DRC-2024-007533

November 15, 2024 CD-2024-233
Mr. Doug Hansen
Director Division of Waste Management and Radiation Control 195 North 1950 West Salt Lake City, UT 84114-4880

Subject: EPA ID Number UTD982598898 Radioactive Material License UT2300249 Follow up to Potential Discrepancy with Shipment 1075-09-0004
Dear Mr. Hansen, In a letter dated November 10, 2024 (CD-2024-231), EnergySolutions notified the Director of the Division of Waste Management and Radiation Control of a potential
discrepancy from shipment 1075-09-0004 (GSAP 0110000502). As described previously; while inspecting the shipment, liquid was observed within the Oil Tray Sealand (Sealand) container equipped with a secondary containment system. The shipment 1075-09-0004 (Bates Number XL01004), consisting of aqueous/non
aqueous liquids for solidification at Mixed waste, followed by disposal at LLRW as an LLRW Destined Waste, was moved into the Restricted Area and the generator notified. The radiological survey from ESUU600109 (see attached) performed in the field yielded results less than Minimum Detectable Activity (MDA). Results from the onsite gamma spectroscopic analyses of the liquid beneath the grate of the Sealand container (see
attached) detected slightly elevated levels of Cobalt 60 and Cesium 137 consistent with the manifested concentrations. The Sealand container ESUU600109 is designed to provide secondary containment for liquids being shipped. The inner secondary containment is an added level of conservatism
in case something unexpected happens to the inner packages. ESUU600109 was successfully tested and passed the Secondary Containment Compliance Test (See attached) ensuring the containers secondary containment integrity in the event it is needed.

Container ESUU600109 was the manifested container on the Uniform Low-Level Radioactive Waste Manifest (Form 540), while the Form 541 lists each of the 16 individual containers (see attached). It was discovered that container # 24-029 within ESUU600109 had a hole not meeting the requirements of 49 CFR 173.410 (f) and leaked
into the secondary containment of the Sealand container (see attached) but remained
Mr. Doug Hansen November 15, 2024 CD-2024-233 Page 2
within the manifested shipping container. The liquids were placed inside an overpack
container. In Summary, EnergySolutions investigation into this discrepancy confirms that a potential threat of human health and the environment was minimized and not at risk
although the liquid from container # 24-029 leaked, the liquid remained contained within
the manifested package identified on Form 540, ESUU600109. The shipment remains in compliance with Department of Transportation (DOT) and Clive’s Waste Acceptance Criteria (WAC) requirements.
Condition Report CR-2024-1083 has been generated to track actions associated with this
issue. Please consider this the follow-up written notification (required in Radioactive Materials License UT2300249, Condition 68) for this discrepancy.
Should there be any questions regarding this notification, please contact me at 801-649-2043.
Sincerely,

Steve D. Gurr Environmental Engineer and Manager

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 directly 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 imprisonment for knowing violations.

Digitally signed by Steve D.
Gurr
Date: 2024.11.15 07:11:05
-07'00'

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