HomeMy WebLinkAboutDRC-2025-000367 CLIVE SITE
LETTER OF TRANSMITTAL DATE: 1/27/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-005
Description of Documents Transmitted Qty
See attached for update to Mixed Waste Treatment. CL-MT-PR-105 Rev 10, Macro Vault Operations 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
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CL-MT-PR-105
Macro Vault Operations
Revision 10
Authored By:
Roger Ekins, Disposal Site Supervisor Date
Reviewed By:
Brett Davis, Treatment Supervisor 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
Roger Ekins Digitally signed by Roger Ekins
Date: 2025.01.27 08:18:42 -07'00'
Brett Davis Digitally signed by Brett Davis
Date: 2025.01.27 08:38:14 -07'00'
Digitally signed by Thomas Brown
DN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown, E=tabrown@energysolutions.com
Reason: I am approving this documentLocation: Clive
Date: 2025-01-27 11:56:40Foxit PhantomPDF Version: 9.7.5
Thomas Brown
Brennon Dick Digitally signed by Brennon Dick
Date: 2025.01.27 13:24:30 -07'00'
Adobe Acrobat version: 2024.005.20320
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Table of Contents
1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose........................................................................................................................... 3
1.2 Scope............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3.1 Definitions ...................................................................................................................... 3
3.2 Responsibilities .............................................................................................................. 4
3.3 Precautions and Limitations ........................................................................................ 4
3.4 Document Control and Records .................................................................................. 5
4 REQUIREMENTS AND GUIDANCE .................................................................................. 5
5 ATTACHMENTS AND FORMS......................................................................................... 11
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1 PURPOSE AND SCOPE
1.1 Purpose
To describe the procedure and inspection criteria for the preparations and casting
the monolithic vault using the MACRO Vault technology.
1.2 Scope
This procedure applies to the operational/construction of MACRO Vault
technology, at the Clive Mixed Waste Treatment Facility.
2 REFERENCES
2.1 State Issued Part B Permit, Attachment II-1-5, Macroencapsulation Plan
2.2 Proprietary Macro Mix Design Formulation, Currently Approved
2.3 CL-MD-PR-211, Mixed Waste: Daily, Weekly, Monthly & Annual Inspections
3 GENERAL
3.1 Definitions
3.1.1 MACRO Vault - Hazardous debris, radioactive lead solids waste, or both
that has been macroencapsulated by placing in an engineered vault, filling
void spaces, and applying surface coating materials such as polymeric
organics (e.g. resins and plastics) or with a jacket of inert inorganic
materials to substantially reduce surface exposure to potential leaching
media. MACRO Vaults may be constructed directly in the Mixed Waste
Landfill Cell in accordance with the applicable requirements of Reference
2.1.
3.1.2 Primary Container - The outer container inside of a MACRO Vault. This
container may hold open waste containers or loose waste.
3.1.3 Macro Mix - The fill material used in constructing the MACRO Vault to
encapsulate the waste material, as defined in Reference 2.2.
3.1.4 Non-Structural Cracks - Small hairline cracks that would not cause loss of
encapsulate material.
3.1.5 Structural Cracks - Cracks that would affect the encapsulates ability to
remain in place in the vault (i.e. a crack with a width ≥ 1/8th inch).
3.1.6 Void Filling - The process of filling void spaces within the waste
containers with Macro Mix, foam, or other flowable material.
3.1.7 CLSM – Controlled Low Strength Material used to fill voids and
encapsulate debris for final disposition.
3.1.8 RWP – Radiation Work Permit that specifies radiological controls and
personal protective equipment for a specific task.
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3.2 Responsibilities
3.2.1 Operations Manager has overall responsibility for this procedure.
3.2.2 Disposal Supervisor is responsible for the overall implementation and
accuracy of this procedure and for ensuring that this procedure is being
followed.
3.2.3 Site Engineer will perform a large object engineering review.
3.2.4 Quality Control Supervisor is responsible for directing and training the
QC Inspector on this Procedure.
3.2.5 QC Inspectors are responsible for, the following: performing batch ticket
verification, verifying 4” spacing, verifying bonding agent application,
performance of slump testing and completing inspection form CL-MT-PR-
105-F1 page 2 attached to this procedure.
3.2.6 Equipment Operators is responsible for loading waste into primary
containers to be macroencapsulated by a MACRO Vault. The operators
are also responsible for forming up the MACRO Vault pour, application of
bonding agent, operating equipment as needed, and filling voids as
needed.
3.3 Precautions and Limitations
3.3.1 Caution shall be used around forklifts and other equipment used during
operations.
3.3.2 Operators shall have radio communication available when loading waste
into Macro vaults.
3.3.3 Follow the RWP written to cover Macro Vault Operations.
3.3.4 All personnel constructing a MACRO Vault shall attend a pre-operational
briefing prior to constructing a Macro Vault. Multiple waste streams may
be covered in the same briefing.
3.3.5 Caution shall be used when working/operating on top of Macro Vaults. A
spotter shall be employed to warn employees of fall hazards when
working within 6 foot of the edge of a Macro Vault edge drop off.
3.3.6 Curing controls shall be applied when ambient air temperatures are above
90F or below 40F any time during the initial cure period of one day.
3.3.7 Voids within the MACRO Vault shall be filled within 24 hours of the first
load of MACRO Mix being added to the MACRO Vault. Voids are
considered to be any space within the 4” layer surrounding the waste
material. Macro mix poured for construction purposes (e.g., Mix poured
outside of the 4” layer used to bring adjoining vaults up to the same
height.) is not considered to be vault void infilling.
3.3.7.1 Document completion of void infilling on form CL-MT-
PR-105-F1, Macro Vault Operations Record,
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3.4 Document Control and Records
3.4.1 The Disposal Supervisor or Designee will review and transmit the Macro
Vault Operations Record (Attachment 5.1) and the Macro Corrective
Action Log (Attachment 5.2) to Document Control within 90 days of
completion.
4 REQUIREMENTS AND GUIDANCE
4.1 General
4.1.1 MACRO Vault construction requirements
4.1.1.1 The MACRO Vault shall be created to minimize interior
voids or air pockets.
4.1.1.2 Waste shall not protrude through the surface of the Macro
Vault.
4.1.1.3 When using removable forms, form oil or vegetable-based
oil shall be applied carefully so as to prevent puddling.
4.1.1.4 A minimum of four inches of Macro Mix on all sides must
be maintained to meet the vault requirements.
Note: The walls adjacent MACRO Vaults and
the top of an underlying vault may be
considered in meeting this requirement.
4.1.1.5 The MACRO Vault shall be protected from precipitation
contacting the waste until void filling is complete.
4.1.1.6 Any precipitation that may accumulate in the Macro Vault
shall be removed prior to waste or Macro Mix placement.
4.1.1.7 Prior to accepting each load, the batch tickets shall be
reviewed by the QC inspector to assure that the load meets
the MACRO mix design and tolerances.
4.1.2 Each load of Macro Mix shall be physically tested by the QC inspector to
ensure the Macro Mix meets the required slump criteria. Slump will be
tested following ASTM C143/ C143M, Standard Test Method for Slump
of Hydraulic-Cement Concrete. No Macro mix material will be loaded
into the monolithic Macro Vault forms after its time is greater than 3 hours
from adding water to the mixture.
4.1.2.1 A slump test will be performed with a resulting minimum
slump of 8-inches and a range up to 11 3/4-inches. If the
resulting slump is less than 8-inches the pour may still
resume by adding up to 10 oz of super plasticizers per yard
of macro mix, not to exceed a total of 35 oz/cy, to the mix
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design to acquire an adequate slump. If the slump still
cannot meet 8 inches or greater, or the slump exceeds 11
3/4 inches, the load will be rejected.
NOTE: Personnel performing slump testing shall
be trained and qualified.
4.1.2.2 A large object engineering review will be performed to
determine the maximum weight of waste that may be
placed in each Macro Vault geometry prior to pouring
macro mix. The QC Supervisor or designee will verify
weight calculations of the vault against the standard
calculations provided by the engineering.
Note: If a Macro Vault dimensions fall outside of
the standard calculations engineering
should perform a specific LOER.
4.1.2.3 Macro Vaults shall have a footprint no larger than 625 ft2
and shall be less than 16ft tall.
Note: permission from Regulatory Affairs
Director shall be obtained for any Macro
Vault that is bigger than 625 ft2 or taller
than 16 foot. Also, a Large Object
Engineering Review (LOER) must be
performed.
4.1.2.4 Multiple waste streams may be placed into a single Macro
Vault so long as they are compatible with one another.
Evaluate RGN’s for compatibility, if incompatible RGN’s
are identified, document justification for placing the waste
in the same vault. This documentation shall be included
with the Macro Vault Operation Record.
4.2 Procedure
4.2.1 Construction of Macro Vaults
4.2.1.1 Prior to the removal of any waste packages from the
storage area for placement in a vault, each package will
undergo a thorough verification process. This process will
include confirming the container number and ensuring the
current management status of the waste package. The
verification will be conducted by a minimum of two
personnel to ensure accuracy and compliance. This multi-
person verification will be completed before the waste is
transported for final placement in the designated vault.
4.2.1.1.1 Names of the individuals verifying containers shall
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be documented on the Macro Vault Operation
Record, CL-MT-PR-105-F1.
4.2.1.2 A minimum of two people shall be present when loading
waste into each Macro Vault.
4.2.1.3 If the base surface is soil or cell floor, a minimum 20 mil
plastic liner shall be placed under the vault to ensure
flowability between waste and the vault base. If the vault is
being constructed on CLSM or cured Macro, no liner is
required.
4.2.1.4 Set four inch or greater risers within the vault area.
NOTE: The four-inch floor of a vault may be
poured separately, (instead of using risers
when pouring on CLSM or non-Vault
material) so long as a bonding agent is
applied to the outer 4 to 6 inch perimeter
of the floor surface prior to pouring the
remainder of the vault.
4.2.1.5 Inspect the concrete risers to ensure they are free of any oil,
gas, grease, paint, etc. Stir bonding agent before use.
4.2.1.6 Set the concrete forms to form the vault ensuring that a
minimum of four inches on all sides of waste not abutting a
pre-existing Macro Vault is maintained when the waste is
placed therein.
NOTE: When
constructing a MACRO vault on the top
surface or using wall of existing MACRO
vaults a floor or walls will not be required
as the 4” requirement will have already
been met by the existing vault. However, a
bonding agent shall be applied to the
perimeter surface of the existing floor
prior to construction and pouring of the
vault.
4.2.1.7 Place the waste container on the risers, or pre-poured vault
floor, by using a forklift or an alternative piece of
equipment within the forms.
4.2.1.8 Facility operators shall verify that all containers have no
void space. This is verified by removing and/or smashing
lids as waste is compacted into vault with track hoe.
4.2.1.9 Waste with special handling and has been verified by the
sampler, or the generator, that all voids are filled will not
require the container to be opened or altered.
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4.2.1.10 Collect any physical data if necessary, (i.e., measurements,
photographs, etc.) prior to casting the monolithic vault.
4.2.2 Pouring the Macro Vault
4.2.2.1 Prior to accepting each load, the batch ticket shall be
reviewed by the QC inspector to verify:
4.2.2.1.1 The mix design on the batch ticket is
“MACRO MIX.”
4.2.2.1.2 The batch size is what was requested.
4.2.2.1.3 The mix meets required tolerances (+/- 2%
for aggregate and +/- 1% for all other
ingredients as specified in Reference 2.2,
Macro Vault Design Report).
4.2.2.2 The reviewing QC inspector shall sign and date the actual
batch ticket and the Macro Vault Operations Record
(Attachment 5.1) to verify the review.
4.2.2.3 The Cement Truck shall be allowed to pour 1/3 of the load.
During that time a sample of the mix shall be collected and
a slump test shall be performed before the Cement Truck
discharges any more mix.
4.2.2.4 If a Macro Vault is being poured with dimensions greater
than 6 feet in height, the pour rate shall be controlled to
prevent cold joints and outward pressure against the forms.
The pour rate shall be at the QC inspector or Macro
Operator’s discretion but no more than 6 vertical feet an
hour.
Note: Macro vaults cannot exceed 16 feet in
height unless prior approval has been
received from compliance.
4.2.2.5 Continuously fill the vault around the primary container
using Macro Mix.
Note: The pour may be stopped temporarily as
long as the pour resumes before the Macro
Mix sets, or no longer than 3 hours from
the last load being added to prevent cold
joints. In the event that the concrete cures
without finishing the pour, concrete
bonding agent shall be used on the outer 4
to 6 inches of the cured area prior to
adding new material.
4.2.2.6 The operator will ensure that the vault shall be poured in a
way that will allow for equal filling throughout the entire
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vault. It may be necessary to pour from the middle or
filling the sides to help aid in equal filling.
4.2.2.7 Following completion of the Macro Vault pour, a QC
inspector or Macro Operator will observe after 30-minutes
and before 2 hours ensuring that there isn’t excessive
settlement of the Macro Mix (consolidation of waste within
the primary container).
4.2.2.8 If settling does occur below the four inch requirement,
additional Macro Mix shall be added to meet the minimum
four inch requirement.
Note: Non-compliance issues will be reported to
Compliance and Permitting Manager
within 24 hours.
4.3 Documentation
4.3.1 The following shall be documented on the Macro Vault Operations Record
(Page 1 of Attachment 5.1):
4.3.1.1 Generator and shipment number;
4.3.1.2 Weight of waste;
4.3.1.3 Large Object Engineering Review;
4.3.1.4 Identification of void filling material used;
4.3.1.5 Presence and dimensions of risers and spacers used;
4.3.1.6 Vault dimensions;
4.3.1.7 Vault location in the disposal cell;
4.3.1.8 Surface vault is to be poured on (i.e. plastic liner, CLSM,
Macro Vault).
4.3.2 The following will also be documented on the Macro Vault Operations
Record (Page 2 of Attachment 5.1):
4.3.2.1 Batch ticket(s) for Macro Mix used;
4.3.2.2 Verification of bonding agent application;
4.3.2.3 Verification that the Macro Mix is within established
tolerances;
4.3.2.4 Volume of Macro Mix poured in the vault;
4.3.2.5 The time and dates the Macro Mix waste batched and
started and end of the batch pour.
4.3.3 Stripping the forms
4.3.3.1 Twelve hours after the completion of the Macro Vault, the
forms may be removed from the vault. Caution should be
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used to ensure that the Macro Vault is not damaged during
the form removal process.
4.3.3.2 QC will perform the initial inspection to evaluate integrity
of the Macro Vault. This will be documented on the QC
Daily Construction Report.
4.3.4 Curing of the MACRO Vault
4.3.4.1 Covering of the vault during the curing period is not
required if the ambient air temperatures are above 40° F, or
below 90° F throughout the initial 24-hour curing period.
4.3.4.2 If the temperatures are below 40° F, protection from
freezing shall be provided by blanketing the vault with an
insulating cover. Temperature shall be monitored and
documented following the 24-hour curing period.
4.3.4.3 If the temperatures are above 90° F, the vault shall be
covered with plastic or moist fabric to retain moisture at the
vault surface during the 24-hour curing period.
4.3.5 Inspection of the MACRO Vault
4.3.5.1 Initial inspection
• Initial inspection for curing shall be performed one
day following the completion of the pour.
• Initial inspection consists of evaluation of exposed
surfaces during normal hours, it is also to ensure
that Vaults are covered when required due to
ambient temperatures below 40F or above 90F.
4.3.5.2 Inspection shall be performed on all exposed surfaces with
focus on curing and overall physical condition. These
conditions shall include cracking, spalling, chipping,
swelling, excessive heat generation, sweating after curing
period, etc.
4.3.5.3 If non-structural cracks are identified in the inspection, they
shall be documented on the Macro Vault Operations
Record (Attachment 5.1) and monitored for worsening.
4.3.5.4 If a non-structural crack is identified, it shall be noted on
the QC Daily Construction Report following the initial
inspection. The crack should be repaired immediately using
a concrete sealing agent and documented on the Macro
Corrective Action Log (Attachment 5.3).
4.3.5.5 If a structural crack is identified the Compliance and
Permitting Manager shall be notified for a corrective
action.
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Note: Structural cracks shall be reported within
24 hours to the Compliance Manager.
4.3.5.6 Exposed vaults will continue to be inspected weekly as per
Reference 2.3.
4.4 Disposal
4.4.1 The Quality Control Department (QC) will be notified when vaults are
completed to initiate GPS mapping of each completed vault.
5 ATTACHMENTS AND FORMS
5.1 Macro Vault Operations Record, CL-MT-PR-105-F1 - Example
5.2 Macro Corrective Action Log, CL-MT-PR-105-F3 - Example
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ATTACHMENT 5.1 – CL-MT-PR-105 F1,
Macro Vault Operations Record page 1 - Example
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ATTACHMENT 5.1 – CL-MT-PR-105-F1,
Macro Vault Operations Record page 2 - Example
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ATTACHMENT 5.3 – CL-MT-PR-105 F3, Macro Corrective Action Log - Example
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