HomeMy WebLinkAboutDRC-2025-002697 CLIVE SITE
LETTER OF TRANSMITTAL DATE: 8/18/2025 ATTN: LLRW
CC; Karen Kirkwood Treesa Parker RE: Transmittal 2025-049
Description of Documents Transmitted Qty
See attached list for updates to Mixed Waste Disposal. CL-MD-PR-211 Rev 9, Mixed Waste Site Inspections 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Electronic documents, once printed, are uncontrolled and may become outdated.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-MD-PR-211
Mixed Waste: Site Inspections
Revision 9
Authored By:
Brett Davis, Mixed Waste Treatment Supervisor Date
Reviewed By:
Steve Gurr, Environmental Engineer 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
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Table of Contents
1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose........................................................................................................................... 3
1.2 Scope............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 3
3.1 Definitions ...................................................................................................................... 3
3.2 Responsibilities .............................................................................................................. 3
3.3 Precautions and Limitations ........................................................................................ 4
3.4 Document Control and Records .................................................................................. 4
4 REQUIREMENTS AND GUIDANCE .................................................................................. 5
5 ATTACHMENTS AND FORMS......................................................................................... 10
CL-MD-PR-211
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1 PURPOSE AND SCOPE
1.1 Purpose
The following procedure outlines the site inspection requirements in the State-
issued Part B Permit, and Ground Water Quality Discharge Permit.
1.2 Scope
This procedure addresses items that shall be inspected, the requirements for
resolving any problems found during inspections, and the required documentation
of Permit required inspections at the Mixed Waste Facility.
2 REFERENCES
2.1 ES-AD-PR-008, Condition Reports
2.2 Groundwater Quality Discharge Permit UGW450005, Appendix J, BAT
Performance Monitoring Plan
2.3 State-issued Part B Permit Attachment II-3, Site Inspection Plan
2.4 CL-EN-PR-011, Clive Engineering Field Inspections
3 GENERAL
3.1 Definitions
3.1.1 Acceptable - Items that meet the stated criteria on the inspection forms.
3.1.2 Unacceptable - Items that do not meet the criteria on the inspection form,
including: Problems posing an immediate threat to human health or the
environment.
3.1.3 Notable Items – Items which do not meet the definition of Unacceptable
but could lead to a future noncompliance situation if left unchecked and/or
unattended.
3.1.4 Mixed Waste Evaporation Pond- Pond located in the southwest area of the
Mixed Waste Facility. Designed to collect liquid drainage from the storage
areas inside the restricted of the Mixed Waste Facility. Not approved for
management of Leachate. This pond does not contain hazardous waste and
is regulated by Reference 2.2.
3.1.5 Mixed Waste Surface Impoundment (MWSI)- The impoundment is in the
northeast corner of Mixed Waste designed to contain leachate.
3.2 Responsibilities
3.2.1 The Operations Manager or designee is responsible for reviewing
completed inspection forms and ensuring that corrective actions are
identified for unacceptable items.
3.2.2 Qualified RCRA & BAT Inspectors are responsible for completing Permit
required daily, weekly, and monthly inspections.
3.2.3 The Groundwater Program Manager is responsible for certifying
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Groundwater Monitoring Equipment and Wells annual inspections.
3.2.4 The Manager, Compliance and Permitting is responsible for regulatory
notifications required within this procedure.
3.2.5 The Environmental Engineer is responsible for ensuring the sampling
requirements of the MW Surface Impoundment are completed.
3.2.6 The QA Department is responsible for reviewing and transmitting
completed inspections to Document Control.
3.2.7 The Document Control Department is responsible for filing completed
inspection forms in the operating record.
3.3 Precautions and Limitations
3.3.1 Personnel shall follow the requirements of the applicable Radiation Work
Permit while performing work inside the Restricted Area.
3.3.2 Daily inspections are required any day that work is performed in the
Mixed Waste Facility. Days that there’s no activity (e.g., regularly
scheduled days off, weekends, or holidays) no inspection form is required.
3.3.3 Weekly inspection is required once per calendar week.
3.3.4 Monthly inspection is required once per calendar month. It is
recommended that monthly inspections be conducted at least three weeks
apart.
3.3.5 Annual inspection is required once per calendar year and at least four
months later than the inspection for the previous calendar year.
3.3.6 If an inspection is not required for that day for a given area, line through
the inspection page, write “N/A” or “No Activity” (or similar), then initial
and date the line.
3.3.7 The State-issued Part B Permit inspections shall only be performed by
those individuals who are RCRA & BAT Inspector qualified in
accordance with site procedures.
3.3.8 The Monthly Groundwater Equipment Inspections identified in the Site
Inspection Plan, are performed by the Groundwater Department and are
not included in this procedure.
3.3.9 If an item is identified during an inspection that cannot be immediately
corrected (i.e., within one working day), site management will be notified
(preferably in writing) to ensure that any required notifications can be
made. Document this notification on the inspection form.
3.3.10 Implement the Contingency Plan in the event of a spill, fire or explosion.
3.3.11 Employees shall keep off the pond liners. If at any time access to the liner
becomes necessary, a buddy system will be used, and a life vest with
rescue rope worn.
3.4 Document Control and Records
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3.4.1 Within 60 days of the final review date, the original inspections shall be
transmitted to Document Control for inclusion into the operating record.
3.4.2 The analytical results from the MW Surface Impoundment required in
Condition 4.1.5.5.1 shall be transmitted to document control within 60 days
of receipt.
4 REQUIREMENTS AND GUIDANCE
4.1 Compliance
4.1.1 Daily inspections of the Mixed Waste Evaporation Pond are completed as
required by Reference 2.2. All other inspections are completed as
required by Reference 2.3.
4.1.2 Except as noted below, daily inspections shall be recorded on CL-MD-PR-
211-F1 and conducted for the following areas:
4.1.2.1 The Mixed Waste Evaporation Pond inspection recorded on forms
CL-MD-PR-211 F6 and CL-MD-PR-211 F7. This daily inspection
is required on days when off-site shipments are received into the
Mixed Waste Facility.
4.1.2.2 General Facility Inspection. This daily inspection is required on
days when off-site shipments are received into the Mixed Waste
Facility.
4.1.2.3 Leachate Collection. This daily inspection is required on days
when waste is transferred to, from, or within disposal facility areas.
Note: During partial closure operations,
leachate inspections need only be made
bi-weekly.
4.1.2.4 Decontamination Tank System Operation. This daily inspection is
required:
4.1.2.4.1 On days when waste is transferred to, from,
or within the Decontamination Tanks.
4.1.2.4.2 On days when decontamination activities
involving these tanks are conducted.
4.1.2.5 Treatment Facility Tank System Operation. This daily inspection is
required:
4.1.2.5.1 On days when waste is transferred to, from,
or within the Treatment Facility tanks.
4.1.2.5.2 On days when waste management activities
are conducted within the Mixed Waste
Treatment Building.
4.1.2.6 Treatment Building Baghouse System: Waste management
activities which involve the management of waste in units,
including miscellaneous units, shall not be performed unless the
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HVAC system is operating. Operations of the HVAC system
include operation of the baghouse and HEPA filtration system.
4.1.2.7 Operations Building Baghouse System: Waste management
activities which involve the management of waste in units,
including miscellaneous units, shall not be performed unless the
HVAC system is operating and a negative pressure is attained
within the operations bay. Operations of the HVAC system
includes: operation of the baghouse, the HEPA filtration system,
the organic carbon filtration system. The carbon filters shall be
replaced every two years in baghouse 940-BH-003. An expiration
date for the carbon filters shall be labeled on that baghouse. Filter
change outs shall be documented in the notes on the inspection
form.
4.1.2.8 Baghouse filter differential pressure for all baghouses shall not be
lower than 0.1 inH2O, or higher than 6.0 inH2O when treatment
operations are in progress.
Note: If the differential pressure exceeds 6.0
inH2O, the collection container below the
baghouse shall be replaced with a larger
container. The replacement container
shall be a minimum of 1.0 yd3 to
adequately contain the volume of material
on the bags. The larger contain will
remain in-place throughout the purge
process. Once the levels fall below 6.0
inH2O, and the condition that caused the
excessive build-up are corrected, work
can resume.
4.1.2.9 Mixed Waste Operations Building process area. This daily
inspection is required on days when waste management activities
are conducted in this building.
4.1.2.10 Thermal Desorption System. This daily inspection is
required:
4.1.2.10.1 On days when waste is transferred
to, from, or within the thermal desorption
system.
4.1.2.10.2 On days when waste is processed
within the thermal desorption system.
4.1.2.11 MW Surface Impoundment (recorded on CL-MD-PR-211-
F4 and CL-MD-PR-211-F5). This daily inspection is required on
days when leachate is transferred to, from, or within the Surface
Impoundment.
4.1.2.12 Secondary containment vaults shall be inspected for leaks,
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corrosion, cracks, and deterioration.
4.1.3 Weekly inspections shall be recorded on CL-MD-PR-211-F2 and
conducted for the following areas:
4.1.3.1 Perimeter and General Facility
4.1.3.2 Container Storage
4.1.3.3 MW Surface Impoundment
4.1.4 Monthly inspections shall be recorded on CL-MD-PR-211-F3 and
conducted for the following area:
4.1.4.1 Safety and Emergency Equipment
4.1.5 Annual inspections are recorded in report format and conducted areas as
described below:
4.1.5.1 Annual Tank Condition Assessment
4.1.5.1.1 This assessment is to be conducted for each
permitted tank.
4.1.5.1.2 This assessment is to be performed by an
independent Utah-registered professional
engineer.
4.1.5.1.3 Empty the tank and document that it has
been emptied.
4.1.5.1.4 Inspect internal surface area for leaks and
corrosion, erosion, cracks, and pitting.
4.1.5.1.5 Assess the wall thickness using an
appropriate device. The independent Utah-
registered professional engineer will make a
determination in the report that sufficient wall
thickness remains.
4.1.5.2 Annual Fire Suppression System
4.1.5.2.1 This inspection is to be performed by an
independent certified or qualified fire system
inspector.
4.1.5.2.2 Check the pump flow for adequacy in
accordance with applicable building codes.
4.1.5.2.3 Check gauges for proper function and
accuracy.
4.1.5.3 Groundwater Monitoring Equipment
4.1.5.3.1 This inspection is to be certified by the
Groundwater Program Manager.
4.1.5.3.2 Check dedicated pumps for general
integrity.
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4.1.5.4 Groundwater Monitoring Wells
4.1.5.4.1 This inspection is to be certified by the
Groundwater Program Manager.
4.1.5.4.2 Visually inspect groundwater monitoring
wells and aprons for cracks, corrosion,
damage and degradation.
4.1.5.4.3 Visually inspect groundwater monitoring
wells and aprons for frost heave, vandalism,
and structural integrity problems.
4.1.5.4.4 Visually and manually inspect wells for
security and for the presence and integrity of
locks.
4.1.5.5 Annual MW Surface Impoundment Assessment.
4.1.5.5.1 Collect a sample and analyze for the
following radiological parameters:
▪ Alpha Emitters: Np-237, Sr-90, Th-230,
Th-232, U-233, U-234, U-235, U-236, and
U-238.
▪ Beta/Gamma Emitters: C-14, I-129, Tc-99,
and H-3.
▪ Combined: Ra-226 + Ra-228.
4.1.5.5.2 The analytical data shall be reviewed by the
Environmental Engineer prior to transmitting
to document control.
4.1.5.5.3 Check the winding resistance and insulation
resistance from the submersible pump, in
accordance with Reference 2.4.
4.1.6 The following requirements for problem resolution shall be followed for
unacceptable items identified during inspections.
Note: Items on CL-MD-PR-211-F1 that are marked with an
asterisk (*) are items that are not listed in Reference
2.2. If these items cannot be fixed immediately, sections
4.1.6.2., 4.1.6.4., and 4.1.6.5 shall be followed. Section
4.1.6.3. is not required for these items.
4.1.6.1 Problems that pose an imminent threat to human health or the
environment shall be corrected immediately. Notify the Operations
Manager or designee immediately upon discovery.
4.1.6.2 If an identified problem is corrected within 72 hours of
identification, record how and when (date/time) the problem was
corrected in the “Immediate Corrective Action” column.
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4.1.6.3 If an identified problem cannot be corrected within 72 hours, the
Manager, Compliance and Licensing or designee will be informed,
and regulatory notification made prior to the end of the 72-hour
period. The notification will include a proposed time schedule for
correcting the problem.
4.1.6.4 If an identified problem cannot be corrected within one week a
Condition Report shall be issued in accordance with Reference 2.1.
4.1.6.5 The Operations Manager will ensure that long term problems are
properly addressed and documented in the “Long Term Corrective
Action” column, along with “Initials/Date.”
Note: Reference the Condition Report number
(if needed) in the “Long Term Corrective
Action Column” to provide traceability
between the deficiency and the tracking
mechanism.
4.1.6.6 A comprehensive list of notable items shall be maintained and
available for review on site. This comprehensive list shall be
documented on the individual daily, weekly and monthly
inspection forms.
4.2 Inspection Process
4.2.1 Inspection Completion
4.2.1.1 The inspector shall complete the date and time of inspection on the
top of each form.
4.2.1.2 The inspector shall inspect the facility for each of the items listed
on the inspection form.
4.2.1.3 For each item, the inspector shall document whether the item is
acceptable. Items that pass the criteria listed in the “Item
Description” column are acceptable. Items that fail the criteria or
may harm people or the environment are not acceptable.
4.2.1.4 For unacceptable and notable items, the inspector shall record the
problem in the “Observations” column.
Note: The inspector may make notes of items
found to be in accordance with
requirements. Documentation of such
items is not required.
4.2.1.5 Inspectors should include enough detailed information on the
inspection form regarding identified issues and observations to
clearly identify the nature and location of the issue/observation.
4.2.1.6 Once the inspection is complete, the inspector shall print and sign
the last page of the inspection packet.
4.2.1.7 The completed inspection packet is reviewed by the Operations
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Manager and Quality Assurance personnel. This review is
documented by initialing and dating the bottom of the final page of
the inspection packet.
4.2.2 Mixed Waste Evaporation Pond and Mixed Waste Surface Impoundment
Inspection Completion
4.2.2.1 The Mixed Waste Surface Impoundment Daily Inspection uses
form CL-MD-PR-211-F4.
4.2.2.1.1 Once each week, an average daily leakage
volume from the Mixed Waste Surface
Impoundment will be calculated using form
CL-MD-PR-211-F5.
4.2.2.2 The Mixed Waste Evaporation Pond Daily Inspections uses form
CL-MD-PR-211 F6.
4.2.2.2.1 Once each week, an average daily leakage
volume from the Mixed Waste Evaporation
Pond will be calculated using form CL-MD-
PR-211 F7.
5 ATTACHMENTS AND FORMS
5.1 CL-MD-PR-211 F1, Mixed Waste Daily Inspection Form - Example
5.2 CL-MD-PR-211 F2, Mixed Waste Weekly Inspection Form - Example
5.3 CL-MD-PR-211 F3, Mixed Waste Monthly Inspection Form – Example
5.4 CL-MD-PR-211 F4, Mixed Waste Surface Impoundment Form - Example
5.5 CL-MD-PR-211 F5, Mixed Waste Surface Impoundment Leak Detection System
Volume Weekly Calculation Form – Example
5.6 CL-MD-PR-211 F6, Mixed Waste Evaporation Pond Daily Inspection Form -
Example
5.7 CL-MD-PR-211 F7, Mixed Waste Evaporation Pond Leak Detection System
Volume Weekly Calculation Form - Example
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Attachment 5.1- CL-MD-PR-211 F1,
Mixed Waste Daily Inspection Form, Page 1 – Example
.
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Attachment 5.1- CL-MD-PR-211 F1,
Mixed Waste Daily Inspection Form, Page 2 – Example
CL-MD-PR-211
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Attachment 5.1- CL-MD-PR-211 F1,
Mixed Waste Daily Inspection Form, Page 3 – Example
CL-MD-PR-211
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Attachment 5.1- CL-MD-PR-211 F1,
Mixed Waste Daily Inspection Form, Page 4 – Example
CL-MD-PR-211
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Attachment 5.1- CL-MD-PR-211 F1,
Mixed Waste Daily Inspection Form, Page 5– Example
CL-MD-PR-211
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Attachment 5.1- CL-MD-PR-211 F1,
Mixed Waste Daily Inspection Form, Page 6 – Example
CL-MD-PR-211
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Attachment 5.2 - CL-MD-PR-211 F2,
Mixed Waste Weekly Inspection Form Page 1 – Example
CL-MD-PR-211
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Attachment 5.2 - CL-MD-PR-211 F2,
Mixed Waste Weekly Inspection Form Page 2 – Example
CL-MD-PR-211
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Attachment 5.2 - CL-MD-PR-211 F2,
Mixed Waste Weekly Inspection Form Page 3 – Example
CL-MD-PR-211
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Attachment 5.2 - CL-MD-PR-211 F2,
Mixed Waste Weekly Inspection Form Page 4 – Example
CL-MD-PR-211
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Attachment 5.3 - CL-MD-PR-211 F3,
Mixed Waste Monthly Inspection Form, Page 1– Example
CL-MD-PR-211
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Attachment 5.3 - CL-MD-PR-211 F3,
Mixed Waste Monthly Inspection Form, Page 2 – Example
CL-MD-PR-211
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Attachment 5.4 – CL-MD-PR-211 F4,
Mixed Waste Surface Impoundment Inspection Form – Example
CL-MD-PR-211
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Attachment 5.5 – CL-MD-PR-211 F5, Mixed Waste Surface Impoundment Leak Detection
System Volume Weekly Calculation Form - Example
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Attachment 5.6 – CL-MD-PR-211 F6,
Mixed Waste Evaporation Pond Daily Inspection Form - Example
CL-MD-PR-211
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Attachment 5.7 – CL-MD-PR-211 F7, Mixed Waste Evaporation Pond Leak Detection
System Volume Weekly Calculation Form - Example
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DOCUMENT SUMMARY FORM