DRC-2025-001902

Inspection Module:
Inspection Location:
Inspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted:
INSPECTION REPORT
l3 - Liquid Management
EnergySolutions - Clive Facility, Utah
Liquid Waste Requirements, Management of Unanticipated Liquids,
Containerized Waste Facility Liquid Verification
Opening meeting: February 25,2025
Closeout: Iune 17,2025
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
Goveming Documents:o Radioactive Materials License (RML) UT2300249. Waste Characteization Plano EnergySolutionsProcedureso CL-CW-PR-200, Package Liquid/VoidVerificationo CL-CH-PR-252,Incoming Shipment Inspection and Sampling
Onening Meetins
EnergySolutions:
Tom Brown; Radiation Safety Offrcer (RSO)
Dale Thorne; Assistant Radiation Safety Ofhcer (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 February 25,2025, the inspectors discussed the inspection items and
documentation to be reviewed during the inspection. Division Inspectors informed Clive staffthat they
would be accessing shipping and receiving data through OnBase and Customer Portal, interviewing staff,
and reviewing acceptance procedures for liquid waste.
Inspection Summary
The Division of Waste Management and Radiation Control (Division) inspection consisted of
interviewing EnergySolutions (ES) staffand examining documentation that pertains to the intended and
unintended acceptance of liquid waste. Division inspectors' (Inspectors) interviews with ES staff
provided clarity on ES' operations associated with liquid waste and the facility's compliance with all
applicable Rules and Regulation and ES UT Radioactive Material License UT2300249 (License).
Item 1. Containerized Waste Shipments
Observations: The lnspectors interviewed ES staff and recent Package Liquid Verification forms to
evaluate compliance with the License. The Inspectors were able to verifu:. Only containers/liners that have contact exposure rates less than 80 mR4rr are candidates for
liquid verification due to ALARA concerns.. Very few containers accepted at ES meet the exposure rate threshold to justifr liquid verification.o A few randomly chosen waste shipments were reviewed in OnBase that contained a Package
Liquid Verification form. The selected shipments appeared to indicate that no liquids were
present.
Item 2. Waste C haracteri zation
Observations: Inspectors were able to verifr through interviewing ES staff and document review that:o All waste streams randomly chosen for review included some form of a waste characterization
summary that detailed whether there would be waste containing >lYo free liquid in future
shipments.o Random waste streams were selected within Customer Portal that might contain liquids. EWISS
was cross-referenced to verifu that shipments within the selected waste streams met Class A
levels at receipt.
Item 3. Incidental/Unanticipated (>1%) Liquids
Observations: Inspectors interviewed ES staff and reviewed random l%oFree Liquid Volume
Verification forms:o Inspectors reviewed random l%oFree Liquid Volume Verification forms found in OnBase. The
documents reviewed appeared to have been following ES procedures.o Unanticipated liquids are sometimes detected only when the waste containers are emptied. 1%
Free Liquid Volume Verification forms are completed in these instances. Only estimates can be
made to determine the amount of liquid contained in the waste package for these shipments.
Deficiencies: ES should review their process of confirming the absence/ presence of free liquids to
avoid situations where liquids are only discovered when being emptied.
Closeout Meetins
EnergySolutionsz
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)
Kevin Carney (Health Physics Inspector)
Inva Braha (Health Physics Inspector)
Findinss:
During the inspection time frame, a shipment was received that was leaking. The Inspectors verified that
the shipment was brought into the restricted area as required by ES procedures. ES informed the Division
of the leaking shipment appropriately and completed the l%oFree Liquid Volume Verification form
during disposal on the Class A disposal cell. Questions remain on the effectiveness of this process to
ensure that more than loh free liquids are not being disposed of with shipment that contain free liquids.
Recommendations
l) ES should investigate their process of waste acceptance to avoid unintended liquid waste
disposal. When waste is emptied and liquids are discovered, only estimates of the amount of
liquid can be formulated. A visual estimation is not sufficient to ensure that <l%o liquids are being
disposed of.
Recommendation for Next Year's Inspection
The Inspectors should dig deeper into ES' treatment process and documentation. It became clear after the
inspection was closed that there was confusion with the questions being asked by the Inspectors. The
Inspectors believe that ES staff might have been interpreting many of the questions being asked as
referring to containerized waste only. The lnspectors need to scrutinize ES acceptance and treatment
procedures for all liquid waste during future inspections.
Prepared By:
Reviewed By:Lawrence Kellum
(Print Name)
t? ^5
(Dat€)
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DIVISION OF WASTE MANAGEMBNT
AND RADIATION CONTROL
License Numbers UT2300249 and UT230047 8
INSPECTION MODULE 13
Liquids Management
InspectionDates: Start: 0212512025 End: 06117/2025
Inspector(s): Bryan Woolf, Inva Braha, Kevin Carney
Related Documentso License No. UT 2300249o R3l3-1s-1009(2)(a)(iv)o License Condition 9.G.o License Condition 16.F.o License Condition 17.o Waste Characterization Plan-Step 3, 4, and Exhibit 2o CL-CH-PR-252 Rev. 5, Incoming Shipment Inspecting and Samplingo CL-CW-PR-200, Rev. 5, Packnge Liquid/Void Verffication
SECTION l-Wastes Characterized as Liquid
1. Are wastes characterized as containing>lo/o free liquids profiled as liquid wastes? (WCP Step 4)
IYes ENo nNta
Comments: Random waste profiles were reviewed in Customer Portal by inspectors and the generators
aooeared to characterize liquid waste.
2) Regardless of concentrations, are radioactive liquid wastes received in containers authorized by the
U.S. Department of Transportation as specified in 49 CFR parts 100 thru 180 for transporting Class
7 liquid radioactive material? (Check and review "generator's packaging and transportation plan")
(License Condition 16.F.v. and WCP Step 4)
Xves nNo nNa
Comments: Waste beins sent to ES appeared to be in US DOT approved containers during the inspection.
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3) Are liquid radioactive wastes Class A wastes at receipt? (License Condition 9.G.)
XYes !No !Nla
Comments: Random waste streams were selected within Customer Portal that might contain liquids.
EWISS was cross-referenced to verifr that shipments within a few waste streams met Class A levels at
receiot.
4) Has liquid radioactive waste been solidified or absorbed in a manner that no liquid component is
disposed? (License Condition 16.F.iv.)
Xves nNo nNa
Comments: Reviewed random paint filter tests in OnBase and did not find any recent shipments that
failed the test.
5) Has all treated liquid radioactive waste been disposed in the Mixed Waste Landfill Cell or the
LLRW Facilities in accordance with Exhibit 3 of the Waste Characteization Plan? (License
Condition l6.F.ii.)
X ves n No n Nl,q.
Comments: Review of documentation within OnBase and interviewed ES staff. There did not appear
to be any recent incidents of treated liquid radioactive waste being disposed of outside of the Mixed
Waste Cell or LLRW Facilities.
SECTION II-Solid Wastes with Incidental/Unanticipated (>17o) Liquids
6) Does the Licensee confirm the absence/presence of free liquids in wastes received?
(EnerrySolutions Procedure CL-CH-PR-252, Section 4.1.1.4)
Xyes XNo !Nte
Comments: Unanticipated liquids are sometimes detected only when the waste containers are emptied or
leaking at receipt. Only estimates can be made to determine the amount of liquid contained in the waste
packase for these situations.
Page 3 of57) If unexpected free liquids are present in a waste container, is the shipment either, entirely rejected
for receipt; specific containers rejected for receipt; or liquids separated and re-profiled?
(EnerrySolutions Procedure CL-CH-PR-252, Section 4.1.1.5.1-4.1.1.5.3)
IYes nNo nNtn
Comments: This appears to be decided on a case-by-case basis on which route ES pursues. From what I
gathered. it seems that ES will pursue a liquids separation process over reiection if it is feasible. In a recent
incident. a leakine container was separated until it stopped leakins. then disposal commenced.
8) Is alo/o Free Liquid Volume Verification Performed(by completing CL-CH-PR-252, Fl, Io%
Volume Freestonding Liquids Chart)? (EnerrySolutions Procedure CL-CH-PR-252, Section
4.1.1.s)
IYes nNo INle
Comments: Inspectors reviewed random 1olo Free Liquid Volume Verification forms found in OnBase. The
documents reviewed appeared to have been followinq ES procedures.
9) If the pH is 2 or less or 12.5 or greater has the Licensee notified the Director within 24 hours? (WCP
Step 3)
!Yes nNo XNla
Comments: There have not been any shipments recently that have triggered notiFine the Director due to
pH.
l0) Does the Licensee notiff the generator and the Division of Waste Management and Radiation
Control within 24 hours of determining that the volume of Unanticipated Free Liquids exceeds 1olo.
(WCP Step 3 and License Condition 17.D)
!Yes nNo XNla
Comments: ES staff informed the inspectors that there have not been any recent shipments that contained
liouids in excess of l%o that have reouired Director notification.
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1l) Does the Licensee provide the Director with a written description of the event and corrective actions
taken within 7 calendar days? (WCP Step 3)
IYes []No nNla
Comments: A recent incident of a leaking shipment resulted in ES staff contacting the Director within 24
hours and orovidins. a7 dav follow uo.
12) For generators having repeat occurrences of shipments with free-liquids in excess of l%o by volume,
does the Licensee require a corrective action plan from the generator? (WCP Step 3)
Eves nNo XNln
Comments: Inspectors interviewed ES staff and were informed that they were not aware of any recent
corrective action plans that have been required for a generator due to free liquids in excess of lolo.
13) Are shipments that have free liquids observed or are leaking brought into the Restricted Area and
managed only at an approved liquid management facility? (EnerrySolutions Procedure CL-CH-
PR-252 Section 4.1.1.9)
Xves nNo INra
Comments: During the inspection time frame. a shipment was received that was leaking. The Inspectors
verified that the shioment was brousht into the restricted area as required bv ES procedures.
14) Does the Licensee verifr compliance with the lYo free liquid (by volume) limit in accordance with
standard operating procedure "Package Liquid Verification" at the Containerized Waste Facility?
(WCP Exhibit 2, See also, EnergrSolutions Procedure CL-CW-PR-200, Package Liquid/Void
Veriftcation)
IYes nNo nNta
Comments: Inspectors reviewed Liquid Verification forms on OnBase to ensure completeness. Containers
that are <80 mR/tr are not verv common. however. thev are reviewed for free liquids when applicable.
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Additional Comments: