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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 ------------------------------------------------------------------------------------------------------------ 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EnergySolutions Document Control Clive Facility Electronic documents, once printed, are uncontrolled and may become outdated.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-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 CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 2 of 15 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 CL-MT-PR-105 Macro Vault Operations Rev. 9 Non-Proprietary Page 3 of 15 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. CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 4 of 15 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 90F or below 40F 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, CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 5 of 15 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 CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 6 of 15 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 CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 7 of 15 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. CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 8 of 15 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 CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 9 of 15 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 CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 10 of 15 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 40F or above 90F. 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. CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 11 of 15 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 CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 12 of 15 ATTACHMENT 5.1 – CL-MT-PR-105 F1, Macro Vault Operations Record page 1 - Example CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 13 of 15 ATTACHMENT 5.1 – CL-MT-PR-105-F1, Macro Vault Operations Record page 2 - Example CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 14 of 15 ATTACHMENT 5.3 – CL-MT-PR-105 F3, Macro Corrective Action Log - Example CL-MT-PR-105 Macro Vault Operations Revision 10 Non-Proprietary Page 15 of 15