DRC-2025-002434

Inspection Module:.
Inspection Location:
Inspection Items:
lnspection Dates:
Inspectors:
Personnel Contacted:
INSPNCTTON REPORT
10 - Containerized Waste Facility (CWF)
EnergySolutions - Clive Facility, Utah
Waste Acceptance Criteria, Void Space Criteria, ALARA Review, Waste
Manifests
Opening meeting: June 10,2025
Closeout: July 10,2025
Bryan Woolf, Utah Division of Waste Management and Radiation Control
(DWMRC)
Inva Braha, Utah Division of Waste Management and Radiation Control
(DWMRC)
Kevin Carney, Utah Division of Waste Management and Radiation Control
(DWMRC)
Tom Brown; Radiation Safety Officer (RSO)
Dale Thorne; Assistant Radiation Safety Officer (ARSO)
Curtis Kirk; Quality Assurance Manager
Governing Documents:o Radioactive Materials License (RML) UT2300249o Bulk Waste Disposal and Treatment Facilities Waste Acceptance Criteriao CL-CW-PR-102 - Containerized Waste Void Remediationo CL-CW-PR-200 - Package Liquid/Void Verificatione CL-CW-PR-202 - Containerized Waste Certificationo CL-CW-PR-2O3 - Containerized Waste Facility Waste Acceptance Criteriao CL-RS-PG-001 - ALARA Programo CL-SR-PR-041 - Incoming Radioactive Waste Shipment Acceptanceo CL-RS-PG-0O2 - Radiation Protection Program
Onenins Meeting
EnergySolutions:
Tom Brown; Radiation Safety Officer (RSO)
Dale Thorne; Assistant Radiation Safety Officer (ARSO)
Curtis Kirk; Quality Assurance Manager
Utah DWMRC:
Bryan Woolf (Health Physics Inspector)
Inva Braha (Health Physics Inspector)
Kevin Carney (Health Physics Inspector)
During the opening meeting on June 10,2025, the Inspectors discussed the items and documentation to be
reviewed during the inspection. The Inspectors indicated that they would observe Containerized Waste
handling, interview personnel who work at the Containerized Waste Facility, and evaluate compliance
with all applicable license conditions.
Insoection Summary
The Division of Waste Management and Radiation Control (Division) inspection consisted of
interviewing EnergySolutions (ES) staff, observing waste handling at the Containerized Waste Facility
(CWF), and reviewing documentation/ procedures that related to CWF. Division inspector (Inspectors)
observations and interviews with ES staff provided clarity on ES' compliance with all applicable Rules
and Regulation and ES UT Radioactive Material License UT2300249 (License).
Item 1. Waste Acceptance
Observations: The Division Inspectors reviewed ES' waste acceptance process. The Inspectors were
able to veriff:
o Certified Waste Generator certification is required for CWF disposal.o Review of procedure CL-CW-PR-202 provides some clarity that certain wastes are not accepted
at CWF.
o Procedure CL-CW-PR-}0Z outlines ES' process of reviewing generators prior to accepting
containerized wastes for disposal at the CWF. Each generator is required to attest that they will
not be shipping:
o Sealed sources,
o Waste capable of detonation or explosion,
o Waste containing or capable of generating toxic gases, vapors, or fumes
o Pyrophoric waste
o Untreated biological, pathogenic, or infectious material
o Waste with greater that l% liquid
o Waste packaged in cardboard or with fiberboard
o Neutron sources
o Waste with greater than lSoh void spaceo Because the waste received at the CWF typically has an external radiation measurement over
80mR/hr, there is an ALARA concern for doing any sampling. This has the potential to be an
issue in ensuring the generator is not sending any of the waste listed above.
Deficiencies: None.
Item 2. Waste Handling and Radiation Safety
Observations: The Division lnspectors observed waste handling and interviewed staffduring their
assigned work tasks. The Inspectors were able to verifu:
o ALARA reviews were performed and appeared to be completed thoroughly.o The use of proper packaging was being utilized by the generators during the time of inspection.o The Licensee properly posted the CWF as a "High Radiation Area" with the appropriate signage.o Inspectors reviewed random CWF shipments and found that appropriate void space documents
were maintained.
Deficiencies: None
Closeout Meeting
EnergySolutionsz
Tom Brown; Radiation Safety Officer (RSO)
Dale Thorne; Assistant Radiation Safety Offrcer (ARSO)
Curtis Kirk; Quality Assurance Manager
Utah DWMRC:
Bryan Woolf (Health Physics Inspector)
Kevin Carney (Health Physics Inspector)
Inva Braha (Health Physics Inspector)
Findines:
The Division lnspectors observed and interviewed CWF staff during operation. ES' Containerized Waste
Facility appears to be in compliance with all applicable Radioactive Material License Conditions.
Recommendations
There appears to be room for waste received at CWF to include unacceptable waste sent by the
generators. There is a lot of trust that is relied on by ES for when a generator says they have not included
any prohibited waste. Due to ALARA concerns with the waste shipments typically having higher dose
rates than other forms of waste, it is difficult for ES to fact check their generators.
Recommendation for Next Year's Inspection
The Inspectors should dive deeper into ES' Waste Generator Certification process to gain some further
comfort that the waste being received at the CWF is as manifested by the generators.
Prepared By:
Reviewed By:Lawrence Kellum
(PrintName)
DIVISION OF RADIATION CONTROL
INSPECTION MODULE 10 - Rev.6
CONTAINERIZED WASTE FACILITY
EnergySolutions, LLC
License: UT2300249
299 South Main Street, Suite 1700
Salt Lake City, Utah 84111
Inspectors: Bryan Woolf. Inva Braha. Kevin Carney
Inspection Dates: Start: June_lQ 2025 End:Julv 10.2025
NOTE - THE FOLLOWING PROCDURES ARE TO BE USED WHEN PERFORMING THIS
INPSECTION MODULE.
o Waste Characterization Plano Bulk Waste Disposal and Treatment Facilities Waste Acceptance Criteria
o CL-CW-PR-0OI - Containerized Waste Facility Incoming Shipment Acceptance
o CL-CW-PR-l02 - Containerized Waste Void Remediationo CL-CW-PR-2OO - Package Liquid/Void Verificationo CL-CW-PR-202 - Containerized Waste Certificationo CL-CW-PR-203 - Containerized Waste Facility Waste Acceptance Criteriao CL-RS-PG-00l - ALARA Programo CL-RS-PG-0O2 - Radiation Protection Programo CL-RS-PR-lS0 - Posting Requirements for Radiological Hazard
Inspection Items: License Conditions and Containerized Waste Facility (CWF) Procedure
Requirements
Paee I of13
License Condition 16
Sealed sources as defined in Utah Administrative Code (UAC) R3l3-12 shall not be accepted
for disposal.
Has the licensee received and or disposed of sealed sources at the CWF?
(A)
l.
!Yes XNo nNa
Comments: Certified Waste Generator certification is required for CWF disoosal. All waste
generators certifr sealed sources are not included in waste shipments. Inspectors reviewed ES
procedure CL-CW-PR-203 in coordination with interviewins ES staff to confirm this requirement
was relayed to the generators.
(B) In accordance with UAC R3l3-15-1009(2)(aXv), waste shall not be readily capable of
detonation or of explosive decomposition or reaction at normal pressures and temperatures, or
of explosive reaction with water.
2. Has the licensee received waste which is readily capable of detonation or of explosive
decomposition at the CWF?
!Yes XNo INle
Comments: Certified Waste Generator certification is required for CWF disposal. All waste
generators certifr that waste which is readilv capable of detonation or of explosive decomposition is
not included in waste shipments. Inspectors reviewed ES procedure CL-CW-PR-203 in coordination
with interviewing ES staffto confirm this requirement was relayed to the generators.
(c)In accordance with UAC R313-15-1009(2)(a)(vi), waste shall not contain, or be capable of
generating, quantities of toxic gases, vapors, or fumes harmful to persons transporting,
handling, or disposing of the waste.
3. Has the licensee received and or disposed of waste containing or capable of generating toxic
gases, vapors, or fumes at the cwF?
tr yes X No I N/a
Comments: Certified Waste Generator certification is required for CWF disoosal. All waste
generators certifr waste containinq or capable of qeneratinq toxic gases. vapors. or fumes are not
included in waste shipments. Inspectors reviewed ES procedure CL-CW-PR-203 in coordination
with interviewing ES staff to confirm this requirement was relayed to the generators.
Page 2 of 13
(D)
4.
ln accordance with UAC R313-15-1009(2)(a)(vii), waste shall not be pyrophoric.
Has the licensee received and disposed of pyrophoric waste at the CWF?
!Yes XNo nNte
Comments: Certified Waste Generator certification is required for CWF disposal. All waste
generators certifr waste classified as pvrophoric are not included in waste shipments. Inspectors
reviewed ES procedure CL-CW-PR-203 in coordination with interviewing ES staff to confirm this
requirement was relayed to the generators.
Waste containing untreated biological, pathogenic, or infectious material including
radiologically contaminated laboratory research animals is prohibited.
Has the licensee received and disposed waste containing untreated biological, pathogenic, or
infectious material including radiologically contaminated laboratory research animals at the
CWF?
!Yes XNo INle
Comments: Certified Waste Generator certification is required for CWF disposal. All waste
eenerators certift waste containing untreated biological. pathogenic. or infectious material including
radiologicallli contaminated laboratory research animals are not included in waste shipments.
Inspectors reviewed ES procedure CL-CW-PR-203 in coordination with interviewinq ES staff to
confirm this requirement was relayed to the generators.
F. Liquid Waste Restrictions
i. Except for liquid mercury and minimal quantities as dasc,ribed in Condition l7 and in the Waste
Characterization Plan, receipt of non-aqueous liquid wasts is prohibitd unless specifically
approved by the Executive Secretary.
ii. Treatd liquid radioactive waste shall be disposed at the Mixed Waste Facility or ths LLRW
Facilities in accordanse with Exhibit 3 of the Wasie Charactsrization Plan.
iii. Only Utatr Division of Radiation Control approved solidification ot absorption agents as listed in
the State-issued Part B Pennit are authorized for liquid waste treatneot.
iv. Liquid radioactive waste shalt be solidified or absorbed in a manner such that no liquid
component is disposed.
v. Only containers authorized by &e U. S. Departrrent of Transportation as specified in the
regulatibns (49 CFR parts t00 thru lS0) for transporting liquid radioactive materials shall be
accepted for all liquid radioactive wastes, regardlesr of radioactivity concentrations.
(E)
5.
Page 3 of 13
6. Has the licensee received liquid radioactive waste at the CWF?
!Yes XNo nNta
6a. If yes above, has the licensee managed the liquid waste in accordance with
License Condition F above?
!ves ENo XNln
Comments: Inspectors reviewed random CWF shipments within the past few months and
confirmed that these shipments did not include liquid radioactive waste to the CWF.
(G) In accordance with UAC R313-15-1009(2)(a)(viii), gaseous waste received for disposal in
the Containeized Waste Facility shall be packaged at an absolute pressrue that does not
exceed 1.5 atmospheres at a temperature of 20 degrees Celsius and the total activity of any
container shall not exceed 100 curies (3.7 X l0l2 Bequerels).
7. Has the licensee received gaseous waste at the CWF?
7a. If yes, has the licensee managed the gaseous waste in accordance with L.C. G above?
! ves XNo n Nle
Comments: Inspectors reviewed random CWF shipments within the past few months and
confirmed that these shipments did not include gaseous waste to the CWF.
(H) In accordance with UAC R313-15-1009(2)(a)(ii), waste received for disposal in the
Containerized Waste Facility shall not be packaged in cardboard or fiberboard containers.
8. Has the licensee received for disposal waste packaged in cardboard or fiberboard containers
at the CWF?
!Yes XNo nNa
Comments: Certified Waste Generator certification is required for CWF disposal. All waste
generators certifr waste will be shipped in appropriate waste packaeine. Interviews with staff
indicated no issues with this with their generators. Inspectors reviewed ES procedure CL-CW-PR-
203 in coordination with interviewing ES staff to confirm this requirement was relayed to the
genefafors
Page 4 of 13
(r)
9.
The Licensee shall not accept for disposal any neutron source (e.g., polonium-210, americium-
24l,radium-226 in combination with beryllium or other target).
Has the licensee accepted for disposal any neutron sources at the CWF?
!Yes XNo INle
Comments: Certified Waste Generator certification is required for CWF disposal. All waste
generators certifr waste will not contain any neutron sources. Inspectors reviewed ES procedure CL-
CW-PR-203 in coordination with interviewing ES staff to confirm this requirement was relayed to
the qenerators.
Radioactive waste containing chelating agents greater than
disposed of in the Mixed Waste Cell.
Have any radioactive wastes containing chelating agents >0.1
at the CWF?
!Yes XNo nNte
Comments: Certified Waste Generator certification is reouired for CWF disoosal. All waste
eenerators certifr waste will not contain chelating agents greater than 0.1 percent by weight.
Inspectors reviewed ES procedure CL-CW-PR-203 in coordination with interviewing ES staff to
confirm this requirement was relayed to the qenerators.
The Licensee shall not accept containerized radioactive waste unless each waste
package has been:i. Classified in accordance with R3l3-15-1009, "Classification and Characteristics
of Low-Level Radioactive Waste". In addition, the Licensee shall require that all
radioactive waste received for disposal meet the requirements specified in the
Nuclear Regulatory Commission, "Branch Technical Position on Concentration
Averaging and Encapsulation", as amended.
ii. Marked as either Class A Stable or Class A Unstable as defined in the most recent
version of the "Low-Level Waste Licensing Branch Technical Position on
Radioactive Waste Classification" originally by the U.S. Nuclear Regulatory
Commission.
a. When destined for the Containerized Waste Facility, the marking may be
affrxed to either disposal container or transport package, in accordance with
UAC R313-15-1006(a) and Section III of Appendix G of 10 CFR 20.1001 to
20.2402 (incorporated by reference).
iii. Marked with a unique package identification number, clearly visible on the
package, that can be correlated with the manifest for the waste shipment in which
the package arrives at the facility.
Page 5 of 13
(K)
10.
0.1 percent by weight shall be
percent by weight been disposed
(L)
I 1. Has the licensee determined the above conditions exist for each waste package?
IYes nNo nNte
Comments: Certified Waste Generator certification is required for CWF disposal. All waste
generators certifr waste packages will meet the above criteria. The Inspectors also viewed the
handling of a few CWF shipments. and the above conditions appeared to have been met.
(M)The Licensee may accept containerized Class A LLRW in the following waste packages for
disposal in the Containerized Waste Facility of the Class A disposal cell:
i DOT "strong, tight" containers in accordance with 49 CFR 173.403 and meeting
the following void space criteria: void spaces within the waste and between the
waste and its packaging shall be reduced to the extent practicable, but in no case
shall less than 85 percent of the capacity of the container be filled.
ii. High-Integrity Containers (HICs) exceeding the void space criteria provided in
License Condition l6.M.i, shall be approved by the Director.
iii DOT "strong, tight" containers in accordance with 49 CFR 173.403 exceeding the
void space criteria provided in License Condition 16.M.i and large components
shall be placed as approved by the Director.
iv Oversized DOT containers (larger than 215 cubic feet) meeting the void space
criteria provided in License Condition 16.M.i shall placed in accordance with the
current approved Construction QA/QC Manual.
12. Has the licensee determined the void space criteria have been met?
IYes nNo ENa
Comments: Inspectors reviewed random CWF shipments and found that appropriate void space
documents were maintained.
Page 6 of 13
13.
License Condition 17
(A)In accordance with UAC R3l3-15-1008(2)(a)(iv), solid waste received for disposal shall
contain as little free-standing and non-corrosive liquid as reasonably achievable, but shall
contain no more free liquid than one percent of the volume of the waste.
Hasthe licensee determined the free liquid volume in waste shipments?
f,Yes nNo XNta
80mR/hr. Insoectors interviewed ES staff and there have not been any shipments recently that meet
this criteria. Inspectors reviewed random CWF shipments with no evidence found to dispute ES'
claims.
License Condition 2l
The Licensee's RSO shall review and approve written procedures as stated in License
Condition 20 andsubsequent changes to the procedures related to waste disposal operations.
14. Has the RSO reviewed and approved the written procedures related to waste disposal
operations?
Ives INo INla
Comments: Tom Brown has reviewed and signed the applicable procedures related to waste
disoosal ooerations.
License Condition 37
All ion exchange resins shall be disposed of as follows:
A. Solidified using solidification agents approved by the Director and disposed of in the
Containerized Waste Facility; or
B. Packaged in High-Integrity Containers (HIC) approved by the Director, carbon-steel
liners, unapproved HICs, or poly HICs meeting the void space criteria described in
License Condition l6.M.i and disposed of in the Containenzed Waste Facility; or
C. Packaged in High-Integrity Containers (HIC) approved by the Director, carbon-steel
liners, unapproved HICs, or poly HICs not meeting the void space criteria described in
License Condition 16.M.i and disposed of as approved by the Division under License
Page 7 of 13
Condition l6.M.ii or 16.M.iii in the Containerized Waste Facility; or
D. Disposed of in accordance with the requirements of the Construction Quality
Assurance/Quality Control Manual.
15.Has the licensee disposed of ion exchange resins at the CWF according to the above criteria?
Xves ENo XNa
Comments: Interviewed ES staff and resins only come into the facility in approved HICs. The
inspectors did not see any issues with containers during inspection.
License Condition 56
Containerized Class A waste shall be certified by the generator to meet the Waste Acceptance
Criteria in accordance with the Waste Characterization Plan described in License Condition
58.
16. Has the Generator certified the waste meets the Waste Acceptance Criteria, in accordance
with the Waste Characterization Plan?
XYes nNo INla
Comments: The generator is required to veriF this as part of tfre Certified Generator certification.
Inspectors reviewed ES procedure CL-CW-PR-203 in coordination with interviewing ES staff to
confirm this requirement was relayed to the generators.
License Condition 77
Except while waste packages are being handled in the active areas of the Containerized Waste
Facility, Except while waste packages are being handled in the active areas of the
Containerized Waste Facility, external gafirma radiation levels shall be posted in accordance
with the most current version of EnergySolutions' SOP CL-RS-PR-I50, Posting requirements
for Radiological Hazards.
17. Has the CWF been posted in accordance with SOP CL-RS-PR-150?
Page 8 of 13
IYes nNo nNta
Comments: The Licensee properly posted the CWF as a "High Radiation Area" with the
appropriate signage.
License Condition 78
NOTE - THE INSPECTOR SHALL OBSERVE THE FOLLOWING CONTROLS ON
WASTE HANDLING AT THE CONTAINERIZED WASTE FACILITY:
Description of waste handling operations observed: Inspectors entered the CWF area iust as ES
staffstarted their process of unloading a shipment of container UN2908. Mobile stares were placed
around the container for ES staff easier access. The lid was lifted bv the crane and smears were
observed to be taken b)'HPs. A stretch scope was utilized by HPs to eather readines from inside the
container. All staff then moved behind sheilded area while the waste was removed from the
container to be placed in the cell. The lid was closed, and HP's took smears of the exterior of the
container as it exited the CWF area. Inspectors scrutinized the ALARA review performed by ES HPs
and found they appeared to he frrofrerly comnleted.
(A)Before unloading any waste container whose external gamma radiation at the surface exceeds
10 R/hr, an ALARA review shall be performed and documented and a pre-job briefing shall
be conducted.
Has the licensee conducted an ALARA review prior to unloading any waste container that
exceeds l0 R/hr?
IYes nNo XNla
Comments: Inspectors interviewed ES staff and were informed that no shignent exceeding 10 R/hr
has been received in years. Review of random CWF shipments did not find any shipments over this
threshold.
As part of the ALARA review, the Licensee shall determine and record (1) estimates of the
radiation dose rates for the waste container, disposal unit working face, and any other
potentially significant radiation sources; (2) expected durations of exposures to and distances
from each radiation source; and (3) expected doses to each person involved in the actual
disposal operation.
If yes to 18. above, did the review include the above estimates, expected duration, doses, and
Page 9 of 13
18.
(B)
19.
distances from radiation source?
!Yes nNo XNte
Comments:
20.
(c)Before unloading any waste container whose external gamma radiation at the surface exceeds
200 R/hr, a practice run shall be conducted. The practice nrn shall involve shielding,
container(s) filled with non-radioactive material, and handling equipment that are similar to
those involved with the actual shipment. Similarity includes similar rigging and physical
characteristics (e.g., weight, dimensions, ffid attachments). Those personnel who will
participate in receiving, processing, handling, and disposing of the actual waste will participate
in the practice run, using actual procedures. The Licensee shall notiff the Division 24 hours in
advance of conducting the practice runs.
Has the licensee performed the above evaluation and practice run for waste packages that
exceed 200 R/hr?
!Yes nNo XNte
Comments: Interviews with ES staffand review of random CWF shipments found that there have
not been any CWF shipments over 200 R/hr is recently.
2I. Has the licensee notified the DWMRC of practice runs?
Comments:
!Yes nNo XNtn
License Condition 80
The Licensee shall notifr in writing the Director at the earliest possible date, but no later than
10 days before scheduled receipt of each shipment with contact radiation levels in excess of
200 R/hr. The notification shall include the anticipated dates of receipt and plan for disposal
in the Containerized Waste Facility.
22. Has the licensee received shipments that are in excess of 200 R/hr? f Yes X No
22a. If yes, has the licensee notified the Director in writing? n Yes I No I NIR
Page 10 of13
23.
Comments: Interviews with ES staff and review of random CWF shipments found that there have
not been any CWF shipments over 200 R/hr is recently.
License Condition 81
The RSO or other qualified person designated by the RSO shall be present for and shall observe
the receipt, processing, handling, and disposal of each waste package with contact radiation
levels in excess of 200 R/hr.
If applicable, has the licensee's RSO or other qualified person designated by the RSO been
present during the receipt, processing, handling, and disposal of each waste package?
!Yes XNo XNla
Comments:
License Condition 82
The Licensee shall dispose of only closed containers in the Containerized Waste Facility. The
Licensee shall not dispose of any breached waste container in the Containerized Waste Facility
without first repairing the breached container or overpacking it in an undamaged container.
The Licensee is authorized to open packages at its facility only to:
Repair or repackage breached containers.
Inspect for compliance with conditions of this license.
Confirm package contents and fill voids in packages/containers that have
greater thanl5%o void space.
Accomplish other purposes as approved by the Director.
Has the licensee conducted the above activities in the Containerized Waste Facility?
XYes ENo nNa
A.
B.
C.
D.
24.
Page 1l of13
Comments: Inspectors reviewed random CWF shipments and found that appropriate void space
documents were maintained.
License Condition 83
The Licensee shall handle and emplace LLRW packages in the Containerized Waste Facility
such that packaging integrity is maintained during handling, emplacement, and subsequent
backfilling. Waste packages deposited in the Containerized Waste Facility shall be protected
from any adverse effects of operations which may damage them.
25. Has the licensee maintained package integrity during handling, emplacement and subsequent
backfilling?
Xves nNo nNn
Comments:
Operational Procedures
Packase Liquid/Void Verification Procedure: CL-CW-PR-200
26. Liquid verification: (4.2.1)
Has the licensee inspected at least one Class A package per week for liquid verification provided a
suitable package is received for disposal? (Section 3.3.5 sates: ooPackages with external radiation levels
in excess of 80 mR/tr on contact shall.not be punctured or opened for inspection, unless approved by
the RSO).
!Yes ENo XNln
Comments: Most recent CWF shipments have been in excess of 80 mR/hr. Inspectors did could not
locate a shipment that was received below this threshold.
Additional Comments:
Page 13 of13