HomeMy WebLinkAboutDRC-2025-002022 CLIVE SITE
LETTER OF TRANSMITTAL DATE: 6/24/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-038
Description of Documents Transmitted Qty
See attached updates for Laboratory. CL-LB-PR-041 Rev 2 Analytical Data Review 1
------------------------------------------------------------------------------------------------------------ Please replace your current procedure revisions with the documents within this Transmittal. You are not required to sign any documents to verify receipt of this distribution. However, you should make every effort to ensure that your copy of the License is current. FROM: EnergySolutions
Document Control Clive Facility
Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-LB-PR-041
Analytical Data Review
Revision 2
Authored By:
Jared Stark, Lead, Laboratory Date
Reviewed By:
Jerrod Andresen, Gamma Spec Specialist Date
Approved By
Steve D. Gurr, Environmental Engineer &
Manager
Date
Approved By
Thomas A. Brown, Radiation Safety Officer Date
Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation
CL-LB-PR-041
Analytical Data Review Revision 2
NON-Proprietary Page 2 of 17
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 ...................................................................................................................... 4
3.2 Responsibilities .............................................................................................................. 5
3.3 Precautions and Limitations ........................................................................................ 6
3.3.1 Chemical Analysis ...................................................................................................... 6
3.3.2 Radiological Analysis ................................................................................................. 8
3.4 Records......................................................................................................................... 10
4 REQUIREMENTS AND GUIDANCE ................................................................................ 10
4.1 Chemical Analysis Review ........................................................................................... 10
4.2 Radiological Analysis Review ...................................................................................... 11
4.3 Radiological Quality Control Check Analysis .............................................................. 12
4.4 Analytical Results Reporting ........................................................................................ 13
5 ATTACHMENTS AND FORMS......................................................................................... 13
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 3 of 17
1 PURPOSE AND SCOPE
1.1 Purpose
To provide a process for reviewing and evaluating chemical and radiological
analytical data for compliance with disposal requirements.
1.2 Scope
This procedure applies to the analytical results for LLRW, MW, MW Post-
Treatment and 11e.(2) deferred chemical samples as well as incoming waste
shipments to the EnergySolutions, Clive Facility that require radiological
sampling in accordance to the Radioactive Material License(s).
2 REFERENCES
2.1 ES-AD-PR-008, Condition Reports
2.2 ES-QA-PR-003, Supplier Evaluation
2.3 EnergySolutions, Clive Facility, Ground Water Quality Discharge Permit, License
#UGW450005
2.4 EnergySolutions, Clive Facility, Utah Division of Radiation Control 11e.(2)
Radioactive Material License - UT 2300478
2.5 EnergySolutions, Clive Facility, Utah Division of Radiation Control Radioactive
Material License - UT 2300249
2.6 EnergySolutions, Clive Facility, Utah State-issued Part B Permit Attachment II-1,
Waste Analysis Plan
2.7 U.S. EPA, 40 CFR Part 261, Identification and Listing of Hazardous Waste
2.8 U.S. EPA, 40 CFR Part 268, Land Disposal Restrictions
2.9 U.S. EPA, National Functional Guidelines - USEPA, OSWER 9240.1-45; EPA
540-R-04-004
2.10 U.S. EPA, SW-846 Methods
2.11 CL-WM-PR-001, Waste Profile and Acceptance Process
2.12 CL-LB-PR-003, Sample Control
2.13 CL-LB-PR-100, Gamma Spectroscopy
2.14 CL-TN-PR-030, Qualification Procedure
2.15 CL-LB-PR-004, Incoming Chemical Screening Parameters
2.16 CL-LB-PR-005, Laboratory Instrument Calibration and Maintenance
2.17 CL-LB-PR-007, Calibration and Operation of the Canberra Alpha Analyst
2.18 CL-LB-PR-133, Liquid Scintillation
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 4 of 17
2.19 American Nuclear Society, verification and validation of radiological data for use
in waste management and environmental remediation - ANSI/ANS-41.5
3 GENERAL
3.1 Definitions
3.1.1 11e.(2) Deferred Chemical – Analytical requirements for 11e.(2) regulated
waste, as specified in the 11e.(2) Radioactive Material License, Condition
10.2(a).
3.1.2 Analytical Report – A report issued by a Third-Party Laboratory including
method results, sample custody information and summary quality control
data.
3.1.3 BI Publisher – a computer based reporting program that takes shipment
information from the EWIS database and compiles it into practical reports
for shipment management purposes.
3.1.4 Constituent of Concern – A chemical constituent detected in a sample of
waste that is equal or greater than an Action Level.
3.1.5 Deferred Chemical (DC) Analyses – Analyses for chemical constituents
from an incoming shipment sample, performed by a Third Party
Laboratory.
3.1.6 Electronic Waste Information System (EWIS) -- The EWIS is a centralized
relational database management systems application that provides
information on EnergySolutions’ customers, their waste streams, and the
waste material sent to EnergySolutions for management and disposal. The
information contained in the database is obtained from required hard copy
quality assurance documentation, electronic imports, and real-time entry.
3.1.7 EWIS Shipment-Sample-Lab Log – a function within EWIS used to track
samples that are collected for on-site and/or off-site radiological analysis
and etc.
3.1.8 EWIS Shipment-Sample-Lab (Cntr Rad) Log – a function within EWIS
used to evaluate radiological data reported versus shipment manifest
and/or generator profile information.
3.1.9 Laboratory Data Qualifier (Flags) – Code applied to the data by the
contract analytical laboratory to indicate a verifiable or potential data
deficiency or bias.
3.1.10 Licensed Material – radioactive material that is received, possessed, used,
generated, transferred, or disposed at EnergySolutions, Clive Facility.
3.1.11 Minimum Detectable Concentration – the minimum radionuclide
concentration an instrument can detect with 95% confidence of the true
value.
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 5 of 17
3.1.12 Mixed Waste HSWA – Incoming shipment off-site analytical requirements
specified in reference 2.6. Additional analytical requirements as specified
by the Environmental Engineer on the Mixed Waste Profile Evaluation
form described in reference 2.11 and hazardous waste codes supplied by
the generator.
3.1.13 Mixed Waste Post-Treatment – Analytical requirements for treated waste
to meet Treatment Standards, including applicable Universal Treatment
Standards (UTS) described in reference 2.8.
3.1.14 Offsite Radiological Analysis – Analysis performed by a Third Party
Laboratory on incoming waste to determine compliance with Radioactive
Material License limits and Waste Profile Record for nuclides that cannot
be detected Onsite.
3.1.15 Onsite Radiological Analysis – Analysis performed on incoming waste to
determine compliance with reference 2.5, Radioactive Materials License
limits and Waste Profile Record for detectable nuclides.
3.1.16 Standard Deviation – a measure of the dispersion of the frequency
distribution of net counts around the mean.
3.1.17 SW-846 (Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods) –A set of analytical methods with corresponding quality control
requirements specified by the Environmental Protection Agency for the
purpose of testing hazardous wastes for chemical composition. See
Reference 2.10
3.1.18 Third Party Laboratory – Utah Certified laboratory contracted to perform
Chemical Analyses or Radiological Analyses.
3.1.19 Treatment Standards – The concentration limits that hazardous wastes
must meet for land disposal, as listed in reference 2.8. Underlying
Hazardous Constituents (UHCs) described in Reference 2.8 are also
applicable if the waste contains characteristic hazardous waste codes.
3.2 Responsibilities
3.2.1 Lead, Laboratory, or designee, oversees the daily operations of the onsite
Chemistry and Radiological Laboratories. This includes the overall
responsibility for this procedure, for the initial review of data provided by
Third-Party Laboratories and for all documentation related to analytical
reporting and review.
3.2.2 Environmental Engineer, or designee, documents analysis requirements in
accordance with Reference 2.11, and evaluates analytical data for
compliance with the requirements, licenses and permits, and Reference 2.7
and 2.8.
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 6 of 17
3.2.3 Gamma Spectroscopy Specialist, or designee, oversees the routine
operation of the Gamma Spectrometers, as well as preventative
maintenance and troubleshooting of the system(s). Supervises the Gamma
Spectroscopy Technician in gamma spectroscopy analysis performance.
Performs onsite and offsite radiological analytical data review. Provide
technical knowledge and assistance for ongoing site operations.
3.2.4 Gamma Spectroscopy Technician performs the routine operations of the
Gamma Spectrometers, to include daily quality control checks and
assigned maintenance tasks. Perform external sample container surveys
on samples prior to the gamma spectroscopy analysis.
3.3 Precautions and Limitations
3.3.1 Chemical Analysis
3.3.1.1 The Lead, Laboratory shall only submit samples to
laboratories certified by the State of Utah to perform
requested methods, and approved as vendors in accordance
with reference 2.2.
3.3.1.2 Third-Party Laboratories shall only sub-contract sample
analysis to laboratories certified by the State of Utah to
perform the requested method.
3.3.1.3 The Lead, Laboratory and Environmental Engineer may
utilize preliminary Analytical Reports to evaluate the
analytical data prior to final reporting.
3.3.1.4 The Lead, Laboratory and Environmental Engineer may
use total concentration results (in mg/kg) divided by a
factor of fifteen to determine compliance with Action
Levels or Treatment Standards listed as TCLP
concentrations (in mg/L).
3.3.1.5 Any analytical data associated with waste intended for
direct disposal into the cell, the applicable compound
Method Detection Limits (MDLs) shall not exceed the
Action Levels and/or Universal Treatment Standards,
where applicable.
3.3.1.6 Disposal of any waste which exceeds the characteristic
levels found in 40 CFR 261.24, Table 1 (LLRW), 40 CFR
268.40 and if necessary, the Universal Treatment Standards
(UTS) limits found in 40 CFR 268.48 (MW), or GWQDP,
Part I action levels (11e.(2)) is expressly prohibited without
prior written approval from the Manager, Compliance and
Permitting or Designee.
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 7 of 17
3.3.1.7 If analytical results indicate the waste may be different than
profiled, the shipment will be placed on hold then the waste
and sampling process used shall be evaluated prior to
implementing a Condition Report in accordance with
reference 2.1. The following items should be included in
the evaluation:
• Quality Control failures of analytical results
• Quality Control qualifiers that may influence
analytical results
• Potential interferences in the instrument used to
analyze the sample
• Lab contaminants
• Sample cross contamination during the sampling
process
• Sample matrix
• Sample preparation outside parameters (i.e.
temperature or hold time)
Note: This evaluation shall be done using
the guidelines listed in reference 2.19,
specifically section 5 of that document.
3.3.1.8 If Lead, Laboratory and/or Environmental Engineer and /or
RSO determine there is an issue with the sampling or
analytical process, the follow-up actions may be taken prior
to implementing a Condition Report in accordance with
reference 2.1:
• Discount analytical results and properly document
the justification
• Re-sample the waste
• Re-analyze the sample with same analytical method
• Re-analyze the sample with an equivalent method
• Include blank sample(s) to determine cross
contamination
• Other actions deemed necessary by the Lead,
Laboratory and/or Environmental Engineer and/or
RSO
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 8 of 17
3.3.1.9 Upon completion of evaluation and follow-up actions, the
Lead, Laboratory and/or Environmental Engineer and/or
RSO shall determine if a Condition Report in accordance
with reference 2.1 is necessary and shall process the
information accordingly.
3.3.1.10 If the determination is that a Condition Report is necessary,
the shipment will remain on hold and samples will be taken
from the next shipment of that generator and sent for
analysis. All subsequent shipments shall be placed on hold
until samples yield acceptable analytical results.
3.3.2 Radiological Analysis
3.3.2.1 Samples for radiological analysis shall be analyzed in
accordance with reference 2.13.
3.3.2.2 Inspect sample containers prior to handling or transferring
to the gamma spectrometer for analysis to ensure container
integrity and that there is no material on the outside of the
container.
Note: Any container damage or material on the
outside of the container may contaminate
the detector. Return such sample
containers to Sample Control for proper
preparation.
3.3.2.3 Personnel performing this procedure shall be qualified on
the tasks or activities contained in this procedure according
to reference 2.14, Qualification Procedure. Those
individuals not qualified according to reference 2.14 may
perform tasks within this procedure provided they are
operating under the direction of a qualified individual.
3.3.2.4 As directed by the Lead, Laboratory, qualitative and/or
quantitative analysis of unknown samples may be
performed as determined by the sample matrix and sample
container geometry.
3.3.2.4.1 Unknown samples of comparative matrix and in
sample containers matching the calibration source
can be analyzed quantitatively and/or qualitatively
using gamma spectroscopy.
3.3.2.4.2 Unknown samples of non-comparative matrix
and/or in containers not matching the geometry of
the calibration source can only be analyzed
qualitatively using gamma spectroscopy.
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 9 of 17
Note: Mathematical modeling of sample
geometries may be used as
calibration source analogs.
3.3.2.5 As directed by the Lead, Laboratory, gamma spectroscopy
analysis may only be performed for radioisotopes that emit
gamma rays of sufficient energy and abundance to provide
an adequate gamma ray spectrum. For all other
radioisotopes, other method(s) of analysis is necessary to
obtain accurate results. However, given the nature of
radioactive decay, daughter progeny may be used to
quantify concentrations of non-gamma emitting
radioisotopes providing the presence of secular
equilibrium.
3.3.2.6 Samples shall be managed in accordance with reference
2.12.
3.3.2.7 The Lead, Laboratory should use the BI Publisher report
“90-Day or 45-Day 11e. (2) Compliance” on a weekly basis
to monitor sample management, analysis and reporting
scheduling to ensure compliance to the requirements for
incoming waste shipment analysis.
Note: Radiological Analysis results for LLRW
and MW incoming waste samples must be
received within 90 days of the shipments’
arrival, unless additional time is
approved by the Director of the Utah
Division of Radiation Control. When 90Sr
analysis is included, the required time
period is 120 days.
Note: Radiological Analysis results for 11e. (2)
incoming waste samples must be received
within 45 days of shipment arrival, unless
additional time is approved by the
Director of the Utah Division of Radiation
Control.
3.3.2.8 When an incoming shipping manifest indicates
radionuclide concentrations >75% of Class A limits or
shipments requested by the RSO, radiological analysis
shall be reviewed prior to approval for management; unless
prior authorization for management is received by the
RSO.
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 10 of 17
3.3.2.9 If analytical results indicate non-conforming waste,
immediate notification will be made to the RSO. Then
steps listed in 3.3.1.7 through 3.3.1.10 in this procedure
shall be followed.
3.3.2.10 As a quality control check, at least five percent of the
incoming waste samples that are analyzed on-site for
gamma spectroscopy shall be sent to a Third Party
Laboratory for the same analysis.
3.4 Records
3.4.1 All analytical data review documentation shall be transmitted to
Document Control for storage and maintenance upon completion.
4 REQUIREMENTS AND GUIDANCE
4.1 Chemical Analysis Review
4.1.1 Conduct an analytical data review for all sample analytical data received.
This review is documented on form CL-LB-PR-041-F1, Analytical
Results Data Review (Example, attachment 5.1)
Note: Detailed information concerning items of review, if
applicable, will be noted in the ‘Comment:’ section of
the CL-LB-PR-041-F1 form.
4.1.2 For analytical reports of waste intended for disposal in the LLRW (Class
A) cell, include a comment of the review of the sample(s) results to ensure
that results shall not exceed the characteristic levels found in reference
2.7.
4.1.3 For analytical reports of waste intended for disposal in the Mixed Waste
cell, to include Mixed Waste Post-Treatment, include a comment of the
review of the sample(s) results to the applicable Treatment Standard limits
and if applicable, the Universal Treatment Standards (UTS) and/or
Underlying Hazardous Constituent limits found in reference 2.8.
4.1.4 For analytical reports for 11e.(2) waste, include a comment of the review
of the sample(s) results to the applicable Action Level limits found in
Table 6 of reference 2.3. Further, all reported contaminants will be
reviewed to the characteristic concentrations found in reference 2.7.
4.1.4.1 If the constituent of concern(s) are not listed in Table 6 of
reference 2.3 and is greater than 50% of the concentration
described in Table 1 of reference 2.7, the constituent shall
be added to Table 6 of reference 2.3.
4.1.4.2 All reported contaminants will be reviewed to the
applicable Treatment Standard limits and UTS limits found
in reference 2.8. Any contaminant at concentrations greater
than 50% of these limits shall be noted.
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 11 of 17
4.1.5 The Analytical Results Data Review form (attachment 5.1) shall be
reviewed, comments included, where applicable, and approved by both the
Lead, Laboratory and the Environmental Engineer.
4.1.6 The comments and applicable approval periods (e.g. date range and/or
shipment specific range) shall be communicated to all applicable
managers involved with the handling of the waste material.
4.1.7 Finalization of the approval process shall be noted within EWIS Database
for reference.
4.2 Radiological Analysis Review
4.2.1 Initiate a CL-LB-PR-041-F2, Radiological Review Form.
4.2.2 Review onsite gamma spectroscopy analysis reports to ensure that the
following information was included:
• Sample and detector information
• Interference corrected report section
• Unidentified peak report section
• MDA analysis section
4.2.3 In instances where the sample being reviewed is also sent out for Quality
Control check per section 3.3.2.10, review the associated offsite
radiological analysis reports for completeness and validity, to include the
following items:
• Check for a complete case narrative of the sample
• Check the Quality Control data to verify data validity
• Review the Chain of Custody (EC-0101) for completeness
4.2.4 Review all radiological analysis reports for the following items and record
on the Radiological Review form (note what types of analysis were
performed):
• Is the data generated complete?
• Is each radionuclide MDC less than 50% of applicable action
levels?
• Are there any radionuclide(s) or radionuclide concentration(s)
other than background?
• Is each radionuclide concentration less than applicable action
levels?
• For incoming waste only: Do the identified radionuclides reflect
the generator’s manifest and profile?
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 12 of 17
4.2.5 The approved radiological analysis report is used to enter the identified
radionuclide concentrations into the EWIS Shipment-Sample-Lab (Cntr
Rad) Log function in the EWIS database, where the comparison of
identified radionuclides versus generator’s manifest and/or profile can be
evaluated.
Note: If the identified radionuclides do not reflect the
generator’s manifest or profile, notify the Lead,
Laboratory.
4.2.6 If there are any discrepancies during the review, either correct or provide
explanation in the comment section.
4.2.7 Forward the completed Radiological Review Form with the radiological
analysis report(s) attached to the Lead, Laboratory, or designee, for review
and approval.
4.3 Radiological Quality Control Check Analysis
4.3.1 This section is only applicable to incoming waste samples chosen for the
Quality Control verification – offsite analysis according to section
3.3.2.10.
4.3.2 Compare the onsite gamma spectroscopy results to the offsite gamma
spectroscopy results using the gamma spectroscopy analysis reports.
4.3.3 Qualify the data using the following criteria:
4.3.3.1 If the nuclide comparison differs greater than 20% or
identified nuclides do not agree, and the concentration is
greater than 5 X MDC, and relative error ratio is greater
than 3, further investigation is required.
NOTE: Relative error ratio is defined as the absolute value of
the difference in value for sample vs. duplicate, divided
by the square root of the sum of the squares for the
respective total propagated uncertainties, and is
expressed as:
S-D ≤3
√(TPUS)2+(TPUD)2
WHERE:
S= Sample result
D= Duplicate result
TPUS= Total propagated uncertainty of the sample
TPUD=Total propagated uncertainty of the duplicate
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 13 of 17
4.3.3.2 Either re-run the analysis or qualify the data as estimated
high or low (J + or J -).
4.3.4 Forward the completed Radiological Review Form with the radiological
analysis report(s) attached to the Lead, Laboratory, or designee, for review
and approval.
4.4 Analytical Results Reporting
4.4.1 Once the radiological analytical data has been reviewed and approved, the
“Data Received” date in the EWIS-Shipment-Sample-Lab screen in the
EWIS database shall be updated with the approval date noted.
5 ATTACHMENTS AND FORMS
5.1 CL-LB-PR-041-F1, Analytical Results Data Review- EXAMPLE
5.2 CL-LB-PR-041-F2, Radiological Review Form - EXAMPLE
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 14 of 17
Attachment 5.1 - CL-LB-PR-041-F1, Analytical Results Data Review, Example Page 1
CL-LB-PR-041-F1
Revision 0
ANALYTICAL RESULTS DATA REVIEW
Generator:
Waste stream:
Tracking No:
Sample Type/Disposal:
Chain of Custody:
Workorder No:
Analytical Laboratory:
Dates:
Shipment Shipment Samples Results
Arrival Sampled Sent Obtained
Lead, Laboratory Comments:
Lead, Laboratory Date
Additional Waste Codes:
Where required, the generator verified this information. Based on these results and statements from the generator:
Y N NA This waste meets applicable treatment standards (MW).
Y N NA This waste meets characteristic limits for hazardous waste (LLRW).
Y N NA EPA Hazardous Waste Codes were added to the waste.
Generator Contact Date Confirmed Confirmed By
Environmental Engineer Comments:
Environmental Engineer Date
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 15 of 17
Attachment 5.1 - CL-LB-PR-040-F1, Analytical Data Quality Review, Example Page 2
CL-LB-PR-041-F1
Revision 0
ANALYTICAL RESULTS DATA REVIEW
QC Summary Review:
Data Quality Reviewer: Date Data Quality Reviewer: Date
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 16 of 17
Attachment 5.2 - CL-LB-PR-040-F2, Radiological Review Form, Example
CL-LB-PR-041-F2
Revision 0
RADIOLOGICAL REVIEW FORM
Sample ID: COC number: Date Sampled:
Description: APEX Sample Number:
SECTION I: EXTERNAL SAMPLE CONTAINER SURVEY
Surface Gamma Radiation Level:
Removable Contamination:
Container is visually clean: Yes / No (Check One)
External Sample Container Survey by:
SECTION II: RADIOLOGICAL ANALYSIS REVIEW
Onsite Offsite Condition
Yes / No / N/A Yes / No / N/A Is the data generated complete?
Yes / No / N/A Yes / No / N/A Is each radionuclide MDC less than 50% of applicable action
levels?
Yes / No / N/A Yes / No / N/A Are there any radionuclide(s) or radionuclide concentration(s) other
than background?
Yes / No / N/A Yes / No / N/A Is each radionuclide concentration less than applicable action
levels?
Yes / No / N/A Yes / No / N/A For incoming waste only: Does the identified radionuclides reflect
the generator’s manifest and/or profile?
SECTION III: COMPARISON OF ONSITE AND OFFSITE ANALYSES
Onsite / Offsite Condition
Yes / No / N/A Does Onsite analysis require comparison to Offsite analysis for quality control?
Yes / No / N/A Does Onsite and Offsite analysis meet quality control parameters?
Comments:
Radiological Review Packet Generated by:
Onsite/Offsite Analysis Report(s) Reviewed & Approved by:
Page 1 of 1
CL-LB-PR-041
Analytical Data Review Revision 2
Non-Proprietary Page 17 of 17