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Home My WebLink AboutDRC-2025-001523 299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 (801) 649-2000 ▪ Fax: (801) 880-2879 ▪ www.energysolutions.com May 8, 2025 CD-2025-099 Mr. Doug Hansen Director Utah Division of Waste Management and Radiation Control 195 North 1950 West Salt Lake City, Utah 84114-4880 Subject: Radioactive Material License UT 2300249 Follow Up to Notification of Discrepancy with 9125-13-0007 with 3rd Party Data Dear Mr. Hansen, In letters dated April 30, 2025 (CD-2025-084) and May 6, 2025 (CD-2025-096), EnergySolutions notified the Director of the Utah Division of Waste Management and Radiation Control (DWMRC) of a discrepancy with Shipment 9125-13-0007 (Bates Number M16438) (GSAP 1307008022). The May 6, 2025 letter noted a sample had been sent for third party analysis to confirm findings, but those results had not been received yet. The letter also stated that EnergySolutions would provide those results when received. Those results have been received and are provided herein. Results from GEL Work Order #721949 (attached) were received on May 7, 2024. This alpha spectrometry analysis detected Americium-241 at 168,000 pCi/g, confirming the waste is greater than Class A. Additionally, results for Plutonium-238 (155 pCi/g) and Plutonium 239/240 (133 pCi/g) were below the SNM limits of RML UT2300249 and therefore do not require Nuclear Regulatory Commission (NRC) notification. As the investigation continues, and corrective actions are committed by the generator, this information will be made available to the Division. Should there be any questions regarding this follow-up notification, contact Tom Brown or myself at 801-649-2043. Sincerely, Steve D. Gurr Environmental Engineer and Manager Digitally signed by Steve D. Gurr Date: 2025.05.08 11:50:28 -06'00' May 06, 2025 Mr. Jared Stark EnergySolutions, LLC. 299 South Main Street, Suite 1700 Salt Lake City, Utah 84111 Re: EUI-09 Mixed Waste Rad Purchase Order:729954 - 25-EUI-09 Work Order: 721949 Chain of Custody:69536 SDG: EUI-13088 Dear Mr. Stark: GEL Laboratories, LLC (GEL) appreciates the opportunity to provide the enclosed analytical results for the sample(s) we received on April 30, 2025. Our policy is to provide high quality, personalized analytical services to enable you to meet your analytical needs on time every time. Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards, with any exceptions noted. The results reported relate only to the items tested and to the sample as received by the laboratory. These results may not be reproduced except as full reports without approval by the laboratory. Copies of GEL’s accreditations and certifications can be found on our website at www.gel.com. This original data report has been prepared and reviewed in accordance with GEL’s standard operating procedures. We trust that you will find everything in order and to your satisfaction. If you have any questions, please do not hesitate to call me at (843)556-8171 extension 1605. Sincerely, PM_SIGN_HERE Zachary Worsham Project Manager Enclosures Mary Stover for Table of Contents Case Narrative..................................1 Chain of Custody and Supporting Documentation.4 Laboratory Certifications......................8 Radiological Analysis.........................10 Case Narrative.............................11 Sample Data Summary........................16 Quality Control Data.......................18 Case Narrative Page 1 of 20 SDG: EUI-13088 Case Narrative for EnergySolutions (729954) SDG: EUI-13088 Work Order: 721949 May 06, 2025 Laboratory Identification: GEL Laboratories, LLC. PO 729954 - 25-EUI-09 Summary Sample Receipt The sample arrived at GEL Laboratories, LLC., Charleston, South Carolina on April 30, 2025 for analysis. The samples associated with Chain of Custody 69536 were received at a temperature of 2 degrees C. The samples were analyzed for Radiochemistry parameters. Sample Identification The laboratory received the following sample: Laboratory Identification Sample Description 721949001 9125-13-0007(Post Shred) M16438 Items of Note There are no items to note. Page 2 of 20 SDG: EUI-13088 Case Narrative Sample analyses were conducted using methodology as outlined in GEL Laboratories, LLC (GEL) Standard Operating Procedures. Any technical or administrative problems during analysis, data review, and reduction are contained in the analytical case narratives in the enclosed data package. PM_SIGN_HERE Zachary Worsham Project Manager Mary Stover for Page 3 of 20 SDG: EUI-13088 Chain of Custody and Supporting Documentation Page 4 of 20 SDG: EUI-13088 Page 5 of 20 SDG: EUI-13088 Page 6 of 20 SDG: EUI-13088 Page 7 of 20 SDG: EUI-13088 Laboratory Certifications Page 8 of 20 SDG: EUI-13088 State Certification Alabama Alaska Alaska Drinking Water Arkansas CLIA California Colorado Connecticut DoD ELAP/ ISO17025 A2LA Florida NELAP Foreign Soils Permit Georgia Georgia SDWA Hawaii Idaho Illinois NELAP Indiana Kansas NELAP Kentucky SDWA Kentucky Wastewater Louisiana Drinking Water Louisiana NELAP Maine Maryland Massachusetts Massachusetts PFAS Approv Michigan Mississippi Nebraska Nevada New Hampshire NELAP New Jersey NELAP New Mexico New York NELAP North Carolina North Carolina SDWA North Dakota Oklahoma Pennsylvania NELAP Puerto Rico S. Carolina Radiochem Sanitation Districts of L South Carolina Chemistry Tennessee Texas NELAP Utah NELAP Vermont Virginia NELAP Washington 42200 17-018 SC00012 88-00651 42D0904046 2940 SC00012 PH-0169 2567.01 E87156 525-24-281-19660 SC00012 967 SC00012 SC00012 200029 C-SC-01 E-10332 KY90129 KY90129 LA024 03046 (AI33904) 2023019 270 M-SC012 Letter 9976 SC00012 NE-OS-26-13 NV-C24-00175 205424 SC002 SC00012 11501 233 45709 R-158 2023-152 68-00485 SC00012 10120002 9255651 10120001 TN 02934 T104704235 SC000122024-45 VT87156 460202 C780 List of current GEL Certifications as of 06 May 2025 Page 9 of 20 SDG: EUI-13088 Radiological Analysis Page 10 of 20 SDG: EUI-13088 Case Narrative Page 11 of 20 SDG: EUI-13088 Radiochemistry Technical Case Narrative EnergySolutions SDG #: EUI-13088 Work Order #: 721949 Product: Alphaspec Am241, Solid High Rad Analytical Method: DOE EML HASL-300, Am-05-RC Modified Analytical Procedure: GL-RAD-A-011 REV# 29 Analytical Batch: 2790263 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 21 Preparation Batch: 2790226 The following samples were analyzed using the above methods and analytical procedure(s). GEL Sample ID# Client Sample Identification 721949001 9125-13-0007(Post Shred) M16438 1206090047 Method Blank (MB) 1206090048 721949001(9125-13-0007(Post Shred) M16438) Sample Duplicate (DUP) 1206090049 Laboratory Control Sample (LCS) The samples in this SDG were analyzed on an "as received" basis. Data Summary: All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions. Quality Control (QC) Information RDL Met The blank (See Below) did not meet the detection limit due to keeping the blank volume consistent with the other sample aliquots. Sample Analyte Value 1206090047 (MB)Americium-241 Result 0.000103 < MDA 0.0011 > RDL 0.0001 uCi/g Technical Information Recounts Sample 1206090047 (MB) was recounted due to a peak shift. The recount is reported. Product: Alphaspec Pu, Solid High Rad Analytical Method: DOE EML HASL-300, Pu-11-RC Modified Page 12 of 20 SDG: EUI-13088 Analytical Procedure: GL-RAD-A-011 REV# 29 Analytical Batch: 2790264 Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 21 Preparation Batch: 2790226 The following samples were analyzed using the above methods and analytical procedure(s). GEL Sample ID# Client Sample Identification 721949001 9125-13-0007(Post Shred) M16438 1206090050 Method Blank (MB) 1206090051 721949001(9125-13-0007(Post Shred) M16438) Sample Duplicate (DUP) 1206090052 Laboratory Control Sample (LCS) The samples in this SDG were analyzed on an "as received" basis. Data Summary: All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable, with the following exceptions. Quality Control (QC) Information Duplication Criteria between QC Sample and Duplicate Sample The Sample and the Duplicate, (See Below), did not meet the relative percent difference requirement; however, they do meet the relative error ratio requirement with the value listed below. Sample Analyte Value 1206090051 (9125-13-0007(Post Shred) M16438DUP)Plutonium-238 RPD 41.7* (0.00%-20.00%) RER 2.9 (0-3) Miscellaneous Information Additional Comments The tracer peak centroid for samples 1206090050 (MB) and 1206090052 (LCS) are greater than 50 keV from the expected library energy value for the tracer; however, the tracer yield requirement was met and the tracer peaks are within the tracer region of interest. Preparation Method: Client Requested Procedure Preparation Procedure: GL-RAD-A-015 REV# 21 Preparation Batch: 2790226 The following samples were analyzed using the above methods and analytical procedure(s). GEL Sample ID# Client Sample Identification 721949001 9125-13-0007(Post Shred) M16438 The samples in this SDG were analyzed on an "as received" basis. Page 13 of 20 SDG: EUI-13088 Data Summary: There are no exceptions, anomalies or deviations from the specified methods. All sample data provided in this report met the acceptance criteria specified in the analytical methods and procedures for initial calibration, continuing calibration, instrument controls and process controls where applicable. Certification Statement Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless otherwise noted in the analytical case narrative. Page 14 of 20 SDG: EUI-13088 GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com CARE013 EnergySolutions (729954) Client SDG: EUI-13088 GEL Work Order: 721949 GEL requires all analytical data to be verified by a qualified data reviewer. In addition, all CLP-like deliverables receive a third level review of the fractional data package. The following data validator verified the information presented in this data report: The Qualifiers in this report are defined as follows: * A quality control analyte recovery is outside of specified acceptance criteria ** Analyte is a Tracer compound U Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD. for Qualifier Definition Report Signature:Name: Date:Title:07 MAY 2025 Theresa Austin Analyst III - Data Validator Review/Validation Page 15 of 20 SDG: EUI-13088 Sample Data Summary Page 16 of 20 SDG: EUI-13088 Certificate of Analysis GEL LABORATORIES LLC 2040 Savage Road Charleston SC 29407 - (843) 556-8171 - www.gel.com Report Date: May 7, 2025 Parameter Result UnitsQualifier Analyst Date TimeDF Batch MethodRLMDCPF High Rad Testing 2790263 2790264 1536 0905 uCi/g uCi/g uCi/g 05/06/25 05/06/25 JXC5 JXC5 1.00E-04 1.00E-04 1.00E-04 Mr. Jared StarkContact: EnergySolutions, LLC.Company : 299 South Main Street, Suite 1700 Salt Lake City, Utah 84111 Address : EUI-09 Mixed Waste RadProject: 721949001 Solid 29-APR-25 08:09 30-APR-25 9125-13-0007(Post Shred) M16438 CARE EUI-09Project: CARE013Client ID: Client +/-0.00918 +/-1.21E-05 +/-1.12E-05 Sample ID: Receive Date: Client Sample ID: Surrogate/Tracer Recovery Matrix: Collect Date: Collector: Recovery%Test Acceptable Limits 0.000723 1.15E-06 1.33E-06 1 2 Americium-241 Plutonium-238 Plutonium-239/240 Alphaspec Am241, Solid High Rad "As Received" Alphaspec Pu, Solid High Rad "As Received" 0.168 0.000155 0.000133 Americium-243 Tracer Plutonium-242 Tracer Alphaspec Am241, Solid High Rad "As Received" Alphaspec Pu, Solid High Rad "As Received" 94.3 118 (15%-125%) (15%-125%) The following Prep Methods were performed: Client Requested Procedure Dissolution Soil Prep GL-RAD-A-015 04/30/25 27902261627WGR Method Description Analyst Date Time Prep Batch The following Analytical Methods were performed: 1 2 Method Description DOE EML HASL-300, Am-05-RC Modified DOE EML HASL-300, Pu-11-RC Modified Analyst Comments Uncertainty NominalResult Notes: Counting Uncertainty is calculated at the 95% confidence level (1.96-sigma). Lc/LC: Critical Level PF: Prep Factor RL: Reporting Limit SQL: Sample Quantitation Limit Column headers are defined as follows: DF: Dilution Factor DL: Detection Limit MDA: Minimum Detectable Activity MDC: Minimum Detectable Concentration Page 17 of 20 SDG: EUI-13088 Quality Control Data Page 18 of 20 SDG: EUI-13088 QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com High Rad Testing 2790263 2790264 Batch Batch Americium-241 Americium-241 Americium-241 Plutonium-238 Plutonium-239/240 Plutonium-238 Plutonium-239/240 Plutonium-238 Plutonium-239/240 Parmname Mr. Jared StarkContact: EnergySolutions, LLC. 299 South Main Street, Suite 1700 Salt Lake City, Utah May 7, 2025Report Date: Units uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g uCi/g Anlst Date Time JXC5 JXC5 05/06/25 15:36 05/06/25 15:36 05/07/25 09:04 05/06/25 09:05 05/06/25 09:05 05/06/25 09:05 QC 0.179 0.0450 0.000103 0.000237 0.000131 -3.54E-07 3.75E-05 -1.08E-07 -7.23E-08 NOM Sample 0.168 0.000155 0.000133 Range (0%-20%) (75%-125%) (0%-20%) (0%-20%) (75%-125%) Qual U U U U QC1206090048 721949001 QC1206090049 QC1206090047 QC1206090051 721949001 QC1206090052 QC1206090050 The Qualifiers in this report are defined as follows: 6.3 41.7 1.58 REC% 93.2 92.2 0.0483 4.07E-05 DUP LCS MB DUP LCS MB 721949Workorder: U J Analyte was analyzed for, but not detected above the MDL, MDA, MDC or LOD. Value is estimated +/-0.00918 +/-1.21E-05 +/-1.12E-05 +/-0.00871 +/-0.00519 +/-0.000572 +/-1.63E-05 +/-1.21E-05 +/-1.01E-06 +/-8.53E-06 +/-6.07E-07 +/-6.03E-07 * RPD% Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Uncertainty Notes: Counting Uncertainty is calculated at the 95% confidence level (1.96-sigma). Page 1 of 2 Page 19 of 20 SDG: EUI-13088 QC Summary GEL LABORATORIES LLC 2040 Savage Road Charleston, SC 29407 - (843) 556-8171 - www.gel.com Parmname Page 2 of 2 Units Anlst Date TimeQCNOMSampleRangeQualREC% 721949Workorder: X H < > UI BD h R ^ N/A ND M NJ FA UJ Q K UL L N1 Y ** M x Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Analytical holding time was exceeded Result is less than value reported Result is greater than value reported Gamma Spectroscopy--Uncertain identification Results are either below the MDC or tracer recovery is low Preparation or preservation holding time was exceeded Sample results are rejected RPD of sample and duplicate evaluated using +/-RL. Concentrations are <5X the RL. Qualifier Not Applicable for Radiochemistry. RPD or %Recovery limits do not apply. Analyte concentration is not detected above the detection limit M if above MDC and less than LLD Consult Case Narrative, Data Summary package, or Project Manager concerning this qualifier Failed analysis. Gamma Spectroscopy--Uncertain identification One or more quality control criteria have not been met. Refer to the applicable narrative or DER. Analyte present. Reported value may be biased high. Actual value is expected to be lower. Not considered detected. The associated number is the reported concentration, which may be inaccurate due to a low bias. Analyte present. Reported value may be biased low. Actual value is expected to be higher. See case narrative Other specific qualifiers were required to properly define the results. Consult case narrative. Analyte is a Tracer compound REMP Result > MDC/CL and < RDL Subaliquot was taken. See Case Narrative for details. N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc. by a factor of 4 or more or %RPD not applicable. ^ The Relative Percent Difference (RPD) obtained from the sample duplicate (DUP) is evaluated against the acceptance criteria when the sample is greater than five times (5X) the contract required detection limit (RL). In cases where either the sample or duplicate value is less than 5X the RL, a control limit of +/- the RL is used to evaluate the DUP result. * Indicates that a Quality Control parameter was not within specifications. For PS, PSD, and SDILT results, the values listed are the measured amounts, not final concentrations. Where the analytical method has been performed under NELAP certification, the analysis has met all of the requirements of the NELAC standard unless qualified on the QC Summary. RPD% Page 20 of 20 SDG: EUI-13088