DRC-2018-003266 - 0901a068807e4cf2

DRC-2018-003266 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah
GARY R. HERBERT Governor SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director
April 12, 2018
Vern Rogers, Manager Compliance and Permitting EnergySolutions, LLC 299 South Main Street, Suite 1700 Salt Lake City, UT 84111
RE: EnergySolutions’ Letter (CD18-0065) dated March 30, 2018 regarding Railcar Release Matters Dear Mr. Rogers:
The Division of Waste Management and Radiation Control appreciates EnergySolutions’ attention and hard work to reach a final resolution regarding the appropriate license conditions relating to the control of radioactive materials in railcars and other conveyances that fall below the U.S. Department of Transportation
(USDOT) definition of Class 7 radioactive material (49 C.F.R. 173.403) but are still deemed to contain some
level of licensed material pursuant to NRC Regulations because such railcars and conveyances have not been free released. Without necessarily accepting all of the rationale set forth in your letter, the Division is prepared to agree
with its conclusions. More specifically, the Division intends to incorporate the following specific criteria and conditions into the license: 1. All vehicles, containers, facilities, materials, equipment or other items for Unrestricted Use shall not
be released from Licensee’s control if contamination exceeds the applicable limits found in Table 27-A. 2. Prior to transfer or shipment of radioactive material, the Licensee shall complete the radioactive material authorization verifications as stated in CL-SR-PR-060/2, Outgoing Shipment of Radioactive
Material.
3. Specific to 49 C.F.R. 173.443(c) released conveyances or packages, the Licensee shall: a. Verify each conveyance or package meets the following fixed and non-fixed radioactive contamination limits: i. Internal and external surfaces:
1. Non-Fixed: equal to or less than 2,400 dpm/100 cm2 beta-gamma; 2. Non-fixed: equal to or less than 240 dpm/100 cm2 alpha; and 3. Radiation dose rate: equal to or less than 0.5 mrem/hour (Over)
b. Verify Exclusive Use Instructions, as specified in 49 C.F.R. 173.403, accompany each shipment whether in paper form for truck shipments or on the electronic waybill for rail shipments.
The foregoing conditions shall apply until such time as the license is amended. If you have any questions, please call Boyd Imai at [phone]. Sincerely,
Scott T. Anderson, Director
Division of Waste Management and Radiation Control STA/BMI/km
c: Jeff Coombs, EHS, Health Officer, Tooele County Health Department Bryan Slade, Environmental Health Director, Tooele County Health Department