DRC-2025-000861

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 2/20/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-011
Description of Documents Transmitted Qty
See attached for update to LLRW Disposal. CL-LD-PR-020 Rev 15 Management and Disposal of MW and LLRW Waste 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
CL-LD-PR-020

Management and Disposal of LLRW,
11e. (2), and Mixed Waste
Revision 15

Authored By:
Roger Ekins, Lead Disposal Cell Date
Reviewed By:
Curtis Kirk, Quality Assurance Director 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

Management and Disposal of LLRW,
11e.(2), and Mixed Waste
CL-LD-PR-020
Revision 15

Table of Contents

1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose ............................................................................................................................ 3
1.2 Scope ............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 4
3.1 Definitions....................................................................................................................... 5
3.2 Responsibilities ............................................................................................................... 9
3.3 Precautions and Limitations .......................................................................................... 11
3.4 Document Control and Records .................................................................................... 13
4 REQUIREMENTS AND GUIDANCE ................................................................................ 15
5 ATTACHMENTS AND FORMS......................................................................................... 38

Management and Disposal of LLRW,
11e.(2), and Mixed Waste
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1 PURPOSE AND SCOPE
1.1 Purpose
This procedure provides consistent guidelines for the Treatment and Disposal of
LLRW, 11e.(2), and Mixed Waste at the Clive Disposal Facility.
1.2 Scope
This procedure applies to all EnergySolutions personnel involved in the direct
handling and disposal of waste materials accepted which may include non-
hazardous waste generated from daily work assignments inside the LLRW
restricted area, Ion Exchange Resin, Asbestos Containing Material, or HPTC
Materials, and the management, segregation, and transfer of waste received at for
management at the Mixed Waste Facility that will be disposed at the LLRW
Facility.
2 REFERENCES
2.1 40 CFR 761.79, Decontamination Standards and Procedures
2.2 40 CFR 61.154(j), Standard for Active Waste Disposal Sites
2.3 40 CFR 261.20 – 261.24
2.4 40 CFR 261.30 – 261.33
2.5 40 CFR 268.7(b)(4)(v), Land Disposal Restrictions
2.6 40 CFR 268.7(d)(3)(iii), Land Disposal Restrictions
2.7 CL-AD-PR-004, Document Preparation, Control, Distribution, Interim Storage,
and Destruction
2.8 CL-CH-PR-250, Decontamination Procedure
2.9 CL-CH-PR-251, Container Management and Storage
2.10 CL-CH-PR-252, Incoming Shipment Inspection and Sampling
2.11 CL-EV-PR-011, PCB Air Sampler Operation
2.12 CL-IN-PR-450, Instrument Operation
2.13 CL-LB-PR-003, Sample Control
2.14 CL-MD-PR-300, On site Waste Management
2.15 CL-MD-PR-211, Mixed Waste : Site Inspections
2.16 CL-MT-PR-007, Solidification and Stabilization with Reagents
2.17 CL-MT-PR-009, Waste Sorting, Sizing, Repackaging
2.18 CL-MT-PR-105, Macro Vault Operations
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2.19 CL-RS-PR-115, Radiological Surveys
2.20 CL-SH-PR-100, Clive Health and Safety Program
2.21 CL-SH-PR-500, Contingency Implementation Plan
2.22 CL-SR-PR-060, Outgoing Shipment of Radioactive Material
2.23 CL-TN-PR-100, Clive Facility Training
2.24 CL-WM-PR-001, Waste Profile Acceptance Process
2.25 CL-WT-PR-001, Waste Facility Tracking
2.26 ES-SH-PR-106, Personal Protective Equipment (PPE)
2.27 Waste Characterization Plan, as amended
2.28 LLRW and 11e.(2) Construction Quality Assurance/Quality Control Manual
(CQA/QC Manual), as amended
2.29 DAQ Air Quality Approval Order DSQE-AN0107170019-11, as amended
2.30 Groundwater Quality Discharge Permit UGW450005, as amended
2.31 EPA Approval for the Shredder Operation to Process PCB Wastes (EPA
Approval), as amended
2.32 Letter Dated June 11, 2007, from Dennis R. Downs, Utah Solid and Hazardous
Waste Control Board to Sean McCandless, Director of Compliance and
Permitting, EnergySolutions, Subject: Approval of Alternative Daily Cover for
Asbestos/Radioactive Waste.
2.33 LLRW Radioactive Material License No. UT 2300249, as amended
2.34 11e.(2) Radioactive Material License No. UT 2300478 , as amended
2.35 Radioactive Materials License UT2300249, Site Radiological Security Plan, as
amended
2.36 State-issued Part B Permit, Attachment II-1-10, Management of Waste
Containing Polychlorinated Biphenyls (PCBs) at the Mixed Waste Facility
2.37 State-issued Part B Permit, Attachment II-1-10.1, Management of Waste
Containing Polychlorinated Biphenyls (PCBs) at the LLRW Facility
2.38 State-issued Part B Permit, Attachment II-1-5, Macroencapsulation Plan
2.39 State-issued Part B Permit, Attachment II-3, Site Inspection Plan
2.40 State-issued Part B Permit, Attachment II-1-15, Aerosol Can Puncturing System
Operating Plan
2.41 CL-QC-PR-001, Quality Control Inspections and Testing.
2.42 CL-CH-PR-109, Rotary Dump Facility Operation
3 GENERAL
Management and Disposal of LLRW,
11e.(2), and Mixed Waste
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3.1 Definitions
3.1.1 11e.(2) waste - 11e.(2) waste is defined as ”…tailings or wastes produced
by the extraction or concentration of uranium or thorium from any ore
processed primarily for its source material content” as defined in section
11e.(2) of the U.S. Atomic Energy Act of 1954, as amended.
3.1.2 Alternative Cover –Alternative daily cover shall consist of a paper/wood
mulch with a cement fly ash, or polymer binder. Specific products that
meet these requirements are Waste Cover® and Soil-Sement®. Other
products that meet the requirements may be used.
3.1.3 Approved Secondary Waste Container – Containers designed to minimize
the potential for the spread of Dry Active Waste (DAW) and accumulation
of storm water. Secondary waste containers shall be labeled in accordance
with the guidance of this procedure.
3.1.4 Asbestos Containing Material – Any waste that contains asbestos in any
form. This includes friable asbestos, non-friable asbestos, and materials
contaminated with asbestos (e.g., Personal Protective Equipment).
3.1.5 Best Available Technology (BAT) – The application of design, equipment,
work practice, operation standard, or combination thereof, at a facility to
affect the maximum reduction of a pollutant achievable by available
processes and methods considering energy, public health, environmental
and economic impacts and other costs.
3.1.6 Blending Layer - A minimum 6-inch layer of native clay that meets the CL
classification. The blending layer is used to homogenously blend Ion
Exchange Resin (IER). The thickness shall be verified by a Quality
Control (QC) survey.
3.1.7 Bridge Crane – A device for lifting gondola lids prior to rolling or
washing, when applicable. The Bridge Crane consists of a powered winch
and motorized carriage connected to a lifting fixture specifically designed
for gondola lids.
3.1.8 Combustible Material –Any material capable of igniting and burning.
3.1.9 Combustion – For the purpose of this procedure combustion is the process
in which a substance reacts with oxygen or water to create heat and light
resulting in a spark that has the potential to create a fire or explosion
hazard with nearby combustible material.
3.1.10 Danger Zone – Areas where personnel access must be limited due to
potential injury from flying projectiles during shredder operations.
3.1.11 Debris - Solid material exceeding a 60 mm particle size that is intended
for disposal and that is: A manufactured object; or plant or animal matter;
or natural geologic material. A material is subject to regulation as debris if
the mixture is comprised primarily of debris, by volume, based on visual
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inspection.
3.1.12 Deluge System – A system designed to apply water to a fire quickly and
simultaneously over a large area activated manually by the Control Tower
Operator.
3.1.13 Disposal - Final approval of the waste lift in accordance with the
Reference 2.18, Macro Vault Operations.
3.1.14 Double Feed Roller (DFR) – Provides additional compaction and controls
the feed rate of material from the feed chute into the hammer mill.
3.1.15 Engineered Vault - A term applicable to the approval and construction of a
MACRO Vault. An engineered vault has been evaluated and approved by
the Executive Secretary in accordance with the applicable requirements of
The Permit.
3.1.16 Feed Chute – A structure that temporarily holds and funnels material into
the DFR located at the end of the Feed Chute.
3.1.17 Feeding System – A combined assembly of the Feed Chute, Double Feed
Rollers, In-Feed Conveyor, and associated hydraulic components that
enables forward movement of material into the hammer mill.
3.1.18 Free Liquids - Any liquid(s) which separate from the solid portion of a
waste.
3.1.19 Friable Asbestos Containing Material -is any asbestos containing material
that can be crumbled, pulverized, or reduced to powder by hand pressure.
This includes previously non-friable material that has been damaged and
can then be crumbled, pulverized, or reduced to powder by hand pressure.
3.1.20 Gondola Railcar – A railcar that is open at the top.
3.1.21 Hammer Mill – A machine comprised of a combination of rotor-mounted
hammers and hydraulic components to reduce the physical size and
volume of debris material.
3.1.22 Headspace Void – Any void of material between the top plane of the
container opening and area of the inner floor and walls of the container.
3.1.23 HPTC Material – Any material that has a high propensity toward
combustion. Specifically, when impacted with other dense objects, under
optimal conditions, could create heat resulting in a spark that can ignite
combustible material.
3.1.24 Identification Labels - Label affixed to each container used to identify
waste material by generator, waste stream, shipment identification
number, date accepted and other applicable information to assist field
personnel in handling waste.
3.1.25 In-Feed Conveyor – A heavy duty conveyor used to transport material
from the feed hopper into the Feeding System.
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3.1.26 In-Feed Pad – A concrete surface approved for bulk waste storage where
bulk and containerized waste material is temporarily staged prior to the
start of the shredding process.
3.1.27 Lid – A covering for a Gondola railcar that protects the load from the
elements and prevents waste material from blowing out during transport.
3.1.28 Liquid Waste - Liquid phase of a waste stream.
3.1.29 LLRW Waste - Low-Level Radioactive Waste as defined in Utah
Administrative Code (UAC) R313-15-1008. LLRW includes waste
formerly described as LLRW, mobile waste, and NORM/NARM.
Although LLRW includes Class A, B, and C, Radioactive Material
License UT2300249 limits waste received by EnergySolutions to Class A
LLRW.
3.1.30 LLRW-Destined Waste - Waste that shall be managed in the Mixed Waste
Facility and disposed in the LLRW Facility. This waste shall be identified
by having an “X” before the Tracking number.
3.1.31 Macroencapsulation (MACRO) - Encapsulation with 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.
3.1.32 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
2.40, Macroencapsulation Plan.
3.1.33 Macro Mix - A specifically designed concrete mix used in constructing the
MACRO Vault (e.g. controlled low strength material, concrete).
3.1.34 Management Status - A container/item may have one of the following
management statuses: storage, treatment, holding, or disposal.
3.1.35 Marker Layer - A minimum 6-inch layer of native clay or sand that
separates the resin blending layer from other types of waste. The 6-inch
layer shall be verified by QC surveys. This is used to identify separation of
resin from other waste lifts.
3.1.36 Mechanical/Motor Control Center (MCC) – The main point of operations
where most electrical equipment is located.
3.1.37 Motor Management Relay – Located in the Motor Room, a
microprocessor-based relay designed for the protection and management
of the 6000 hp Shredder motor and associated drive equipment.
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3.1.38 Out Feed Conveyor - A heavy duty “exit” conveyor used to transport
shredded material from the hammer mill to the out-feed containment pad.
3.1.39 Out-Feed Containment Pad – A concrete surface approved for bulk waste
storage where shredded material is discharged.
3.1.40 Oversized Debris – Debris over 16 inches in all dimensions as defined in
the LLRW & 11e.(2) CQA/QC Manual.
3.1.41 Personal Protective Equipment (PPE) – Personal Protective Equipment:
Devices or clothing worn to help isolate a worker from direct exposure to
hazardous materials; e.g., waterproof outer covering, gloves, safety
glasses, hardhat, respirator, etc.
3.1.42 Placed Waste - Waste that has been disposed in the embankment and
meets all the LLRW & 11e.(2) CQA/QC Manual requirements.
3.1.43 PPE – Personal Protective Equipment, such as steel toed boots, Tyvek,
hard hat and other protective equipment as assigned by the Radiation
Work Permit (RWP) and determined necessary for the specific work being
performed.
3.1.44 Primary Container - The outer container inside of a MACRO Vault. This
container may hold open waste containers or loose waste.
3.1.45 RCRA Empty - Containers of acute hazardous waste (All "P" codes) are
empty once triple rinsed with a solvent capable of removing the chemical.
All other hazardous waste containers are empty once all wastes have been
removed that can be removed by common practices and no more than one
inch of waste residue shall remain on the bottom of a given container or for
containers less than 110 gallons, no more than 3% by weight; or for
containers more than 110 gallons, no more than 0.3% by weight.
3.1.46 Restricted Area - The area within the controlled area that requires control
of access and occupancy for radiation protection purposes. The restricted
area boundary is posted with “Caution, Radioactive Material” and is
bordered by a 6-foot-high fence.
3.1.47 Secondary Containment - A building, portable containment unit or other
device used to store containers of liquid waste. The secondary
containment shall be able to either hold 10% of the total volume or all the
volume of the largest container, whichever is greater, in the event of a leak
or spill.
3.1.48 Secondary Waste – Non-hazardous waste generated because of operations
inside the LLRW Restricted Area including (but not limited to) waste
shipment samples, miscellaneous wood debris, disposable PPE, and
packaging used for parts, materials, and supplies necessary for operations.
3.1.49 Shredder Facility – The hammer mill, its components, and the surrounding
fenced area where there exists significant risk of personnel injury during
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shredding operations.
3.1.50 Sludge – A precipitated semi-solid matter produced because of the
introduction of water injected during material shredding to control
temperature and emissions.
3.1.51 Temporary Restricted Area Road – An access road located east of the
Shredder Facility that allows access to the Class A North Embankment.
3.1.52 Tracking Label - Label used to identify a waste container/item, which
includes the generator number, waste stream number, shipment
identification or treatment run number, the management status, the
Reactive Group Numbers (RGN), date of arrival, and the words
"Hazardous Waste” if applicable.
3.1.53 Un-Containerized Waste - Waste that has been unloaded from a
transportation container.
3.1.54 Undermill Oscillator (UMO) – A vibrating pan which, when activated,
causes shredded material to drop onto the out-feed conveyor.
3.1.55 Visibly Clean – All potentially contaminated material that can be removed
by a squeegee, shovel or other tools must be removed.
Note: Road dust and grime, or other similar materials that are
on a Gondola railcar need not be removed unless radioactive
material is reasonable suspected to have contacted these
surfaces.
3.1.56 Void Filling - The process of filling void spaces within the MACRO Vault
with Macro Mix or other approved filling material (i.e. foam, Controlled
Low-Strength Material or CLSM).
3.1.57 Waste Container - Any portable device, in which waste is stored,
transported, treated, disposed of, or otherwise handled. This does not
include containers that are RCRA empty.
3.1.58 Water Cannon – A low pressure (not greater than 140 psi) water nozzle
used to wash the inside of gondola railcars and provide additional dust
suppression, when needed, as they are rolled.
3.1.59 Water Injection System – An automatic and/or manually operated
emissions and temperature control unit monitored and activated by the
Control Tower Operator.
3.2 Responsibilities
3.2.1 Operations Manager is overall responsible for the implementation of this
procedure.
3.2.2 All Personnel are responsible for the proper management of secondary
waste as outlined in this procedure.
3.2.3 BAT Inspector is responsible for performing inspections in accordance
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11e.(2), and Mixed Waste
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with the GWQDP BAT Performance Monitoring Plan (Appendix J).
3.2.4 Control Tower Operator is responsible for ensuring completion of the
shredder Daily Startup Checklist, inspecting material to be shredded,
operating the shredder and its components, visually monitoring the feeding
process, and for ensuring material is managed in accordance with the
GWQDP, as amended.
3.2.5 Disposal Supervisor is responsible for ensuring all employees involved in
the Operation of the Shredder Facility or the direct handling and disposal
of accepted waste material including Asbestos, Ion Exchange Resin
(IER), or HPTC material are trained to and working under the
requirements of this procedure and the GWQDP, as amended.
3.2.6 Environmental Engineer is responsible for identifying and documenting
waste streams that contain or have the potential to contain specific hazards
in accordance with CL-WM-PR-001, Waste Profile Acceptance Process.
3.2.7 Equipment Operators are responsible for verifying compliance to this
procedure and for labeling equipment in treatment and disposal of Mixed
Waste, LLRW, and 11e.(2) waste. In the case of waste removal the
operator is responsible for the removal and packaging of the waste that is
being removed from the cell area.
3.2.8 Facility Operators are responsible for verifying compliance with this
procedure and for labeling facilities with appropriate labels when handling
“11e.(2) Waste Management” or “PCB Waste Handling” signs prior to
managing 11e.(2) or PCB waste material.
3.2.9 An operator may perform multiple functions provided that applicable
training and qualification is completed.
3.2.10 Quality Control Supervisor is responsible for making required
notifications in accordance with the LLRW & 11e.(2) CQA/QC Manual.
3.2.11 Quality Control Technician is responsible for documenting the location of
waste material and identifying the approximate location of the waste to be
removed.
3.2.12 Radiation Safety Officer (RSO) (or designee) is responsible for
performing a review of all shipments as they arrive on site and sending
applicable managers required information specific to pertinent hazards.
3.2.13 Radiation Safety Technicians (RST) are responsible for performing the
radiological survey of gondola railcars and for performing verification
release inspections; and for documenting the RST inspections as required
by this procedure.
3.2.14 Waste Tracker is responsible for updating the Facility Tracking Record.
3.2.15 Environmental Monitoring Technician or designee is responsible for
checking and verifying air monitoring stations are operational following a
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site power outage.
3.3 Precautions and Limitations
3.3.1 A pre-shift inspection shall be performed on all equipment prior to facility
operations. Unsafe equipment shall be removed from service to prevent
use until it can be repaired or replaced.
3.3.2 Personnel may be assigned to perform more than one task outlined in this
procedure provided that adequate training and qualification has been
completed for each task.
3.3.3 This procedure does not apply to the storage and management of
potentially hazardous secondary waste.
3.3.4 The 11e.(2) labels shall be visible from both sides of a vehicle or facility
designated for 11e.(2) waste management.
3.3.5 Equipment Operators should use the designated clean-out areas when
equipment clean-out is required due to excessive build-up of waste
material prior to management of 11e.(2) waste or LLRW waste.
Note: Designated clean-out areas are established in the
LLRW waste embankment for LLRW clean-out and in the
11e.(2) embankment for 11e.(2) clean-out.
3.3.6 Tasks listed within this procedure shall be performed in conjunction with
other site procedures CL-LB-PR-003, Sample Control, and CL-MD-PR-
300, On Site Waste Management. CL-MD-PR-300, On Site Waste
Management shall also be followed for the management of potentially
hazardous secondary waste.
3.3.7 The Shredder Facility can be dangerous; for your safety, follow all signs,
postings, and procedures.
3.3.8 To avoid excessive operating costs, operation of the Shredder Facility
should only occur during off-peak energy usage billing hours prescribed
by Rocky Mountain Power (a division of PacifiCorp).
3.3.9 The Disposal Supervisor or designee shall ensure the following items are
not intermingled with material designated for the shredder:
• Batteries or pieces of batteries
• Un-punctured gas or fuel tanks
• Oil & oil filters
• Explosive materials
• Material containing Asbestos
• Material containing Beryllium
• Potentially ignitable metals
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• Metals which exceed radiological limits as defined in the RWP
• Any sealed or closed containers including closed barrels, drums,
pails and buckets (must be dry and open)
• Steel cable & wire, >8 feet
• Steel or cast-iron borings or turnings
• 1 inch cable, > 30 ft sections
• Alloy shaft, > 2 inches
• Mild steel shafting, > 2½ inches
• Plate, > 1 inch thick and more than 1 foot in any direction
• Structural shapes, > ½ inch sections
• Concrete reinforcement bar, > 2 inches in diameter
• High carbon bars, > 1 inch in diameter
• Ingots, billets, and similar types of material
• Material greater than 96 inches wide
• Any material designated 11e.(2) waste
• Any material designated hazardous waste
• PCB light ballasts, small or large capacitors or any article
containing liquid with PCB Concentrations equal to or greater than
two parts per million (2 ppm)
3.3.10 Managing HPTC Material waste streams concurrently with other
combustible waste streams on the same lift area should be minimized.
3.3.11 Potential High Propensity toward Combustion (HPTC) Materials include:
• Solid metals which may potentially ignite, spark, or smolder in air
when fines/chips are generated (more reactive HPTC Materials
include depleted uranium (DU), calcium, cobalt, magnesium,
manganese, thorium, titanium, and zirconium).
• Alkali metal (lithium, sodium, potassium, rubidium, and cesium)
compounds.
• Azide Salts
• Phosphorous compounds
• Arsenic compounds (generally managed at Mixed Waste).
• Any other material identified by the Environmental Engineer.
3.3.12 When removing waste containing known industrial or chemical safety
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hazards such as lead, asbestos, or beryllium, the Lead, Safety or designee
shall be notified so that proper control measures and/or compliance
requirements may be implemented as necessary.
3.3.13 All personnel working with asbestos shall receive asbestos awareness
training and carefully follow all relevant instructions regarding asbestos
containing material handling.
3.3.14 All personnel shall receive an asbestos physical prior to handling asbestos
containing material
3.3.15 Any damaged or open container of asbestos containing material shall be
sprayed with sufficient water or alternative cover to prevent asbestos from
becoming airborne.
3.3.16 All equipment used to spread, blend, or directly handle bulk IER shall be
visually inspected by a Health Physics Technician to ensure that it is free
of IER prior to leaving the cell.
3.3.17 All individuals working with IER shall be signed in, on, and follow the
instructions of the current resin management Radiation Work Permit
(RWP).
3.3.18 Caution shall be used around forklifts and other heavy equipment used to
transport containers/items.
3.3.19 Containers/items shall be transported by forklift or other appropriate
equipment, only if that equipment is rated to lift the weight of that
container.
3.3.20 In the event of a spill, fire, explosion, or medical emergency the
Emergency Response Plan, shall be implemented in accordance with
Reference 2.21, Emergency Response Plan Procedure.
3.4 Document Control and Records
3.4.1 Completed Daily worksheets shall be turned into the Waste Tracker daily.
3.4.2 The LLRW Cells Waste Tracker shall use the daily worksheets to
complete forms, CL-LD-PR-020-F2, Equipment and Facility Release
Form (Attachment 5.4).
3.4.3 Completed Equipment and Facility Release Forms shall be reviewed and
signed by the Disposal Supervisor.
3.4.4 Upon review from the Manager, Waste Disposal Operations, or Designee
the forms shall be transmitted to Document Control within 90 days of
completion.
3.4.5 The Waste Tracker shall use the daily worksheets to complete forms, CL-
LD-PR-020-F1, (Attachment 5.1), Placed Waste Removal Record, and
transmit to Document Control within 90 days upon completion.
3.4.6 Water injection monitoring records for PCB shredding shall be maintained
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in an Excel spreadsheet stored in a shared network drive for at least one
year. These records shall clearly designate the full capacity of the system
as well as the 75% operational value in accordance with Reference 2.33.
3.4.7 Shredded material temperature data collected during the shredding of PCB
waste shall be reviewed by the Disposal Supervisor and the Environmental
Engineer after each shift the shredder is in operation. The data shall be
maintained in an Excel spreadsheet format and stored on a shared network
drive for a period of one year after it is collected.
3.4.8 PCB analytical reports for wastewater and sludge samples collected from
the concrete pad and from the evaporation pond shall be retained for a
minimum of five years from the date of the sample collection.
3.4.8.1 The Shredder Pad Samples shall be reported to the EPA
within 90 calendar days from the date of the sample or 30
calendar days from the date the sample results are obtained,
whichever occurs first.
3.4.8.2 The evaporation pond samples shall be reported to the EPA
in an annual report prior to March 31 of the following year.
3.4.8.3 Duplicate copies of the reports shall be submitted to the
Director of the Division of Solid and Hazardous Waste.
3.4.9 If the ambient air monitoring levels exceed three-tenths of a microgram
total PCBs per cubic meter of air, the EPA shall be notified, in writing,
within twenty-four hours of the date of discovery.
3.4.10 The Daily Start-up Checklist shall be turned in to the Disposal Supervisor
for review and retention daily when the shredder is in operation.
3.4.11 Inspection and test results requiring verification and documentation by a
QC Technician shall be documented on EC-1902, Daily Construction
Report found in Appendix A of the LLRW & 11e.(2) CQA/QC Manual.
3.4.12 Documentation of the treatment performed, and the waste transfer shall be
maintained in the operating record. Documentation of the treatment
performed shall include:
• Records of inspections and evaluations that determine compliance
with the treatment standards.
• Records of treatment data or information that identifies key
operating parameters of the treatment method .
• Verification analytical data (if applicable).
• Certifications, described in Section 4.15.1.3 of this procedure, that
the waste is non-hazardous.
• Classification checks and manifest generated through EWIS
reports.
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4 REQUIREMENTS AND GUIDANCE
4.1 Safety
4.1.1 All personnel shall follow cautions and warnings posted throughout the
facility and work areas.
4.1.2 Personnel should be aware of hazards associated with the management,
disposal, and treatment of waste on the disposal cell or in a waste
management facility, including secondary waste (i.e., sharp objects,
protruding nails, and lifting).
4.1.3 PPE shall be worn by all personnel as prescribed in applicable RWPs.
4.1.4 The Control Tower Operator is the point of contact for all applicable
communication during Shredder Facility operation. All shredder Facility
personnel shall ensure appropriate communication is maintained during
operations and for emergency response.
4.1.5 Only authorized personnel shall be present within the established Danger
Zone during shredder operations. The danger zone shall be clearly
demarcated by a combination of fencing and/or postings.
4.1.6 The Out-Feed Conveyor shall have a pull cord running the full length of
the platform which shall activate the emergency stop in accordance with
applicable ANSI standards.
4.1.7 Personnel shall not enter the shredder platform located on the south side
until authorized by the Control Tower Operator. When access to the
shredder platform is required during facility operation, the Control Tower
Operator shall perform the following tasks prior to granting authorization:
4.1.7.1 Notify the Equipment Operator to stop adding material to
the In-Feed Conveyor.
4.1.7.2 Inspect the feeding system to be sure it is free of material to
be shredded.
4.1.7.3 Lower the DFR.
4.1.8 Prior to shredder start up, the Control Tower Operator shall sound an
alarm (e.g. horn, etc.) to alert all personnel of startup operations.
4.1.9 The Disposal Supervisor, or designee shall ensure all personnel evacuate
the shredder facility when lightning is within 3 miles.
4.1.10 Appropriate fire response measures shall be taken prior to shredding
operations or managing HPTC material. Fire response measures include:
4.1.10.1 Radiation Safety personnel shall be contacted regarding
potential airborne radiological hazards associated with a
fire involving shredded or HPTC material.
4.1.10.2 At least two designated Operators (preferably ground-level
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operators) shall be clean shaven and have in their presence
a respirator and other required PPE ready to don in case a
fire should occur that cannot immediately be extinguished
at the time of ignition.
NOTE: Fires may only be extinguished in the incipient
stages.
4.1.10.3 Shredded material shall be monitored for sixty minutes
after shredder operations cease. All air monitoring
equipment shall stay running until after the sixty-minute
fire monitoring period.
4.1.10.4 Prior to shredding, appropriate equipment or material
(water trucks, hydro seeder, soil, etc.) shall be placed on
standby and ready to respond in the event a fire should
occur that cannot immediately be extinguished using fire
extinguishers or the Shredder Facility’s water injection
system.
4.1.10.5 Air monitoring equipment shall be placed downwind from
the disposal area prior to beginning HPTC disposal.
4.1.10.6 HPTC material shall remain in its original container until it
can be directly placed/staged on the assigned disposal lift
area.
4.1.10.7 Enough soil shall be placed adjacent to the HPTC disposal
area to be used as a means to extinguish potential fires.
Note: ABC type fire extinguishers and water
can be ineffective at extinguishing HPTC
Material fires.
4.1.10.8 A fire watch will remain near the disposal location until the
HPTC Material is completely covered with fill material.
Note: A qualified equipment operator assigned
to the HPTC Material disposal area can
be the designated fire watch.
4.1.10.9 Personnel safety shall be the top priority when managing a
fire.
4.1.11 Qualified personnel who observe unsafe acts or conditions shall stop
activity in the affected area until such unsafe act or condition has been
properly addressed and remedied.
4.1.12 In addition to daily inspections, all cranes, cables, rigging, and hoists shall
be inspected annually in accordance with Reference 2.28.
4.1.13 Riders are not permitted on the equipment used to blend or spread resin.
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4.1.14 Personnel shall not work on the equipment used to blend IER with the
engine running. (Do not attempt to remove debris from the tines of the
tiller while the tractor engine is running).
4.1.15 All personnel shall stay clear of the tiller while in operation. The tiller may
throw loose debris.
4.1.16 Ensure equipment is shut down and appropriate means are used to prevent
unexpected movement of equipment or components prior to manually
removing soil and debris from equipment.
4.2 Compliance
4.2.1 The BAT Inspector shall perform inspections in accordance with current
BAT requirements of the GWQDP, Appendix J, as amended.
4.2.2 Sludge shall be removed from sumps using appropriate waste handling
equipment and hauled to an approved disposal embankment. If the sludge
is placed in a container, it shall be appropriately labeled and then
transported to an approved storage facility.
4.2.3 Following a power outage to the site, all waste operations shall be
suspended until air monitoring stations have been checked and verified
that they are operational. This check will be performed by a qualified
Environmental Monitoring Technician or Security Personnel under their
direction and will notify the General Manager, Operations Manager,
Radiation Safety Officer, and Security when waste operations can resume.
4.2.4 Quality Control shall coordinate with the Disposal Operation Lead or
Designee to ensure that waste placement focuses on the area of highest
priority based on Attachment 5.22 and 5.23 of the Final Cover Placement
Plan found in QC Procedure CL-QC-PR-001. (i.e., lift area planning
should focus on areas with the shortest amount of time until final cover is
required).
4.2.5 Prior to shredding, all material will be surveyed and verified suitable for
shredding by the RSO or designee in accordance with authorized
contamination limits.
4.2.6 The water injection system at the Shredder Facility, used for emissions
and temperature control, shall be maintained regularly in accordance with
manufacturer’s specifications and to ensure compliance with the Air
Quality Approval Order, as amended.
Note: Whenever material is being fed through the DFR to the
shredder mill, the water injection system shall be in
continuous operation to control operating temperatures
and to minimize dust and radiological effluent release
into the air.
4.2.7 Opacity observations shall be made in accordance with 40 CFR 60,
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Appendix A, Method 9.
4.2.8 Operators conducting opacity observations shall be certified to 40 CFR 60,
Appendix A, Method 9 every six months.
4.2.9 In accordance with the Air Quality Approval Order, the shredder shall be
operated so that visible emissions do not exceed 10% opacity. Operators
shall increase dust suppression efforts as necessary to maintain
compliance.
4.2.10 Shredding operations shall cease whenever the 5-minute average wind
velocities exceed 35 miles per hour.
Note: If shredding PCB wastes, operations shall cease
whenever the instantaneous wind gusts (reported on
one-minute intervals) are equal to or greater than 35
miles per hour.

Note: “Ceasing” operations may mean that the equipment
operator stops loading the conveyor and the tower
operator stops feeding the mill if high winds are short
term.
4.2.10.1 When both the 5-minute average and the 5-minute
maximum wind velocities are less than 35 MPH as
observed on the meteorological station, operations may
resume.
4.2.11 Shredded material shall be removed from the outfeed pad by 64 hours
following shredding operations.
4.2.12 Prior to releasing the road, the Radiation Safety Technician shall perform
a visual inspection of the Temporary Restricted Area Road and the area
just outside the south shredder area fence for debris, perform radiological
surveys as necessary and notify the RSO if debris is found.
4.2.12.1 If no debris is found and the radiological surveys indicate
acceptable conditions, the Radiation Safety Technician may
authorize the release of the Temporary Restricted Area
Road.
4.2.13 Leaking shipments and wastes containing free liquids shall be managed in
accordance with Reference 2.9.
4.2.14 A leaking rail shipment shall be handled to prevent leakage from falling
on an unimproved surface. Upon discovery of a leak, immediately contain
leakage using buckets or similar container that would capture the liquid.
As soon as possible, move the leaking rail shipment to a Railcar
Decontamination Facility until it can be managed.
4.2.15 Waste materials spilled outside of an approved management facility shall
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be managed in accordance with Reference 2.9.
4.2.16 Upon verbal approval of a qualified manager, and after completion of a
pre-job briefing the Rotary Dump Bay may also be used to manage waste
that has been delivered using other transport vehicles.
4.2.17 Radioactive waste containing PCBs for disposal at the LLRW Facility
shall be managed in accordance with Reference 2.39.
4.2.17.1 Radioactive waste containing PCBs for disposal at the
Mixed Waste Facility may be managed at the Rotary Dump
in accordance with the requirements of Section 17 in
Reference 2.38. These requirements are in CL-CH-PR-109
4.2.18 If HPTC material has a high potential for airborne contamination (as
determined by the Director of Health Physics or designee) it shall be
disposed with CLSM in accordance with the current LLRW & 11e.(2)
CQA/QC Manual.
4.2.19 HPTC Material shall be disposed in accordance with all governing policies
and procedures including the current LLRW and 11e.(2) CQA/QC manual
4.2.20 Personnel handling HPTC Material (including the designated fire watch)
shall have been trained on the requirements of this procedure.
4.2.21 All personnel handling asbestos containing material shall wear appropriate
PPE as defined in the applicable RWP. Prior to sampling, exposing, or
cleaning up asbestos containing material the applicable department
manager shall ensure all personnel working with asbestos are properly
logged into the appropriate asbestos waste management RWP. When
available, the Industrial Hygienist should be notified and given the
opportunity to reiterate asbestos waste management requirements or
address additional concerns that may be pertinent to specific waste
streams.
4.2.22 The Operations Manager (or designee) shall brief personnel designated in
the implementation of the action plan.
4.2.23 Disposal of EIR in bulk lifts shall be performed in accordance with the
LLRW & 11e.(2) CQA/QC Manual.
Note that DWMRC Director Approval is required prior for each
shipment of EIR that will be disposed of in a bulk lift.
4.2.24 The equipment operators shall place a blending layer of native clay that
meets the CL classification before the IER is hauled to the lift. This native
clay shall be tested by ASTM method D-2487 at a rate of one test every
250 cubic yards. The blending layer shall be graded to eliminate wheel
ruts and depressions greater than one inch prior to spreading resins.
4.2.25 QC Technicians shall verify the calculation for volume of IER to be
placed on the lift at maximum ratio of 1:9 (One-part IER to at least nine
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parts CL clay).
4.2.26 IER shall be spread evenly across the lift, with no areas greater than 1 inch
thick and with no areas greater than 25 square feet without some IER.
4.2.27 After blending IER, place a cover layer of clay cover at least 2 inches
thick over the lift prior to compacting the lift. Cover must be in place by
the end of the day.
4.2.28 The completed IER blending lift shall not exceed a compacted thickness
of one foot.
4.2.29 All equipment used to spread or blend resin shall be visually inspected by
a Health Physics Technician to ensure that it is free of IER prior to leaving
the cell.
4.2.30 Disposal of IER with CLSM shall be performed in accordance with the
LLRW & 11e.(2) CQA/QC Manual.
4.2.31 Ten percent of all containers (that will not be dumped) that include or are
filled with IER and will be placed for disposal in a CLSM lift area, shall
be tested for free liquids in accordance with this procedure.
4.2.32 Each IER container shall be free of headspace void. Headspace voids shall
be filled in accordance with the LLRW & 11e.(2) CQA/QC Manual.
4.2.33 IER containers shall be disposed in accordance with the LLRW & 11e.(2)
CQA/QC Manual.
4.2.34 When IER containers are approved for placement in a CLSM pour area,
they shall be clearly marked with “RESIN” on all four sides and the lid to
identify the container as IER.
4.2.35 The total IER waste volume shall be limited to no more than 25 percent of
the total volume of the CLSM pour area verified by a Quality Control
Technician.
4.2.36 IER containers shall be placed following the LLRW & 11e.(2) CQA/QC
Manual spacing requirements and not directly above an IER container in a
lower tier pour area verified by a Quality Control Technician.
4.2.37 All personnel are responsible for collecting and properly depositing wind-
blown and other debris in approved containers or authorized waste
management facilities.
4.2.38 This procedure will be performed in addition to all requirements listed in
the Site Radiological Security Plan, Reference 2.37.
4.2.39 When waste is removed from the landfill cell for return shipment to the
generator, the Environmental Engineer shall be notified.
4.2.40 When removing waste containing known industrial or chemical safety
hazards such as lead, asbestos, or beryllium, the Safety and Health
Manager or designee shall be notified so that proper control measures
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and/or compliance requirements may be implemented as necessary.
4.2.41 11e.(2) material may be unloaded but not stored at the East Truck
Unloading Facility.
4.2.42 Prior to changing waste types (LLRW to 11e.(2) or 11e.(2) to LLRW), all
equipment used to manage waste shall be cleaned of bulk material residue
to the limit of 500 grams per square foot average, with a maximum limit
of 100 lbs.
4.2.43 Liquid waste shall be stored in the Mixed Waste Storage Building, Mixed
Waste Treatment Building, Mixed Waste Operations Building, or within a
portable containment unit, that meets the definition of secondary
containment, in permitted Storage Areas.
4.2.44 All containers in storage shall be stored on pallets or runners and only in
permitted areas.
4.2.45 Storage areas shall be inspected in accordance with Reference 2.15, Daily,
Weekly, and Monthly Inspections.
4.2.46 The following wastes shall not be managed as LLRW-Destined wastes:
• Wastes which maintain a listed hazardous waste code as described
in Reference 2.4, 40 CFR 261.30 – 261.33. This includes any
waste that maintains an F-, K-, P-, or U- hazardous waste code.
• Wastes which maintain a characteristic (D-) hazardous waste code
or that maintains Underlying Hazardous Constituents (UHC) that
have not been treated to meet their respective Universal Treatment
Standards (UTS).
• Thermal desorption residues.
• Evaporation tank liquids.
• Amalgamated
mercury.
• Debris that has been treated using an immobilization technology
(e.g., macroencapsulation).
4.3 EPA Compliance (Applicable when shredding PCB contaminated waste)
4.3.1 The Shredder Facility shall be posted in accordance with 40 CFR 760 as a
PCB storage facility. This posting shall remain until the facility is
decontaminated in accordance with 40 CFR 761.79.
4.3.2 Prior to storing PCB materials, the Shredder Facility shall be configured to
manage PCB containing waste by posting a sign at the southwest access
ramp indicating “PCB Waste Management”.
4.3.3 Storage of PCB material shall be limited to 5,000 cubic yards or 7,000
tons of waste, whichever is greater.
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Note: Volumes will be determined by Q.C. survey of bulk
piles. Weights will be determined by the waste
manifest.
4.3.4 Storage of PCB material on the in-feed pad shall be limited to 90 calendar
days unless prior approval is obtained from EPA.
Note: PCB Waste for Shredding may also be stored within an
approved Class A West Embankment, above approved
liner, for a maximum of 90 days.
4.3.5 PCB Shredding operations shall cease whenever the instantaneous wind
gusts (reported on one-minute intervals) are equal to or greater than 35
miles per hour.
Note: This requirement differs from the requirement listed in
4.2.6. The General requirement measure wind speed on
a five-minute average, PCB requirement is whenever
wind gusts exceed 35 miles per hour.
4.3.6 When PCB wastes have been managed at the shredder, annually,
wastewater and sludge samples shall be collected from the Northwest
Corner Evaporation Pond regardless of whether PCB containing waste has
been shredded. These samples will be analyzed for PCBs and reported in
accordance with section 3.4.10.2 of this procedure.
4.3.7 The water injection system shall be maintained to operate within 75% of
its programmed capacity as measured by the number of functioning
nozzles and quantity of water running through the nozzles. Shredder
operations shall cease when the measured capacity falls below 75%.
4.3.8 An infrared pyrometer shall be used to monitor and record the temperature
of shredded material in two second increments as it is discharged from the
shredder mill. If the recorded temperature is equal to or greater than 350
degrees Fahrenheit, a report including the entire day’s recorded
temperatures shall be submitted to the EPA within five working days.
4.3.9 Ambient air concentrations shall be monitored for PCBs during PCB
shredding operations in accordance with Reference 2.11. Monitoring
results shall be reviewed by the Environmental Engineer.
Note: If ambient air monitoring levels exceed five-tenths of a
microgram total PCBs per cubic meter of air, the
Environmental Engineer shall inform the Manager,
Waste Disposal Operations, or designee, and shredding
operations shall cease until operational controls can be
implemented to prevent recurrence.
4.4 Shredder Operations
Note: The steps listed below shall be performed in conjunction to
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Reference 2.31, DAQ Air Quality Approval Order DSQE-
AN0107170019-11, as amended.
4.4.1 PCB Start-up Operations
Note: These steps only apply when the material to be
shredded includes PCB wastes in accordance with the
EPA Approval (Reference 2.33). Otherwise, continue to
4.5.2 below.
4.4.1.1 Isolate the Shredder sumps from the Northwest Pond by
closing the valve in Manhole 3.
4.4.1.2 Open the valves to the storage tanks.
4.4.1.3 Check the storage tanks, piping, and manhole 1 for
blockage.
4.4.1.4 Ensure proper labeling of the facility in accordance with
section 4.3.2 of this procedure.
4.4.1.5 Ensure PCB air samplers have sampling media installed
and are properly running in accordance with CL-EV-PR-
011, PCB Air Sampling Procedure.
4.4.2 General Start-up Operations:
4.4.2.1 The Control Tower Operator shall monitor and control the
Shredder Facility operation, in accordance with
manufacturer’s operating instruction and Reference 2.31.
4.4.2.2 Prior to start up operations, Shredder Facility personnel
shall perform a visual inspection of the facility perimeter
fence in the immediate vicinity of the shredder to verify the
condition of the fence and to inspect for debris.
4.4.2.3 Shredder Facility personnel shall perform start up
equipment/machine testing and shall complete Daily Start-
Up Checklist (Attachment 5.3) in accordance with
manufacturer’s operations manuals and the GWQDP, as
amended.
4.4.2.4 Shredder Facility personnel shall inspect debris on the in-
feed pad and remove non-conforming items in accordance
with section 3.3.9 of this procedure.
4.4.2.5 Shredder Facility personnel shall follow Reference 2.31 for
sequence of start-up and shut-down operations.
4.4.3 General Operation:
4.4.3.1 The Equipment Operator shall place material on the in-feed
conveyor at the direction of the Control Tower Operator.
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4.4.3.2 The Equipment Operator shall monitor material loaded
onto the conveyor to ensure non-shreddable or non-
conforming material, as defined in Section 3.3.9 is
removed.
4.4.4 End of Shift Shutdown:
4.4.4.1 The Control Tower Operator shall inform the Equipment
Operator to discontinue placing waste in the Hopper and
that the In-Feed Conveyor will shut down.
4.4.4.2 If possible, the Equipment Operator shall ensure all
material has traveled to the feed chute, that the conveyor is
free of any material, and shall inform the Control Tower
Operator that the In-Feed Conveyor is ready for shut down.
4.4.4.3 The Control Tower Operator shall follow the
manufacturer’s shut down directions.
4.4.4.4 If possible, the Control Tower Operator shall ensure the
Out-Feed conveyor is free of all managed material prior to
shut down.
4.4.4.5 The Control Tower Operator or designee shall perform an
end of shift visual inspection of the Shredder Facility and
perimeter fence in accordance with the GWQDP.
4.4.5 Post PCB Operational Requirements (Daily when PCB Operations occur)
4.4.5.1 The Disposal Supervisor, or designee, shall ensure the
following:
• All reports, including water injection monitoring
and temperature data monitoring are downloaded in
accordance with manufacturer’s instructions and
formatted to an excel spreadsheet.
• The reports shall be evaluated and managed in
accordance with sections 3.4 and 4.3 of this
procedure.
• The reports shall be available on the shared network
drive and forwarded to the Environmental Engineer
daily after PCB shredding operations.
4.4.6 Prior to changing the Shredder Facility from PCB Management to General
Waste Management, perform the following:
4.4.6.1 Collect samples if accumulated volumes of water and
sludge in the sumps allow for sampling. Consult with the
Environmental Engineer for detailed sampling
requirements.
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Note: Prior to removing water from the
collection tanks, the water will be
sampled and analyzed for PCB content.
Note: If PCB concentrations exceed five-tenths
of a microgram per cubic liter, the water
shall remain in the storage tank until an
action plan can be approved by the
Environmental Engineer.
4.4.6.2 Ensure catch basins, sumps, manholes, and the shredder
pad surfaces are cleaned of bulk PCB material to a limit of
500 grams per square foot average, with a maximum limit
of 100 lbs.
4.4.6.3 Remove or cover the “PCB Waste Management” sign at the
southwest corner of the facility.
4.5 Disposal of HPTC Material
4.5.1 Upon notification of HPTC arrival in accordance with Reference 2.25,
Waste Profile Acceptance Process, the Disposal Supervisor or designee,
shall determine when and where the material will be placed. If the material
cannot be immediately placed in an approved embankment, the shipment
shall be labeled “HOLD, Contact Disposal Supervisor prior to
disposal” and taken to an approved storage area until final placement can
occur.
4.5.2 Equipment operators shall prepare fire response material in accordance
with section 4.1.10 of this procedure.
4.5.3 HPTC containers shall be staged on the lift chosen for final disposal.
4.5.4 If the container lid cannot be removed without disrupting the container
contents, the container lid latching devices shall be removed by hand as an
effort to prevent abrupt handling characteristic of opening some containers
by way of mechanical assistance.
Note: For example: B-25 lids with metal clips can be carefully
removed using an excavator, however; drum rings and
B-25’s with bolted lids will require the use of hand tools
to carefully remove the lid.
4.5.5 Container contents will be carefully removed in such a way that the
material can be properly dispersed on the lift with minimal effort and
contact with construction equipment. Equipment operators shall avoid
forceful handling of containers as an unloading method consequently
minimizing friction and potential for sparking or combustion.
4.5.6 After the HPTC material has been properly dispersed it shall immediately
be covered with an approved fill material prior to the end of the shift.
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4.5.7 The risk for combustion is significantly reduced when all HPTC material
is covered. The fire watch may leave the area immediately following the
completion of the fill material.
4.6 Asbestos Disposal
4.6.1 Asbestos containing material must be properly identified and labeled by
the receiving department before such waste shall be accepted for disposal.
4.6.2 Asbestos containing material which is stockpiled or placed in temporary
storage shall either remain in the original packaging or shall be covered
with non-asbestos containing material. Alternative Daily Cover shall not
be used to cover exposed asbestos containing (torn bags, or exposed bulk
material) material that has been stockpiled or placed in temporary storage.
Note: Alternative Daily Cover can be used to cover bagged
asbestos containing waste in stockpiles or directly on a
lift. Bagged asbestos containing waste covered with
Alternative Daily Cover shall not be compacted until it
has been completely covered with soil or other non-
asbestos containing material.
4.6.3 Damaged containers or other inadequately containerized asbestos
containing material shall be identified by the receiving department and the
Disposal Supervisor shall be notified in writing of the damage or
inadequate containment.
4.6.4 If the receiving department accepts damaged or inadequate containment,
authorized Facility Operator(s) shall be instructed to spray the asbestos
containing material either with water or alternative cover in quantities to
sufficiently wet the material and eliminate the possibility of generating
airborne asbestos. If possible, employees shall contact the Industrial
Hygienist prior to working to determine proper PPE and sampling
requirements.
• Spill clean-up activities for asbestos containing material shall be
conducted using wet methods. If wet methods or HEPA vacuuming
are deemed impractical then clean-up may be conducted with dry
sweep methods.
• All surfaces shall be maintained as free as practical of asbestos
containing waste and debris and any spilled material shall be
cleaned up as soon as possible.
• Any exposed asbestos containing material shall be covered with
alternative cover and/or water during handling, transport, and cell
placement to eliminate the possibility of airborne contamination.
4.6.5 When an open or damaged bag or other containment device is discovered
inside an intermodal container, the intermodal container shall be sprayed
with water or alternative cover and if possible, the Industrial Hygienist
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shall be contacted to determine proper sampling and PPE requirements as
required in the RWP.
4.6.6 Asbestos containing material must be transported to and placed in a cell
for disposal and covered with either six inches of non-asbestos containing
material or with an adequate layer of alternative cover before the end of
the work shift.
• Alternate cover shall not be used as fill material.
• Alternate cover may be used to prevent airborne contamination of
asbestos containing material that has been placed in an active lift
area of a disposal cell provided that daily inspections verify that
the asbestos containing material is adequately covered.
• Alternate cover shall only be used as a treatment to prevent
airborne contamination of asbestos and shall not be a permanent
disposal option.
4.7 Ion Exchange Resin (IER) Blending and Disposal
4.7.1 Disposal with CLSM
4.7.1.1 Ten percent of all IER containers that will be disposed in a
CLSM lift area shall be tested for free liquids prior to
placement in a CLSM pour. This is measured per CLSM
lift: for example, if 10 containers of IER are to be placed in
a particular CLSM pour, at least 1 of these containers shall
have a free liquid inspection.
4.7.1.2 This inspection is performed by operations personnel.
Operations will provide container information to Quality
Control. The container information will be documented on
the CLSM lift approval.
4.7.1.3 Headspace voids shall be filled in accordance with section
4.7.3 of this procedure.
4.7.1.4 A Quality Control Technician shall inspect and verify that
the IER containers are placed and disposed in accordance
with the LLRW & 11e.(2) CQA/QC Manual.
4.7.2 Liquid Verification
Caution: The removal of a large volume of liquid may affect waste
classification. Liquid verification shall not be allowed to result in waste
that is greater than Class A
Expected SNM concentrations in resin and liquid shall be calculated be
Radiation Safety to ensure compliance with section 13 of LLRW
Radioactive Material License No. UT2300249
4.7.2.1 IER Liquid verification shall be performed in locations
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approved for bulk waste management (Disposal cells,
Rotary Dump, etc).
4.7.2.2 The IER container shall be placed on an elevated surface
high enough to allow collection of potential liquids. The
container used to collect potential liquids should be large
enough to hold at least one percent of the total volume of
the container being tested.
4.7.2.3 Puncture the IER container as close to the bottom as
possible and allow any liquids present to drain into the
collection container.
4.7.2.4 If liquids drain from the container, manage the liquids in
accordance with Reference 2.10, CL-CH-PR-252,
Incoming Shipment Inspecting and Sampling.
4.7.3 Headspace Void Remediation
4.7.3.1 Upon discovery, headspace voids shall be filled in
accordance with the LLRW & 11e.(2) CQA/QC Manual, –
CLSM POURS WITH RESIN-FILLED CONTAINERS.
4.7.4 Resin Blending
4.7.4.1 The equipment operator shall prepare a blending layer of
native clay material, graded to eliminate wheel ruts or
depressions greater than 1” in depth.
4.7.4.2 The equipment operator or facility operator shall contact
QC to verify the blending layer preparation.
4.7.4.3 QC verification will be performed by visual inspection.
4.7.4.4 The equipment operator shall unload IER from its container
and spread material evenly across the blending layer of
native clay (no thicker than 1” and no areas greater than 25
square feet without resin). When the container is empty, the
equipment operator shall inspect the container to ensure
that it is empty.
4.7.4.5 The equipment operator or facility operator shall contact
QC to verify even distribution of IER material.
4.7.4.6 QC verification will be performed by visual inspection.
4.7.4.7 The equipment operator shall blend IER using a tiller or
similar equipment.
4.7.4.8 The equipment operator or facility operator shall contact
QC to visually verify that the IER is homogenously
blended. If the QC inspection results in finding areas of
IER that are not homogenously blended, the area shall be
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reworked with the tiller until it passes the QC visual
inspection.
4.7.4.9 The equipment operator shall cover blended material with
at least two inches of clay by the end of the workday and
prior to compaction of the lift.
4.8 EnergySolutions Generated Waste at LLRW
4.8.1.1 Disposal
4.8.1.1.1 Accumulated lab samples shall be disposed in the
appropriate embankment according to its waste
type.
4.8.2 Secondary Waste Management
4.8.2.1 Compliance
4.8.2.1.1 Potentially hazardous materials including oil,
solvents, and liquid paint shall not be placed in a
secondary waste container.
4.8.2.1.2 Personnel shall avoid depositing liquid-filled
containers in secondary waste receptacles.
4.8.2.2 Labeling
4.8.2.2.1 Containers used to store secondary waste inside the
LLRW restricted area shall be labeled with “LLRW
SECONDARY WASTE”.
4.8.2.3 Storage
4.8.2.3.1 Containers used to store secondary waste shall be
designed to minimize the potential for the spread of
DAW and accumulation of storm water. Lids on
secondary waste containers shall be closed when
not in use.
4.8.2.3.2 As an effort to minimize clutter and control the
spread of trash, secondary waste containers should
be staged at locations where secondary waste
generation is typical. Container management areas,
access control points, maintenance shops, and the
batch plant are examples of typical secondary waste
generation areas.
4.8.2.3.3 Secondary waste containers should be emptied
before they become overfull.
4.8.2.4 Disposal
4.8.2.4.1 Secondary waste containers shall only be emptied in
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an approved LLRW waste management area.
4.8.2.4.2 Secondary waste generated inside the LLRW
restricted area shall be disposed in an approved
Class A West disposal embankment in accordance
with the current LLRW & 11e.(2) CQA/QC
Manual.
Note: Typical secondary waste
generating operations will
generate LLRW type waste and
shall not be disposed in the 11e.(2)
embankment. If secondary waste is
generated solely from 11e.(2)
operations, it can be disposed in
the 11e.(2) disposal embankment.
4.8.3 PPE Accumulation at Access Control Points
4.8.3.1 Compliance
4.8.3.1.1 Potentially hazardous materials including oil,
solvents, and liquid paint shall not be placed in PPE
collection bins.
4.8.3.1.2 Personnel shall avoid depositing liquid-filled
containers in PPE collection bins.
4.8.3.2 Labeling
4.8.3.2.1 Containers used to store accumulated PPE inside
the LLRW restricted area shall be labeled with
“LLRW SECONDARY WASTE”.
4.8.3.3 Storage
4.8.3.3.1 As an effort to minimize clutter and control the
spread of trash, PPE accumulation containers
should be staged near access control points.
4.8.3.3.2 Containers used to store accumulated PPE shall be
designed to minimize the potential for the spread of
DAW and accumulation of storm water.
Note: Smaller PPE accumulation containers
placed inside buildings and at access control
points can be open at the top.
4.8.3.3.3 All PPE accumulation containers should be emptied
before they become overfull.
4.8.3.4 Disposal
4.8.3.4.1 PPE accumulation containers shall only be emptied
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in another PPE accumulation container with
sufficient capacity or in an approved LLRW waste
management area.
4.8.3.4.2 Secondary waste generated inside the LLRW
restricted area shall be disposed in an approved
Class A West disposal embankment in accordance
with the current LLRW & 11e.(2) CQA/QC Manual
with specific consideration to the disposal of DAW.
4.9 Removal of Placed Waste
4.9.1 Removed waste shall be tracked in accordance with Reference 2.9,
Container Management and Storage.
4.9.2 Review the Facility Tracking Record (Reference 2.26), or the lift cover
sheet to determine when the waste was transferred to the cell and if
Asbestos waste was disposed of in the disposal lift where the waste was
placed.
4.9.3 The review will be documented on attachment 5.1, Placed Waste Removal
Record. If it is determined that asbestos waste is present in the lift(s) to be
removed, inform the Compliance and Permitting group so that required
regulatory notifications can be made.
4.9.4 For placed waste containing asbestos refer to, Reference 2.2, 40 CFR
61.154(j) for waste removal. Prior to excavating, the Environmental
Engineer or Manager, Compliance & Permitting shall notify the EPA at
least 45 days in advance.
4.9.5 Asbestos waste being removed from the Mixed Waste or Class A West
Embankments shall be recorded on Attachment 5.1, Placed Waste
Removal Record.
Note: See Attachment 5.2, Placed Waste Removal Record
Completion Instructions, for form completion
instructions.
4.9.6 The Quality Control Technician shall determine the appropriate disposal
lift to determine the approximate location of the waste to be removed.
4.9.7 The Quality Control Technician shall locate the waste within the cell and
mark the area with engineering stakes, paint, or any other means
necessary.
4.9.8 The equipment operator shall excavate the waste, using any means
necessary (i.e. loaders, shovels, excavators, or bulldozers).
Note: If the affected waste has been covered with additional
waste, that additional waste shall be stockpiled within
the landfill cell, removed, and replaced in a separate
section of the cell, or containerized and placed in
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permitted storage.
4.9.9 The equipment operator shall containerize the waste in the landfill.
4.9.10 Radiation Safety Technician shall survey the container to determine
whether radiological precautions should be taken with the containerized
waste. Dose rates for each container shall be annotated on the label.
4.9.11 If the waste is to be returned to the generator, label the containers and ship
according to the guidelines in Reference 2.22, Shipment of Radioactive
Material. Document the waste as a rejected load in the Rejected Waste
Record.
4.9.12 If the waste is to be managed in permitted storage, label each container
with the date removed from the cell, generator number, waste stream
number, tracking number, hazardous waste codes, the words "Hazardous
Waste," and any applicable hold labels, etc. The tracking number may
consist of the Shipment identification number, treatment run number, or
cell removal number.
Note: For tracking purposes, a unique number may be assigned to
each container of removed waste, if unidentifiable.
4.9.13 The equipment operator shall transport the containers to permitted storage
in accordance with Reference 2.9 Container Management and Storage.
4.9.14 The completed Placed Waste Removal Record (Attachment 5.1) shall be
forwarded to the Disposal Supervisor for review of the form for accuracy,
completion, and legibility. The form shall then be forwarded to the Cells,
Waste Tracker to update the EWIS database.
4.10 Equipment and Facility Labeling Requirements
4.10.1 Prior to changing waste types in a bulk waste handling facility, the facility
foreman shall ensure the area is free of waste material in accordance with
4.2.43 of this procedure.
4.10.2 Prior to changing waste types in bulk waste handling equipment, the
equipment operator shall ensure truck beds, tires, tracks, buckets, rippers,
(or any other typical soil waste or debris collection occurs) is free of waste
material in accordance with 4.2.42 of this procedure.
4.10.3 Upon verification of step 4.2.42 or 4.2.43, the Equipment Operator or
facility foreman shall indicate a passing inspection on their daily
worksheets.
Note: Truck Drivers use the CL-LD-PR-020 F3, Daily Truck
Load sheet (Attachment 5.5), Facility Operators use
CL-LD-PR-020-F2, Equipment and Facility Release
Form, (Attachment 5.4).
4.10.4 When the equipment or facility is verified and documented to be free of
LLRW waste material for the purpose of managing 11e.(2) waste material,
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the facility or equipment shall be labeled with a sign indicating approval to
manage 11e.(2) waste.
Note: The labels shall be visible from both sides of a vehicle or
facility designated for 11e.(2) waste management.
4.11 LLRW-Destined Waste
4.11.1 General
4.11.1.1 LLRW-Destined waste shall have an “X” before the
Tracking number.
4.11.1.2 LLRW-Destined waste can be disposed in LLRW or Mixed
Waste. Some wastes require sort and segregation, where
part of the waste will be disposed of in Mixed Waste, and
part will be disposed of in LLRW.
4.11.1.3 Containers/items shall not be moved to LLRW disposal
unless they have been approved as described in Section and
added to the Approved for disposal report.
4.11.1.4 Non-Hazardous Verification.
4.11.1.4.1 Waste that is treated using stabilization or
solidification is approved for disposal by the
Environmental Engineer, or designee, using a
certification that all treatment standards have been
met via email, letter, or verbal (with follow-up
documentation).
4.11.1.4.2 Waste that is treated by a technology is approved
for disposal by the Operations Manager certifying
that the waste has been treated using the specified
technology.
4.11.1.4.3 LLRW not requiring treatment is approved for
disposal by the Environmental Engineer, or
designee, using a certification that a review of the
waste information and/or analytical data has
confirmed that the waste is not a RCRA Hazardous
waste.
4.11.1.4.4 It is recommended that labels be placed on opposing
sides such that they are visible during inspection.
4.11.2 Liquid Verification of Dewatered Resin Liners
4.11.2.1 The area of the facility where management of LLRW-
Destine wastes is to be performed will be prepared as
follows to avoid contamination of the waste with Mixed
Waste contaminants.
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4.11.2.2 All containment and equipment that contact the waste shall
be decontaminated by triple-rising with water or another
suitable solvent prior to managing the waste.
4.11.2.2.1 Documentation of the triple rinse, if needed, shall
be recorded on CL-CH-PR-250- F2, Triple Rinse
Verification Form.
Note: The Triple Rinse Verification Document will
be clearly marked with the words “triple rinse” for
all tanks and equipment that have been triple rinsed.
4.11.2.2.2 Containments and equipment that have not been
exposed to characteristic wastes since the last
decontamination event will not require additional
decontamination.
4.11.2.2.3 Containments and equipment that have been tripled
rinsed and not exposed to listed wastes shall be
labeled “X waste” or with and “X Tracking #”
Tracking label.
4.11.2.2.4 The surface where LLRW-Destined waste will be
managed shall be maintained free from hazardous
contamination.
4.11.2.2.5 Empty containers shall be inspected and certified to
meet the visibly clean criterion. This shall be
documented on treatment and solidification run
sheets.
4.11.2.3 Mixed wastes may be stored within the building in which
LLRW-Destined wastes are being managed; however, the
LLRW-Destined waste management area shall be clearly
designated and segregated from other areas.
4.11.2.4 The transport will be staged for offload within the Mixed
Waste Facility (High Rad Storage Area).
4.11.2.5 Inspect rigging and hoist equipment.
4.11.2.6 Inspect liner containment and punch.
4.11.2.7 Remove cask lid using safety platforms.
4.11.2.8 Rigging shall be completed using long handle tools, or
smart hook.
4.11.2.9 RST conducts survey (dose rates)
4.11.2.10 Attach lifting cables to lifting equipment.
4.11.2.11 Safety Stop.
4.11.2.12 Clear area of personnel to low dose shielded area.
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4.11.2.13 Lift liner from cask and place into shielded area.
4.11.2.14 Lower liner into sampling cask on secondary containment
for sampling.
4.11.2.15 If liquids are observed, collect, and manage in accordance
with section 4.15.4 Waste Management of this procedure.
4.11.2.16 If no liquids are observed, lift liner from shielded area and
place into transportation vehicle. Prior to lifting ensure all
personnel have moved behind low dose shielded area.
4.11.2.17 RST will escort shipment to LLRW disposal area for final
disposition.
4.11.2.18 Cask reassembly and inspection
4.11.2.18.1 Inspect cask prior to lid placement.
4.11.2.18.2 Remove all markings and labeling.
4.11.2.18.3 Inspect cask for transport release from Restricted
Area.
4.11.2.18.4 Complete cask return checklist.
4.11.2.18.5 Release cast transport from Restricted Area.

4.11.3 Treatment Facilities Preparation
4.11.3.1 The area of the facility where management of LLRW-
Destine wastes is to be performed will be prepared as
follows to avoid contamination of the waste with Mixed
Waste contaminants.
4.11.3.1.1 All tanks and equipment that contact the waste shall
be decontaminated by triple-rising with water or
another suitable solvent prior to managing the
waste.
4.11.3.1.1.1 Documentation of the triple rinse
shall be recorded on CL-CH-PR-
250- F2, Triple Rinse Verification
Form.
Note: The Triple Rinse
Verification Document will be
clearly marked with the words
“triple rinse” for all tanks and
equipment that have been triple
rinsed.
4.11.3.1.1.2 Tanks and equipment that have only
been exposed to characteristic wastes
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since the last decontamination event
will not require additional
decontamination.
4.11.3.1.1.3 Tanks and equipment that have been
tripled rinsed and not exposed to
listed wastes shall be labeled “X
waste” or with and “X Tracking #”
Tracking label.

4.11.3.1.2 The surface where LLRW-Destined waste will be
managed shall be maintained free from hazardous
contamination.
4.11.3.1.2.1 Floors will be swept, washed, and
inspected. This activity shall be
documented on the Treatment or
Solidification Records (Reference
2.16).
4.11.3.1.2.2 Alternatively, a tarp or other non-
contaminated coverings may be
placed onto the floor where the
LLRW-Destined wastes are
managed.
Note: Tarps and other non-
contaminated coverings may be
reused. Tarps which are damaged
or stained shall not be reused.
Final disposal of the tarps shall be
in the Mixed Waste Landfill Cell.
4.11.3.1.3 Empty containers shall be inspected and certified to
meet the visibly clean criterion. This shall be
documented on treatment and solidification run
sheets.
4.11.3.2 Mixed wastes may be stored within the building in which
LLRW-Destined wastes are being managed; however, the
LLRW-Destined waste management area shall be clearly
designated and segregated from other areas.
4.11.4 Waste Management
4.11.4.1 LLRW-Destined wastes requiring treatment shall be
managed in accordance with the following procedures:
• Stabilization/Solidification of LLRW-Destined
wastes shall be performed in accordance with
Reference 2.16, CL-MT-PR-007, Solidification and
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Stabilization with Reagents.
• Sorting and Segregation and downloading shall be
performed in accordance with Reference 2.17, CL-
MT-PR-009, Waste Sorting, Sizing and
Repackaging.
4.11.5 Non-Hazardous Verification
4.11.5.1 Treatment of characteristic wastes and soils shall be
verified through sampling and analysis of treatment
residues.
4.11.5.1.1 Sampling frequencies shall be as described in
Reference 2.16, CL-MT-PR-007, Solidification and
Stabilization with Reagents.
4.11.5.1.2 The analytical results shall be reviewed and
certified by the Environmental Engineer that the
treatment standards have been met for all applicable
characteristics and UHCs.
4.11.5.1.3 The certification shall be signed by the Manager,
Operations or designee based on approval from the
Environmental Engineer and include the certifying
language of Reference 2.5, 40 CFR 268.7(b)(4)(v).
4.11.5.1.4 This review and certification shall be completed
before transfer to the LLRW disposal facilities.
4.11.5.2 LLRW liquids shall be verified non-hazardous by the
Environmental Engineer through waste acceptance
sampling and review of analytical results. Post-
solidification sampling will not be required.
4.11.5.3 Verification of debris treatment by an extraction or
destruction treatment technology shall be certified by the
Manager, Waste Disposal Operations, or designee.
4.11.5.4 There certification shall be signed and include the
certifying language of Reference 2.6, 40 CFR
268.7(d)(3)(iii).
4.11.5.5 LLRW solids shall be verified non-hazardous by the
Environmental Engineer through waste acceptance
sampling and review of analytical results, and/or a review
of generator certification in the profile and the shipping
paperwork.
4.11.6 Storage
4.11.6.1 LLRW-Destined wastes shall only be stored in tanks or
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containers which have been prepared in accordance with
Section 4.15.2.
4.11.6.2 LLRW-Destined wastes shall be clearly labeled as defined.
4.11.6.3 LLRW-Destined wastes shall be segregated from other
mixed wastes at all times, either by aisle spacing, labeling,
or physical barrier.
4.11.7 Waste Transfer
4.11.7.1 The following waste may be approved for transfer by the
Environmental Engineer and Manager, Waste Disposal
Operations; from the Mixed Waste facility to the LLRW
facility after appropriate action is completed in accordance
with this procedure.
4.11.7.1.1 Formerly characteristic wastes that meet the
required treatment standards for all characteristic
codes and applicable UHC’s.
4.11.7.1.2 Solidified LLRW liquids that never retained listed
or characteristic hazardous waste codes.
4.11.7.1.3 Debris that has been treated to the alternate debris
treatment standards using an extraction or
destruction treatment technology (e.g. spray
washing).
4.11.7.1.4 Soil that has been treated to the alternative soil
standards, provided that:
4.11.7.1.4.1 The soil was not originally
contaminated with a listed waste:
and
4.11.7.1.4.2 The treated waste does not exhibit
any hazardous characteristics as
described in Reference 2.3 40 CFR
261.20 – 261.24.
4.11.7.1.5 Empty containers that meet the definition of visibly
clean.
4.11.7.1.6 Solid LLRW that never retained listed or
characteristic hazardous waste codes.
4.11.7.2 LLRW-Destined wastes shall be classified and manifested
prior to transfer in accordance with the Radioactive
Material License Conditions 15.C and 15.d.

5 ATTACHMENTS AND FORMS
Management and Disposal of LLRW,
11e.(2), and Mixed Waste
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5.1 CL-LD-PR-020 F1, Placed Waste Removal Record
5.2 Placed Waste Removal Record Completion Instructions
5.3 Example of Shredder Daily Start-Up Checklist
5.4 CL-LD-PR-020 F2, Equipment and Facility Release Form
5.5 CL-LD-PR-020 F3, Daily Truck Load Worksheet

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Attachment 5.1 – CL-LD-PR-020 F1, Placed Waste Removal Record –Example

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Attachment 5.2 Placed Waste Removal Record Completion Instructions

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Attachment 5.3 - Shredder Daily Start-Up Checklist

Inspection Item Item
Checked
Comments
LE
V
E
L
S

&

L
E
A
K
S
HPU1 hydraulic fluid level 
HPU2 hydraulic fluid level 
ORU fluid level 
Liquid Rheostat water level 
Cooling System: Glycol level 
Motor: check oil level 
Main water tank level 
Leaking hoses 
Leaking fluids 
GE
N
E
R
A
L

Reset conveyor scale 
Mill safety switch 
Close water drain valves 
Air compressor oil level 
Air compressor belts 
UMO belts/guards 
Inspect shielding
Double Feed Rollers out of
Maintenance Lock 
Rotor chain and lock removed 
Cooling Fans for loose bolts/guards 
Motor room gates locked shut 
Service platform unlocked 
Fire extinguishers 
Previous shift maintenance report
reviewed 
Plant walk-around completed 
CO
M
P
L
I
A
N
C
E
Leak detection port 
Concrete surfaces 
Collection sump alarm 
Water containment for leaks 
Water collection for leaks 
Sump Level 
Drainage pipes for build-up 
Notes:

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Attachment 5.4 - Example of CL-LD-PR-020-F2, Equipment and Facility Release Form

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Attachment 5.5 - CL-LD-PR-020 F3, Daily Truck Load Sheet

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DOCUMENT SUMMARY FORM