• Underground ore bodies depleted by the extraction or
concentration of uranium or thorium.
• NARM wastes.
3.1.8 Mixed Waste - Waste containing both radioactive and chemically
hazardous waste.
3.1.9 Naturally Occurring and Accelerator-Produced Radioactive Materials
(NARM) -
• Any discrete source of radium-226 that is produced, extracted, or
converted for use for a commercial, medical, or research activity.
• Any material that has been made radioactive by use of a particle
accelerator; for use for a commercial, medical, or research activity.
• Any discrete source of naturally occurring radioactive material
used in a commercial, medical, or research activity, other than
source material, that the U.S. Nuclear Regulatory Commission
determines would pose a threat similar to the threat posed by a
discrete source of radium-226 to the public health and safety or the
common defense and security.
• Accelerator-produced radioactive waste produced during the
operation of atomic particle accelerators.
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3.1.10 Processor Attributed Waste – Processed waste where original ownership is
assigned to the processor as permitted by license. This is not ancillary
waste e.g. protective clothing, cleanup debris, air filters, and ion exchange
resin that is created by processing and is also attributed to the processor.
3.1.11 Processor Waste - Waste generated (or is otherwise owned) by an entity
not named in the contract used by EnergySolutions to accept the waste.
3.1.12 Unaffiliated State - A State that is not committed to a Compact agreement.
3.1.13 Waste Generator - An organization or entity that is ultimately responsible
for a waste.
3.2 Responsibilities
3.2.1 The Manager, Shipping and Receiving (or designee) is responsible for
confirming and documenting per the requirements of reference 2.2, the
ATE for each waste component from its original point of generation, prior
to accepting each waste shipment.
3.2.2 Upon receipt of a Shipment Manifest with Attribution record, Manager,
Shipping and Receiving (or designee) is responsible for ensuring the
presence of the Attribution record is flagged in the electronic waste
tracking system and records management system.
3.2.3 For all Shipment Manifests with Attribution records, Manager, Shipping
and Receiving (or designee) is responsible for ensuring the presence of all
applicable time appropriate ATE for all attributed waste from the point of
original generation. The Shipment Manifests with Attribution records and
ATEs shall be managed per the requirements of reference 2.2.
3.2.4 The Business Development Account Executive (or designee) is
responsible for notifying processors that time appropriate ATE
documentation is required to be accompanying all Shipment Manifests
from each Compact/State for waste incoming to their respective process,
as delineated by the specific compact/state, prior to any contract
agreement.
3.2.5 The Radiation Safety Officer (RSO) (or designee) is responsible for
verifying the generator has ATE documentation.
3.2.6 The Director of Regulatory Affairs (or designee) is responsible for:
• Identifying Compact/State approval requirements.
• Notifying the Compact/State when there is an approval
discrepancy.
• Maintaining this procedure.
• Compiling flagged Attribution records in support of the generation
of Monthly Compact Reports.
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3.2.7 Director, Technical Services (or designee) is responsible for assisting new
processors (including generators of processor-attributed waste) in
compilation of complete ATE documentation, as required by the original
waste generator’s compact/state. Also responsible to assist generators in
submission of complete ATE documentation with each LLRW shipment
for disposal at the Clive facility.
3.3 Precautions
Do not use the Processor’s address recorded on Manifest Form 542, block 5 to
determine the State where the waste was generated.
3.4 Limitations
3.4.1 Each Waste Generator or shipper is responsible for demonstrating
State/Compact approval. Each Waste Generator or shipper requiring an
ATE document approval shall attach the applicable ATE to each shipping
manifest. Only ATE documents specifically submitted for each profile
request and shipment, by the shipper or waste generator, shall be used for
ATE document validation.
3.4.2 Waste Generators, processors, or shippers do not need to provide ATE
documentations for when waste does not require Case-by-Case ATE and
Manager, Shipping and Receiving has confirmed that applicable Blanket
Approval ATEs are already on file, per the requirements of reference 2.2
3.5 Records
3.5.1 The ATE documents submitted by Waste Generators, processors, and
shippers shall be archived with the associated profile and manifest
documents in OnBase, according to the requirements of reference 2.2.
3.5.2 Compact/State correspondence, related to RML condition 9.A., shall be
archived in OnBase, according to the requirements of reference 2.2.
3.5.3 Business Development Account Executive (or designee) verifies that all
time applicable ATEs from the Compact/State of original generation from
each low-level radioactive waste component are archived in OnBase,
according to the requirements of reference 2.2.
3.5.4 The Manager, Shipping and Receiving (or designee) verifies the presence of
any applicable time applicable ATEs from the Compact/State of original
generation from each low-level radioactive waste component of a shipment
and ensures they accompany the archived paperwork. Signature in block 9 on
the form 540 certifies that the shipment has all required ATEs.
4 REQUIREMENTS AND GUIDANCE
4.1 Determination of ATE Documentation Requirement
4.1.1 Identify the State where the waste was generated.
Note: The State where the waste was generated is recorded on:
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• Radioactive Waste Profile Record, Form EC-0230, Section A.1 for
non-processor waste.
• Shipment Manifest, Form 540, Block 5, when shipment is not
Processor Waste.
• Shipment Manifest Form 541 block 5 or Form 542 block 10 when
shipment is Processor Waste.
4.1.2 Ensure receipt of the ATE record for processor-attributed waste.
4.1.3 Identify the low-level waste compact affiliation for the State where the
waste was generated using Table 1 or Table 2.
4.1.4 Select the waste type from the “Waste Types” listed in Table 3.
Note: The waste type is recorded on:
• Radioactive Waste Profile Record, Form EC-0230, Section A.2.
• Uniform Hazardous Waste Manifest.
4.1.5 Using the waste type and the Compact/State determine if Case-by-Case
ATE is required for the waste, using Table 3.
4.2 ATE Document Validation
4.2.1 Verify the name on the ATE document matches the original Generator
name recorded on the profile or manifest.
4.2.2 Verify the originating State listed on the profile or manifest corresponds to
the Compact/State issuing the ATE document.
4.2.3 Verify the originating generator waste shipment dates are consistent with
the ATE issue date (or period start date) and the last day when waste may
be shipped or ATE end date).
• Central, Northwest, Southwestern, and Texas compacts require
waste is shipped outside the compact, before the expiration date.
• Rocky Mountain will identify the ATE termination conditions and
dates on the ATE.
4.2.4 If waste generated in the Rocky Mountain Compact or the Texas Compact,
verify the shipment does not cause the total waste volume received to
exceed the permitted ATE waste volume.
4.3 Procedure Maintenance
4.3.1 When informed that a Compact/State ATE requirement has been changed,
the Manager, Compliance and Permitting, or designee, shall review the
change and update procedures as necessary to consistent with the new
requirement.
5 ATTACHMENTS AND FORMS
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5.1 Table 1, Compact Members, Ordered by States
5.2 Table 2, Compact Members, Ordered by Compact
5.3 Table 3, Approval by Waste Type
5.4 Table 4, Compact Contact Information
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Attachment 5.1 - Table1, Compact Members, Ordered by States
AB
B
R
S
COMPACT AT
E
STATE AB
B
R
S
COMPACT AT
E
STATE
AK Northwest Compact C Alaska MT Northwest Compact C Montana
AL Southeast Compact Alabama NC Unaffiliated States North Carolina
AR Central Compact C Arkansas ND Southwestern Compact C North Dakota
AZ Southwestern Compact C Arizona NE Unaffiliated States Nebraska
CA Southwestern Compact C California NH Unaffiliated States New Hampshire
CO Rocky Mountain Compact C Colorado NJ Atlantic Compact New Jersey
CT Atlantic Compact Connecticut NM Rocky Mountain Compact C New Mexico
DC Unaffiliated States
District of
Columbia NV Rocky Mountain Compact C Nevada
DE Appalachian Compact Delaware NY Unaffiliated States New York
FL Southeast Compact Florida OH Midwest Compact Ohio
GA Southeast Compact Georgia OK Central Compact C Oklahoma
HI Northwest Compact C Hawaii OR Northwest Compact C Oregon
IA Midwest Compact Iowa PA Appalachian Compact Pennsylvania
ID Northwest Compact C Idaho PR Unaffiliated States Puerto Rico
IL Central Midwest Compact Illinois RI Unaffiliated States Rhode Island
IN Midwest Compact Indiana SC Atlantic Compact South Carolina
KS Central Compact C Kansas SD Southwestern Compact C South Dakota
KY Central Midwest Compact Kentucky TN Southeast Compact Tennessee
LA Central Compact C Louisiana TX Texas Compact C Texas
MA Unaffiliated States Massachusetts UT Northwest Compact C Utah
MD Appalachian Compact Maryland VA Southeast Compact Virginia
ME Unaffiliated States Maine VT Texas Compact C Vermont
MI Unaffiliated States Michigan WA Northwest Compact C Washington
MN Midwest Compact Minnesota WI Midwest Compact Wisconsin
MO Midwest Compact Missouri WV Appalachian Compact West Virginia
MS Southeast Compact Mississippi WY Northwest Compact C Wyoming
C- Compact/state issues Case-by-Case ATE.
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Attachment 5.2 – Table2, Compact Members, Ordered by Compact
AB
B
R
S
COMPACT AT
E
STATE AB
B
R
S
COMPACT AT
E
STATE
DE Appalachian Compact Delaware WY Northwest Compact C Wyoming
MD Appalachian Compact Maryland CO Rocky Mountain Compact C Colorado
PA Appalachian Compact Pennsylvania NM Rocky Mountain Compact C New Mexico
WV Appalachian Compact West Virginia NV Rocky Mountain Compact C Nevada
CT Atlantic Compact Connecticut AL Southeast Compact Alabama
NJ Atlantic Compact New Jersey FL Southeast Compact Florida
SC Atlantic Compact South Carolina GA Southeast Compact Georgia
AR Central Compact C Arkansas MS Southeast Compact Mississippi
KS Central Compact C Kansas TN Southeast Compact Tennessee
LA Central Compact C Louisiana VA Southeast Compact Virginia
OK Central Compact C Oklahoma AZ Southwestern Compact C Arizona
IL Central Midwest Compact Illinois CA Southwestern Compact C California
KY Central Midwest Compact Kentucky ND Southwestern Compact C North Dakota
IA Midwest Compact Iowa SD Southwestern Compact C South Dakota
IN Midwest Compact Indiana TX Texas Compact C Texas
MN Midwest Compact Minnesota VT Texas Compact C Vermont
MO Midwest Compact Missouri DC Unaffiliated States
District of
Columbia
OH Midwest Compact Ohio MA Unaffiliated States Massachusetts
WI Midwest Compact Wisconsin ME Unaffiliated States Maine
AK Northwest Compact C Alaska MI Unaffiliated States Michigan
HI Northwest Compact C Hawaii NC Unaffiliated States North Carolina
ID Northwest Compact C Idaho NE Unaffiliated States Nebraska
MT Northwest Compact C Montana NH Unaffiliated States New Hampshire
OR Northwest Compact C Oregon NY Unaffiliated States New York
UT Northwest Compact C Utah PR Unaffiliated States Puerto Rico
WA Northwest Compact C Washington RI Unaffiliated States Rhode Island
C- Compact/state issues Case-by-Case ATE.
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Attachment 5.3 – Table 3, Approval by Waste Type
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LLRW generated within a State (other
than Federal Government) B B B B B C C B C C B B B B B B B B B B
LLRW generated within a State by
Federal Government B B B B B C C B C C B B B B B B B B B B
a. Owned or generated by the DOE B B B B B B B B B B B B B B B B B B B B
b.
Owned or generated by the US
Navy, resulting from
decommissioning vessel
B B B B B B B B B B B B B B B B B B B B
c.
Owned or generated resulting from
research, development, testing, or
production of atomic weapons.
B B B B B B B B B B B B B B B B B B B B
Compact authorization limits for section
3(a)(1)(B)(i-iii) Waste N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Low-Level Radioactive Waste (LLRW) N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
11e.(2) Waste B B B B B B B B B B B B B B B B B B B B
Ra-226 (Used for commercial, medical,
or research) B B B B B B B B B B B B B B B B B B B B
Particle Accelerator Produced (Used for
commercial, medical, or research) B B B B B B B B B B B B B B B B B B B B
NORM (Used for commercial, medical,
or research)1 B B B B B B C B B B B B B B B B B B B B
Mixed Waste B B B B B B C B B B B B B B B B B B B B
Notes
1. The Rocky Mountain Compact does not approve exceeding the gross waste volume limits listed on the Approval To Export
document.
B - Blanket Approval
C - Case-by-Case Approval Required
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Attachment 5.4 – Table 4, Compact Contact
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