DRC-2024-007318

16043 Dunbarton Blvd Barnwell, South Carolina 29812 http://www.energysolutions.com
October 23, 2024
ES-BR-24-017
Douglas J. Hansen, Director Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
PO Box 144880 Salt Lake City, UT 84114-4880 RE: Notice of Violation, Administrative Order, and Proposed Assessment of Civil Penalty Letter, Docket # 2403042, Dated September 23, 2024
Dear Mr. Hansen,

This letter is in response to your referenced letter concerning the shipment errors that occurred at the Colorado Interstate Gas project site, where EnergySolutions was contracted by RadPros to manage the shipment of contaminated waste to the Clive Disposal site on December 14, 2023. We sincerely apologize for the errors made by
the EnergySolutions Broker during preparation of this shipment. Compliance with
regulations is of the utmost importance to EnergySolutions and we maintain a zero-tolerance policy for shipment errors. EnergySolutions’ comprehensive Broker training and operations program is designed
with this commitment in mind, as outlined in our policy ES-BR-PR-001 (Exhibit 1). The details of our Broker training program can be found in procedure ES-BR-PR-003 (Exhibit 2), and our operations and shipping requirements are detailed in ES-BR-PR-002 (Exhibit 3). ROOT CAUSE ANALYSIS AND CORRECTIVE ACTIONS The following sections summarize the Root Cause (also referred to as Apparent Cause in some attached Exhibits), the corrective actions taken, the date of violation resolution, actions to prevent similar violations in the future, and our disputes regarding the Notice
of Violation (NOV). These errors were significant enough to warrant a review by our Corrective Action Review Board (CARB) Committee, comprising EnergySolutions Senior Management and Quality Assurance (QA) teams, resulting in five corrective actions directly related to these shipment errors (Exhibit 4).
The First Notification, FN-2023-0175 (Exhibit 5), preceded the Condition Report, CR-2024-0115 (Exhibit 6), which included three additional corrective actions (Exhibit 7).

16043 Dunbarton Blvd Barnwell, South Carolina 29812 http://www.energysolutions.com

Root Cause
EnergySolutions identified the root cause of the shipment errors as Human
Performance Errors, primarily due to inadequate decision-making by the Broker.
Specifically, the Broker failed to adhere to several procedural requirements:
• Inspecting the exterior of shipping packages, as mandated by Steps 4.2.1.5, 4.2.1.12, and Attachment 5.6 of ES-BR-PR-002 for waste shipments.
• Verifying and affixing “Radioactive Material-LSA” markings per Step 4.2.1.10 and Attachment 5.6 of ES-BR-PR-002 for waste shipments.
• Checking the package for correct type, integrity, and potential leakage according to
Step 4.3.1.15 and Attachment 5.6 of ES-BR-PR-002 for waste shipments.
• Ensuring that the Exclusive Use statement was provided to the driver and included in the shipping papers as required by Step 4.3.1.15 and Attachment 5.6 of ES-BR-PR-002.
• Utilizing proper lab results to classify and characterize the material as Exempt Quantity instead of LSA, per Steps 4.1.1 and 4.1.18 of ES-BR-PR-002. All Brokers receive comprehensive training and testing on these procedural
requirements in accordance with EnergySolutions procedure ES-BR-PR-003, “Training
and Certification of Hazardous Material Brokers”.
Additional contributing factors to these errors include: • Inexperience – The Broker had previously handled only four projects (48 shipments) before this incident. Although fully trained and assigned a Senior Broker
as a Mentor, he lacked sufficient experience to manage this type of shipment alone. • Poor Weather Conditions – The site was located on a mountain, making it difficult to access due to winter weather. The road was impassable during the first shipment attempt, and everything was frozen on the day of the shipment. The freezing whether increased the urgency to finish quickly, prevented the ability to detect leaks,
and cleaning the package surface. • Remote Location – The job site was over an hour from the nearest town, with no cellular service or access to necessary supplies, such as adhesive spray or cleaning materials. • Time Constraints – There was a collective urgency among the Broker, Project
Manager, laborers, and truck driver to complete the shipment in one day due to the remote location, weather conditions and potential driver detention charges. Corrective Actions
The Broker errors were documented in Condition Report CR-2024-0115 which led to three corrective actions. Given the seriousness of the issues, a CARB Committee review was conducted, resulting in five additional corrective actions directly linked to the shipment errors. This issue prompted a Quality Assurance surveillance audit of the entire Broker Program, culminating in Condition Report CR-2024-0511, which led to four
further corrective actions and a review of recordkeeping with three corrective actions

16043 Dunbarton Blvd Barnwell, South Carolina 29812 http://www.energysolutions.com
indirectly associated with these shipping errors but contributing to improvements in the Broker Program.
The CARB committee’s Root Cause Analysis, corrective actions taken, and completion
dates are as follows:
CA Number Corrective Action Date Completed
CA-1 The Director of Broker & Training Programs implemented guidance per Section 4.4 of ES-BR-PR-002 for Shipping Errors. This event was classified as a Level 4 compliance error, meeting the criteria for a regulatory NOV. Actions taken against the Broker were documented (Exhibits 1 and 2).
3/1/2024
CA-2 The Broker was immediately restricted from shipping and required to attend additional training sessions, including the
next Broker Requalification class. He will work under a Senior
Certified Broker until he gains more knowledge and experience (Exhibit 8).
2/16/2024
CA-3 The Director of Broker and Training Program will implement Section 4.3.2.1 of ES-BR-PR-001 and submit a report to the Broker Committee regarding the error and remedial actions taken for review (Exhibit 9).
5/8/2024
CA-4 The Director of Broker and Training Program will recommend the use of a Peer Review Checklist for all Brokers implementing ES-BR-PR-002 (Exhibit 2).
5/8/2024
CA-5 A Lessons Learned communication will be issued to all Brokers, detailing the identified inappropriate actions (IA), underlying causes, and preventive measures (Exhibit 10).
5/8/2024
Corrective Actions and completion dates for CR 2024-0115:

CAP Number Corrective Action Date Completed
CRA01-2024-
0478
Implement an employee performance review per ES-BR-PR-001 with remedial actions. This includes fostering self-critique
and feedback opportunities to enhance understanding of
errors and management expectations (Exhibit 8).
5/3/2024
CRA01-
2024-0479
Revise ES-BR-PR-002 to incorporate a Peer Review
Checklist for manifesting paperwork. This checklist will assist Brokers in completing required tasks and will require peer checks prior to shipment authorization (Exhibit 2 is the revised procedure).
6/8/2024
CRA01-2024-0480
Implement a Lessons Learned communication to all ES Brokers, detailing the causes of the event and corrective actions taken to prevent future violations (Exhibit 10).
4/26/2024

16043 Dunbarton Blvd Barnwell, South Carolina 29812 http://www.energysolutions.com
Preventing Similar Violations
These errors necessitated an evaluation of the extent of the condition. An internal QA
Surveillance Audit was conducted, resulting in multiple corrective actions and recommendations for enhancing the entire Broker Program. Not list herein because the corrective actions were not directly related to these shipment errors. Consequently, three Broker Procedures, ES-BR-PR-001, 002, and 003, were revised to improve
Broker training, requalification, operation tools, and recordkeeping.
A Lessons Learned memo was distributed to all Brokers, highlighting the following key points:
• Description of the errors
• Strategies to prevent similar mistakes
• Mandatory peer checking
• Importance of the Broker Operating Procedure Checklists as error prevention tools Disputes with NOVs

EnergySolutions wishes to dispute the following items within the NOV:
• Finding 11: Per 49 CFR 173.427(b)(4), LSA-II solids or liquids can be shipped in an IP-I container as long as the activity is less than the A2 quantity (from the table in 49
CFR 173.434) and is shipped as exclusive use. While EnergySolutions acknowledges that the totes did not meet all requirements due to the closure seal and damaged drain plug, EnergySolutions contends that the exclusive use conditions were met through verbal instructions to the driver and checking the exclusive use block on the shipping form.
• Finding 21b: In conjunction with our dispute of Finding 11, EnergySolutions believes that 600 points should not be assessed since the IP-I package is compliant.

16043 Dunbarton Blvd Barnwell, South Carolina 29812 http://www.energysolutions.com
EnergySolutions sincerely apologizes for the errors made during this shipment and is confident that the corrective actions outlined above will prevent future occurrences. As allowed within the Compliance Evaluation, EnergySolutions would like the opportunity to
meet with the Director to further discuss the corrective actions described within this
letter. Sincerely,
Mark Lewis
Director of Broker and Training Programs EnergySolutions C: Vern Rogers
Tim Orton
Broker Program files

Exhibit 1

Broker Training Program

ES-BR-PR-001

ES-BR-PR-001
EnergySolutions Broker Program
Administration
Revision 8

Authored By: Signature on file

Donnie James, Broker Training Specialist

Date
Reviewed By: Signature on file
Larry Conway, Broker Supervisor Date
Approved By: Signature on file
Mark Lewis, Broker Committee Chairperson Date

New Procedure
Title Change
X Procedure Revision
Procedure Rewrite

Electronic documents, once printed, are uncontrolled and may become outdated. Refer to the intraweb or the Document Control authority for the correct revision.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 2 of 22
Table of Contents
Section Page
1. PURPOSE AND SCOPE .........................................................................................3
1.1 Purpose .....................................................................................................................3
1.2 Scope ........................................................................................................................3
2. REFERENCES AND FORMS ................................................................................3
3. GENERAL ...............................................................................................................4
3.1 Definitions................................................................................................................4
3.2 Responsibilities ........................................................................................................6
3.3 Precautions and Limitations .....................................................................................7
3.4 Records ....................................................................................................................7
4. REQUIREMENTS AND GUIDANCE ...................................................................8
4.1 Broker Committee Procedures .................................................................................8
4.2 Broker/Shipper Errors ..............................................................................................9
4.3 Remedial Actions ...................................................................................................12
5. DEFINITION AND SCOPE OF AUTHORITY ...................................................13
5.1 Definition and Scope of Authority – Assistant Broker ..........................................13
5.2 Definition and Scope of Authority – Senior Assistant Broker ..............................14
5.3 Definition and Scope of Authority – Conditional Broker ......................................16
5.3 Definition and Scope of Authority – Certified Broker ..........................................17
5.4 Definition and Scope of Authority – Senior Certified Broker ...............................18
5.6 Definition and Scope of Authority – Broker Supervisor .......................................18
5.7 Definition and Scope of Authority – Contract Shipper .........................................19
6. ATTACHMENT ....................................................................................................20
6.1 Shipment Summary Report (Example) ..................................................................21

ES-BR-PR-001 Broker Program Administration Revision 8

Page 3 of 22
1. PURPOSE AND SCOPE
1.1 Purpose
The purpose of this procedure is to specify the requirements for administration of the EnergySolutions Broker Program. EnergySolutions has invested considerable effort and money over the years developing the company program for the
shipment of radioactive and hazardous materials and maintaining the program to
meet current regulatory requirements. Therefore, the procedures listed in Reference 2.1 and 2.2 are considered proprietary and are not released outside the company without the consent of the Broker Committee Chairperson.
1.2 Scope This procedure applies to all EnergySolutions employees who ship hazardous materials or EnergySolutions employees that make arrangements for the shipping of hazardous materials. The EnergySolutions Broker Program is to be utilized at
all EnergySolutions locations within the United States, and projects where EnergySolutions is responsible for the shipping of hazardous materials. If EnergySolutions is responsible for or, if an EnergySolutions permit number (i.e., Generator Site Access Permit Number, South Carolina Waste Transport Permit Number, Tennessee License for Delivery, etc.) is used for a radioactive and/or
hazardous material shipment, the Broker or Shipper must be EnergySolutions Certified in accordance with reference 2.2. Hazardous material shipments (i.e., radioactive material, radioactive waste, hazardous waste and mixed-hazardous waste) shall be performed by EnergySolutions employees that are certified under this program. Contract Shippers shall not be used to ship hazardous materials
unless specifically approved by the EnergySolutions Broker Program, in accordance with guidelines outlined in Section 5.7. 2. REFERENCES AND FORMS
2.1 ES-BR-PR-002, Operating Procedure for Brokering of Hazardous Materials [Proprietary] 2.2 ES-BR-PR-003, Procedure for Training and Certification of Hazardous
Materials Brokers [Proprietary]
2.3 ES-AD-PR-005, First Notifications 2.4 ES-AD-PR-008, Condition Reports

2.5 Quality Assurance Records Broker Program
ES-BR-PR-001 Broker Program Administration Revision 8

Page 4 of 22
3. GENERAL

3.1 Definitions. 3.1.1 Assistant Broker – An Assistant Broker is an individual that qualifies according to the prerequisites and training requirements outlined in 49
CFR 172 Subpart H (Hazmat Employee Training) and Reference 2.2 for
the highway shipments of radioactive material and as a hazmat . 3.1.2 Senior Assistant Broker – A Senior Assistant Broker is an individual certified by the Broker Committee Chairperson based on
recommendation by the Broker Supervisor. The Senior Assistant Broker must meet the prerequisite and training requirements for the shipment of specific hazardous material and as a hazmat employee. A Senior Assistant Broker shall have met the requirements of Reference 2.2.
3.1.3 Certified Broker – A Certified Broker is an individual that is certified by the Broker Committee Chairperson by recommendation of the Broker Supervisor and concurrence of the Broker Committee. The individual must meet the prerequisites and training requirements
outlined in 49 CFR 172 Subpart H (Hazmat Employee Training), Reference 2.2 and are authorized to ship certain hazardous materials as defined in Sections 5.3 - 5.4. 3.1.4 Conditional Broker – A Broker candidate that has qualified per DOT
49 CFR 172 Subpart H within the last year and meets a minimum level of training and experience, as defined in Section 5.3. Conditional Brokers must be approved by the Broker Executive Committee. Once approved, the Conditional Broker will be assigned a Mentor, Step 3.1.17, and, with the help of the Mentor, is authorized to make the same
shipments as a Certified Broker, Step 3.1.3. Conditional Brokers must attend one of the next two Broker Week 2 classes. 3.1.5 Senior Certified Broker – A Senior Certified Broker is an individual
certified by the Broker Committee Chairperson based on
recommendation by the Broker Supervisor to have met the prerequisite and training requirements for the shipment of specific hazardous material and as a hazmat employee. A Senior Certified Broker shall have met the requirements of Reference 2.2.

ES-BR-PR-001 Broker Program Administration Revision 8

Page 5 of 22
3.1.6 Broker Committee – The Broker Committee oversees the brokering activities. Responsibilities include Brokering procedures preparation
and review, training, testing, and error review. The Committee has
representatives from each of the business groups that are affected by broker activities. 3.1.7 Broker Committee Chairperson – The Chairperson has responsibility
for all Broker Committee activities, including management of the
Broker Program. The Broker Committee Chairperson or designee maintains a list of committee members. The committee member list is a tracking tool only and is not consider a record. The Broker Supervisor may act as the Broker Committee Chairperson when the Broker
Committee Chairperson is not available.
3.1.8 EnergySolutions Broker Program – The EnergySolutions Broker Program consists of the procedures for packaging and shipping hazardous materials and the training and certification of individuals to
perform these functions. The Broker Program is contained in this procedure and References 2.1 and 2.2. The Broker Program may also include other special shipping procedures provided they have received concurrence from the Broker Committee.
3.1.9 Broker Supervisor – The Broker Supervisor is appointed by the Broker Committee Chairperson and is responsible to ensure decisions made by each Certified Broker are not affected by operational concerns. Certified Brokers are indirectly supervised technically, as necessary, by the Broker Supervisor when performing such work. The Broker
Supervisor’s responsibilities include review of the Certified Broker’s work; assisting in the preparation of Broker projects; consultation on regulations and correct methods of shipping and inspection; and ensuring that the Certified Brokers are properly trained. The Broker Supervisor shall designate an alternate to perform the Broker
Supervisor’s functions when not available (i.e., Mentor, or experienced Certified Broker). The Broker Supervisor shall be a Certified Radioactive Material and Mixed-Waste Broker.
3.1.10 Broker Committee Member – A member has broad knowledge and
experience in the areas of shipment preparation, shipping documentation, shipping procedures and regulations, and transportation of hazardous materials. Members are designated by the Broker Committee Chairperson and are approved by the Broker Committee.
The Chairperson will identify members that may chair a Broker Oral
Board examination. Members will be responsible for ensuring that assigned action items associated with their organizations are completed.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 6 of 22
3.1.11 Broker Executive Committee – The Broker Executive Committee consists of the Broker Committee Chairperson, Broker Supervisor, and
Broker Trainer. The Broker Executive Committee can make the
decisions required by this procedure on a contingent basis, but must present to the Broker Committee at the next Broker Committee meeting.
3.1.12 Error – Federal, State or procedural non-conformance or potential non-
conformance as determined by the Broker Supervisor, or designee that is detected after the shipment has been released and in the care of the carrier or consignor.
3.1.13 Notice of Violation – A notice of violation in the form of a letter with or without accompanying fines levied and/or suspension of permits issued by a State or Federal Agency. 3.1.14 Quorum – A quorum of the Broker Committee consists of the Broker
Committee Chairperson or designee plus (3) other Broker Committee members. 3.1.15 Voting – After discussions to obtain a consensus of the Broker Committee, Broker Committee decisions and approvals require a
quorum. Approvals and decisions are based on a simple majority of members present at the meeting. In cases of a tied vote, the Broker Committee Chairperson has the deciding vote. 3.1.16 Contract Shipper – A Contract Shipper is an individual approved by the
Broker Committee based on recommendation by the Broker Committee Chairperson or Broker Supervisor or to have met a minimum level of training and experience, as defined in Section 5.7.2, for the shipment of hazardous materials and as a hazmat employee. A Contract Shipper shall have been trained similar to the requirements of Reference 2.2.
and are authorized to ship hazardous materials on a project by project basis in accordance with specific guidelines prepared by the designated supervising Certified Broker.
3.1.17 Mentor – A senior or very experienced Broker that has been assigned
by the Broker Supervisor or Broker Committee Chairman to a newly trained and certified Broker and a Conditional Broker in order to assist or mentor until the new Certified Broker and Conditional Broker gains experience and confidence in shipping.

3.2 Responsibilities
ES-BR-PR-001 Broker Program Administration Revision 8

Page 7 of 22
3.2.1 Broker Committee Chairperson – The chairperson has responsibility for all Broker Committee activities, including management of the Broker
Program.
3.2.2 Broker Supervisor – Responsibilities include periodic and as-needed reviews of the Certified Broker’s work; assisting in the preparation of Broker projects; consultation on regulations and correct methods of
shipping and inspection; and ensuring that the Certified Brokers are
properly trained. 3.2.4 Project Managers or Equivalent (e.g., D&D Waste Managers) – Must ensure all EnergySolutions projects that require the Brokering of
hazardous materials be performed by EnergySolutions Certified Brokers that have been trained and certified in accordance with reference 2.2. 3.2.5 Broker Committee Member – Are responsible for ensuring that
assigned action items associated with their organizations are completed.
3.2.6 Mentor – A newly Certified and inexperienced Broker and a Conditional Broker will be assigned a Mentor that will oversee shipment activities, help perform all of the pre-shipment preparations,
calculations, classification, package determination, and etc.; ask and answer any questions; review work and shipping papers; assist with profiles approvals and portal entries; and perform the final Peer review prior to shipment release. The Mentor will remain assigned to the inexperienced Certified Broker and Conditional Broker until the
Certified Broker and Conditional Broker feels comfortable making shipments with only the final Peer review and Mentor feels the inexperienced Certified Broker and Conditional Broker no longer needs this level of oversite.
3.2.7 Broker Trainer – Is an employee that has been appointed by the Broker
Committee Chairperson and approved by the Broker Committee to train EnergySolutions Certified Brokers. The Broker Trainer is a member of the Broker Executive Committee. 3.3 Precautions and Limitations
None 3.4 Records

Records generated by this procedure shall be controlled in accordance with Reference 2.5 and, as required, applicable Project specific procedure. This
ES-BR-PR-001 Broker Program Administration Revision 8

Page 8 of 22
includes Shipment Discrepancy Records, Shipment Summary Report, Committee Minutes, and Records of Corrective Action.

4. REQUIREMENTS AND GUIDANCE 4.1 Broker Committee Procedures
The Broker Committee will operate under the following guidelines.
4.1.1 Any interested individual with a Broker issue of concern may attend a Broker Committee meeting to present the issue, but must be authorized by the Broker Committee Chairperson.
4.1.2 All Broker Committee decisions and recommendations need approval of a quorum of the Committee. 4.1.3 The following Broker topics should be discussed at each regularly
scheduled Broker Committee meeting. 4.1.3.1 Previous meeting minutes approved. 4.1.3.2 Broker Executive Committee actions.
4.1.3.3 Recent Broker errors and corrective action. 4.1.3.4 Committee membership
4.1.3.5 Procedure status of:
• Broker Operating Procedures
• Broker Training Procedure
• Broker Program Administration
4.1.3.6 Broker training status 4.1.3.7 Broker activity status

4.1.3.8 Emerging regulatory requirements and industry events. 4.1.4 Broker Committee meeting minutes shall be recorded and distributed to the Broker Committee members for dissemination in their
organizations. Minutes shall also be made available to Certified
Brokers and Senior Certified Brokers on the Company network. Broker Committee meeting minutes to be controlled in accordance with Reference 2.5.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 9 of 22
4.2 Broker Errors

It is the responsibility of all Brokers to report ALL shipping errors to their Broker Supervisor immediately. Broker Program errors are actions or errors that occur during the performance of or arrangements for the shipping of hazardous materials and do not comply with approved Broker procedures. Shipping errors
that occur must be managed appropriately. This includes assigning a severity
level, making initial reports/notifications, following up with the Broker or Project Manager, and documenting and distributing lessons-learned to prevent recurrence of the error. All Broker Errors shall be documented in the Condition Report (CR) System in accordance with Reference 2.4.
4.2.1 Error Severity Levels 4.2.1.1 Level 1 — Administrative oversight, minor calculation mistake or other minor errors that can be corrected by
revising the paperwork, preferably self-reported prior to receipt.
4.2.1.2 Level 2 — Compliance issue/error identified in transit or by consignor. It may also result in actions taken by the consignee such as restrictions on shipping by
EnergySolutions.
4.2.1.3 Level 3 — Compliance error that results in a telephone warning call, written warning letter from a regulatory agency, site restriction and or fine associated with the Brokers actions.
4.2.1.4 Level 4 — Compliance error that results in a Notice of Violation letter from a regulatory agency. 4.2.1.5 Broker Program – Assigned to individuals or groups that are not EnergySolutions Certified Brokers within
EnergySolutions that perform or make arrangements for the shipping of hazardous materials and do not comply with approved Broker Program procedures.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 10 of 22
4.2.2 Actions to be taken in the event of an error:

4.2.2.1 The Broker Committee Chairperson or Broker Supervisor is the primary point-of-contact for inquiries from any individual or organization regarding actual or potential shipping errors. In the event that an individual Broker is
contacted by any Federal, State, Local, or other authority
regarding an actual or potential shipping error, the Broker may provide basic factual information concerning the shipment in question, but then must immediately perform the appropriate notifications as required by this procedure.
Note: Only the Broker Committee Chairperson, Broker Supervisor, or designee are authorized to represent EnergySolutions in regard to the mitigation of any actual or potential severity Level 4 shipping error.
4.2.2.2 All actual or potential shipping errors must be reported as soon as possible.
4.2.2.2.1 Most shipping errors require reporting of the error in accordance with Reference 2.3.
4.2.2.2.2 Certain minor errors (Severity Level 1 only)
may not require reporting in accordance with Reference 2.3 and can be reported only to the Broker Supervisor. The requirements for minor errors are addressed further below.
Note: If any doubt exists as to whether a
shipping error requires notification, submit the notification. The appropriateness of the notification will be discussed at the Broker Committee meeting.
4.2.2.3 All written correspondence regarding shipping errors received from regulatory authorities shall be immediately forwarded to the Broker Committee Chairperson and
Broker Supervisor.
4.2.2.4 Minor errors that are reported to the Broker Supervisor do not require submittal of a First Notification Form as required by Reference 2.3, and are limited to the following:

4.2.2.4.1 Minor paperwork errors that are identified by a site operator and are immediately
ES-BR-PR-001 Broker Program Administration Revision 8

Page 11 of 22
corrected to the satisfaction of all parties via telephone communication.

Examples of these minor errors include, but are not limited to: not checking required blocks, simple mathematical errors that do not alter disposal/processing requirements,
not completely filling out administrative
information, and other minor paperwork errors that do not additionally impact on site or transportation requirements.
4.2.2.4.2 Simple clarification of minor technical questions related to a shipment that is immediately clarified to the satisfaction of all parties via telephone communication.
Examples of these errors include, but are not limited to: processing methodology, packaging questions, communication requirements, and other minor technical issues that only clarify the manner in which
the shipment was prepared.
Note: Any interaction regarding an actual or potential error with federal, state, or local regulatory authorities warrants the implementation of the notification
requirements of Reference 2.3. 4.2.2.5 he responsible Certified Broker shall notify the Broker Supervisor as soon as possible of all errors.
4.2.2.5.1 The initial notification may be verbal; however, leaving a message on a voice mail system does not satisfy this requirement.
4.2.2.5.2 A follow-up written report shall be filed as
required in accordance with Section 4.3. 4.2.2.6 The Broker Supervisor to ensure all errors reported by the Certified Broker are processed and recorded in accordance
with Reference 2.3 and Reference 2.4.

ES-BR-PR-001 Broker Program Administration Revision 8

Page 12 of 22
4.2.2.7 If Broker responsibilities are improperly executed and negligence is shown on the part of the Broker, appropriate
action shall be taken in accordance with Section 4.3.
4.2.2.8 If a Broker’s certification is suspended, he/she will not be reinstated until he/she is retrained and recertified in accordance with Section 4.3.4 and Reference 2.2.

4.2.2.9 The Broker Supervisor shall ensure all shipping errors are included in the Shipment Summary Report (Attachment 6.1) and are to be controlled in accordance with Reference 2.5.
4.3 Remedial Actions 4.3.1 Errors shall be reviewed and actions will be taken as necessary by the Broker Supervisor and the Broker’s Supervisor/Manager as soon as
possible after the error. The error and corrective action/lesson learned report shall be reviewed by the Broker Committee. Actions taken will be documented in the minutes. 4.3.2 For Severity Level 2, 3 or 4 errors in shipping radioactive materials,
Sections 4.3.2.1 and 4.3.2.2 apply.
4.3.2.1 The Certified Broker shall immediately review the error with the Broker Supervisor or designee and the Certified Broker’s Supervisor/Manager and within a timely manner after shipment error submit a written report (lessons
learned) for review by the Broker Committee. The Certified Broker shall coordinate with the Broker Supervisor to ensure the lessons-learned report is adequate to address the error and corrective actions.
4.3.2.2 The written lessons-learned report shall include a detailed
explanation of the error, suspected or probable cause(s), circumstances surrounding the error (e.g., package/vehicle damage, radiation/contamination levels and any changes, load shifting, environmental release of hazardous materials,
procedural issues, security issues, etc.), and a proposal for
corrective action to ensure a similar error does not occur in the future. 4.3.2.3 The Broker Committee shall review the lessons-learned
report and assign corrective action. Actions taken will be
documented in the meeting minutes.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 13 of 22
4.3.2.4 The Broker responsible for the error shall explain to the Broker Committee (in person or by telephone) the details of
the error, the lessons-learned report, and the corrective
action taken to prevent recurrence. 4.3.3 If a Broker makes two Level 4 errors in a 12-month period the Broker’s certification shall be suspended.

4.3.4 The Broker Committee may suspend a Broker’s certification based on performance discrepancies or errors. These include, but are not limited to, violation of procedures or regulations, performance deficiencies, failure to meet the Broker Program objectives, ethics deficiencies,
repetitive errors, or any combination thereof. If a Broker’s certification is suspended, he/she will be reinstated upon successful completion of additional training, demonstrated correction of identified deficiencies, and approval by the Broker Committee. The
training and demonstration requirements shall be determined by the Broker Committee and communicated to the Broker and his/her supervisor/manager at the time the suspension is imposed. 5. DEFINITION AND SCOPE OF AUTHORITY
5.1 Definition and Scope of Authority — Assistant Broker 5.1.1 Assistant Broker - is an employee that qualifies according to the prerequisites and training requirements outlined in 49 CFR 172 Subpart
H (Hazmat Employee Training) and Reference 2.2 for the highway shipments of radioactive material and as a hazmat employee. 5.1.2 Scope of Authority — An Assistant Broker can only perform the following functions:
5.1.2.1 Prepare and ship non-waste radioactive materials that meet the following DOT Categories:
• UN2910, Radioactive material, excepted package-
limited quantity of material, 7, (49 CFR 173.421).
• UN2911, Radioactive material, excepted package-instruments or articles, 7, (49 CFR 173.424).
ES-BR-PR-001 Broker Program Administration Revision 8

Page 14 of 22
• UN2909, Radioactive material, excepted package-
articles manufactured from natural uranium or depleted
uranium or natural thorium, 7, (49 CFR 173.426).
• UN2908, Radioactive material, excepted package-empty packaging, 7, (49 CFR 173.428)
5.1.2.2 Ship other radioactive materials or waste under the direct
supervision of a Certified Broker, Senior Certified Broker, or Broker Supervisor with the approval of the Broker Executive Committee
5.1.2.3 Assist a Certified Broker or Senior Certified Broker with shipments of radioactive material consigned for disposal or transfer. 5.1.3 An Assistant Broker is restricted from the following:
5.1.3.1 Shipping waste material without Executive Committee written approval and without direct supervision of a Certified Broker, Senior Certified Broker, or Broker Supervisor. Documentation to be maintained and controlled
by the Broker Committee Chairperson. 5.1.3.2 Independently shipping any hazardous material for, storage, processing or transfer to other licensed facilities, unless under the direct supervision of a Certified Broker or Senior
Certified Broker 5.1.3.3 Other restrictions as may be applied. 5.2 Definition and Scope of Authority — Senior Assistant Broker
5.2.1 Senior Assistant Broker - is an employee certified by the Broker Committee Chairperson based on recommendation by the Broker Supervisor. The Senior Assistant Broker must meet the prerequisite and training requirements for the shipment of specific hazardous
material and as a hazmat employee. A Senior Assistant Broker shall have met the requirements of Reference 2.2.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 15 of 22
5.2.2 Scope of Authority — A Senior Assistant Broker can only perform the following functions:

5.2.2.1 Prepare and ship radioactive materials that meet the following:
• Materials that are not defined as “Radioactive material”
per 49 CFR 173.403.
• Radioactive materials that are less than the limits of 49 CFR 173.425.
• “Empty Packagings” per 49 CFR 173.428.
• Radioactive waste that is less than the limits of 49 CFR 173.425 and shipped to the Clive Disposal Facility.
5.2.2.2 Ship other radioactive materials or waste under the direct
supervision of a Certified Broker, Senior Certified Broker, or Broker Supervisor with the approval of the Broker Executive Committee
5.2.2.3 Assist in the preparation and shipment of other than exempt
quantities of radioactive waste for disposal or radioactive materials for transfer under the direct supervision of a Certified Broker, Senior Certified Broker, or Broker Supervisor.

5.2.3 A Senior Assistant Broker is restricted from the following: 5.2.3.1 Shipping waste material that exceeds the limits of 49 CFR 173.425 or is consigned to a facility other than the Clive
Disposal Facility.
5.2.3.2 Shipping waste material or shipping to another disposal site than Clive without Executive Committee written approval and without direct supervision of a Certified Broker, Senior
Certified Broker, or Broker Supervisor. Documentation to
be maintained and controlled by the Broker Committee Chairperson. 5.2.3.3 Independently shipping any hazardous material consigned
for disposal, storage, incineration, or other method of
releasing responsibility that exceeds the limits of 49 CFR 173.425 or is otherwise defined as a hazardous material by DOT.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 16 of 22
5.3 Definition and Scope of Authority — Conditional Broker
5.3.1 Conditional Broker - is an employee that is authorized by the Broker
Executive Committee, due to recent training and past experience, to make the same type of radioactive material and waste shipments as a Certified Broker based on recommendation by the Broker Supervisor to have met the prerequisite and training requirements for the shipment of
specific hazardous material and as a hazmat employee. A Conditional
Broker shall have met the requirements of Reference 2.2. A Broker candidate that has qualified per DOT 49 CFR 172 Subpart H within the last year and meets a minimum level of training and
experience, as defined in Section 5.7.2. Conditional Brokers must be approved by the Broker Executive Committee once all required training is completed. Once approved, the Conditional Broker will be assigned a Mentor, Step 3.1.17, and, with the help of the Mentor, is authorized to make the same shipments as a Certified Broker, Step 3.1.3.
Conditional Brokers must attend one of the next two Broker Week 2 classes. 5.3.2 Scope of Authority
5.3.2.1 A Conditional Broker can perform the following functions: Ship any type of radioactive material for transfer and disposal, except for mixed-waste and fissile materials which do not meet the fissile exceptions in 49 CFR 173.453
5.3.2.2. A Conditional Broker must comply with the following restrictions:
• During Conditional Broker status, each Conditional
Broker must review their work prior to, during, and/or
after each shipment with an experienced Certified Broker designated by the Broker Supervisor.
• All highway route controlled quantity (HRCQ) shipments must be reviewed prior to each shipment
with the Broker Supervisor or designee’s.

• No fissile material may be shipped by a Conditional
Broker which do not meet the fissile exceptions in 49
CFR 173.453
• Ship mixed low-level radioactive materials only if trained, experienced, and qualified to do so.
ES-BR-PR-001 Broker Program Administration Revision 8

Page 17 of 22
• Ship non-radioactive hazardous material only if trained,
experienced, and qualified to do so.
5.3.2.3 A Conditional Broker will be assigned a Mentor in accordance with Step 3.2.6 until fully Certified.
5.4 Definition and Scope of Authority — Certified Broker
5.4.1 Certified Broker - is an employee certified by the Broker Committee Chairperson based on recommendation by the Broker Supervisor to have met the prerequisite and training requirements for the shipment of
specific hazardous material and as a hazmat employee. A Certified
Broker shall have met the requirements of Reference 2.2. 5.4.2 Scope of Authority
5.4.2.1 A Certified Broker can perform the following functions:
Ship any type of radioactive material for transfer and disposal, except for mixed-waste and fissile materials in concentrations greater than that incidental to other
radioactive materials.
5.4.2.2. A Certified Broker must comply with the following restrictions:
• During a period after certification, each Certified
Broker must review their work prior to, during, and/or after each shipment with their assigned Mentor or Broker Supervisor as designated by the Broker Committee.
• All highway route-controlled quantity (HRCQ)
shipments must be reviewed prior to each shipment with the Broker Supervisor or designee.
• No fissile material may be shipped by a Broker in concentrations greater than that incidental to other
radioactive materials.
• Ship mixed low-level radioactive materials only if certified to do so.
• Ship non-radioactive hazardous material only if
certified to do so.
5.4.2.3 A new, inexperienced Certified Broker will be assigned a Mentor in accordance with Step 3.2.6 until the Mentor and
ES-BR-PR-001 Broker Program Administration Revision 8

Page 18 of 22
Broker are comfortable with making shipments without this level of oversite.

5.5 Definition and Scope of Authority — Senior Certified Broker 5.5.1 Senior Certified Broker - is an employee certified by the Broker Committee Chairperson based on recommendation by the Broker
Supervisor to have met the prerequisite and training requirements for
the shipment of specific hazardous material and as a hazmat employee. A Senior Certified Broker shall have met the requirements of Reference 2.2.
5.5.2 Scope of Authority 5.5.2.1 A Senior Certified Broker can perform the following functions:
Ship all types of radioactive material.
5.5.2.2 A Senior Certified Broker must comply with the following restrictions:
• Ship mixed low-level radioactive materials only if
certified to do so.
• Ship non-radioactive hazardous material only if certified to do so. 5.6 Definition and Scope of Authority —Broker Supervisor
5.6.1 Broker Supervisor - is an employee appointed by the Broker Committee Chairperson. To ensure decisions made by each Broker are not affected by operational concerns, Brokers are supervised technically by the Broker Supervisor when performing such work. The Broker
Supervisor’s responsibilities include review of the Broker’s work; assisting in the preparation of Broker projects; consultation on regulations and correct methods of shipping and inspection; and ensuring that the Brokers are properly trained. The Broker Supervisor shall designate an alternate to perform the Broker Supervisor’s
functions when not available. The Broker Supervisor shall be a Certified Radioactive Material and Mixed-Waste Broker. 5.6.2 Scope of Authority

5.6.2.1 The Broker Supervisor’s responsibilities include:
• Assisting in the preparation of Broker projects
ES-BR-PR-001 Broker Program Administration Revision 8

Page 19 of 22
• Consultation on regulations and correct methods of
shipping and inspection
• Ensuring that the Brokers are properly trained
• Preparing Shipment Summary Reports

5.7 Definition and Scope of Authority — Contract Shipper 5.7.1 Contract Shipper - is a non-employee approved by the Broker Committee Chairperson based on recommendation by the Broker Supervisor or have
met a minimum level of training and experience, as defined in Section
5.7.2, for the shipment of specific hazardous materials and as a hazmat employee. A Contract Shipper shall have been trained similar to the requirements of Reference 2.2.
5.7.2 Minimum Training and Experience
A Contract Shipper must have achieved the following minimum training and experience requirements:
5.7.2.1 Attended DOT/NRC training within the past year
conducted by a credible training organization and passed the final exam with 90% or greater. Proof is required. 5.7.2.2 At least five (5) years of experience in radioactive material transportation and waste management.
5.7.2.3 Made shipments of radioactive material similar to the type
that EnergySolutions is assigning him to ship. 5.7.3 Conditions of Utilization
A Contract Shipper can only be approved and utilized under the following
conditions: 5.7.3.1 Met the minimum training and experience condition as defined in Section 5.7.2
5.7.3.2 Been recommended by the Broker Supervisor and approved
by the Broker Chairperson per Section 5.7.1 5.7.3.3 Company has exhausted all options of utilizing an EnergySolutions Certified Broker 5.7.3.4 Only authorized on a project-by-project basis
5.7.3.5 The Contract Shipper is closely supervised by an
EnergySolutions Certified Broker that has scoped the project, prepared guidelines in accordance with the Project needs on how the Contract Shipper will perform work, and
ES-BR-PR-001 Broker Program Administration Revision 8

Page 20 of 22
will review all work and shipping papers prior to shipments.

5.7.4 Scope of Authority 5.7.4.1 A Contract Shipper can perform the following functions:
Ship any type of radioactive material for transfer and
disposal, up to the limits of a Certified Broker per Sections 5.4 or 5.5, authorized by the Broker Chairperson, Broker Supervisor, and the designated Certified Broker that will be closely supervising the Contract Shipper on the specific
project in accordance with Section 5.7.3.5. 6. ATTACHMENT 6.1 Shipment Summary Report (Example)
ES-BR-PR-001 Broker Program Administration Revision 8

Page 21 of 22
Attachment 6.1 Shipment Summary Report (Example)

Year: Shipment Summary Report
*SHIPMENTS BROKERED BY ENERGYSOLUTIONS BROKERS
Broker Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec YTD

Total
Assistant Broker

Total

Total for All Brokers
ES-BR-PR-001 Broker Program Administration Revision 8

Page 22 of 22

Shipment Summary Report: ENERGYSOLUTIONS BROKER ERRORS - DETAILS (Example)
Broker Error Disposition/Resolution & CR #

Exhibit 2

Training and Certification of Brokers

ES-BR-PR-003

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the intraweb or the Document Control authority for the correct revision.
ES-BR-PR-003

PROPRIETARY INFORMATION: This document contains proprietary information and
is not to be released or copied without the permission of EnergySolutions.

Training and Certification of Hazardous
Material Brokers
Revision 7

Authored By: Signature on file
Donnie James, Broker Training Specialist Date
Reviewed By: Signature on file
Larry Conway, Broker Supervisor Date
Approved By: Signature on file
Mark Lewis, Broker Committee Chairperson Date

Non-Proprietary New
X Proprietary Title Change
X Restricted Information X Revision
Rewrite
Cancellation

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 2 of 36

Table of Contents

Section Page
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 ........................................................................................................4
3.3 Precautions and Limitations .....................................................................................4
3.4 Records ....................................................................................................................5
4. REQUIREMENTS AND GUIDANCE ...............................................................................5
4.1 Prerequisites .............................................................................................................5
4.2 Training Sequence ...................................................................................................8
4.3 Approvals and Authorizations ...............................................................................12
4.4 Recertification ........................................................................................................13
5. ATTACHMENTS AND FORMS......................................................................................16
5.1 Training Objectives ................................................................................................17
5.2 Broker Training Record .........................................................................................21
5.3 Broker Training Forms ..........................................................................................27
5.4 Mixed Low-Level Material/Waste Shipping .........................................................31
5.5 Non-Radioactive Hazardous Material/Waste Shipping .........................................32
5.6 Radioactive Material and Dangerous Good Shipments by Air (IATA) ................33
5.7 Radioactive Material Shipments by Water ............................................................35
5.8 Broker Qualification Status Report (Example) ......................................................36

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 3 of 36

1. PURPOSE AND SCOPE

1.1 Purpose
This procedure provides guidelines for the training and certification of
EnergySolutions Hazardous Material Assistant Broker, Senior Assistant Broker,
Certified Broker, Senior Certified Broker, and Broker Supervisor.

1.2 Scope
This procedure applies to all EnergySolutions employees who ship hazardous
materials. The EnergySolutions Broker Program is to be utilized at all
EnergySolutions locations within the United States, and projects where
EnergySolutions is responsible for the shipping of hazardous materials.
Hazardous material shipments (i.e. radioactive material, radioactive waste,
hazardous waste and mixed-hazardous waste) shall be performed by
EnergySolutions employees that are certified under this program. Contract
Brokers shall not be used to ship hazardous materials unless specifically approved
by the EnergySolutions Broker Program.

2. REFERENCES

2.1 ES-AD-PR-005, First Notification

2.2 ES-BR-PR-002, Operating Procedure for Brokering of Hazardous Materials

2.3 ES-BR-PR-001, EnergySolutions Broker Program Administration

2.4 HNF-PRO-166, Transportation Safety Training

2.5 49 CFR, Parts 100-178

2.6 10 CFR, Parts 0-199

2.7 49 CFR, Parts 385-397

2.8 40 CFR, Parts 260-299

2.9 33 CFR, Part 165

2.10 Dangerous Goods Regulations, International Air Transport Association (IATA
DGR)

2.11 International Maritime Dangerous Goods (IMDG) Code

2.12 DOE Order 460.1B, Packaging and Transportation Safety

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 4 of 36

2.13 DOE 460.2A, Department Materials Transportation and Packaging Management

2.14 ANI Guideline 15-02, Transportation of Radioactive Materials

3. GENERAL

3.1 Definitions

3.1.1 Assistance - Assistance is performing any of the Department of
Transportation (DOT) communication requirements for an experienced
Certified Broker. The communication requirements include markings,
labels, placards, or shipping paper preparations. Assistance also implies
that the shipper does not rely on the Broker to take responsibility for the
preparation and shipping of radioactive material. Assisting an
inexperienced shipper in packaging, shipping, or DOT communications
requires a Certified Broker. If the Broker takes responsibility for the
shipment, the Broker must be a Certified Broker or Senior Certified
Broker. Processing or packaging radioactive material/waste does not
constitute assistance and does not require any Certified Broker
qualifications unless the processing and/or packaging includes compliance
with DOT communications and shipping.

3.1.2 Examination Board - The examination board shall consist of at least three
eligible individuals and shall include at least one Broker Committee
member and one Certified Broker. Eligible individuals include Certified
Brokers, Senior Certified Brokers, Broker Committee Members, and
individuals designated by the Broker Committee Chairperson.

3.2 Responsibilities

None

3.3 Precautions and Limitations

All EnergySolutions employees who ship hazardous materials as part of their
employment responsibilities must comply with this procedure and procedure
number ES-BR-PR-001, EnergySolutions Broker Program Administration.
Brokers can only ship the materials that are authorized by their certifications.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 5 of 36

3.4 Records

3.4.1 Records of training shall include Broker Training Record, initial and most
recent recertification examinations and assessments, Broker Committee
Recommendations (when applicable), Certifications by Committee
Chairperson, error reports, lessons learned, etc. Records shall be
maintained as non-permanent records by the Broker Supervisor or
designees. Records must be kept throughout the employee's employment
and three years following termination.

3.4.2 Broker training records shall include the Broker’s name, most recent date
of successful course completion, a copy, description, or location reference
of the training materials used for certification, name and address of the
person providing the training, and a certification indicating the Broker has
been trained and tested in accordance with the requirements of 49 CFR
172 Subpart H. Also included will be any applicable Required Reading
completion documents.

3.4.3 A Broker Qualification Status Report (See example in Attachment 5.8)
shall be maintained and updated at least annually by the Broker Supervisor
or designees.

4. REQUIREMENTS AND GUIDANCE

4.1 Prerequisites

4.1.1. Assistant Broker

4.1.1.1 A candidate must be an EnergySolutions employee (permanent or
temporary) or personnel associated with an EnergySolutions
project.

4.1.1.2 A candidate must be capable of lifting heavy objects, climbing
ladders, and using hand tools.

4.1.1.3 A candidate shall have completed radiation worker training prior
to Assistant Broker training.

4.1.1.4 All Assistant Broker candidates must be recommended for
training by cognizant management.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 6 of 36

4.1.2 Senior Assistant Broker

4.1.2.1 A candidate must be an EnergySolutions employee. Temporary
EnergySolutions or non-EnergySolutions employees shall not be
trained as a Senior Assistant Broker without prior authorization
of the Broker Committee.

4.1.2.2 Candidate must be an Assistant Broker.

4.1.2.3 A candidate must be capable of lifting heavy objects, climbing
ladders, and using hand tools.

4.1.2.4 A candidate shall have completed radiation worker training prior
to Broker training.

4.1.2.5 A candidate shall possess the training, knowledge, and
experience in radiation protection/health physics required to
perform the associated duties when shipping radioactive material.
Each candidate’s training, knowledge and experience shall be
evaluated and approved by the Broker Supervisor prior to
training.

4.1.2.6 All Senior Assistant Broker candidates must be recommended for
training by cognizant management

4.1.3 Certified Broker

4.1.3.1 A candidate must be an EnergySolutions employee. Temporary
EnergySolutions or non-EnergySolutions employees shall not be
trained and certified as Brokers without prior authorization of the
Broker Committee.

4.1.3.2 A candidate must be capable of lifting heavy objects, climbing
ladders, and using hand tools.

4.1.3.3 A candidate shall have completed radiation worker training prior
to Broker training.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 7 of 36

4.1.3.4 A candidate shall possess the training, knowledge, and
experience in radiation protection/health physics required to
perform the associated duties when shipping radioactive material.
Each candidate’s training, knowledge and experience shall be
evaluated and approved by the Broker Supervisor prior to
training. The Broker Supervisor shall assign a mentor to help
guide the candidate through the successful completion of
training, certification, and initial shipments.

4.1.3.5 The candidate must pass a Broker screening examination with a
minimum score of 80% prior to the beginning of training. The
Broker Supervisor will inform each candidate who makes less
than 80% of the additional training required prior to retaking the
screening exam. Broker candidates must observe a minimum
thirty-day study period prior to re-screening. The Broker
Supervisor may require evidence of additional training.

4.1.3.6 Successful completion of the Assistant Broker final exam may be
substituted for the Broker screening exam.

4.1.3.7 With the approval of the Broker Committee, the Broker
Supervisor or designees may waive Steps 4.1.3.5 and/or 4.1.3.6
based on the candidate’s previous experience.

4.1.3.8 All Broker candidates must be recommended for training by
cognizant management.

4.1.4 Senior Certified Broker

4.1.4.1 Candidate must be a Certified Broker.

4.1.4.2 Candidates must have successfully shipped at least twenty loads
of hazardous material. The shipments shall include a minimum
of ten different types of the following general type shipments:

4.1.4.2.1 Low-level radioactive waste shipment to the Barnwell
Waste Management Facility or Clive LLW Disposal
Facility

4.1.4.2.2 Low-level radioactive waste shipment to another
disposal site other than Barnwell or Clive

4.1.4.2.3 Excepted Quantity shipment

4.1.4.2.4 Low Specific Activity (LSA) shipment
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 8 of 36

4.1.4.2.5 Type A or B non-LSA

4.1.4.2.6 Cask shipment

4.1.4.2.7 Wooden or metal box shipment

4.1.4.2.8 Non-waste radioactive material shipment from one
licensee to another

4.1.4.2.9 Mixed waste shipment, such as, scintillation liquids or
uranium and thorium pyrophoric material

4.1.4.2.10 Fissile material with DOE/NRC Form 741

4.1.4.2.11 Rail Shipment

4.1.4.2.12 Vessel Shipment

4.1.4.2.13 Air Shipment

4.1.4.2.14 Aqueous Filter Media

4.1.4.2.15 Non-Radioactive Hazardous Waste

4.1.4.2.16 SCO Shipment

4.1.5 Broker Supervisor

The Broker Supervisor shall have an appropriate combination of
education, professional certifications, and experience to be judged an
expert in the field of hazardous material shipping.

The Broker Supervisor shall be an EnergySolutions Certified Radioactive
Material and Mixed-Waste Broker.

4.2 Training Sequence

4.2.1 Assistant Broker

4.2.1.1 Candidates shall complete the self-study, self-paced training
found in the Assistant Broker Training Manual.
4.2.1.2 Answers to questions found at the end of each section shall be
graded by the Broker Supervisor or designees as the candidate
completes each section.
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 9 of 36

4.2.1.3 At the completion of the entire manual, a comprehensive final
exam will be given that must be passed with a score of 80% or
better.
4.2.1.4 Final exams must be proctored by the individual's supervisor or
other person authorized by the Broker Committee Chairperson,
Broker Supervisor or designees.
4.2.1.5 In lieu of the training requirements addressed in Steps 4.2.1.1
through 4.2.1.4 and with Broker Committee Chairperson’
approval, an Assistant Broker candidate may complete the
training requirements outlined in Step 4.2.3.1 and pass the tests
addressed in Step 4.2.3.2 or the Assistant Broker Candidate may
provide proof of previous radioactive waste shipper training and
testing within the last 12 months.

4.2.2 Senior Assistant Broker

The Senior Assistant Broker candidate shall satisfactorily assist in two
radioactive material shipments under the guidance of a Certified Broker.
The Certified Broker shall document the shipments using the Evaluation
of Broker Candidate During Two Assisted Shipments Form (Attachment
5.3).

The Broker Supervisor or designees shall certify the Senior Assistant
Broker following completion of Step 4.2.2.

4.2.3 Certified Broker

4.2.3.1 The Broker candidate shall complete classroom training,
according to the Broker Training Record (Attachment 5.2), that
covers the applicable requirements.

4.2.3.1.1 One or both weeks of Initial Broker Training Class
requirement may be waived by the Broker Committee
Chairperson provided the Broker Candidate provides
proof of previous radioactive waste shipper training or
Broker Certification (training and/or Certification must
be within one year of expiration), must provide two
shipment manifests that indicate receipt (receipt
signature) with no issues. The Broker Candidate will
be required to complete the steps in Section 4.2.3.2
prior to being certified as an EnergySolutions Broker.
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 10 of 36

4.2.3.1.2 Week 1 of the Initial Broker Training Class may be
completed by attending a commercially offered RAM
packaging, transport, and disposal class that covers the
Training Objectives outlined in Attachment 5.1 and is
approved by the Broker Committee Chairperson.

4.2.3.2 After satisfactory completion of classroom training, Broker
candidates shall demonstrate that they meet the Broker training
objectives listed in Attachment 5.1, by completing the tests and
exercises described in Steps 4.2.3.2.1 through 4.2.3.2.3.

4.2.3.2.1 The Broker candidate shall pass an open, closed book,
and shipping paper exam with an average score of 90%
minimum and an individual score of 80% minimum on
an examination that has been approved for use by the
Broker Supervisor and Broker Committee Chairperson.
This examination shall be proctored by a member of
the Broker Committee.

4.2.3.2.2 The Broker candidate shall satisfactorily assist in two
radioactive material shipments under the guidance of a
Certified Broker. The Certified Broker shall document
the shipments using the Evaluation of Broker
Candidate During Two Assisted Shipments Form
(Attachment 5.3).

4.2.3.2.3 The Broker candidate shall pass an oral examination
given by an Examination Board.

4.2.3.2.4 Selected Certified Brokers may receive additional
training to prepare them to ship mixed low-level
radioactive material or non-radioactive hazardous
waste, hazardous material shipments by air (IATA), or
hazardous material shipments by water (IMDG). This
training will be accomplished in accordance with
Attachments 5.4, 5.5, 5.6, and 5.7.

4.2.4 Senior Certified Broker
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 11 of 36

A Certified Broker shall perform and document the shipments meeting the
requirements of Step 4.1.4.2 and forward to the Broker Supervisor for
review and approval; and must:
 Be a Certified Broker
 Complete a minimum of twenty shipments
 Must perform at least ten different types of shipments as
identified in Section 4.1.4.2

4.2.5 Optional Additional Broker Training

4.2.5.1 Optional additional training outlined below may be offered upon
request of the Certified Broker’s or Senior Certified Broker’s
immediate Supervisor/Manager.
Optional Training for Certified Broker:
 IATA
 IMDG
 Mixed-Waste
 Spent Fuel
 Special Permit (DOT-SP)
 Fissile with DOE/NRC 741
 Cask QA
 Highway Route Controlled Quantity (HRCQ)
 Category 1 and Category 2
 Department of Defense
 Decommissioning and Decontamination (D&D)

4.2.5.2 Training will be offered in specific areas of need by classroom
and/or on-the-job as available.

4.2.5.3 Specific areas of completed training will be documented and
placed in the Certified Broker or Senior Certified Broker training
file after passing a written test with 90% or greater. The Broker
Supervisor has be notified after successful completion of any
additional training.

4.2.5.4 Additional authorized duties will be based on the amount and
type of additional training.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 12 of 36

Note: Certified Broker or Senior Certified Broker must
have completed the training specified in Step
4.2.5.1 prior to performing associated shipments.

4.2.6 ANI Transportation Risk

As part of the initial or annual recertification, all Brokers must be
instructed in risk mitigation per the ANI Guidelines 15-02: Transportation
of Radioactive Materials, as amended.

4.3 Approvals and Authorizations

Note: If the candidate does not successfully complete any of the
requirements in Section 4.2, a minimum thirty-day waiting period
must be observed prior to re-examination. The thirty-day period is
reserved for additional studies as directed by the Broker Supervisor.
The Broker Supervisor may waive the thirty-day waiting period.

4.3.1 Assistant Broker

The Broker Supervisor or designees shall certify Assistant Brokers
following completion of Step 4.2.1.

4.3.2 Senior Assistant Broker

The Broker Supervisor or designees shall certify Senior Assistant Broker
following completion of Step 4.2.2.

4.3.3 Certified Broker

4.3.3.1 Following satisfactory completion of Step 4.2.3, the Broker
Supervisor shall review the candidate's training and performance
and shall make a recommendation on certification to the Broker
Committee.

4.3.3.2 The Broker Supervisor shall report additional training and
qualifications of the candidate to the Broker Committee.

4.3.3.3 The Broker Committee shall approve the candidate to become a
Certified Broker.

4.3.3.4 Approval of the Broker Committee is required prior to a
Certified Broker or Senior Certified Broker performing
shipments identified in Section 4.2.5.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 13 of 36

4.3.3.5 The Broker Supervisor or Designees may qualify a Certified
Broker for the performance of specific types of hazardous
material shipments as listed in Section 4.1.4.2.

4.3.4 Senior Certified Broker

4.3.4.1 Following completion of Step 4.2.4, the Broker Supervisor shall
recommend Senior Certification to the Broker Committee.

4.3.4.2 The Broker Committee shall act on the Broker Supervisor
recommendation at the next Broker Committee Meeting.

4.3.4.3 Approval of the Broker Supervisor is required prior to a Certified
Broker or Senior Certified Broker performing shipments
identified in Step 4.2.5.1.

4.3.4.4 The Broker Supervisor shall report additional training and
certifications to the Broker Committee.

4.4 Recertification

4.4.1 Assistant Broker

4.4.1.1 To maintain certification, within 425 days after certification, all
Assistant Brokers are required to complete training and a
recertification examination approved for use by the Broker
Supervisor. A minimum score of 80% is required to pass this
examination.

4.4.1.2 If an Assistant Broker fails the recertification exam, the Assistant
Broker shall lose his/her certification until a recertification exam
is passed.

4.4.1.3 If the Assistant Broker fails the second recertification exam the
Broker Committee shall determine the remedial action prior to re-
examination.

4.4.2 Senior Assistant Broker

4.4.2.1 To maintain certification, within 425 days after certification, all
Senior Assistant Broker are required to complete training and a
recertification examination approved for use by the Broker
Supervisor. A minimum score of 90% is required to pass this
examination.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 14 of 36

4.4.2.2 If a Senior Assistant Broker fails the recertification exam, the
Senior Assistant Broker shall lose his/her certification until a
recertification exam is passed.

4.4.2.3 If the Senior Assistant Broker fails the second recertification
exam the Broker Committee shall determine the remedial action
prior to re-examination.

4.4.3 Certified and Senior Certified Broker

4.4.3.1 Certified Broker and Senior Certified Broker shall recertify by:

4.4.3.1.1 Documenting the performance or assistance in at least
two hazardous material shipments made since the last
certification.

4.4.3.1.2 Attending a recertification class.

4.4.3.1.3 Achieving at least a 90% score on a recertification
exam approved for use by the Broker Supervisor and
Broker Committee Chairperson.

4.4.3.1.4 Recertifying on a frequency of:
 Annually (+ 90 days) for radioactive and mixed
material/waste (shipping by highway and rail)
 Annually for IATA (+ 90 days) (shipping by air)
 Triennially for IMDG (+ 90 days) (shipping by
vessel)

4.4.3.2 If a Certified Broker or Senior Certified Broker is unable to
attend the recertification class, he or she may request from the
Broker Supervisor or Broker Committee Chairperson, in writing,
a waiver of the requirement to attend the classes. However, the
Certified Broker or Senior Certified Broker must take the exam
satisfy the requirements of Steps 4.4.3.1.2 through 4.4.3.1.3. A
request to miss the annual recertification class and challenge the
recertification exam will not be granted for two (2) consecutive
years.

4.4.3.3 Following passage of the recertification exam and satisfactory
review of previous shipment records, the Broker Committee
Chairperson or Broker Supervisor shall recertify the Certified
Broker or Senior Certified Broker.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 15 of 36

Note: Upon satisfactory completion of Step 4.4.3.1, the
Certified Broker or Senior Certified Broker is
considered recertified pending final review and
approval by the Broker Committee Chairperson or
Broker Supervisor.

4.4.3.4 If the Certified Broker or Senior Certified Broker does not pass
the recertification examination, a study period of at least 30 days
is required prior to re-examination, unless the Broker Supervisor
authorizes re-examination in less than 30 days. Broker
Supervisor authorization shall be documented in the Broker's
training file.

4.4.3.4.1 If a Certified Broker or Senior Certified Broker fails
the annual recertification exam, that Certified Broker
or Senior Certified Broker certification will be
suspended and will be downgraded to an Assistant
Broker. The Broker Supervisor may specify additional
limitations during the study period.

4.4.3.4.2 If the Certified Broker or Senior Certified Broker fails
the second recertification exam the Broker Supervisor
shall specify the remedial action prior to re-
examination.

4.4.3.5 A Broker with a suspended certification must pass the
recertification exam within an additional twelve (12) months or
the Broker must repeat the training requirements of Step 4.3.2 as
appropriate. The Broker Supervisor shall document suspensions
and extensions in the Broker’s training file.

4.4.5 Broker Supervisor

To maintain Broker certification and Supervisor authorization, the Broker
Supervisor shall each year perform at least one each of the following
shipments:

4.4.5.1 Disposal Shipment

4.4.5.2 Radioactive Material Transfer

4.4.5.3 Be a Certified Broker and Mixed-Waste Broker in accordance
with this procedure.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 16 of 36

5. ATTACHMENTS AND FORMS

5.1 Training Objectives

5.2 Broker Training Record

5.3 Broker Training Forms

5.4 Mixed Low-Level Material/Waste Shipping

5.5 Non-Radioactive Hazardous Material/Waste Shipping

5.6 Radioactive Material Shipments by Air

5.7 Radioactive Material Shipments by Water

5.8 Broker Qualification Status Report [Example]
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 17 of 36

Attachment 5.1
Training Objectives

Assistant and Senior Assistant Broker Objectives

1. Given relevant data, the Assistant Broker candidate will calculate the type and
quantity designations for various radioisotopes or mixtures thereof using 49 CFR and
10 CFR.

2. Given relevant data, the Assistant Broker candidate will specify the proper
packaging to be used for various types and quantities of radioisotopes or mixtures
thereof using 49 CFR and 10 CFR.

3. The Assistant Broker candidate will demonstrate proper procedures for use and care
of various radiological survey instruments including the Eberline E-520 Portable
Beta-Gamma Geiger Counter with HP-210 probe or equivalent and other counting
equipment.

4. The Assistant Broker candidate will properly prepare and distribute all paperwork
necessary for making a non-disposal radioactive shipment with few non-radiological
errors. No radiological errors are allowed. The candidate will use 49 CFR, 10 CFR,
and other applicable procedures.

5. The Assistant Broker candidate will discriminate between acceptable and
unacceptable package conditions for the shipment of radioactive material using 49
CFR, 10 CFR, and applicable procedures.

6. Given relevant data, the Assistant Broker candidate will calculate or verify the
activity per package in a radioactive shipment using isotopic analyses, 6CEN
formula, or equivalent method.

7. Given an Eberline E520 Portable Beta-Gamma Geiger Counter with HP-210 probe
or equivalent and an adequate supply of smear pads, the Assistant Broker candidate
will perform a radioactive shipment vehicle survey.
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.1
Training Objectives (continued)

EnergySolutions Proprietary/Restricted Information Page 18 of 36

8. The Assistant Broker candidate will state radiation level and contamination control
limits for exclusive use and non-exclusive use vehicles carrying radioactive material.

9. Given relevant data, the Assistant Broker candidate will demonstrate specification
marking, labeling, placarding, and packaging requirements for various radioactive
material shipments using 49 CFR, 10 CFR, and other applicable regulations.

10. Given relevant data, the Assistant Broker candidate will specify proper loading and
bracing procedures and appropriate communications with transport personnel for
radioactive material shipments using 49 CFR, 10 CFR, and other applicable
procedures.

11. The Assistant Broker candidate will list duties, responsibilities, and authorities of an
Assistant Broker from memory.

12. Given various circumstances, the Assistant Broker candidate will demonstrate the
ability to properly establish and maintain good customer relations and resolve
customer complaints and problems.

13. Given relevant data, the Assistant Broker candidate will demonstrate the ability to
perform radioactive material shipment inspections other than radiological surveys
using 49 CFR, 10 CFR, and other applicable procedures.

14. The Assistant Broker candidate shall identify the safety aspects associated with
shipping radioactive material.

15. The Assistant Broker candidate will successfully complete a self-study course of
instruction, "The Assistant Broker Training Manual".

16. The Assistant Broker candidate will successfully pass a comprehensive open book
examination covering the topics presented in the Assistant Broker Training Manual.

17. The Assistant Broker candidate will ship an excepted quantity shipment as defined
by the DOT.

18. The Assistant Broker candidate will read ANI Guideline 15-02: Transportation of
Radioactive Materials.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.1
Training Objectives (continued)

EnergySolutions Proprietary/Restricted Information Page 19 of 36

Broker Training Objectives

1. Given relevant data, the Broker candidate will calculate the type and quantity
designations for various radioisotopes or mixtures thereof using 49 CFR and 10
CFR.

2. Given relevant data, the Broker candidate will specify the proper packaging to be
used for various types and quantities of radioisotopes or mixtures thereof using 49
CFR and 10 CFR from memory.

3. The Broker candidate will demonstrate proper procedures for use and care of various
radiological survey instruments including the Eberline E-520 Portable Beta-Gamma
Geiger Counter with HP-210 probe or equivalent and other counting equipment.

4. The Broker candidate will properly prepare and distribute all paperwork necessary
for making a radioactive shipment with few non-radiological errors. No radiological
errors are allowed. The candidate will use 49 CFR, 10 CFR, applicable burial site
license and criteria, and other applicable procedures.

5. The Broker candidate will discriminate between acceptable and unacceptable
package conditions for the shipment of radioactive material using 49 CFR, 10 CFR,
applicable burial site criteria, and applicable procedures.

6. Given relevant data, the Broker candidate will calculate or verify the activity per
package in a radioactive shipment using isotopic analyses, 6CEN formula, or
equivalent method.

7. Given an Eberline E520 Portable Beta-Gamma Geiger Counter with HP-210 probe
or equivalent and an adequate supply of smear pads, the Broker candidate will
perform a radioactive shipment vehicle survey.

8. Given a list of waste forms, the Broker candidate will state which waste forms are
acceptable at each burial site from memory.

9. Given a list of burial site criteria, prior notification requirements, and burial site
procedures, the Broker candidate will match each item from the list to the
appropriate burial site from memory.

10. Given relevant data, the Broker candidate will apply specification marking, labeling,
placarding, and packaging requirements for various radioactive material shipments
using 49 CFR and 10 CFR.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.1
Training Objectives (continued)

EnergySolutions Proprietary/Restricted Information Page 20 of 36

11. Given relevant data, the Broker candidate will specify proper loading and bracing
procedures and appropriate communications with transport personnel for radioactive
material shipments using 49 CFR, 10 CFR, consignee license and criteria, and other
applicable procedures.

12. The Broker candidate will list duties, responsibilities, and authorities of a certified
Broker from memory.

13. Given various circumstances, the Broker candidate will demonstrate the ability to
properly establish and maintain good customer relations and resolve customer
complaints and problems.

14. Given relevant data, the Broker candidate will demonstrate the ability to perform
radioactive material shipment inspections other than radiological surveys using 49
CFR, 10 CFR, consignee license and criteria, and other applicable procedures.

15. The Broker candidate shall identify the safety aspects associated with shipping
radioactive material.

16. The Broker candidate will perform two actual radioactive material shipments under
the supervision of a certified Broker. For the first shipment, the Broker candidate
shall assist the Certified Broker. For the second shipment, the Broker candidate will
complete all paperwork, surveys, calculations, prior notifications, etc. using 49 CFR,
10 CFR, applicable consignee license and criteria, and other applicable procedures
under the guidance of a Certified Broker/ Shipper.

17. The Broker candidate will successfully complete written examinations and oral
examinations as specified by this procedure.

18. Through training instruction, the Broker candidate shall demonstrate understanding
and risk mitigation per ANI Guideline 15-02: Transportation of Radioactive
Materials.

19. Through training instruction, the Broker candidate shall demonstrate understanding
of the D&D packaging, modes of transportation, additional support (eg Waste
Certifier and RST), utilization of transload facilities, and high volume/low activity
shipping pressures associated with D&D projects.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 21 of 36

Attachment 5.2
Broker Training Record
BROKER CANDIDATE Employee No.
TRAINING DATE(S)
INSTRUCTOR
INSTRUCTOR
PREREQUISITES
Meets
Requirement Broker Supervisor Date
1. Employment (4.1.3.1)
2. Physical Attributes (4.1.3.2)
3. Rad Worker (4.1.3.3)
4. Knowledge (4.1.3.4 & 4.1.3.5)

TRAINING TOPICS
I. FEDERAL REGULATIONS - TRANSPORTATION
A. Department of Transportation, 49 CFR
1. Regulation Organization and References
2. Definitions
3. Normal Form vs. Special Form
4. A1 and A2; single vs. mixtures
5. Limited Quantity
6. Type A Quantity
7. Type B Quantity
8. Highway Route Controlled Quantity
9. Low Specific Activity (LSA)
10. Surface Contaminated Object (SCO)
11. Hazardous Material Tables
12. Pecking Order and Mixed Hazards
13. Non-Specification Packaging
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.2
Broker Training Record (continued)

EnergySolutions Proprietary/Restricted Information Page 22 of 36

TRAINING TOPICS
14. Specification Packaging
15. Radiation Levels
16. Contamination Levels
17. Marking
18. Labeling
19. Placarding
20. Shipping Papers
21. Emergency Response Communications
22. Carriers Requirements, Part 177
23. Emergency Notifications
24. Overpacks and Quality Assurance
25. Federal Motor Carrier Requirements
26. Load Securing and Planning
B. Nuclear Regulatory Commission, 10 CFR 71
1. Specification Packaging
2. Reference to DOT
3. Safety Analysis Reports
4. Certificates of Compliance
5. Casks
6. Registered Users
7. Quality Assurance
8. Advance Notification
9. Category 1 and Category 2 Material and Additional Security Measures
II. FEDERAL REGULATIONS - DISPOSAL
A. 10 CFR 61
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.2
Broker Training Record (continued)

EnergySolutions Proprietary/Restricted Information Page 23 of 36

TRAINING TOPICS
1. Stability - Packages
2. Stability - Disposal Site
3. Site Design Periods
4. Low Level vs High Level
5. Radionuclide Decay
6. Classification
7. Disposal Containers Characteristics
8. BTP on Waste Characteristics
9. BTP on Waste Form
10. Specific Activity determinations
B. 10 CFR 20 Appendix G
1. Generator's Responsibility
2. Classification
3. Package Characteristics
4. Labeling
5. Manifest
6. Quality Control
7. Lost Shipment Investigation
III. SITE REGULATORY REQUIREMENTS
A. South Carolina Site
1. License 097
2. Transportation of Radioactive Waste into or within South Carolina 61-83
3. South Carolina DHEC Regulations, Title A, 61-63, Radioactive Materials
4. Site Prior Notifications
5. License 287-02
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.2
Broker Training Record (continued)

EnergySolutions Proprietary/Restricted Information Page 24 of 36

TRAINING TOPICS
6. License 287-04
7. Site Criteria
B. Bear Creek (TN)
1. License
2. Waste Acceptance Guidelines (WAG)
3. TN License for Delivery
C. Clive (UT)
1. License UT 2300249
2. Waste Acceptance Criteria [Containerized Waste Facility (CWF)]
3. Waste Acceptance Guidelines (Bulk Facility)
4. License NRC SMC-1559 [11e.(2)]
5. Utah Regulation - Rule R313-15
6. Utah Regulation - Rule R313-26
D. Waste Control Specialists (WCS)
1. License
2. Acceptance Criteria
IV. OTHER REQUIREMENTS
1. Illinois Waste Tracking Rule
2. Challenges associated with high volume/low activity D&D projects
V. REGIONAL COMPACT STATUS
VI. CURRENT EVENTS AND ISSUES
VII. BROKER POLICY
A. Liability
B. Broker Committee
C. Broker Supervisor
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.2
Broker Training Record (continued)

EnergySolutions Proprietary/Restricted Information Page 25 of 36

TRAINING TOPICS
D. Current Status
E. Peer Review
VIII. BROKER PROCEDURES
A. ES-BR-PR-001
B. ES-BR-PR-002
C. ES-BR-PR-003
IX. SHIPPING NON-WASTE
X. SHIPPING DOCUMENTS
A. RSM - Barnwell (Barnwell Disposal Facility & Barnwell Processing Facility),
Clive, Bear Creek
B. NRC Uniform LLRW Manifests
C. RSR - Non-Waste
D. Bill of Lading
E. Applications
F. Certifications
G. Prior Notifications
H. Shipment Numbers
I. DOE/NRC Form 741
J. Emergency Response Guides & CHEMTREC
K. Exclusive Use Instructions
XI. INSPECTION ROUTINES
A Type of Radiation
B Use of Instruments
C Shipment Preparations
D Good Guy Letter
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.2
Broker Training Record (continued)

EnergySolutions Proprietary/Restricted Information Page 26 of 36

TRAINING TOPICS
E NRC Form 4 or Equivalent
F Inspection of Drum
G Inspection of Box
H Broker vs Shippers Responsibility
I Loading Methods and Considerations
J. Blocking and Bracing the Load
XII. ACTIVITY DETERMINATION
A. 6 CEN
B. Correction Factors
C. Isotopic Analysis to Total
D. Percent by Weight or Volume
E. Influent and Effluent
F. Laboratory Analysis
G. Activity Estimating
H. Accuracy
XIII. SAFETY CONSIDERATIONS FOR BROKERS
A. ANI Technical Guidelines 15-02: Transportation of Radioactive Materials
XIV. TEST AND BROKER OBJECTIVES

Instructor Date

Instructor Date

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 27 of 36

Attachment 5.3
Broker Training Forms

5.3.1 Evaluation of Broker Candidate During Two Assisted Shipments
TO: BROKER SUPERVISOR
FROM:
SUBJECT: EVALUATION OF BROKER CANDIDATE DURING TWO ASSISTED SHIPMENTS
The Broker Candidate, , has (unsatisfactorily/
satisfactorily assisted in (one/two) shipment(s) of low-level radioactive material. The following information
regarding the shipment(s) is provided.
Shipment #1: Shipment Date: Unsatisfactorily/Satisfactorily
Shipper:
Consignee:
Description of material:
Broker Candidate Strengths:
Broker Candidate Weaknesses:
Comments:

Evaluating Broker:
Shipment #2: Shipment Date: Unsatisfactorily/Satisfactorily
Shipper:
Consignee:
Description of material:
Broker Candidate Strengths:
Broker Candidate Weaknesses:
Comments:

Evaluating Broker:
ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.3
Broker Training Forms (Continued)

EnergySolutions Proprietary/Restricted Information Page 28 of 36

5.3.2 Broker Oral Examination

Name: Date:
Certification for:
Examination Type: FINAL

AREA GRADE
General Knowledge
Evaluation of Problems

INSTRUCTIONS:

1. Fill in required information above.
2. Record all questions and question grades on back of this sheet.
3. Enter area grades in table at above (not necessarily an average of questions).
4. Comment on weak areas. Sign in space provided.

WEAK AREAS AND COMMENTS:

SIGNATURE: Certification:

ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.3
Broker Training Forms (Continued)

EnergySolutions Proprietary/Restricted Information Page 29 of 36

5.3.3 Broker Oral Board Summary Record

NAME: Date:
Certification for:
Examination Type: FINAL
INSTRUCTIONS:
1. Fill in each Board member's area grades in the Table below.
2. Calculate and enter average for each area in Area Average column.
3. Calculate average of all entries in the Area Average column to determine overall Board grade.
Area Board Member's Area Grades Area Average
Gen./Know
Problems
OVERALL BOARD GRADE:
Note: The minimum passing overall board grade for certification is 2.8. If all grades are > 2.0, then the overall
board grade shall be the average of all grades. If one or more grade is < 2.0, then the overall board grade
shall be the lowest single grade given.
Committee Member Date
Certified Broker Date
( ) Date
Optional Board Member Date

ES-BR-PR-003
Training and Certification of Brokers Revision 7

Attachment 5.3
Broker Training Forms (Continued)

EnergySolutions Proprietary/Restricted Information Page 30 of 36

5.3.4 Requirements for Grading Broker Oral Examinations

Score on 4.0 Scale Word Description Definition Concerning Understanding of Fundamental
Principles and Regulations
Less than 2.0 Unsatisfactory Knowledge of applied fundamental principles and
regulations is not acceptable.
2.0 - 2.8 Satisfactory Knowledge of applied fundamental principles and
regulations is apparent, but often hesitant in answering
questions.
2.9 - 3.5 Good A good understanding of applied fundamental principles
and regulations. Few major weaknesses. Sometimes
hesitant in answering.
3.6 - 4.0 Excellent Above average understanding of applied fundamental
principles and regulations. A few minor weak points.
Seldom delays in answering.
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 31 of 36

Attachment 5.4
Mixed Low-Level Material/Waste Shipping

I. Description

Selected EnergySolutions Brokers are periodically called upon to ship mixed radioactive
and hazardous low-level material. Additional training is required to ship mixed
waste/hazardous waste.

II. Prerequisites

1. The candidate for certification to ship mixed radioactive and hazardous low-level
material must be a Certified Broker or Senior Certified Broker.

2. The candidate must be recommended for this training by the supervisor.

III. Training Sequence

1. Candidates shall attend a training class approved by the Broker Committee.

2. After the completion of the training, the Certified Broker or Senior Certified
Broker candidate must pass a hazardous material review exam with a score of
90% or better.

The individual’s supervisor shall proctor exams or other person authorized by the
Broker Supervisor, Broker Committee Chairperson, or designees.

3. Upon successful completion of steps 1 and 2, the Broker Committee Chairperson
will certify the candidate as qualified to ship mixed low-level radioactive
material.

IV. Recertification

1. Recertification may be accomplished in conjunction with the normal annual
Broker recertification class and examination.

2. Recertification will be accomplished by successfully passing a comprehensive
exam with a score of 90% or better.
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 32 of 36

Attachment 5.5
Non-Radioactive Hazardous Material/Waste Shipping

I. Description

Selected EnergySolutions Brokers are periodically called upon to ship non-radioactive
hazardous waste material.

II. Requirement

EnergySolutions employees who ship non-radioactive hazardous waste must be currently
qualified as a Mixed Low-Level Certified Broker and complete additional training as
required by 40 CFR.

III Recertification

1. Recertification may be accomplished in conjunction with the normal annual
Broker recertification class and examination.

2. Recertification will include successfully passing a hazardous material exam with a
score of 90% or better.
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 33 of 36

Attachment 5.6
Radioactive Material and Dangerous Good Shipments by Air

I. Description

Selected EnergySolutions Brokers are periodically called upon to ship radioactive
material and/or dangerous goods using conveyance by air.

II. Requirements

1. EnergySolutions employees who ship radioactive material by air must be trained,
assessed, be a Certified Broker or Senior Certified Broker, and complete additional
training and assessment in the Dangerous Goods Regulations, International Air
Transport Association (IATA DGR) Reference 2.10.

2. EnergySolutions employees who ship hazardous material other than radioactive
material or material having multiple hazards (dangerous goods) including radioactive
by air must be trained, be a Certified Broker or an EnergySolutions contract shipper
certified to ship Mixed Low-Level material, and satisfactorily complete training and
assessment in the International Air Transport Association Dangerous Goods
Regulations (IATA DGR) for the applicable dangerous goods being shipped by air

III Assessment

1. Each Certified Broker who desires to ship by air must complete an initial on-the-job
performance evaluation. This assessment is in addition to an IATA DGR training
with a written exam.

2. Submit a copy of the below completed IATA Shipper Assessment Form to the ES
Academy LMS.

IV Recertification

1. Recertification is required every 24 months. The IATA Shipper Assessment Form
below shall be used to document recertification. Once completed submit the
recertification record to the ES Academy LMS.

2. Recertification may be accomplished in conjunction with the normal annual Brokers
recertification class and examination.

3. Recertification will include successfully passing a hazardous material exam and
assessment with a score of 90% or better

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 34 of 36

Attachment 5.6 (continued)
IATA Shipper Assessment Form, Rev 0

SUBJECT: EVALUATION OF BROKER PREPARING AN AIR SHIPMENT
The Broker, , has (unsatisfactorily / satisfactorily)
prepared a radioactive material and/or dangerous goods shipment to be consigned for air transport. The following
information regarding the assessed shipment is provided.
Shipment Date:
Consignor:
Consignee:
Description of Material:
Broker Strengths:
Broker Weaknesses:
Comments:

Evaluating Broker:
Place / Date:

Assessment Objective:
Evaluate a broker is competent to prepare all tasks necessary to prepare and offer a shipment by air.

Please circle the appropriate response (i.e. “Yes”, “No” or “N/A”) to each question below:

1. Was the material classified correctly?
Yes / No
2. Verified material did not contain any forbidden, hidden, nor undeclared substances?
Yes / No
3. Determined accurate shipping description?
Yes / No
4. Select and properly package the material?
Yes / No
5. Apply package marks and labels correctly?
Yes / No
6. Completed necessary air bill and shipper’s declaration?
Yes / No
7. Completed appropriate shipping checklist?
Yes / No
8. Scheduled pickup with carrier? (this maybe “N/A” for mockups)
Yes / No / N/A
9. Carrier reported no issues and shipment arrived with no errors? (this maybe “N/A” for mockups)
Yes / No / N/A
ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 35 of 36

Attachment 5.7
Radioactive Material Shipments by Water

I. Description

Selected EnergySolutions Brokers are periodically called upon to ship hazardous material
using conveyance by water.

II. Requirement

EnergySolutions employees who ship radioactive material by water must be trained and
be a Certified Broker or Senior Certified Broker and complete additional training in the
International Maritime Dangerous Goods Code.

EnergySolutions employees who ship hazardous material other than radioactive material
or material having multiple hazards including radioactive by water must be trained and be
a Certified Broker or Senior Certified Broker certified to ship Mixed Low-Level
material, and complete additional training in the International Maritime Dangerous
Goods Code.

III Recertification

1. Recertification may be accomplished in conjunction with the normal annual
Broker recertification class and examination. See section 5.4 for specific
recertification requirements.

2. Recertification will include successfully passing a hazardous material exam with a
score of 90% or better.

ES-BR-PR-003
Training and Certification of Brokers Revision 7

EnergySolutions Proprietary/Restricted Information Page 36 of 36

Attachment 5.8
Broker Qualification Status Report (Example)
[Date]

Name Location
Assistant
Broker Qual
Date
Assistant
Broker
Recert Due
Broker Qual
Date
Broker
Recert Due
Senior
Broker Qual
Date
Senior
Broker
Recert Due
Additional
Certification* Recert Due Comments

* MW = Mixed Waste
NRHW = Non-Radioactive Hazardous Material/Waste
IATA = International Air Transport Association (Air)
IMDG = International Maritime Dangerous Goods (Water)

Exhibit 3

EnergySolutions Broker Operating
Procedure

ES-BR-PR-002

EnergySolutions Proprietary Page 1 of 141
ES-BR-PR-002

PROPRIETARY INFORMATION: This document contains proprietary information and
is not to be released or copied without the permission of EnergySolutions.

Operating Procedure for Brokering of
Hazardous Materials
Revision 17

Authored By: Signature on file
Donnie James, Broker Training Specialist Date
Reviewed By: Signature on file
Larry Conway, Broker Supervisor Date
Approved By: Signature on file
Mark Lewis, Broker Committee Chairperson Date

Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation

Effective
Date

Electronic documents, once printed, are uncontrolled.
Refer to the Intraweb or the Document Control authority for the correct revision.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 2 of 141
Table of Contents

Section Page
1. PURPOSE AND SCOPE .....................................................................................................4
1.1 Purpose .....................................................................................................................4
1.2 Scope ........................................................................................................................4
2. REFERENCES ....................................................................................................................4
3. GENERAL ...........................................................................................................................6
3.1 Definitions................................................................................................................6
3.2 Responsibilities ........................................................................................................7
3.3 Precautions ...............................................................................................................7
3.4 Limitations ...............................................................................................................8
3.5 Notification Requirements .......................................................................................8
3.6 Records ..................................................................................................................10
4. REQUIREMENTS AND GUIDANCE .............................................................................11
4.1 General Requirements ............................................................................................11
4.2. Actions Prior to Loading of Packages .......................................................................
4.3 Vehicle Loading, Vehicle Inspection, and Shipping Papers Preparation ..................
4.4 Shipping Errors ..........................................................................................................
5. ATTACHMENTS AND FORMS..........................................................................................
5.1 Specific Shipping Requirements - Barnwell ..........................................................28
5.2 Broker Checklist for Shipments to Hanford ..........................................................29
5.3 Specific Shipping Requirements – EnergySolutions Clive Disposal Facility ...........
5.4 Specific Shipping Requirements - Department of Defense .......................................
5.5 Copy Distribution Checklists .................................................................................37
5.6 Shipping Papers and Supporting Documents .........................................................42
5.7 Calculation Worksheets .............................................................................................
5.8 Guidelines for Packaging Magnesium-Thorium and Depleted Uranium Metal
Turnings in Dry Sand .............................................................................................96
5.9 Guidelines for Packaging of Biological Waste for Disposal .................................97
5.10 Reserved .................................................................................................................99
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 3 of 141
5.11 Guidelines for Absorption of Small Volumes of Class A Liquid Waste for
Disposal at Hanford .............................................................................................100
5.12 Guidelines on the Encapsulation of Sources ........................................................102
5.13 Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility........106
5.14 Guidelines for the Use of Federal Express as a Common Carrier for the Transport
of Radioactive Material........................................................................................116
5.15 Specific Shipping Requirements - Bear Creek/Gallaher Road ............................119
5.16 Shipping Requirements – Waste Control Specialists...........................................130
5.17 Consignor Verification for Exclusive Use Radioactive Material Shipments and
License Authorization ..........................................................................................132
5.18 Load Securement and Vehicle Safety Inspection ......................................................
5.19 Category 1 and Category 2 Quantities of Radioactive Material ..........................135
5.20 Shipping Exemption Value Sources ..........................................................................

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 4 of 141
1. PURPOSE AND SCOPE

1.1 Purpose

This procedure specifies the requirements, criteria, and methods for the
packaging, inspection, manifesting, loading and shipping of packaged hazardous
material in compliance with applicable U.S federal and state regulations,
executive orders, burial site licenses, site criteria’s and EnergySolutions policies.
This procedure also provides EnergySolutions Brokers with the guidance and
tools to perform their duties appropriately.

1.2 Scope

This procedure applies to all EnergySolutions employees who ship hazardous
materials. The EnergySolutions Broker Program is to be utilized at all
EnergySolutions locations within the United States, and projects where
EnergySolutions is responsible for the shipping of hazardous materials. Canada
has an independent Broker training and operations program. Hazardous material
shipments (i.e. radioactive material, radioactive waste, hazardous waste and
mixed-hazardous waste) shall be performed by EnergySolutions employees that
are certified under this program. Contract Brokers shall not be used to ship
hazardous materials unless specifically approved by the EnergySolutions Broker
Program.

2. REFERENCES

2.1 Waste Burial Site Licenses: Washington State - US Ecology WN-1019-2; South
Carolina State - CNS - 097; Utah State - EnergySolutions Clive Disposal Facility
- UT 2300249; Texas - Waste Control Specialists - L04971

2.2 South Carolina DHEC License 287-02, 287-04, 287-05 as amended.

2.3 Permafix License and Acceptance Criteria, as amended.

2.4 NRC Special Nuclear Material License No. 16-19204-01, issued to US Ecology,
Inc.

2.5 S20-AD-010, Barnwell Waste Management Facility Site Disposal Criteria Chem-
Nuclear Systems Barnwell Office

2.6 DF-AD-009, Barnwell Processing Facility Radioactive Material Acceptance
Criteria

2.7 States of Utah, Washington, Tennessee, Texas, and South Carolina Regulations
for Radiation Control

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 5 of 141
2.8 Certificate of Compliance for Shipping Cask, as applicable

2.9 Regional Compact and Independent State Procedures for Import and Export of
Radioactive Waste

2.10 ES-BR-PR-003, Training and Certification of Hazardous Material Brokers
(Proprietary)

2.11 Applicable Business Group Minimum Industrial Safety Standards

2.12 International Atomic Energy Agency, SSR-6, Regulations for the Safe Transport
of Radioactive Material

2.13 ES-AD-PR-005, First Notifications

2.14 ES-BR-PR-001, EnergySolutions Broker Program Administration

2.15 EnergySolutions Clive Disposal Facility’s Bulk Waste Disposal and Treatment
Facility’s Waste Acceptance Guidelines

2.16 EnergySolutions Clive Disposal Facility’s Containerized Waste Facility Waste
Acceptance Criteria

2.17 ES-QA-PG-001, Quality Assurance Program

2.18 WM-A-501, Waste Acceptance Guidelines (Bear Creek and Gallaher Road)

2.19 Applicable Business Group, Transportation Security Plan and Transportation
Security Plan – Risk Assessment

2.20 Title 49, Federal Motor Carrier Safety Regulation, Part 393

2.21 [Docket Nos: (Redacted). License Nos: (Redacted), EA-05-090]

2.22 Title 49, Transportation, Parts 100-178

2.23 Title 10, Energy, 10 CFR 71

2.24 Title 40, Protection of Environment, Parts 190-268

2.25 International Air Transport Association (IATA) Dangerous Goods Regulations

2.26 International Maritime Dangerous Goods (IMDG) Code

2.27 Title 10, Energy, Parts 20, 30, 40, 70

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 6 of 141
2.28 33 CFR, Part 165

2.29 DOE Order 460.1B, Packaging and Transportation Safety

2.30 DOE Order 460.2A, Department Materials Transportation and Packaging
Management

2.31 Federal Highway Administration 23 CFR 658

2.32 ANI Technical Guideline 15-02, Transportation of Radioactive Material

2.33 NUREG-1608/RAMREG-003

2.34 RESERVED
2.35 RESERVED
2.36 RESERVED
2.37 ES-QA-PR-005, Records
2.38 ES-BR-PR-006, Quality Assurance (QA) Records Broker Program

3. GENERAL

3.1 Definitions

Reference 2.14 procedure ES-BR-PR-001, EnergySolutions Broker Program
Administration, Section 3

3.1.1 Broker — A Broker is an individual that is certified by the Broker
Committee Chairperson by recommendation of the Broker Supervisor and
concurrence of the Broker Committee. The individual must meet the
prerequisites and training requirements outlined in 49 CFR 172 Subpart H
(Hazmat Employee Training), Reference 2.10 and are authorized to ship
certain hazardous materials as defined in Sections 5.3 - 5.4.

3.1.2 Shipper of Record – The Shipper of Record (same as Licensee or
Generator) or consignee is the individual/company that is officially
responsible for compliance with the DOT Hazardous Material regulations,
Reference 2.22, and ensuring that the consignor is authorized to receive
the material, Reference 2.23. The Shipper of Record is listed on the
transportation, disposal, and/or transfer shipping papers or manifest. The
Shipper of Record may or may not be EnergySolutions. A Broker making
a shipment for a customer licensed by the NRC or Agreement State is not
the Shipper of Record.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 7 of 141
3.2 Responsibilities

3.2.1 Brokers must comply with this procedure and procedure number ES-BR-
PR-001, EnergySolutions Broker Program Administration. If there are
step(s) in this procedure that the Broker has good reason for not
complying with, the Broker may request a waiver from the step(s).
Waivers are subject to approval by the Broker Committee.

3.2.2 Broker must prevent any transportation errors by using Human
Performance Tools, including PEER checks. PEER checks must be
documented on the Shipping Peer Review Checklist in attachment 5.6 of
this procedure. PEER checks of Type B cask shipments must be
performed by a qualified Type B cask Broker. The PEER checker must
verify that the CoC/SAR limitation calculations (payload, hydrogen gas,
decay heat/watts, and neutrons, as applicable) were performed correctly
and are in compliance. Process knowledge can be used in place of the
calculations when applicable, ie no neutron sources are present.

3.3 Precautions

NOTE: Individual Broker shipping forms attached to this procedure can also be
found on the EnergySolutions’ network drive and folder,
O:/BARSC/Shared/Broker/Broker Forms or on the updated thumbdrive of
Broker documents and references given to each Broker during your last
Requalification class.

Brokers must understand the transportation risks associated with the shipment that
they are making and apply the risk mitigating guidelines as identified in the ANI
Technical Guidelines 15-02, as revised, for the Transportation of Radioactive
Materials, Reference 2.32

This procedure and ES-BR-PR-003, Procedure for Training and Certification of
Hazardous Material Brokers, Reference 2.10, cover the ANI guidelines for the
following Operations Functions:

 Conduct of Transportation Operations
 Radioactive Materials Classification for Transport
 Selection of Packaging and Conveyance
 Application of Radiological Controls
 Application of Transportation Engineering
 Packaging and Handling Operations
 Vehicle Inspection and Loading Operations
 Transportation Quality Control
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 8 of 141
 Transportation Document Management

3.4 Limitations

Packaging of radioactive materials or waste may be performed in conjunction
with preparation of materials for shipment without additional approvals or
development of additional procedures if the following conditions are met (See
Section 3.5 if all of these conditions cannot be met):

3.4.1 Total activity is less than or equal to:
 1% of the A2 value for non-sealed sources, or
 1% of the A1 value for sealed sources,
OR
3.4.2 The material requiring packaging is prepackaged by containment
within a shield, housing or other device, which will not be
opened/unsealed during packaging operations. The shield, housing or
device's design and construction shall incorporate a positive closure. In
addition, the contact external dose rate does not exceed 2 mSv/hr (200
mR/hr) and external contamination levels are less than 40 Bq/100 cm2
(2,400 dpm/100 cm2, Beta-gamma and less than 4 Bq/100 cm2 (240
dpm/100 cm2), alpha.
AND
3.4.3 Decontamination is limited to the immediate packaging area, packages
and/or transport vehicle,
AND
3.4.4 Protection from anticipated industrial safety hazards can be
accomplished with typical PPE of hardhat, safety glasses/shield, safety
shoes and gloves. The packaging operations will not involve personnel
exposure to toxic or hazardous chemicals or atmospheres containing
toxic or hazardous chemicals,
AND
3.4.5 If the material requiring packaging is under the customer's radioactive
material license, a review of the customer's license indicates that the
proposed packaging activities are authorized or not specifically
prohibited.

3.5 Notification Requirements

3.5.1 If the conditions in Section 3.4 cannot be met, the applicable Business
Group's procedures for hazard evaluation, development and
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 9 of 141
implementation of hazard controls and performance of work shall be
implemented in addition to this procedure.

3.5.2 If the limitations prescribed in Steps 3.4.1, 3.4.2, or 3.4.3 cannot be
met; concurrence is required from the Broker Supervisor.

3.5.3 If the limitations prescribed in Step 3.4.4 cannot be met, concurrence is
required from the applicable business group Health and Safety
Manager.

Note: The words "inspect" and/or "inspection" as mentioned
throughout this procedure, refers to visual verification
and/or validation performed by the qualified Broker
during work activity under this procedure. When a
safety-related function or activity is required, an inspector
qualified in accordance with Reference 2.17 shall perform
the duties.

3.5.4 Notification of Special Shipment – In accordance with American
Nuclear Insurers (ANI) Technical Guideline 15-02. Transportation of
Radioactive Materials (Ref. 2.32), “special shipments” require
notification to ANI. ANI considers a special shipment of radioactive
materials any shipment that is a non-routine (off normal) shipment that
requires special planning or support. Non-routine is the key factor in
determining whether an insurer should consider a shipment of
radioactive material a special shipment. Non-routine is any shipment
that is not conducted on a regular basis. A “special shipment” of
radioactive materials may meet the following basic characteristics:

 Shipments containing Route-Controlled quantities other than spent
fuel;
 Shipments requiring special State or Federal regulatory approval;
 Shipments requiring special packaging or supplemental protective
device to assure compliance with U.S. Department of
Transportation (USDOT) regulations;
 Shipments of components that are oversized or overweight
requiring special regulatory approval and/or permits;
 Single shipment or radioactive liquids in excess of 500 gallons;
 Shipping campaigns is support of major non-routine activities (e.g.
replacement of major reactor components, decommissioning site
remediation, etc.); and/or
 Shipment of new radioactive products (e.g., tritium, cobalt 60, etc.).

The EnergySolutions RSO will notify ANI of non-routine shipments
when necessary.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 10 of 141
3.6 Records

3.6.1 Broker

The Broker, if the Shipper of Record, shall retain copies of required
lifetime and non-permanent records, forms, and shipping papers
generated as a result of this procedure for at least three years, in
accordance with Reference 2.22. Business Groups, divisions, facilities,
and projects must have recordkeeping procedures and processes in
place per References 2.37 and 2.38 that the Broker, when Shipper of
Record, must comply with specifying the indexing, distribution,
identification, supplemental information (addition or revision),
authentication and retention requirements, if EnergySolutions is the
Shipper of Record. If the shipment originated from an EnergySolutions
licensed Project or fixed-based facility, the record requirement shall be
met and authenticated by the records retention personnel for the
business group, division, or project. The records retention staff shall
maintain an Index that, as a minimum, includes the type of records
stored, document number, record retention time, storage location, as
well as shipping documents defined in Steps 3.6.4 and 3.6.5. If the
Broker is not the Shipper of Record, there is no regulatory requirement
to retain shipping papers or other documentation, although as a
courtesy, personally keep the shipping documentation in the event the
Shipper of Record misplaces their copies.

3.6.2 Broker Supervisor

The Broker Supervisor shall retain the Broker Supervisor Notification
Form or equivalent and manifest readily accessible until after delivery
and acceptance of the shipment.

3.6.3 Shipper of Record/Licensee/Generator

The Broker shall advise the Shipper of Record/licensee/generator to
keep copies of the lifetime shipping records until license termination or
until disposal is authorized by the appropriate licensing agency per
Reference 2.27. Also, advise that the non-permanent shipping records
per Reference 2.22 must be kept for a period of three years.

3.6.4 Lifetime Shipping Records

Lifetime shipping records shall be kept by the radioactive
material/waste licensee (Licensee) in accordance with Reference 2.27
which includes the Disposal Manifest forms or License Transfer
document, such as a Radioactive Shipping Record (RSR). Disposal
Manifest forms are the NRC 540, 541, and 542 (if applicable), or the
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 11 of 141
Disposal Site equivalent forms authorized by the Agreement State that
is licensing the disposal site. The Licensee may or may not be
EnergySolutions. All other checklists, guides, and worksheets included
in the document distribution (Attachments 5.5 and 5.6), which are
optional for the Broker to complete, should not be included in the
lifetime shipping records. If EnergySolutions is the Shipper of
Record/licensee/generator, refer to Step 3.6.1 for requirements
associated with Receipt of Records, Storage and Preservation, and
Custodial Oversight for lifetime shipping records.

3.6.5 Non-Permanent Shipping Records

Non-permanent shipping records are those that are kept for a period of
three years in accordance with Reference 2.22 and include, in addition
to the records defined in Step 3.6.4, the Bill of Lading, Exclusive Use
statement (if applicable), emergency response guidelines, DOE/NRC
741 form (if applicable), and shipment radiation and contamination
surveys (as applicable). Depending on the DOT shipping category,
some of records may not be required, such as for limited quantity and
DOT Exempt shipments.

4. REQUIREMENTS AND GUIDANCE

4.1 General Requirements

The following requirements must be satisfied before any EnergySolutions
individuals may make a hazardous material shipment:

4.1.1 Spreadsheets and/or software programs used to perform calculations
shall have on file documented evidence of verification, validation and
approval from the Broker Committee prior to use. The verification and
validation (V&V) performed by the supplier can be used as an
alternative to EnergySolutions performing the V&V. Any V&Ved
software being used by a Broker at a customer/job site needs to ensure
that the software adheres to local and/or customer specific standards
and software licenses.

4.1.2 The individual shall hold the appropriate current certification or
qualification as an Assistant Broker, Senior Assistant Broker, Certified
Broker, Conditional Broker, and Senior Certified Broker in accordance
with Reference 2.10 for the type of shipment being made. If you’re
shipping to a new facility, call the Broker Supervisor for guidance.

4.1.3 Brokers making shipments of mixed low-level material/waste,
EPA-regulated hazardous wastes, and shipments consigned for
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 12 of 141
transport by means other than highway and rail, require additional
training in accordance with Reference 2.10.

4.1.4 Shipments of non-hazardous or non-regulated (per DOT)
waste/materials shall be prepared in accordance with the applicable
Waste Acceptance Criteria or Guidelines for the receiving facility.

4.1.5 The conditions of Attachment 5.4 apply when shipments are made for
the U.S. Army, Joint Munitions Command (JMC) (Department of
Defense).

4.1.6 The Broker shall have the appropriate instruments, labels, markings,
paperwork, and other materials as listed in the Broker Pre-Departure
Guide (Attachment 5.6), are available as needed.

4.1.7 Waste shipments shall not be performed unless the shipper has
documented evidence showing authority to use the appropriate disposal
site (Disposal Permit), ship into or within the state (Transportation
Permit), and/or ship into or out of a state or compact, as applicable.

4.1.8 The Broker shall confer with cognizant individuals, as necessary, such
as the Broker Supervisor, Dispatcher, the waste generator, etc.,
concerning local, state, or compact restrictions prior to shipping. The
Broker shall also determine any additional restrictions or commitments
placed on the generator/shipper by the consignee.

4.1.9 The Broker shall review the consignee's license for authorization to
accept the radioactive material to be shipped prior to release of the
shipment. If the shipper has a completed Attachment 5.17 on file for a
facility along with a current copy of their radioactive materials license
the shipment may be released.

4.1.10 The Broker should review the guidance in the Broker Pre-Departure
Guide (Attachment 5.6) in preparing for the shipment.

4.1.11 Shipment certification shall be made only when an inspection of the
package(s) and the vehicle confirms that the shipment complies with all
applicable rules, regulations, and license conditions and all applicable
references in Section 2.0, e.g References 2.1, 2.2, 2.3, 2.4, 2.5, 2.7, 2.8,
2.9, 2.12, 2.20, 2.22, 2.23, 2.24, 2.25, 2.26, 2.28, 2.29, 2.30, 2.31, and
2.33.

4.1.12 General procedures and guidelines for the inspection and shipping of
radioactive material are found in Section 4 and Attachments 5.1
through 5.20.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 13 of 141
4.1.13 The Broker shall use appropriate safety equipment (safety shoes, safety
glasses, etc.) and observe applicable safety requirements and practices
specified in the customer's and EnergySolutions Safety Policies and
Procedures, Reference 2.11.

4.1.14 Shipments involving the use of Federal Express shall comply with the
requirements and guidelines in Attachment 5.14.

4.1.15 The Broker shall identify and implement controls, restrictions and/or
notifications required by Reference 2.19 (Transportation Security Plan
and Risk Assessment).

Note: See Attachment 5.19 for Category 1 and Category 2
Quantities of Radioactive Material

4.1.16 The Broker shall validate that the Driver has a Commercial Driver’s
License (CDL), appropriate Hazardous Material Endorsements, and a
valid DOT Medical Card (if applicable). A copy of the driver’s CDL
and medical card shall not be maintained due to privacy concerns.

4.1.17 Packages or vehicles, which exceed 90% of any applicable DOT limit,
shall not be shipped without prior approval of the Broker Supervisor.

4.1.18 Prior to the use of a DOT Specification Packaging (Type A, UN, IP-2,
and IP-3), ensure that:

4.1.18.1 Complete documentation of Type A, UN, IP-2, IP-3
packaging tests and an engineering evaluation or
comparative data showing that the construction methods,
packaging design, and materials of construction complying
with the specification are on file.

4.1.18.2 The proposed package contents are similar (physical
characteristics and compatibility) to the contents used to
demonstrate compliance with the Type A, UN, IP-2, IP-3
packaging tests. Further demonstration of compliance with
testing requirements for dissimilar proposed packaging
contents shall be completed and documented in accordance
with 49 CFR 173.461 prior to using the 7A packaging.

4.1.18.3 Specification packagings shall be inspected, filled, closed
and closures torqued in accordance with the Certificate of
Conformance (C of C) where applicable. At a minimum,
packages shall be inspected per 49 CFR 173.22, 173.474,
and 173.475.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 14 of 141
4.1.19 Prior to the use of a DOE or NRC Specification Packaging (Type B
and/or Fissile), ensure that:

4.1.19.1 Shipper is a registered user per 49 CFR 173.471 and 10
CFR 71.17.

4.1.19.2 Complete package documentation (i.e. Certificate of
Compliance (CoC), SAR, cask manuals, procedures where
applicable) is maintained and followed. Perform the CoC
calculations, as applicable, to ensure compliance with the
Type B cask CoC/SAR payload, hydrogen generation,
neutron, decay heat (watts), and weight limitations, as
necessary.

4.1.19.3 The outside package identification marking matches the
DOE/NRC approval documentation and is indicated on the
shipping paper.

4.1.20 Determine if there are any workplace restrictions that would hinder in
fully complying with the requirements of this procedure or any
regulation. Workplace restrictions might include, but are not limited
to, security, safety (at a minimum Company safety standards per
Reference 2.11), PPE, training, access to packages, access to the
vehicle, access to waste/material characterization, etc. Resolve any
workplace restrictions prior to mobilizing to site.

4.2. Actions Prior to Loading of Packages

4.2.1 Exclusive Use Shipments

This section describes the actions required prior to the loading of
packages on transport vehicles consigned as exclusive use. Section
4.2.2 describes the required actions for non-exclusive use.

4.2.1.1 Confirm the vehicle condition and record results on the
Vehicle Inspection Form (Attachment 5.6).

4.2.1.2 If the vehicle floor (cargo area) shows evidence of
moisture:

4.2.1.2.1 The floor will be wiped as dry as possible
before loading.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 15 of 141
4.2.1.2.2 The condition of the floor and the action
taken will be noted on the Prior Notification
Form and/or other shipping forms.
Consignee of the shipment shall be notified
of the findings prior to shipment.

4.2.1.3 Perform or ensure that a radiation and contamination
survey of the vehicle is performed prior to loading. Notify
the Broker Supervisor of any vehicle which exceeds 90%
of the applicable DOT limits in Reference 2.22; such
vehicles shall not be loaded or released without the Broker
Supervisor or designee’s authorization. Surveys do not
need to be performed by the Broker if surveys are provided
by qualified RCT, RP Tech, HP, RST, or equivalent
personnel.

4.2.1.4 Enter vehicle survey data on "Broker Tractor/Trailer
Survey” or “Cask Survey” (Attachment 5.6) or the
job/facility specified survey form.

4.2.1.5 Ensure a radiation and contamination survey of the
packages has been conducted by a qualified RCT, RP Tech,
HP, or equivalent. Shipments to the US Ecology site,
Richland, WA, require that the surveys be performed
within 48 hours of shipping.

If there is any reason to not trust the survey results
performed by someone other than the Broker, repeat the
survey for at least 10% of the packages. If the previous
survey results are in substantial agreement with the new
survey, the previous survey may be used to prepare the
shipping papers.

Note: Packages or vehicles, which exceed 90%
of any applicable DOT limit, shall not be
shipped without prior approval of the
Broker Supervisor.

4.2.1.6 Enter the survey data, including date, on "Broker Inventory
Sheet (Attachment 5.6).

In regards to the dose rate limit of 1 R/hr at 3 meters from
the unshielded material for LSA/SCO classification, ensure
that actual surveys, if performed, match with any calculated
dose rate. Use the higher of the 2 dose rates to determine
the proper DOT shipping category and required packaging,
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 16 of 141
unless an exception is granted by the Broker Supervisor. If
either the actual or calculated exceed 1 R/hr at 3 meters
unshielded, then the shipment cannot be LSA or SCO and
may require a different type packaging.

4.2.1.7 Package weights and volumes must be verified and
validated from all possible sources. Sources may include
previous commitments made by Business Development,
Project Management, Clive Technical Services staff,
intercompany IWR or entries in the Clive Portal or
EnergySolutions EWT. This is especially important when
shipping large components or other non-standard waste
objects.

4.2.1.8 For disposal shipments, all packages shall be inspected for
internal freestanding liquids (water, oil, etc.).

Note: Packages containing biological waste/carcasses
shall not be punched or drilled.

4.2.1.8.1 Packages of solidified liquids shall be
inspected by using the “tap test”.

Note: The tap test is performed by
using a wooden or metal
hand-held rod to tap the sides
of a metal drum or box of
solidified material. Voids or
unsolidified areas within the
package can sometimes be
identified based on the sound of
the tapping. Solid, solidified
areas typically sound solid and
higher pitched, while
voids/unsolidified areas sound
empty and low pitched.

4.2.1.8.2 Packages of absorbed fluids shall be
inspected by the method described in Steps
4.2.1.8.3 or 4.2.1.8.4.

4.2.1.8.3 Ten percent of non-EnergySolutions
solidified liquid packages shall be inspected
by being turned upside down, held for 24
hours, turned upright, opened, and observed
for liquids.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 17 of 141

4.2.1.8.4 An alternative to Step 4.2.1.8.3 is to inspect
by punching a hole in the bottom edge and
observing for liquids; the hole must be small
enough to be sealed with a gasket or caulked
metal screw.

Note: Holes cannot be made in
specification packages (Type A,
Type B, IP-2, IP-3).

4.2.1.8.5 Packages containing any internal liquids
shall not be shipped, unless they comply
with conditions of consignee’s site
acceptance criteria.

4.2.1.9 Inspect contents to ensure full compliance with the
consignee’s acceptance criteria, paying close attention for
scintillation fluids, pyrophoric/flammable material, other
hazardous materials, gas generation, mixed waste, etc.

4.2.1.10 Inspect all packages for integrity, appropriate markings,
and labels, correcting any deficiencies. The number of
days exposed to UV rays from sunlight must be determined
for plastic or polyethylene containers. If exposed for more
than 30 days or the package integrity is questionable, check
to verify integrity.

4.2.1.11 All handling procedures must be followed and
requirements of the Certificates of Compliance (CoC) and
SAR complied with when shipments are made in a NRC
approved package (cask). Perform the CoC calculations, as
applicable, to ensure compliance with the Type B cask
CoC/SAR payload, hydrogen gas generation, neutron,
decay heat (watts), and weight limitations, as necessary.
Refer to the Type B cask Reference documents 2.34, 2.35,
and 2.36. Ensuring compliance with all packages that have
handling procedures and/or a CoC/SAR, is also required

4.2.1.12 If any of the packages shows evidence of external moisture;
the shipment will be certified only if all the following
conditions are met:

4.2.1.12.1 The moisture is the result of natural
precipitation/condensation and does not
come from the package contents.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 18 of 141

4.2.1.12.2 A smear pad is used to absorb a sample of
the moisture, is dried, and is analyzed to
determine the absence or presence of
contamination.

4.2.1.12.3 Verbal notification is to be made to the
receiving destination (consignee) to advise
them on the condition of the proposed
shipment, result of the analysis, and to
receive verbal direction on how to proceed.
This call shall be documented in standard
memo format and included in the shipment
records.

4.2.1.12.4 All affected packages are wiped as dry as
possible before the shipment leaves the site.

4.2.1.13 The lid to body gap on ALL B-25 and similar type steel
containers and similar containers shall be completely sealed
prior to shipment.

4.2.1.14 Ensure the proper gaskets that have been properly
installed, are not damaged and provide a proper seal are
used on intermodal containers to prevent leakage.

4.2.1.15 Any package contents that could shift in transit shall be
fixed in place or have internal containment/restraint to
restrict shifting.

Note: Packages with contents that are flowable,
(i.e. sludges, etc.) shall be carefully
evaluated to ensure that shifting of the
contents will not increase the dose rate on
the package surface; increasing the DOT
Category may be necessary.

4.2.1.16 Complete the "Broker Inventory Sheet” (Attachment 5.6).
Ensure package numbers on the Broker Inventory Sheet are
the same.

4.2.1.17 "Post Checklist of Broker's Work" (Attachment 5.6) may
be completed in order to aid with shipping requirements.

4.2.2 Non-Exclusive Use Shipments

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 19 of 141
4.2.2.1 Verify that the non-exclusive carrier is approved on the
applicable business group Authorized Vendor List (AVL)
for the type of shipment being performed (e.g., radioactive
material/waste, hazardous waste, etc.).

4.2.2.2 Review the consignee’s radioactive materials licenses,
permits, and procedures to verify acceptability of the
shipment.

4.2.2.3 Observe or perform a radiation and contamination survey
of the packages.

If a non-EnergySolutions Broker or RS person has already
performed the survey, repeat the survey on at least 10% of
the packages. If the previous survey results are in
substantial agreement with the new survey, the original
survey may be used to prepare the shipment.

Note: Packages or vehicles, which exceed 90%
of any applicable DOT limit, shall not be
shipped without prior approval of the
Broker Supervisor Broker

4.2.2.4 Enter the survey data, including date of the survey, on
“Broker Inventory Sheet” (Attachment 5.6).

4.2.3 Empty Package Shipments (Radioactive "Empty")

4.2.3.1 Verify that the non-exclusive carrier is approved on the
Authorized Vendor List (AVL).

4.2.3.2 Observe or perform a radiation and contamination survey
of the packages.

4.2.3.3 Complete the “Empty Package Check List” (Attachment
5.6).

4.2.3.4 Review the “Shipping Guidelines for Empty Packages”
(Attachment 5.6), for package and paperwork requirements.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 20 of 141
4.3 Vehicle Loading, Vehicle Inspection, and Shipping Papers Preparation

4.3.1 Exclusive Use Shipments

4.3.1.1 Load the truck only with the packages listed on Broker
Inventory Sheet and Radioactive Shipment Manifest
(RSM), Radioactive Shipment Record (RSR), or Hazardous
Waste Manifest.

4.3.1.2 Complete shipping papers identified on appropriate “Copy
Distribution Checklist Sheets” (Attachment 5.5).

Note: For blocks or lines on the shipping papers
that require an EnergySolutions point-of-
contact, indicate the Facility Broker or
Broker Supervisor, by name.

4.3.1.2.1 Calculate the activity for each isotope and
the total activity in each package in the
shipment.

Note: Convert all radioactivities to
units of terabecquerels (TBq)
for DOT quantity calculations.
Only TBq values from the
A1/A2 Tables (49 CFR 173.435)
are to be used for DOT
quantity calculations.

4.3.1.2.2 Determine the DOT classification of the
material.

4.3.1.2.3 Calculate the DOT quantity using the
quantity, SCO or LSA Worksheet
(Attachment 5.7) or equivalent with
approval per Step 4.1.1.

4.3.1.2.4 Determine the Reportable Quantity
requirements using the RQ Worksheet
(Attachment 5.7) or equivalent with
approval per Step 4.1.1.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 21 of 141
4.3.1.2.5 Verify that each package is DOT Fissile
Excepted using the Fissile Exception
Worksheet in Attachment 5.7 or equivalent
with approval per Step 4.1.1. If nuclides
exceed the Fissile Excepted limit, complete
the DOE/NRC 741 form.

4.3.1.2.6 For waste shipments, determine the waste
classification using the Waste Classification
Worksheet (Attachment 5.7) or equivalent
with approval per Step 4.1.1.

4.3.1.2.7 If the shipment contains SNM, calculate the
individual isotope and total SNM grams per
package using the SNM Worksheet
(Attachment 5.7) or equivalent with
approval per Step 4.1.1.

4.3.1.3 Sequentially number each separate page of the entire
paperwork package as part of a set, i.e., 1 of 10, 2 of 10,
etc.

4.3.1.4 Use "Broker Inventory Sheet" (Attachment 5.6) to visually
verify that all packages are loaded on the vehicle.

4.3.1.5 Verify proper blocking and bracing and tie-downs, as
applicable per the Federal Motor Carrier Safety
Regulations, Part 393, Subpart I, Reference 2.20.

4.3.1.5.1 Any and all loose material (cribbing, blocking,
etc.) must be physically secured to the
conveyance using appropriate load securing
techniques (i.e. nailing, strapping and/or adding
friction mat to cribbing, blocking, shims,
spacers together and to the trailer deck so they
are independently secured to the conveyance
and not relying on pressure alone).

4.3.1.5.2 Any unusual load securing configurations
should be evaluated by a structural engineer.

4.3.1.5.3 Securements, tiedowns, blocking, and bracing
must be designed and capable of meeting the
braking strength, working load and vertical
prevention criteria in 49 CFR 393.102,
Reference 2.20.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 22 of 141

4.3.1.5.4 Ad hoc blocking and bracing must be
fabricated and installed in a quality manner so
as to not fail, weaken, or become questionable
in transit under normal conditions of transport.

4.3.1.5.5 Review load placement and blocking and
bracing with shipment driver if possible.

4.3.1.6 Verify vehicle is properly placarded.

4.3.1.7 Ensure the final contamination and radiation survey of the
vehicle has been completed by a qualified RCT, RP Tech,
HP, or equivalent. Shipments to the US Ecology site,
Richland, WA, require that the surveys be performed
within 48 hours of shipping.

If there is any reason to not trust the survey results
performed by someone other than the Broker, resurvey the
vehicle.

4.3.1.8 Record final survey data of vehicle on "Broker
Tractor/Trailer Survey” or “Cask Survey" (Attachment
5.6).

Note: Pictures can be helpful to document your
shipment, but are not required.

4.3.1.9 Affix seals, if required, or verify that security seals have
been affixed to drums, casks, and/or trailer doors, as
applicable.

4.3.1.10 Have driver and shipper, or shipper's agent, sign all
required forms, as applicable. If a Hanford shipment, sign
broker certification (DSHS RHF-31A, B, or C) as
applicable to release the waste shipments.

4.3.1.11 Complete "Post Checklist for Broker's Work" (Attachment
5.6).

4.3.1.12 Ensure all paperwork and copies are legible.

4.3.1.13 Make required copies and distribute according to "Copy
Distribution Checklist" (Attachment 5.5).

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 23 of 141
4.3.1.14 Ensure that any special instructions and/or comments from
the receiving destination to the carrier are documented,
included in the shipping papers, and read to the driver.

4.3.1.15 Verify that the driver has received all special instructions
for maintaining exclusive use and making the prior
notification phone calls verifying that instructions are
recorded on the shipping documents, and that the driver has
signed as receiving these instructions, if applicable
(Attachment 5.6).

4.3.1.16 Make required prior notifications and correction calls in
accordance with "Post Checklist of Broker's Work"
(Attachment 5.6).

4.3.1.17 Notify the Broker Supervisor or designee and the
emergency response organization (as indicated on the DOT
shipping paper) of the shipment. Provide the required
information to the emergency response contact
organization. Notification to the Broker Supervisor may be
accomplished by fax or E-mail using the Broker Supervisor
Notification Form in (Attachment 5.6), or equivalent.

Note: Notification to the Broker Supervisor
Broker is required only when the
shipment is being performed under this
procedure.

4.3.1.18 Distribute copies of the shipping papers in accordance with
the "Copy Distribution Checklist" (Attachment 5.5) and
release the shipment. Mail or send electronically a copy of
the Radioactive Shipment Manifest (RSM) to the disposal
site if shipping waste.

4.3.2 Non-Exclusive Use Shipments

4.3.2.1 Load the truck only with the packages listed on Facility
Broker Inventory Sheet (Attachment 5.6).

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 24 of 141
4.3.2.2 Complete radioactive shipping papers identified on the
Copy Distribution Checklist (Attachment 5.6).

Note: For blocks or lines on the shipping papers
that require an EnergySolutions point-of-
contact, indicate the Facility Broker or
Broker Supervisor by name.

4.3.2.2.1 Calculate the activity for each isotope and
the total activity in each package in the
shipment with approval per Step 4.1.1.

Note: Convert all radioactivities to
units of terabecquerels (TBq)
for DOT quantity calculations.
Only TBq values from the
A1/A2 Tables (49 CFR 173.435)
are to be used for DOT
quantity calculations.

4.3.2.2.2 Determine the DOT classification of the
material with approval per Step 4.1.1.

4.3.2.2.3 Calculate the DOT quantity using the
quantity, SCO or LSA Worksheet
(Attachment 5.7) or equivalent as
appropriate with approval per Step 4.1.1.

4.3.2.2.4 Determine the Reportable Quantity
requirements using the RQ Worksheet
(Attachment 5.7) or equivalent with
approval per Step 4.1.1.

4.3.2.2.5 Verify that each package is DOT Fissile
Excepted using the Fissile Exception
Worksheet (Attachment 5.7) or equivalent
with approval per Step 4.1.1. If nuclides
exceed the Fissile Excepted limit, complete
the DOE/NRC 741 form.

4.3.2.2.6 For waste shipments, determine the waste
classification using the Waste Classification
Worksheet (Attachment 5.7) or equivalent
with approval per Step 4.1.1.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 25 of 141
4.3.2.2.7 If the shipment contains SNM, calculate the
individual isotope and total SNM grams per
package using the “SNM Worksheet”
(Attachment 5.7) or equivalent with
approval per Step 4.1.1.

4.3.2.3 Sequentially number each separate page of the entire
paperwork package as part of a set, i.e., 1 of 10, 2 of 10,
etc.

4.3.2.4 Use “Broker Inventory Sheet” (Attachment 5.6) to visually
verify that all packages are loaded on the vehicle.

4.3.2.5 Complete “Post Checklist for Broker Work“, (Attachment
5.6).

4.3.2.6 Ensure all paperwork and copies are legible.

4.3.2.7 Make required copies and distribute according to “Copy
Distribution Checklist” (Attachment 5.6).

4.3.2.8 Ensure that any special instructions and/or comments from
the receiving destination to the carrier are documented,
included in the shipping papers, and read to the driver.

4.3.2.9 Make required prior notifications and correction calls in
accordance with “Post Checklist of Broker Work”
(Attachment 5.6).

4.3.2.10 Notify the Broker Supervisor, Broker Committee
Chairperson and the emergency response organization (as
indicated on the DOT shipping paper) of the shipment.
Provide the required information to the emergency
response contact organization. Notification to the Broker
Supervisor and Broker Committee Chairperson may be
accomplished by fax or E-mail using the Broker Supervisor
Notification Form (Attachment 5.6), or equivalent.

Note: Notification to the Broker Supervisor
Broker is required only when the
shipment is being performed under this
procedure.

Note: Pictures can be helpful to document your
shipment, but are not required.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 26 of 141
4.3.2.11 Distribute copies of the shipping papers in accordance with
the “Copy Distribution Checklist” (Attachment 5.5), and
release the shipment.

4.3.3 Empty Package Shipments

4.3.3.1 Verify that the non-exclusive use carrier is approved on the
Authorized Vendor List (AVL).

4.3.3.2 Observe or perform a radiation and contamination survey
of the packages.

4.3.3.3 Complete the “Empty Package Check List” (Attachment
5.6).

4.3.3.4 Review the “Shipping Guidelines for Empty Packages”
(Attachment 5.6), for package and paperwork requirements.

4.4 Shipping Errors

4.4.1 If the Broker believes an error has occurred or has any questions
regarding an error, the Broker should notify the Broker Supervisor or
any member of the Broker Committee.

4.4.2 Specific requirements in the event of an error are provided in
References 2.13 and 2.14.

5. ATTACHMENTS AND FORMS

NOTE: Individual Broker shipping forms attached to this procedure can also be found
on the EnergySolutions’ network drive and folder, O:/BARSC/Shared/Broker/Broker
Forms or on the updated thumbdrive of Broker documents and references given to each
Broker during your last Requalification class.

5.1 Specific Shipping Requirements - Barnwell

5.2 Broker Checklist for Shipments to Hanford

5.3 Specific Shipping Requirements - EnergySolutions Clive Disposal Facility

5.4 Specific Shipping Requirements - Department of Defense

5.5 Copy Distribution Checklists

5.6 Shipping Papers and Supporting Documents

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 27 of 141
5.7 Calculation Worksheets

5.8 Guidelines for Packaging Magnesium-Thorium and Depleted Uranium Metal
Turnings in Dry Sand

5.9 Guidelines for Packaging of Biological Waste for Disposal

5.10 Reserved

5.11 Guidelines for Absorption of Small Volumes of Class A Liquid Waste for
Disposal at Hanford

5.12 Guidelines on the Encapsulation of Sources

5.13 Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility

5.14 Guidelines for the Use of Federal Express as a Common Carrier for the Transport
of Radioactive Material

5.15 Specific Shipping Requirements - Bear Creek/Gallaher Road

5.16 Shipping Requirements - Waste Control Specialists

5.17 Consignor Verification for Exclusive Use Radioactive Material Shipments and
License Authorization

5.18 Load Securement and Vehicle Safety Inspection

5.19 Category 1 and Category 2 Quantities of Radioactive Material

5.20 Shipping Exemption Value Sources
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 28 of 141
Attachment 5.1
Specific Shipping Requirements - Barnwell

1. Shipments to Barnwell must be in compliance with the applicable license Reference 2.1
and 2.2.

2. Transportation permits must be renewed by the first of January of each year. Ensure that
these permits are current.

3.. Weight and volume dilution of the activity concentration is not acceptable for aqueous
filters and sources that have been encapsulated.

4. Encapsulation for stability requires a specific thickness of cement all around the item
being encapsulated. Contact Barnwell Licensing Department.

5. Absorbed fluids are not acceptable.

6. DHEC 802, Prior Notification Form, is not required if the activity in the shipment is less
than one (1) curie and the volume is less than 75 cubic feet and shipment can be
consigned as non-exclusive use.

7. A Shipment ID# must be obtained from the Barnwell PNP Department for every
shipment being sent to the Barnwell Site for disposal.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 29 of 141
Attachment 5.2
Broker Checklist for Shipments to Hanford, Rev 0

This checklist is intended to be an aid to the Broker preparing a shipment consigned to Hanford.
This checklist is not a substitute for thorough understanding and use of the correct and up-
to-date license. This checklist must be used in conjunction with the license to ensure that the
shipment is properly prepared.

Broker Checklist for Shipments to Hanford
Shipping Scenario Did you consider the following license condition or
other requirement?
Broker
Initials or
N/A
Animal Carcasses 34: Layered with absorbent and lime and specified
packaging (DOT 7A) required

Biological waste 33: Special conditions must be met in treatment,
packaging, and sorbents.

Cardboard, paper, wood
or fiber-board containers
18: These package materials are not allowed
Certifications 44: Waste certification form RHF-31 is required
Chelates 41: Waste liquids with >1.0% chelates by weight shall
be treated by solidification or stabilization. For
concentrations of 0.1 - 1.0% other license
conditions should be considered as indicated by
the waste characteristics (i.e. liquids, etc.)
49: Segregation in trench by 10 feet is required and
may be reflected in the disposal charges.
Stabilized chelates do not require segregation.

Classification 26a: Use the classification worksheet provided in
Attachment 5.7

Closure on Packages 19: Heavy duty closures are required on 55-gallon
drums or greater capacity

Consumer Products 38: Consumer products (including smoke detectors)
require a specific exemption or proof the original
manufacturer has been licensed by the NRC or
Agreement State agency to manufacture the
product as a consumer product and the consumer
does not have or need a specific license to possess
the product. This proof must accompany the
shipping papers. Approved sorbent for cushioning
is required.
Must be Waste Class A unstable to qualify for
Condition 38.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 30 of 141
Broker Checklist for Shipments to Hanford
Shipping Scenario Did you consider the following license condition or
other requirement?
Broker
Initials or
N/A
Corrosives 28: Must be rendered non-corrosive
Deformed, degraded, or
heavily rusted containers
20: Not Allowed
DOT 7A Type A
packages
19: Meet certification requirements and file retention
requirements specified

Filters 36: Stability may be required dependent on
concentration levels; Free standing liquid is
limited; Cobalt-60 is unique in its requirements

Gaseous Waste 35: 1.5 atmospheres maximum, curie limitations, (1)
approved DOT gas cylinders, or (2) gas ampoules
in specification packaging (7A Type A) and state-
approved sorbent materials.
If the gaseous waste is not categorized as a
consumer product and exceeds Class A limits,
SPECIAL DEPARTMENT APPROVAL IS
REQUIRED.

High Integrity Containers 26: Approved containers have C of C’s or Specific
State Approvals

Ion Exchange Media 28: Shall not be treated by sorption
36: Stability may be required dependent on
concentration levels; Free standing liquid is
limited; Cobalt-60 is unique in its requirements

Incinerator Ash 39: Class A waste and must be rendered non-
dispersible

Inspections 44: State Patrol inspection at state's border
Note: Always do a second drum count and package
verification prior to release to the carrier.

Liquids 24: Not acceptable unless authorized
28: Must be properly treated, <1.0% by volume in
HIC's and <0.5% by volume if processed
30: Solidification allowed under certain conditions
31: Sorption allowed under certain conditions
32: Incidental and unintentional liquids in solid
material, may be acceptable under certain
conditions

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 31 of 141
Broker Checklist for Shipments to Hanford
Shipping Scenario Did you consider the following license condition or
other requirement?
Broker
Initials or
N/A
Lifting Devices 25: Must be appropriate, of sufficient length, and
securely attached
Markings 26: Waste Class marking required; unique package
I.D. number linked to the RSM
27: Must be 1/2 inch or greater, durable, contrasting
color, visible and in close proximity to the
radioactive marking or label.
For casks the class markings must be on the outside of
the cask as well as the internal container

Mixed Waste 17: No mixed waste unless authorized
NORM/NARM WAC 246-249-080 (RA-226):
Special approvals for concentrations less than 0.002
microcurie/gram and if >1,000 cubic feet per year
No co-mingling of NORM/NARM with low-level waste

Neutron Sources 42: Oral and written notifications required
Oil 40: Waste liquids of >10% by weight are not
acceptable, <10% absorbed
50: Segregation in trench by Engineered Concrete
barrier (ECB) is required and may be reflected in
the disposal charges. Stabilized oil does not
require segregation

Permits Note: A shipment may not be released to the carrier
until it is verified that the Disposal Site Users
Permit is valid, not expired, and will not expire
before the shipment arrives at the disposal site

Pyrophoric, hazardous,
dangerous, chemically
explosive, or react
violently when exposed to
water or agitation
23: Not allowed
Radioactive Shipment
Manifest (RSM)
44: RSM is required
Note: Three codes can be entered in each of the waste
description and solidification/
stabilization/sorbent columns on the RSM. Do
not use the code for a solidification agent when
a stabilization agent is used. If code 99 is used
an explanation must be included

Radium / Transuranics 37: Must be uniformly distributed and homogeneous;
If >Class A or if not uniformly distributed requires
special departmental approvals

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 32 of 141
Broker Checklist for Shipments to Hanford
Shipping Scenario Did you consider the following license condition or
other requirement?
Broker
Initials or
N/A
Special Nuclear Material Note: Refer to the Hanford site's SNM License
Note: Any quantity of SNM requires a SNM
Certification statement and signature to
accompany the shipping papers

Solidification 30: Approved media and program and free-standing
liquid restrictions
Sorbents 31: Special requirements for sorption of liquids in
packaging, use of absorbent, and quality control
32: Packaging of vials with liquids therein
33: Packaging of biological materials, void spaces in
double drummed packages
34: Packaging of animal carcasses, void spaces in
double drummed packages
35: Used in conjunction with gaseous waste as
cushioning

Sources Note: Concrete used for the encapsulation of
sources must be cured for 28 days and must
achieve a minimum compressive strength of
2500 PSI. Ensure that any dates that reflect the
28-day cure period are properly explained in
advance and in the paperwork

Stabilization 26: Methods as required by the NRC
29: Approved media and program with limitations on
free-standing liquids

Toxic gases, vapor, fumes 22: Not allowed
Void Spaces 21: 15% in most cases; some exceptions for HIC's and
irradiated metals with special department
approvals

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 33 of 141

Attachment 5.3
Specific Shipping Requirements
EnergySolutions Clive Disposal Facility
1. Review current EnergySolutions Clive Disposal Facility (ES License UT 2300249. A
current copy can be found at www.EnergySolutions.com. All waste must have an
approved profile associated with a valid General Site Access Permit (GSAP). Different
waste streams require different profiles.

2. If sending bulk waste, review ES Waste Acceptance Guidelines. A current copy can be
found at www.EnergySolutions.com

See attached shipping overview for shipping bulk waste to ES.

3. If shipping containerized waste, review ES Containerized Waste Facility Waste
Acceptance Criteria. A current copy can be found at www.EnergySolutions.com

See attached shipping overview for containerized waste shipping.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 34 of 141
Attachment 5.3 (Continued)
Overview of Shipping Bulk Waste to EnergySolutions Clive Disposal Facility

1. Prerequisites

1.1 The waste forms and radionuclides must be homogenous except in the case of
structural debris superficially contaminated with licensed material.

1.2 No sealed sources

1.3 Freestanding liquid shall in no case exceed 1.0% by waste volume per container.

1.4 The authorized forms of materials are volumetric bulky materials or structural
debris. The use of bulk-closed transport is encouraged.

1.5 Structural debris is limited to < 10 inches in at least one direction, and no longer
than 12 feet in any one direction.

2. Sample waste to ensure it meets the requirements of the UT 2300249 license.

3. Contact ES and forward information to include waste volumes, packaging, and
transportation.

4. Obtain signed disposal agreement.

5. Obtain Generator Site Access permit and approval for export from the generators
compact.

6. Waste stream characterization and profile.

6.1 As necessary, obtain and send samples of waste stream to Utah certified lab.

6.2 Complete Profile Form EC-0230 and submit to ES. Form can be found at
www.EnergySolutions.com

7. ES will notify if waste profile is approved.

8. Send pre-shipment sample to ES to allow “finger printing” of waste.

9. Submit 1st manifest to ES for review and approval.

10. ES will issue “Notice to Transport”.

11. Submit 5-Day Shipment Notification.

12. Ship waste.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 35 of 141
Attachment 5.3 (Continued)
Overview of Shipping Containerized Waste to EnergySolutions Clive Disposal Facility

1. Prerequisites

Waste must meet the definition of Class A waste in accordance with Utah Radiation
Control Rule R313-15-1008. This rule is essentially equivalent to 10 CFR 61.55

2. Obtain contract with ES for disposal.

3. Obtain a Generator Site Access Permit for each generator and export approval as
necessary.

4. Submit Certified Containerized Waste Profile Form (C-WPR) to ES.

5. After approval of profile, a Notice to Transport (Form EC-98243) is issued.

6. Submit Advanced Shipment Notification Form.

7. ES will issue a Shipment Identification Number.

8. Schedule shipments.

9. Submit via phone or fax, shipment departure notification when the shipment leaves the
site.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 36 of 141

Attachment 5.4
Specific Shipping Requirements
Department of Defense

1. All brokers and independent inspectors of Department of Defense shipments must be
approved in writing by Headquarters, U.S. Army Joint Munitions Command (JMC).

Note: This requirement applies only if the broker/inspection work is contracted
through JMC.

2. All shipments to the EnergySolutions – Barnwell Processing Facility (BPF) shall be made
in accordance with Reference 2.6.

3. When inspecting the motor vehicle safety, the Department of Defense Form DD-626
shall be used when Section 1 (above) is applicable.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 37 of 141

Attachment 5.5
Copy Distribution Checklist
CONSIGNEE - CHEM-NUCLEAR SYSTEMS, BARNWELL, SOUTH CAROLINA

Documents, as applicable
BWMF/
BPF
Generator/
Shipper/
Licensee Carrier Broker
Emergency
Response
Provider
Waste Manifest Orig 2 Orig 3 Orig Copy Copy
Bill of Lading ** 3 Orig 4 Orig * Copy N/A
DHEC 803 Orig Copy Copy Copy N/A
DHEC 802 Orig Copy Copy Copy N/A
Exclusive Use Instruction Copy Copy Orig Copy N/A
Inventory Sheet N/A Copy N/A Orig N/A
Truck Survey Copy Copy Copy Orig N/A
Broker Checklist** N/A N/A N/A Orig N/A
*HIC Cert. Copy Copy N/A Copy N/A
*NRC Form 741 Orig Copy N/A Copy N/A
*Isotopic Analysis Copy Copy N/A Copy N/A
*Class C Cert Orig Copy N/A Copy N/A
*Comp. Exp. Ltr. or Permit Orig Copy N/A Copy N/A
*Variance Ltr. Copy Copy N/A Copy N/A
Emergency Response Copy Copy Orig Copy Copy

* 1st and 2nd originals
** Optional, may be required by Carrier or Consignee.
ORIG - Original or 1st Original
2 ORIG - 2nd Original
3 ORIG - 3rd Original

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 38 of 141
Attachment 5.5 (Continued)
Copy Distribution Checklist
CONSIGNEE - US ECOLOGY
HANFORD, WASHINGTON

Documents, as applicable
Disposal
Site
Generator/
Shipper/
Licensee Carrier Van Copy Broker
Emergency
Response
Provider
Waste Manifest (norm) Orig 4th 3rd 5th Copy Copy
Waste Manifest Orig 3 Orig 4 Orig 2 Orig Copy Copy
Bill of Lading** 3 Orig 4 Orig * Copy Copy N/A
WA Certification DHS-RHF-
31A, B, or C
Orig Copy Copy Copy Copy N/A
Prior notification call sheet Copy Copy Copy Copy Orig N/A
*Copy Surcharge Check Copy Copy N/A Copy Copy N/A
Exclusive Use Instruction Copy Copy Orig Copy Copy N/A
Inventory Sheet N/A Copy N/A N/A Orig N/A
Truck Survey Copy Copy Copy Copy Orig N/A
Broker Checklist** N/A N/A N/A N/A Orig N/A
*NRC Form 741 Orig Copy N/A Copy Copy N/A
* SNM Certification Orig Copy N/A Copy Copy N/A
* Compact Export Letter Orig Copy N/A Copy Copy N/A
* Variance Ltr. Orig Copy N/A Copy Copy N/A
Emergency Response Copy Copy Orig Copy Copy Copy

* 1st and 2nd originals
** Optional - may be required by Carrier or Consignee
ORIG - Original or 1st Original
2 ORIG - 2nd Original
3 ORIG - 3rd Original
4 ORIG - 4th Original

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 39 of 141
Attachment 5.5 (Continued)
Copy Distribution Checklist
Non-Waste Shipments

Documents, as applicable Consignee
Generator/
Shipper/
Licensee Carrier Broker
Emergency
Response
Provider
RSR*** Orig Copy Copy Copy Copy
Bill of Lading** *** 3 Orig 4 Orig * Copy **
Exclusive Use** ***
Instruction
Copy Copy Orig Copy N/A
Inventory Sheet*** N/A Copy N/A Orig N/A
Truck Survey*** Copy Copy Copy Orig N/A
*NRC Form 741 Orig Copy N/A Copy N/A
Emergency Action Copy Copy Orig Copy Copy
Empty Package Checklist*** N/A Orig N/A N/A N/A

* 1st and 2nd originals
** Optional - may be required by Carrier, Consignee, or consignor.
*** Not required for Empty Packages
ORIG - Original or 1st Original
2 ORIG - 2nd Original
3 ORIG - 3rd Original
4 ORIG - 4th Original

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 40 of 141
Attachment 5.5 (Continued)
Copy Distribution Checklist
CONSIGNEE - ENERGYSOLUTIONS CLIVE DISPOSAL FACILITY OF UTAH

Documents, as applicable Consignee

Generator/
Shipper/
Licensee Carrier Broker
Emergency
Response
Provider
Waste Manifest Orig Copy Copy Copy Copy
Bill of Lading** 3 Orig 4 Orig * Copy **
Exclusive Use Instruction Copy Copy Orig Copy N/A
Inventory Sheet N/A Copy N/A Orig N/A
Truck Survey Copy Copy Copy Orig N/A
*NRC Form 741 Orig Copy N/A Copy N/A
Emergency Action Copy Copy Orig Copy Copy
Vehicle Inspection Form Copy Copy Copy Copy N/A

* 1st and 2nd originals
** Optional - may be required by Carrier or Consignee.
ORIG - Original or 1st Original
2 ORIG - 2nd Original
3 ORIG - 3rd Original
4 ORIG - 4th Original

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 41 of 141
Attachment 5.5 (Continued)
Copy Distribution Checklist
CONSIGNEE - PERMAFIX

Documents, as applicable Permafix
Shipper/
Generator/
Licensee Carrier Broker
Emergency
Response
Provider
Waste Manifest Original 2 Orig 3 Orig Copy Copy
Bill of Lading** 3 Orig 4 Orig * Copy **
Exclusive Use Instruction Copy Copy Orig Copy N/A
Inventory Sheet N/A Copy N/A Orig N/A
Truck Survey Copy Copy Copy Orig N/A
*NRC Form 741 Orig Copy N/A Copy N/A
Emergency Action Copy Copy Orig Copy Copy
Hazardous Waste Manifest Copy 1 Orig
All other
form copies Copy
Copy
Broker Check List N/A N/A N/A Orig N/A
Compact Export Orig Copy Copy Copy N/A
Variance Letters* Copy Copy Copy Copy N/A
Case Specific Documents as required
by Facility use Criteria * * * Copy N/A

* As required by Permafix Waste Acceptance Criteria, Reference 2.3
** Optional - may be required by Carrier or Consignee.
ORIG-Original or 1st Original
2 ORIG-2nd Original
3 ORIG-3rd Original
4 ORIG-4th Original

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 42 of 141

Attachment 5.6
Shipping Papers and Supporting Documents

NOTE: Individual Broker shipping forms attached to this procedure can also be found on
the EnergySolutions’ network drive and folder, O:/BARSC/Shared/Broker/Broker Forms
or on the updated thumbdrive of Broker documents and references given to each Broker
during your last Requalification class.
LIST OF REGULATORY AGENCY OR OTHER OFFICIAL FORMS
1 Barnwell Radioactive Waste Manifest (Approved modified version of USNRC Uniform
Manifest)
2 Barnwell RWM (Radioactive Waste Manifest) Continuation Sheet
3 Barnwell RWM Broker/Processor
4 Barnwell RWM Continuation Sheet
5 US Ecology RWM USNRC Uniform Manifest)
6 US Ecology RWM Continuation Sheet
7 US Ecology RWM and Regional Compact Tabulation

8 US Ecology RWM for Waste Collectors/Processors
9 Forms Contained in Barnwell Site Criteria S20-AD-010

10 Straight Bill of Lading

11 Straight Bill of Lading Continuation Sheet

12 SC DHEC 800

13 SC DHEC 802

14 SC DHEC 803

15 Washington State's Low-Level Waste Shipment Certification for Generators/Packagers and
Broker/Carriers (RHF-31A).

16 Washington State's Low-Level Radioactive Waste Shipment Certification for Governmental Generators/Packagers, Brokers/Carriers (RHF-31B).

17 Washington State's Low-Level Radioactive Waste Shipment Certification for the Federal
Government agency Generator/Packager and its Brokers/Carriers (RHF-31C).
18 US Ecology Broker/Processor/Generator Volume Activity Record.
19 SC DHEC Broker/Processor Addendum to DHEC 802

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 43 of 141
Attachment 5.6 (Continued)
20 State of Washington Application for Broker Site User Permit.
21 NRC Form 741
22 US EPA's Uniform Hazardous Waste Manifest.
23 EnergySolutions Clive Disposal Facility's RSM (USNRC Uniform Manifest)
24 EnergySolutions Clive Disposal Facility's RSM Continuation Sheet
25 EnergySolutions Clive Disposal Facility's SNM Exemption Certificate (EC-0230-SNM)
26 Five Working Day Shipment Notification (Bulk Facility)
27 Advanced Shipment Notification Form (CWF)
28 DD Form 626, Vehicle Inspection Form

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 44 of 141
Broker Inventory Sheet, Rev 0
PACKAGE ID
mR/hr
contact mR/hr @ 1m CONTAMINATION WEIGHT
ACTIVITY
( ) Ci
( ) mCi
CLASS
ABC-SU
CONTAINER
SPECS
LABELING
MARKING
CONTENTS
INSPECTED LOADED

Survey Performed by: Shipment #
Date
Instrument Type
Serial No.
Calibration Date Due Page of
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 45 of 141

Empty Class 7 Packaging Checklist, Rev 0
Note: If any of the above conditions cannot be fully satisfied, the package may not be shipped
as “EMPTY”.

Signature Date
Shipping Date:
Consignor Name:
Consignor Address:
Survey Number: Unit Number:
Consideration Limit or Requirement Actual Value/Condition
Completed by
(Initials)
External On-Contact Dose
Rate
Does not exceed 0.5 mrem/hr mrem/hr
Removable
Contamination on
Package Exterior
(Contamination limits
listed are 10% of
49CFR173.443 Table 9
limits)
Does not exceed:
2,400 dpm/100 cm2 for beta/gamma dpm/100 cm2
240 dpm/100 cm2 for alpha dpm/100 cm2

Fissile Material Non-fissile or fissile-excepted Yes No
Package Condition In good condition & is closed Yes No
Internal Contamination Does not exceed:
240,000 dpm/100 cm2 for beta/gamma dpm/100 cm2
24,000 dpm/100 cm2 for alpha dpm/100 cm2
All labels (WI, YII, or
YIII)
Removed or covered Yes No
EMPTY Label At least 1 is visible on the outside of the
package and is securely affixed
Yes No
ID Marking UN 2908
Placards Not displayed N/A
Miscellaneous Comments:
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 46 of 141
Shipping Guidelines for Class 7 Empty Packagings, Rev 0

Requirements DOT-Empty Packages
Empty Package Checklist Required
Bill of Lading Optional
Survey of Shipment (Vehicle and Package) Required (Filed)
Gate Pass (Barnwell Complex Only) Required
RSR (DOT Shipping Paper) Not Required
Emergency Response Documents Not Required
NRC Form 741 Not Required
Broker Inventory Sheet Not Required

Orange Panels Removed or covered
USA DOT 7A Type A Uncovered
Radioactive Material (Manufacturer's Marking) Covered
Type A Uncovered
Trefoil Uncovered
C of C Uncovered
Type B Uncovered

W-I, Y-II, or Y-III Removed or covered
EMPTY Required
UN 2908 (Non-specification marking. Not orange panel or
white square on point configuration.)
Required
Radioactive Placard on at least 4 sides Not Required

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 47 of 141
Broker Tractor/Trailer Survey, Rev 0

Shipment ID Number: = mrem/hr
Survey Performed by: = dpm/100 cm2
Instrument Used:
Date Calibrated:

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 48 of 141
Cask Survey, Rev 0
Shipment ID Number:
Trailer ID Number:
Survey Performed by:
Instrument/Probe Used:
Survey Number:

Max Reading mrem/hr
Contact
Max Reading mrem/hr
at 2 Meters
Right Side
Left Side
Front
Rear
Top Side
Underside
mrem/hr in Driver’s seat
mrem/hr in Passenger seat
Max mrem/hr in Sleeper
General Dose Rate (mrem/hr) even with the
top center plane of the open cask
(EnergySolutions Clive Disposal Facility
only)

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 49 of 141
Driver’s Instructions for
Exclusive Use Vehicles
HANFORD, REV 0

The Code of Federal Regulations, 49 CFR 173.403, 173.441, and 173.427 requires that specific instructions
for maintenance of exclusive use shipments controls be provided to the carrier. These instructions must be
included with the shipment documents.

The following instructions shall be complied with for all exclusive use vehicles:

 Do not change out tractor before arrival at the radioactive burial site without notifying shipper.
 Do not change the fifth wheel adjustment on the tractor without notifying shipper.
 Do not move or transfer packages within the van or between vans while enroute to site without
notifying shipper.
 The shipment must be loaded by consignor and unloaded by consignee from the transport vehicle
in which originally loaded.
 Shipments must be braced so as to prevent leakage or shifting of load under conditions normally
incident to transport.
 The vehicle must be placarded “RADIOACTIVE” on all four sides when applicable until
shipment is unloaded.
 Notify Hanford 24 hours prior to arrival [phone].
 Notify Washington State Port Authority 4 hours prior to arrival [phone].

If the vehicle is involved in an accident or is required to make emergency braking this could shift the load
and change radiation levels, notify the shipper immediately.

In case of an accident, vehicle malfunction, or deviation from the above instructions immediately contact
the individual/organization identified on the NRC/DOT shipment manifest for instructions. Any deviations
from these instructions are violations of State and Federal laws, and could result in carrier penalty.

Driver's Signature Date

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 50 of 141
Driver's Instructions for
Exclusive Use Vehicles
BARNWELL, SC, REV 0

The Code of Federal Regulations, 49 CFR 173.403, 173.441 and 173.427 requires that specific instructions
for maintenance of exclusive use shipments controls be provided by the shipper to the carrier. These
instructions must be included with the shipment documents.

The following instructions shall be complied with for all exclusive use vehicles:

 Do not change out tractor before arrival at the radioactive burial site without notifying shipper.
 Do not change the fifth wheel adjustment on the tractor without notifying shipper.
 Do not move or transfer packages within the van or between vans while enroute to site without
notifying shipper.
 The shipment must be loaded by consignor and unloaded by consignee from the transport vehicle
in which originally loaded.
 Shipments must be braced so as to prevent leakage or shifting of load under conditions normally
incident to transportation.
 The vehicle must be placarded "RADIOACTIVE" on all four sides when applicable until
shipment is unloaded.

If the vehicle is involved in an accident or is required to make emergency braking this could shift the load
and change radiation levels, notify the shipper immediately.

In case of an accident, vehicle malfunction, or deviation from the above instructions immediately contact
the individual/organization identified on the NRC/DOT shipment manifest for instructions. Any deviations
from these instructions are violations of State and Federal laws and could result in carrier penalty.

Driver's Signature Date
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 51 of 141
Driver’s Instructions for
Exclusive Use Vehicles
PERMAFIX, REV 0

The Code of Federal Regulations, 49 CFR 173.403, 173.427 and 173.441 requires that specific instructions
for maintenance of exclusive use shipments controls be provided by the shipper to the carrier. These
instructions must be included with the shipment documents.

The following instructions shall be complied with for all exclusive use vehicles:

 Do not change out tractor before arrival at the site without notifying shipper.
 Do not change the fifth wheel adjustment on the tractor without notifying shipper.
 Do not move or transfer packages within the van or between vans while enroute to the site
without notifying shipper.
 The shipment must be loaded by consignor and unloaded by consignee from the transport vehicle
in which originally loaded.
 Shipments must be braced so as to prevent leakage or shifting of load under conditions normally
incident to transportation.
 The vehicle must be placarded “RADIOACTIVE” on all four sides when applicable until
shipment is unloaded.

If the vehicle is involved in an accident or is required to make emergency braking this could shift the load
and change radiation levels, notify the shipper immediately.

In case of an accident, vehicle malfunction, or deviation from the above instructions immediately contact
the individual/organization identified on the NRC/DOT shipment manifest for instructions. Any deviations
from these instructions are violations of State and Federal laws and could result in carrier penalty.

Driver's Signature Date
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 52 of 141
Driver’s Instructions for
Exclusive Use Vehicles, Rev 0
Consignee Facility

The Code of Federal Regulations, 49 CFR 173.403, 173.427 and 173.441 requires that specific instructions
for maintenance of exclusive use shipments controls be provided by the shipper to the carrier. These
instructions must be included with the shipment documents.

The following instructions shall be complied with for all exclusive use vehicles:

 Do not change out tractor before arrival at the site without notifying shipper.
 Do not change the fifth wheel adjustment on the tractor without notifying shipper.
 Do not move or transfer packages within the van or between vans while enroute to the site
without notifying shipper.
 The shipment must be loaded by consignor and unloaded by consignee from the transport vehicle
in which originally loaded.
 Shipments must be braced so as to prevent leakage or shifting of load under conditions normally
incident to transportation.
 The vehicle must be placarded “RADIOACTIVE” on all four sides when applicable until
shipment is unloaded.

If the vehicle is involved in an accident or is required to make emergency braking this could shift the load
and change radiation levels, notify the shipper immediately.

In case of an accident, vehicle malfunction, or deviation from the above instructions immediately contact
the individual/organization identified on the NRC/DOT shipment manifest for instructions. Any deviations
from these instructions are violations of State and Federal laws and could result in carrier penalty.

Driver's Signature Date
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 53 of 141
Instructions for
Exclusive Use Transport Vehicles (Rail), Rev 0
Consignee Facility

The Code of Federal Regulations, 49 CFR 173.403, 173.427, and 173.441 requires that specific
instructions for maintenance of exclusive use shipment controls be provided by the shipper to the
carrier. These instructions must be included with the shipment documents.

The following instructions shall be complied with for all exclusive use vehicles:

 The transport vehicle used for this shipment is designated as “Exclusive Use.” It is
understood that it will be loaded by the consignor, unloaded by the consignee, and no
other materials will be carried in/on the cargo carrying body unless under the direction of
the consignor, consignee, or authorized agent.
 The car configuration including buffer cars (if applicable) shall not be changed while
enroute to the final destination.
 If the railcar is placarded “Radioactive”, the placarding must remain on all four sides
until the shipment is unloaded.
 No humping of railcars because it could shift the load and increase radiation levels

In case of an accident, vehicle malfunction, or deviation from the above instructions immediately
contact the individual/organization identified on the NRC/DOT shipment manifest for instructions. Any
deviations from these instructions are violations of State and Federal laws and could result in
carrier penalty.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 54 of 141
Broker Pre-Departure Guide, Rev 0

The Broker performing any radioactive/hazardous material shipment, shall have in their
possession a copy of the waste acceptance guidelines (WAG), waste acceptance criteria
(WAC), radioactive materials license and any required documentation specific to the
facility their shipping to.

I. Initial contact with generator (phone)
A. Description of material
B. Amount - Volume
C. Activity (Act/Est)
D. Tentative Dates (Act/Est)
E. Permit Number
F. Directions to Site
G. Handling Equipment Available (If
required)

H. Workplace restrictions
(e.g. Safety, PPE, Security, etc.)

II. Office Work-Up
A. Planning Job
1. Classification of material
2. How will it be shipped
3. Waste Category
4. Man-hours and equipment needed
5. Shipping arrangements (materials)
6. Shipping ID # /Generator #
7. Permission or Permit to Export/Import to Compact
8. Submit DHEC 802, if necessary
9. Submit DHEC 803, if necessary
10. Transportation
11. Obtain Illinois Tracking Number, if required
12. Applicable procedures up to date
13. Check National Security Threat Level
Page 1 of 5

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 55 of 141
B. Re-Contact Generator
1. Shipping Dates
2. Materials to be supplied by Customer

III. Material Needed for Job
A. Instruments
1. Eberline 520 with appropriate probes, or equivalent
2. Alpha detector, if necessary
3. Additional instruments, if necessary
B. Packaging(s)
1. Non-specification (excepted quantity, IP-I)
2. Specification (Type A, Type B(U), Type B(M), Type IP-
1, Type IP-2, Type IP-3)
Correct packaging(s) selected based on DOT
requirements, physical characteristics, and compatibility
of contents

C. Labels
1. WI
2. YII
3. YIII
4. Empty
5.
6.
Fissile
Corrosive

7. Oxidizer
8. Flammable Liquid
9. Flammable Solid
10 Spontaneously Combustible
11. Organic Peroxide
12. Cargo Aircraft Only
13. ID # (orange panels)
14. Other

Page 2 of 5

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 56 of 141
D. Markings
1. Specification
a. Proper shipping name and ID #
b. Consignor/Consignee name and address
c. Item number/weight
d. Container specification
e. Orange Panels
2. Non-Specification
a. Radioactive (limited quantity)
b. Radioactive-LSA, Radioactive-SCO, (exclusive
Use vehicle)

c. Waste class: A ___ B____ C____
d. Stable ____ Unstable ____
e. Dry solid
f. Absorbed liquids
g. Biological

E. Paperwork Required
1. Barnwell Site
a. Waste Manifest
b. Completed DHEC 802
c. Blank DHEC 803
d. Broker/Processor forms as applicable
2. Hanford Site
a. RSM, continuation, and compact tabulation pages
b. Washington State Certification,
c. Washington State Certification, government
d. Broker/Processor forms as applicable

Page 3 of 5

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 57 of 141
3. EnergySolutions Clive Disposal Facility Utah
RSM and continuation pages
4. Non-Disposal Shipments
RSR and continuation pages (not required for Empty Packages)
5. Bill of Lading and Continuation Sheets
6. Broker packages
7. Extra Broker Surveys
8. HIC operating procedures
9. Stabilization/encapsulation/solidification process procedures
10. Variance Letter(s)
11.
12.
Export Permission
Specification packaging documentation

F. Other Materials Needed
1. Ruler
2. Calculator
3. Marking pencils
4. Batteries
5. Paper
6. Rubber bands
7. Clip boards
8. Placards
9. Seals
10. Smears
11. Necessary tools
12. Shipping envelopes
13. Time sheets and expense reports

Page 4 of 5

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 58 of 141
G. Travel Arrangements
1. Confirm plane reservations
2. Confirm hotel reservations
3. Confirm car reservations
4. Passport
5. Visa

Page 5 of 5
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 59 of 141
Post-Checklist of Broker’s Work (Non-Waste), Rev 0

Check or N/A as applicable Shipment No.
A. Container Inspection
1. Container integrity satisfactory
2. Clean, contents inspected, no free -standing liquid
3. Solidified drums tapped
4. Wooden boxes banded (Wooden boxes to Hanford not acceptable)
5. Metal boxes clipped
6. Caulking visible on wooden boxes
7. Drum lids sealed
8. Lock nuts tight
9. Tamper seal (Type A, Type B(U), Type IP-III)
10. Survey container (<90% of DOT limits dose rate + contamination, Step 4.2.1.3)
11. Dose rate recorded on container
12. Item/weight label (completed)
13. Waste classification/stability
14. Proper shipping name and I.D. number marking
15. Specification labels (two sides) w/SI units (i.e., TBq, MBq, etc.)
16. Contents that can shift are fixed in place

B. Loading
1. Driver has CDL, appropriate Hazardous Materials Endorsement, and valid DOT Medical Card
(if applicable) Do not include a copy of driver’s CDL and medical card in the shipping papers,
Step 3.15, for privacy reasons.
2. Conduct and record initial survey of trailer
3. Higher dose rate containers shielded from lower dose rate container's exterior side
4. Drums weighing greater than 1000 lbs. palletized
5. Check with driver about weight placement
6. Load properly braced and secured
7. Freight Container placarded (Truck placarded for bulk and Non-Bulk packages)
8. Bulk Package placarded (2 placards opposite sides if <640 ft3 and not labeled, 4 placards if
>640 ft3)
9. Conduct and record final truck survey
10. Seal doors on trailer

Page 1 of 4
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 60 of 141
Continued Shipment No.
C. Cask Inspection
1. Tie-Downs
a. Tightness (no slack)
b. Turnbuckles/ratchet binders (handles secure)
c. Cable clamps properly installed
d. No sharp objects to damage cable or chains
e. Tie-down attachment welds (no cracks)
f. Cable/chain conditions (do not touch)
2. Liner:
a. Type Serial No.
b. Barrel top covers (pipe caps in place)
c. QA Inspection sticker and # of sunlight days
d. Liner properly marked for Class (A,B,C)

3. Cask Cover/Lid:
a. Nuts/bolts/washers (condition, lubricated, torqued)
b. Lids bolted/cask seal affixed; leaked tested, as necessary, for Type B casks
c. Rain cover installed (proper tie-down)
d. Lid lifting shackles/rings, lugs properly covered
e. Lid top surface clean

4. General:
a. Cask trailer base retainer plates in place
b. Cask in proper location on trailer
c. Paint appearance/nameplate/cleanliness of cask

__________
__________
d.

e.
Ensure compliance with CoC/SAR limitation conditions, ie payload, decay heat, hydrogen
gas, and neutrons, as applicable.
HOLD POINT: PEER check required to ensure compliance with d. above

D.

Shipping Papers
1. Non-Waste/Waste Manifest sheets completed
2. Cover sheet:
a. Driver's signature
b. Release signatures
c. Check for entries in every block
d. Verify totals
e. Emergency Response information is entered

Page 2 of 4
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 61 of 141
Continued Shipment No.
3. DOT Shipping Paper
a. Number of packages
b. Hazardous material column
c. Proper shipping name and I.D. number
d. RQ entered
e. Weight
f. Description
g. Radionuclides
h. Total activity
i. Physical form
j. Chemical form
k. Specification Label or non-specification marking
l. T. I.
m. C.S.I.
n. Container Type
o. LSA, SCO Category
p. Fissile Excepted
q. Time/date - arrived/departed
r. Exclusive use statement
s. Page numbers if continuation used
t. Driver's signature
u. Shipper's signature

4. Complete radioactive waste shipment certification forms:
a. Broker's signature
b. Driver's signature
c. Broker's signature (Hanford)

5. Corrections to DHEC 802

6. Shipping papers and copies legible

Page 3 of 4
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 62 of 141
Continued Shipment No.
7. Reproduce copies:
a. Shipper's copy
b. Carrier copy
c. Site copy
d. Broker copy
e. Broker Supervisor
f. U.S. Ecology trailer copy (attached inside trailer door)
g. Mail (Waste Manifest cover sheet to disposal site)
h. Clive (Fax RSM to 801-537-7345)

8. Prior notification calls:
a. Hanford – 509-377-2411
b. Barnwell – 803-541-5004
c. DHEC – 803-898-0422 (FAX corrections to 803-898-0391)
d. Broker Supervisor

9. Illinois Waste Tracking System Notification, if required:

10. Transportation Security Plan requirements met? (Threat Level, Radioactive Quantities of
Concern, QC, etc.)

Signature Date

Page 4 of 4
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 63 of 141
Post-Checklist of Broker's Work (Waste), Rev 1

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

SCHEDULING ACTIVITIES
1. EnergySolutions has been notified if configured shipment contains
more than 8000 pCi/gm of the following radioactive elements; Th, Np,
Am, Pu, U, Cm, OR contains any amount of Cl.

2. EnergySolutions has approved this shipment in advance, IF it contains
Al-36, Bk-247, Ca-41, Cf-249, Cf-250, Re-187, Tb-157, or Tb-158.
3. Current copy of consignee license is in the possession and is consistent
with the isotopes, activities, and forms to be shipped.
4. Broker possesses a valid South Carolina Radioactive Waste Transport
Permit
5. Each waste generator in shipment possesses a copy of a valid South
Carolina radioactive waste transport permit.
6. A shipment ID number has been obtained from Barnwell at least
10 days prior to shipment.
7. DHEC 802 Form has been faxed or mailed to both DHEC and Barnwell
at least 72 hours prior to release of shipment.
8. Advanced prior shipment notifications have been made to appropriate
state agencies (i.e., Iowa, Maine, Mississippi, etc.).
9. Class C Waste Classification Record has been submitted prior to
shipment.
10. Broker possesses a valid State of Washington Use Permit and a
Generator Number.
11. Each waste generator in shipment possesses a copy of a valid State of
Washington Use Permit and a Generator Number.
12. Broker has obtained the approval of US Ecology NARM Services for
NARM shipment, if applicable.
13. Broker has on file a valid radioactive waste profile record (Energy
Solutions Form EC-0230, Attachment 13) that is consistent with the
waste to be shipped.

14. Broker possesses a valid notice to transport (Energy Solutions Form
EC-1800) for shipments consigned to Clive BWF.
15. The 5 Day Shipment Notification Form has been submitted to
EnergySolutions a minimum of 5 working days prior to shipment.
16. Broker possesses a valid User’s Permit issued by the state of Utah.
17. The Broker has reviewed and approved the LDR notification form
and the Uniform Hazardous Waste Manifest.
18. Broker has on file a valid Certified Containerized Waste Profile
Record (Energy Solutions Form EC-98210) that is consistent with the
waste to be shipped.

19. Broker possesses a valid Notice to Transport (Energy Solutions Form
EC-98243) for shipments consigned to Clive CWF.
20. The Advanced Shipment Notification Form and digital photographs
have been submitted to EnergySolutions.
21. A shipment ID number has been obtained from EnergySolutions.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 64 of 141

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

22. A site clearance number has been obtained from the Barnwell
Processing Facility.
23. Broker has on file a WCS-approved waste profile sheet for the waste
to be shipped.
24. Shipment has been scheduled at least 72 hours prior to arrival at WCS.
25. Waste has been properly classified for transportation in accordance
with the Broker Procedure.
26. Waste to Energy Solutions does not exceed Class A
27. Waste containers have no more than 15% void space.
28. Waste containers have no more than 15% void space (container size
up to 215 cubic feet) or 10% void space (container size greater than
215 cubic feet to 331 cubic feet) unless a variance request is approved
by Energy Solutions

29. If waste class is  90% of unity, perform a verification calculation to
ensure package has been properly classified.
30. The Navy has been notified at least 10 days prior to the shipment of
any navy waste and authorization by the navy to ship has been
granted.

31. Prior notifications have been made when shipping radionuclides that
exceed the shipping facility’s Security MQC.
32. The radionuclide activity does not exceed the MQC values during a
national security threat of high or severe.
33. If shipment is made in cask and total transuranics exceed
10 nCi/gram, determine whether the transport permit fee to Nebraska
is to be paid OR if the shipment is to bypass the state of Nebraska.

34. Checklist CP-WM-PR-304-F1 has been completed by the WCO,
except for attaching NV-211 label.
35. Ensure compliance with CoC/SAR limitation conditions, ie
payload, decay heat, hydrogen gas, and neutrons, as applicable
36. HOLD POINT: PEER check required to ensure compliance with 35
above
LOADING ACTIVITIES
1. Packages have been leak tested in accordance with Broker Procedure.
2. Each package has been properly inspected and can be shipped for
disposal.
3. Each package has a minimum of two identification numbers.
4. The gross weight has been marked on each package.
5. Each package has the two NTS barcode labels that include the
package weight.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 65 of 141

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

6. Packages containing “Radioactive LSA” or “Radioactive SCO” to be
shipped exclusive use have “Radioactive-LSA” or “Radioactive-
SCO” Markings at least ½ inch high applied to opposite sides of each
package.

7. Packages containing reportable quantities have the marking “RQ”.
8. Non-LSA and non-SCO packages and packages shipped non-
exclusive use are marked and labeled with specification markings and
labels in accordance with the Broker Procedure.

9. Reserved
10. The waste class is durably marked on the side of each container
(intermodals and sealands) and on top for all other containers
11. The waste class is durably marked on two sides of each container
within six inches of the “RADIOACTIVE-LSA” marking.
12. Containers with asbestos have an “Asbestos” label and a label with
the name and physical address of the facility
13. Each container has an NV-211 label.
14. Accessible rigging is provided for each box if the box is loaded with
runners oriented across the Sealand
15. Packages loaded onto flatbeds have tamper-indicating seals.
16. Vans and casks have tamper-indicating seals
17. The loading of non-bulk containers into bulk containers has been
verified and documented.
18. Waste Acceptance Criteria vehicle-loading requirements have been
met.
19. Packages have been properly braced on/in vehicle, and no foreign
materials on containers or vehicle (i.e., tools, debris, soil, etc.).
20. Any package handled during a reconfiguration of the load has been
re-inspected and is acceptable for shipment.
21. Bulk Package placarded (2 placards opposite sides if <640 ft3 and not
labeled, 4 placards if >640 ft3).
22. Freight Container placarded (Truck placarded for Bulk and Non-
Bulk).
23. Cask User Check-Off Sheet per the applicable Cask Handling
Procedure has been completed.
24. Container lifting devices shall be secured at the top of the container(s)
in a manner to prevent cables or slings from being trapped between
containers or between containers and cask wall.

25. Container lifting devices shall be of sufficient length to allow retrieval
and crane hook-up without physically entering the cask
26. Each package is marked with the appropriate waste class and stability.
27. Package internally inspected and contains no free-standing liquid (in
accordance with step 4.2.1.7. Absorbent material placed in package
for incidental liquids.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 66 of 141

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

28. Gondola/Railcar lid closure/locking latches are properly
engaged/secured
29. Gondola/Railcar drain(s) have been sealed by the use of Teflon tape,
thread sealing compound, caulking, etc. to achieve a leak tight
closure.

30. Evaluation of Radioactive Quantities of Concern values performed.
31. Transportation Security Plan in place.
MANIFEST PREPARATION AND REVIEW
1. FORM 540 AND 540A
 Verify all blocks are complete.
 Verify Block 4 is correct.
 Verify Shipper (Block 5) and Consignee (Block 9) are correct.
 Verify Shipment ID Number and User Permit Number (Block
5) are correct.
 Verify that Proper Shipping name (Block 11) is correct
(Reference 2.22, 49CFR172.202), Package Inventory from
Broker Procedure.

 Verify that “RQ” is on package survey for each package with
“RQ” in its Proper Shipping Name (Block 11).
 Verify that the entries in Blocks 12 and 13 are consistent with
the Proper Shipping Name (Block 11).
 Verify that the total package activity in Block 16 of Form 540
matches the total shipment activity from Block 16 of Form
541/541A as well as the total activity from Block 11 Column
C of Form 542/542A. Minor variations due to LLD values are
allowed

2. FORM 541 AND 541A
 Verify all blocks are complete.
 Verify Blocks 2 and 4 match Blocks 5 and 8 of Form 540.
 Verify dose rate in Block 10 matches survey map for each
container.
 Verify Blocks 10 and 11 are correct.
 Verify proper solidification media in Block 14. NOTE: Most
facilities are not authorized to ship solidified material to
EnergySolutions CWF.

 Verify radionuclides and activities (Block 16) are correct.
NOTE: EnergySolutions can only accept Class A waste for
disposal.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 67 of 141

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

 Verify that the waste class and stability for each package
match the waste class and stability from the Broker Worksheet.
3. FORM 542 AND 542A
 Verify all blocks are complete.
 For shipments to South Carolina, verify the Transport Permit
Number against the current Transport Permit List provided by
South Carolina.

 Verify dose rates in Block 11 Column F are consistent with
dose rates on Form 541 Block 10.
SHIPPING AND RELEASE ACTIVITIES
1. The Uniform Low-Level Radioactive Waste Manifest has
been submitted to EnergySolutions at least 3 business days
prior to scheduled arrival of shipment.

2. Waste has been properly classified for disposal in accordance
with the Broker Procedure.
3. Waste has been packaged in accordance with the appropriate
disposal facility Waste Acceptance Criteria.
4. Package contamination levels have been documented and do
not exceed the limits established in the Broker Procedure.
5. Package radiation levels have been documented and do not
exceed the limits established in the Broker Procedure.
6. NARM waste has been packaged in accordance with current
U. S. Ecology guidance, if applicable.
7. Prior approval has been obtained for any package in excess of
50,000-dpm/100 cm2.
8. Incoming vehicle survey has been performed and documented.
9. For shipment by highway directly to consignee, an overweight
permit has been obtained for vehicle in excess of 80,000
pounds gross vehicle weight.

10. Outgoing contamination survey is complete and contamination
levels do not exceed the limits established in Broker
Procedure.

11. Outgoing radiation survey is complete and dose rate levels do
not exceed the limits established in Broker Procedure.
12. The following documents have been completed and provided
to the driver.
 NRC Uniform LLRW Manifest Forms 540, 541, and 542
(facility specific)
 NRC Form 540 Attachment for Rail Shipments, if applicable
 Radioactive Material Shipment Exclusive Use Instructions
 The applicable instructions from the current version of the
ERG booklet.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 68 of 141

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

 Full Vehicle Survey
 Special Nuclear Material, NRC 741 Form, if applicable
 Special Nuclear Material Certification Statement, if applicable
 Special Nuclear Material Exemption
 Reportable Quantity List, if applicable
 Cask User Check Off Sheet, if applicable
 Sealed Source or Other Special Waste Approval Letter, if
applicable
 Written statement of any unusual hazards and/or precautions
that must be taken, if applicable
 Class C Waste Documentation Record (from Barnwell WAC),
if applicable
 Radioactive Waste Shipment Certification Form (SCDHEC
803
 Radioactive Waste Shipment Prior Notification Form
(SCDHEC 802)
 Isotopic Analysis for Resin and Filter Media, if applicable
 High Integrity Container Certification, if applicable
 DSHS LLRW Shipment Certification Form (RHF31)
 Uniform Low Level Radioactive Waste Manifest Isotopes
Report
 WAC Variance Request Form, if applicable
 Uniform Hazardous Waste Manifest (mixed waste only)
 Land Disposal Restriction Notice (mixed waste only)
 Texas Hazardous Waste Manifest, if applicable
 Asbestos Waste Shipment Record, if applicable.
 Package Storage and Disposal Request
 Package Certification Label, NV-211
13. A copy of the Uniform Low Level Radioactive Waste
Manifest has been sent to the appropriate facility.
14. SCDHEC and Chem-Nuclear have been notified of any
modification to Radioactive Waste Shipment Prior
Notification Form (SCDHEC 802)

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 69 of 141

SHIPMENT NUMBER:___________________________________________

Ba
r
n
w
e
l
l

Ri
c
h
l
a
n
d

En
e
r
g
y

So
l
u
t
i
o
n
s

Bu
l
k

En
e
r
g
y

So
l
u
t
i
o
n
s

CW
F

Ba
r
n
w
e
l
l

Pr
o
c
e
s
s
i
n
g

WC
S

BC
O

15. Consignee has been contacted at time of shipment release and
informed of expected arrival date.
16. EnergySolutions has been notified of any modifications to the
5 Work-Day Shipment Notification.
17. Driver has been briefed on the exclusive use requirements.
18. Driver has been briefed on the shipment inspection
requirements and provided with a copy of Form CP-SR-PR-
204-F12

19. Load and conveyance have been photographed
20. Verify (front and back) of driver’s CDL with hazardous
material endorsement.
21. If applicable, driver has been briefed on any disposal site
check-in requirements.

FINANCIAL/ACCOUNTING FOLLOW-UP POST SHIPMENT
1. If the shipment is being made for a customer under contract,
send manifests, timesheets, and expense report to Accounting
for customer billing

Print Name and Signature / Date
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 70 of 141
Prior Notification Call Sheet
Shipment of Low-Level Solid Waste to
US Ecology (Hanford, WA)
509-377-2411, Rev 0

Date of Call: Time of Call (estimated):
Name of Person Contacted:
Message
"This call is to inform you that the
plant at will make a truckload shipment of
drums, boxes of radioactive material for burial in accordance with your
license at your Hanford, Washington, site through arrangements with EnergySolutions
Plant Shipment number is EnergySolutions Control
Carrier is
Driver's name is
Trailer ID Number is Tractor Number is
Date of departure is
Estimated date of departure is
Estimated date of arrival at Hanford, Washington, is
Additional Message

Comments of Contact

Prepared By Date

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued), Rev 0

EnergySolutions Proprietary Page 71 of 141
___ UN2910, Radioactive material, excepted package, limited quantity of
material, 7
___ UN2911, Radioactive material, excepted package, articles, 7
___ UN2911, Radioactive material, excepted package, instruments, 7
___ UN2908, Radioactive material, excepted package, empty packaging; 7
___ UN2909, Radioactive material, excepted package, articles manufactured
from depleted Uranium, 7
___ UN2909, Radioactive material, excepted package, articles manufactured
from natural Thorium, 7
___ UN2909, Radioactive material, excepted package, articles manufactured
from natural Uranium, 7
Guide 161 Radioactive Materials (Low-Level Radiation) POTENTIAL HAZARDS HEALTH  Radiation presents minimal risk to transport workers, emergency response personnel and the public during transportation accidents. Packaging durability increases as potential hazard of radioactive content increases.  Very lowlevels of contained radioactive materials and lowradiation levels outside packages result
in low risks to people. Damaged packages may release measurable amounts of radioactive material, but the resulting risks are expected to be low.
 Some radioactive materials cannot be detected by commonly available instruments.
 Packages do not have RADIOACTIVE I, II, or III labels. Some may have EMPTYlabels or may
have the word “Radioactive” in the package marking.
FIRE OR EXPLOSION  Some of these materials may burn, but most do not ignite readily.  Many have cardboard outer packaging; content (physically large or small) can be of many
different physical forms.
 Radioactivity does not change flammability or other properties of materials.
PUBLIC SAFETY  CALL 911. Then call emergency response telephone number on shipping paper. If shipping
paper not available or no answer, refer to appropriate telephone number listed on the inside back cover.  Priorities for rescue, life-saving, first aid, fire control and other hazards are higher thanthe priority for measuring radiation levels.  Radiation Authority must be notified of accident conditions. Radiation Authority is usually
responsible for decisions about radiological consequences and closure of emergencies.  Stay upwind, uphill and/or upstream.  Keep unauthorized personnel away.  Detain or isolate uninjured persons or equipment suspected to be contaminated; delay decontamination and cleanup until instructions are received fromRadiation Authority.

PROTECTIVE CLOTHING
 Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters’ protective
clothing will provide adequate protection.
EVACUATION
Immediate precautionary measure
 Isolate spill or leak area for at least 25 meters (75 feet) in all directions.
Large spill
 Consider initial downwind evacuation for at least 100 meters (330 feet). Fire
 When a large quantity of this material is involved in a major fire, consider an initial evacuation
distance of 300 meters (1000 feet) in all directions.
EMERGENCY RESPONSE FIRE
 Presence of radioactive material will not influence the fire control processes and should not
influence selection of techniques.
 If it can be done safely, move undamaged containers away fromthe area around the fire.
 Do not move damaged packages; move undamaged packages out of fire zone.
Small Fires  Dry chemical, CO2, water spray or regular foam.
Large Fires
 Water spray, fog (flooding amounts).
SPILL OR LEAK
 Do not touch damaged packages or spilled material.
 Cover liquid spill with sand, earth or other non-combustible absorbent material.
 Cover powder spill with plastic sheet or tarp to minimize spreading.
FIRST AID
 Call 911 or emergency medical service.
 Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
 Medical problems take priority over radiological concerns.
 Use first aid treatment according to the nature of the injury.
 Do not delay care and transport of a seriously injured person.
 Give artificial respiration if victim is not breathing.
 Administer oxygen if breathing is difficult.
 In case of contact with substance, immediately flush skin or eyes with running water for at least 20
minutes.
 Injured persons contaminated by contact with released material are not a serious hazard to health
care personnel, equipment or facilities.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued), Rev 0

EnergySolutions Proprietary Page 72 of 141
___ UN2912, Radioactive material, low specific activity (LSA-I), non fissile or
fissile-excepted, 7
___ UN3321, Radioactive material, low specific activity (LSA-II), non fissile or
fissile-excepted, 7
___ UN3322, Radioactive material, low specific activity (LSA-III), non fissile or
fissile-excepted, 7
___ UN2913, Radioactive material, surface contaminated objects (SCO-I) non
fissile or fissile-excepted, 7
___ UN2913, Radioactive material, surface contaminated objects (SCO-II) non
fissile or fissile-excepted, 7
Guide 162 Radioactive Materials (Low to Moderate Level Radiation)
POTENTIAL HAZARDS HEALTH
 Radiation presents minimal risk totransport workers, emergency response personnel and
the public during transportation accidents. Packaging durability increases as potential hazard of
radioactive content increases.
 Undamaged packages aresafe. Contents of damaged packages maycause higher external
radiation exposure, or both external and internal radiation exposure if contents
arereleased.
 Lowradiation hazard when material is inside container. If material is released
frompackage or bulk container, hazard will vary fromlowtomoderate. Level of hazard
will depend on the type and amount of radioactivity, the kind of material it is in, and/or the
surfaces it is on.
 Some material may be released frompackages during accidents of moderate severity but
risks to people are not great.
 Released radioactive materialsor contaminated objects usually will be visible if packaging
fails.
 Some exclusive useshipments of bulk and packaged materialswill not have
“RADIOACTIVE” labels. Placards, markings and shipping papers provide identification.
 Some packages may have a“RADIOACTIVE” label and asecond hazard label. The second
hazard is usually greater than the radiation hazard; sofollowthis GUIDE aswell asthe
response GUIDEfor the second hazard class label.
 Some radioactive materialscannot be detected bycommonly available instruments.
 Runoff fromcontrol of cargo firemaycause low-level pollution.
FIRE OR EXPLOSION
 Some of these materialsmay burn, but most do not ignite readily.
 Uraniumand Thoriummetal cuttings mayignite spontaneously if exposed toair (see
GUIDE 136).
 Nitrates areoxidizers and mayignite other combustibles (see GUIDE 141).
PUBLIC SAFETY  CALL 911. Then call emergency response telephone number on shipping paper. If shipping paper not available or no answer, refer to appropriate telephone number listed on the inside back cover.  Priorities for rescue, life-saving, first aid, firecontrol and other hazardsarehigher thanthepriority for
measuring radiation levels.  Radiation Authority must be notified of accident conditions. Radiation Authority isusually responsible for decisions about radiological consequences and closureof emergencies.  Stay upwind, uphill and/or upstream.
 Keep unauthorized personnel away.  Detain or isolate uninjured persons or equipment suspected to be contaminated; delay decontamination
and cleanup until instructions arereceived fromRadiation Authority.
PROTECTIVE CLOTHING
 Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters’
protectiveclothing will provide adequate protection.
EVACUATION
Immediate precautionary measure
 Isolate spill or leak area for at least 25 meters (75 feet) in all directions.
Large Spill
 Consider initial downwind evacuation for at least 100 meter (330 feet). Fire
 When a large quantity of this material is involved in a major fire, consider an initial
evacuation distance of 300 meters (1000 feet) in all directions.
In Canada, an Emergency Response Assistance Plan (ERAP) may be required for this
product. Please consult the shipping paper and/or the ERAP Program Section (page 390).
EMERGENCY RESPONSE
FIRE
 Presence of radioactive material will not influence the fire control processes and should not
influence selection of techniques.
 If it can be done safely, move undamaged containers away from the area around the fire.
 Do not move damaged packages; move undamaged packages out of fire zone. Small Fires
 Dry chemical, CO2, water spray or regular foam.
Large Fires
 Water spray, fog (flooding amounts).
 Dike runoff from fire control for later disposal.
SPILL OR LEAK  Do not touch damaged packages or spilled material.  Cover liquid spill with sand, earth or other non-combustible absorbent material.
 Dike to collect large liquid spills.
 Cover powder spill with plastic sheet or tarp to minimize spreading.
FIRST AID
 Call 911 or emergency medical service.
 Ensure that medical personnel are aware of the material(s) involved and take precautions to
protect themselves.
 Medical problems take priority over radiological concerns.
 Use first aid treatment according to the nature of the injury.
 Do not delay care and transport of a seriously injured person.
 Give artificial respiration if victim is not breathing.
 Administer oxygen if breathing is difficult.
 In case of contact with substance, wipe fromskin immediately; flush skin or eyes with running
water for at least 20 minutes.
 Injured persons contaminated by contact with released material are not a serious hazard to health
care personnel, equipment or facilities.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued), Rev 0

EnergySolutions Proprietary Page 73 of 141
___ UN2915, Radioactive material, Type A package, non-special form, non fissile or
fissile-excepted, 7
___ UN2916, Radioactive material, Type B(U) package, non-special form, non
fissile or fissile-excepted, 7
___ UN2917, Radioactive material, Type B(M) package, non-special form, non
fissile or fissile-excepted, 7
___ UN2919, Radioactive material, transported under special arrangement, non
fissile or fissile-excepted, 7
Guide 163 Radioactive Materials (Low to High Level Radiation) POTENTIAL HAZARDS HEALTH
 Radiation presents minimal risk totransport workers, emergency response personnel and the
public during transportation accidents. Packaging durability increases as potential hazard of radioactive
content increases.  Undamaged packages are safe. Contents of damaged packages may cause higher external radiation
exposure, or both external and internal radiation exposure if contents are released.
 Type A packages (cartons, boxes, drums, articles, etc.) identified as “Type A” by marking on
packages or by shipping papers contain non-life-endangering amounts. Partial releases might be
expected if “Type A” packages are damaged in moderately severe accidents.
 Type B packages, and the rarely occurring Type C packages (large and small, usually metal), contain
the most hazardous amounts. They can be identified by package markings or by shipping papers.
Life-threatening conditions may exist only if contents are released or package shielding fails. Because
of design, evaluation and testing of packages, these conditions would be expected only for accidents of
utmost severity.
 The rarely occurring "Special Arrangement" shipments may be of Type A Type B or Type C
packages. Package type will be marked on packages, and shipment details will be on shipping papers.
 Radioactive White-I labels indicate radiation levels outside single, isolated, undamaged packages are
very low(less than 0 .005 mSv/h (0 .5 mrem/h)).  Radioactive Yellow-II and Yellow-III labeled packages have higher radiation levels. The transport
index (TI) on the label identifies the maximumradiation level in mrem/h one-meter froma single,
isolated, undamaged package.  Some radioactive materials cannot be detected by commonly available instruments.
 Water fromcargo fire control may cause pollution.
FIRE OR EXPLOSION
 Some of these materials may burn, but most do not ignite readily.
 Radioactivity does not change flammability or other properties of materials.  Type B packages are designed and evaluated to withstand total engulfment in flames at temperatures
of 800°C (1475°F) for a period of 30 minutes.
PUBLIC SAFETY  CALL 911. Then call emergency response telephone number on shipping paper. If shipping paper not available or no answer, refer to appropriate telephone number listed on the inside back cove.  Priorities for rescue, life-saving, first aid, firecontrol and other hazardsarehigher
thanthepriority for measuring radiation levels.  Radiation Authority must be notified of accident conditions. Radiation Authority is usually responsible for decisions about radiological consequences and closure of emergencies.  Stay upwind, uphill and/or upstream.  Keep unauthorized personnel away.  Detain or isolate uninjured persons or equipment suspected to be contaminated; delay decontamination and cleanup until instructions are received fromRadiation Authority.
PROTECTIVE CLOTHING
 Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters’
protectiveclothing will provide adequate protection against internal radiation exposure, but not external
radiation exposure.
EVACUATION
Immediate precautionary measure  Isolate spill or leak area for at least 25 meters (75 feet) in all directions
Large Spill  Consider initial downwind evacuation for at least 100 meters (330 feet).
Fire
 When a large quantity of this material is involved in a major fire, consider an initial evacuation
distance of 300 meters (1000 feet) in all directions.
EMERGENCY RESPONSE FIRE
 Presence of radioactive material will not influence the fire control processes and should not influence
selection of techniques.
 If it can be done safely, move undamaged containers away fromthe area around the fire.
 Do not move damaged packages; move undamaged packages out of fire zone. Small Fires  Dry chemical, CO2, water spray or regular foam.
Large Fires  Water spray, fog (flooding amounts).
 Dike runoff from fire control for later disposal.
SPILL OR LEAK
 Do not touch damaged packages or spilled material.
 Damp surfaces on undamaged or slightly damaged packages are seldoman indication of packaging failure.
Most packaging for liquid content have inner containers and/or inner absorbent materials.
 Cover liquid spill with sand, earth, or other non-combustible absorbent material.
FIRST AID  Call 911 or emergency medical service.
 Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
 Medical problems take priority over radiological concerns.
 Use first aid treatment according to the nature of the injury.
 Do not delay care and transport of a seriously injured person.
 Give artificial respiration if victim is not breathing.  Administer oxygen if breathing is difficult.
 In case of contact with substance, immediately flush skin or eyes with running water for at least 20
minutes.
 Injured persons contaminated by contact with released material are not a serious hazard to health care
personnel, equipment or facilities.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued), Rev 0

EnergySolutions Proprietary Page 74 of 141
___ UN3332, Radioactive material, Type A package, special form, non fissile or
fissile-excepted, 7
Guide 164 Radioactive Materials (Low to High Level Radiation)
POTENTIAL HAZARDS HEALTH
 Radiation presents minimal risk to transport workers, emergency response personnel and
the public during transportation accidents. Packaging durability increases as potential
hazard of radioactive content increases.
 Undamaged packages are safe; contents of damaged packages may cause external radiation
exposure, and much higher external exposure if contents (source capsules) are released.
 Contamination and internal radiation hazards are not expected, but not impossible.
 Type A packages (cartons, boxes, drums, articles, etc.) identified as “Type A” by marking
on packages or by shipping papers contain non-life-endangering amounts.
Radioactive sources may be released if “Type A” packages are damaged in moderately
severe accidents.
 Type B packages, and the rarely occurring Type C packages, (large and small, usually metal)
contain the most hazardous amounts. They can be identified by package markings or by
shipping papers.
Life-threatening conditions may exist only if contents are released or package shielding fails.
Because of design, evaluation and testing of packages, these conditions would be expected
only for accidents of utmost severity.
 Radioactive White-I labels indicate radiation levels outside single, isolated, undamaged
packages are very low(less than 0 .005 mSv/h (0 .5 mrem/h)).
 Radioactive Yellow-II and Yellow-III labeled packages have higher radiation levels. The
transport index (TI) on the label identifies the maximumradiation level in mrem/h one meter
froma single, isolated, undamaged package.
 Radiation fromthe package contents, usually in durable metal capsules, can be detected by
most radiation instruments.
 Water fromcargo fire control is not expected to cause pollution.
FIRE OR EXPLOSION
 Packagings can burn completely without risk of content loss fromsealed source
capsule.
 Radioactivity does not change flammability or other properties of materials.
 Radioactive source capsules and Type B packages are designed and evaluated to withstand total
engulfment in flames at temperatures of 800°C (1475°F) for a period of 30 minutes.
PUBLIC SAFETY  CALL 911. Then call emergency response telephone number on shipping paper. If shipping paper not available or no answer, refer to appropriate telephone number listed on the inside back cover.
 Priorities for rescue, life-saving, first aid, fire control and other hazards are higher
thanthe priority for measuring radiation levels.
 Radiation Authority must be notified of accident conditions. Radiation Authority is usually
responsible for decisions about radiological consequences and closure of emergencies.
 Stay upwind, uphill and/or upstream.
 Keep unauthorized personnel away.
 Delay final cleanup until instructions or advice is received fromRadiation Authority.
PROTECTIVE CLOTHING
 Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters’
protective clothing will provide adequate protection against internal radiation exposure,
but not external radiation exposure.
EVACUATION
Immediate precautionary measure
 Isolate spill or leak area for at least 25 meters (75 feet) in all directions.
Large Spill  Consider initial downwind evacuation for at least 100 meters (330 feet). Fire
 When a large quantity of this material is involved in a major fire, consider an initial
evacuation distance of 300 meters (1000 feet) in all directions.
EMERGENCY RESPONSE FIRE
 Presence of radioactive material will not influence the fire control processes and should not
influence selection of techniques.
 If it can be done safely, move undamaged containers away fromthe area around the fire.
 Do not move damaged packages; move undamaged packages out of fire zone.
Small Fires  Dry chemical, CO2, water spray or regular foam
Large Fires
 Water spray, fog (flooding amounts).
SPILL OR LEAK
 Do not touch damaged packages or spilled material.
 Damp surfaces on undamaged or slightly damaged packages are seldoman indication of packaging
failure. Contents are seldomliquid . Content is usually a metal capsule, easily seen if released from
package.
 If source capsule is identified as being out of package, DONOTTOUCH. Stay away and await
advice fromRadiation Authority.
FIRST AID
 Call 911 or emergency medical service.
 Ensure that medical personnel are aware of the material(s) involved and take precautions to
protect themselves.
 Medical problems take priority over radiological concerns.
 Use first aid treatment according to the nature of the injury.
 Do not delay care and transport of a seriously injured person.
 Persons exposed to special formsources are not likely to be contaminated with radioactive material.
 Give artificial respiration if victim is not breathing.
 Administer oxygen if breathing is difficult.
 Injured persons contaminated by contact with released material are not a serious hazard to health
care personnel, equipment or facilities.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued), Rev 0

EnergySolutions Proprietary Page 75 of 141
___ UN3327, Radioactive material, Type A package, fissile non-special form, 7
___ UN3329, Radioactive material, Type B(M) package, fissile, 7
___ UN3328, Radioactive material, Type B(U) package, fissile, 7
___ UN3331, Radioactive material, transported under special arrangement, fissile, 7.
___ UN3333, Radioactive material, Type A package, special form, fissile, 7
Guide 165 Radioactive Materials (Fissile/Low to High Level Radiation) POTENTIAL HAZARDS HEALTH
 Radiation presents minimal risk totransport workers, emergency response personnel and the
public during transportation accidents. Packaging durability increases as potential radiation and criticality
hazards of the content increase.
 Undamaged packages aresafe. Contents of damaged packages maycause higher external radiation
exposure, or both external and internal radiation exposure if contents arereleased.
 Type AFor IFpackages, identified by package markings, do not contain life-threatening
amounts of material. External radiation levelsarelowand packages are designed,
evaluated and tested tocontrol releases and to prevent afission chain reaction under
severetransport conditions.  Type B(U)F, B(M)Fand CFpackages (identified bymarkings on packages or shipping papers) contain
potentially life-endangering amounts . Because of design, evaluation and testing of packages, fission
chain reactions are prevented, and releases are not expected to be life-endangering for all
accidents except those of utmost severity.
 Therarely occurring"Special Arrangement" shipments may beof TypeAF, BFor CFpackages.
Packagetypewill be marked on packages, and shipment details will be on shipping papers.
 The transport index (TI) shown on labels or ashipping paper might not indicate the radiation level at one
meter fromasingle, isolated, undamaged package; instead, it might relatetocontrols needed during
transport because of the fissile properties of the materials . Alternatively, the fissile nature of the contents
may be indicated bya criticality safetyindex (CSI) on aspecial FISSILElabel or on the shipping paper.
 Some radioactive materialscannot be detected bycommonly available instruments.
 Water fromcargo firecontrol is not expected to cause pollution.
FIRE OR EXPLOSION
 These materials areseldomflammable. Packages are designed towithstand fireswithout
damage tocontents.
 Radioactivity does not change flammability or other properties of materials.
 TypeAF, IF, B(U)F, B(M)FandCFpackage aredesignedandevaluatedtowithstandtotal
engulfment inflames at temperatures of 800°C(1475°F) for a period of 30 minutes .
PUBLIC SAFETY  CALL911. Thencall emergency response telephone number onshippingpaper. If shipping paper not available or no answer, refer to appropriate telephone number listed on the inside back cover.  Priorities for rescue, life-saving, first aid, firecontrol andother hazardsarehigher thanthepriority for measuringradiationlevels. • Radiation Authority must be notified of accident conditions. Radiation Authority isusually responsible for decisions about radiological consequences and closureof emergencies.  Stay upwind, uphill and/or upstream.  Keep unauthorized personnel away.  Detain or isolate uninjured persons or equipment suspected to be contaminated; delay decontamination and cleanup until instructions arereceived fromRadiation Authority.
PROTECTIVE CLOTHING
 Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters’
protectiveclothing will provide adequate protection against internal radiation exposure, but not
external radiation exposure.

VACUATION
Immediate precautionary measure
• Isolatespill or leak area for at least 25 meters (75 feet) inall directions. Large Spill  Consider initial downwind evacuation for at least 100 meters (330 feet). Fire  When alarge quantity of thismaterial is involved inamajor fire, consider an initial evacuation
distance of 300 meters (1000 feet) inall directions.
In Canada, an Emergency Response Assistance Plan (ERAP) may be required for this product. Please consult the shipping paper and/or the ERAP ProgramSection (page 390).
EMERGENCY RESPONSE FIRE  Presence of radioactive material will not influence the fire control processes and should not influence
selection of techniques.  If it can be done safely, move undamaged containers away fromthe area around the fire.
 Do not move damaged packages; move undamaged packages out of fire zone.
Small Fires
 Dry chemical, CO2, water spray or regular foam.
Large Fires
 Water spray, fog (flooding amounts).
SPILL OR LEAK
 Do not touch damaged packages or spilled material.  Damp surfaces on undamaged or slightly damaged packages are seldoman indication of packaging failure.
Most packaging for liquid content have inner containers and/or inner absorbent materials.
Liquid Spills
 Package contents are seldomliquid. If any radioactive contamination resulting froma liquid
release is present, it probably will be low-level.
FIRST AID
 Call 911 or emergency medical service.  Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
 Medical problems take priority over radiological concerns.
 Use first aid treatment according to the nature of the injury.
 Do not delay care and transport of a seriously injured person.
 Give artificial respiration if victim is not breathing.
 Administer oxygen if breathing is difficult.  In case of contact with substance, immediately flush skin or eyes with running water for at least 20
minutes.
 Injured persons contaminated by contact with released material are not a serious hazard to health care
personnel, equipment or facilities.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued), Rev 0

EnergySolutions Proprietary Page 76 of 141
___ UN2977, Radioactive material, Uranium hexafluoride, fissile, 7 (6.1, 8)
___ UN2978, Radioactive material, Uranium hexafluoride, non fissile or fissile-
excepted, 7 (6.1, 8)
___ UN3507, Uranium hexafluoride, radioactive material, excepted package, less than
0.1 kg per package, non fissile or fissile-excepted, 6.1 (7, 8)
Guide 166 Radioactive Materials – Corrosive (Uranium Hexafluoride/Water-Sensitive) POTENTIAL HAZARDS HEALTH
 Radiation presents minimal risk to transport workers, emergency response personnel and the
public during transportation accidents. Packaging durability increases as potential radiation
and criticality hazards of the content increase.  Chemical hazardgreatly exceeds radiation hazard.
 Substance reacts with water and water vapor in air to formtoxic and corrosive hydrogen fluoride
gas, hydrofluoric acid, and an extremely irritating and corrosive, white-colored, water-
soluble residue .
 If inhaled, may be fatal.
 Direct contact causes burns to skin, eyes, and respiratory tract.
 Low-level radioactive material; very lowradiation hazard to people.
 Runoff fromcontrol of cargo fire may cause low-level pollution.
FIRE OR EXPLOSION
 Substance does not burn. • The material may react violently with fuels.  Product will decompose to produce toxic and/or corrosive fumes.
 Containers in protective overpacks (horizontal cylindrical shape with short legs for tie-downs),
are identified with "AF", "B(U)F" or "H(U)" on shipping papers or by markings on the
overpacks . They are designed and evaluated to withstand severe conditions including
total engulfment in flames at temperatures of 800°C (1475°F) for a period of 30 minutes.  Bare filled cylinders, identified with UN2978 as part of the marking (may also be marked H(U)
or H(M)), may rupture in heat of engulfing fire; bare empty (except for residue) cylinders will
not rupture in fires .
 Radioactivity does not change flammability or other properties of materials.
PUBLIC SAFETY  CALL 911. Then call emergency response telephone number on shipping paper. If
shipping paper not available or no answer, refer to appropriate telephone number listed on the
inside back cover.
 Priorities for rescue, life-saving, first aid, fire control and other hazards are higher thanthe priority
for measuring radiation levels.
 Radiation Authority must be notified of accident conditions. Radiation Authority is usually
responsible for decisions about radiological consequences and closure of emergencies.
 Stay upwind, uphill and/or upstream.
 Keep unauthorized personnel away.  Detain or isolate uninjured persons or equipment suspected to be contaminated; delay
decontamination and cleanup until instructions are received fromRadiation Authority.
PROTECTIVE CLOTHING
• Wear positive pressure self-contained breathing apparatus (SCBA)
• Wear chemical protective clothing that is specifically recommended by the manufacturer whenthere is NORISKOFFIRE.
• Structural firefighters' protectiveclothing provides thermal protection but only limited chemical
protection.
EVACUATION
Immediate precautionary measure
 Isolate spill or leak area for at least 25 meters (75 feet) in all directions.
Spill
 See Table 1 - Initial Isolation and Protective Action Distances.
Fire
 When a large quantity of this material is involved in a major fire, consider an initial evacuation distance
of 300 meters (1000 feet) in all directions.
In Canada, an Emergency Response Assistance Plan (ERAP) may be required for this product. Please consult the shipping paper and/or the ERAP ProgramSection (page 390).
EMERGENCY RESPONSE FIRE
 DONOTUSE WATERORFOAMONMATERIAL ITSELF.
 If it can be done safely, move undamaged containers away fromthe area around the fire.
Small Fire
 Dry chemical or CO2.
Large Fires
 Water spray, fog or regular foam.
 Cool containers with flooding quantities of water until well after fire is ou .
 If this is impossible, withdraw fromarea and let fire burn.
 ALWAYS stay away fromtanks engulfed in fire.
In Canada, an Emergency Response Assistance Plan (ERAP) may be required for this product . Please
consult the shipping paper and/or the ERAP ProgramSection (page 390) .
SPILL OR LEAK
 Do not touch damaged packages or spilled material.
 DONOTGETWATERINSIDECONTAINERS .  Without fire or smoke, leak will be evident by visible and irritating vapors and residue forming at the
point of release.
 Use fine water spray to reduce vapors; do not put water directly on point of material release from
container.
 Residue buildup may self-seal small leaks.
 Dike far ahead of spill to collect runoff water.
FIRST AID
 Call 911 or emergency medical service.  Ensure that medical personnel are aware of the material(s) involved and take precautions to protect
themselves.
 Medical problems take priority over radiological concerns.
 Use first aid treatment according to the nature of the injury.  In case of skin contact withhydrogen fluoride gas and/or Hydrofluoric acid, if calciumgluconate
gel is available, rinse 5 minutes, then apply gel. Otherwise, continue rinsing until medical treatment
is available.
 Do not delay care and transport of a seriously injured person.
 Give artificial respiration if victim is not breathing.
 Administer oxygen if breathing is difficult.  In case of contact with substance, immediately flush skin or eyes with running water for at least 20
minutes.
 Effects of exposure (inhalation, ingestion or skin contact) to substance may be delayed.
 Keep victimcalmand warm.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 77 of 141

Rev 0

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 78 of 141
Broker Supervisor Notification, Rev 0
1. Name and Address of Generator: 2. Generator Contact:
a) Name:
b) Title:
c) Telephone:
3. Radioactive Waste Transport Permit No.:

4. Shipment Identification No.:

5. Location from which material will be shipped:

6. Name and Address of Consignee:

7. Scheduled Date of Departure of Shipment:

8. Estimated Date of Arrival of Shipment:

9. Carrier:

10. Trailer No. & Owner:
(if available)

11. Type Transport Vehicle:

12. Routes shipment will follow (Be specific):

13. Type Package or Cask
Model No.:

14. Type Container in Cask:
15. Package or Cask Spec.:

16. Material Description (Be Specific) :

17. Physical & Chemical Form:

18. Total No. of
Packages:

19. Prominent Radionuclides:

20. Total Curies:

21. Waste Class & Stability:

22. Total Cubic Feet:

23. DOT Sub Type:

24. DOT Class & Hazard Class
UN No.:
25. Hwy. Route Controlled:
(Large Quantity)   Yes [ ] No

26. Comments:

27. Broker: Date:
28. Emergency Contact Organization (as listed on DOT shipping paper)
Name: Phone:

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 79 of 141
Vehicle Inspection Form, Rev 0

Shipment Number: Shipment Date:
Carrier: Driver’s Name:
Tractor Number: Trailer Number:
Trailer Type: Van Open Top Van Flatbed
Other

Inspection Checks Sat Unsat
1. Front tire tread: at least 4/32-inch tread (no recaps)
2. Other tire tread: at least 3/32-inch treat
3. Service brakes: good condition and properly attached
4. Parking brake: operational and on while loading
5. Steering mechanism: demonstrated operational
6. Headlights and front reflectors: clean and operational
7. Windshield wipers: demonstrated operational
8. Rear vision mirrors
9. Horn: demonstrated operational
10. Fire extinguishers: Good working condition, fully charged
11. Trailer frame, headboard and bed liner: free of visual defects
12. Load tie-downs: adequate number for load and in good condition
13. Emergency kit: extra placards, rad rope, PC’s
14. Brake lights: demonstrated operational
15. Turn signals: demonstrated operational
16. Reflectors: at proper locations on trailer
17. Tractor/trailer has a current FHWA (Federal Highway Administration) sticker (good for 1 year after
date stamped on sticker). An equivalent inspection sticker is acceptable.

18. Tractor/trailer has valid license plate(s)
19. Driver has CDL, hazmat endorsement, and valid DOT Medical Card (copy on file)
Inspected by:
Driver’s Signature Date EnergySolutions Representative Date
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 80 of 141
Rev 0
US Ecology, Inc.
PO Box 638
Hanford Reservation
Richland, Washington 99352

Dear Sir(s):

"Certification is hereby given to the U.S. Nuclear Regulatory Commission that this shipment of low-level
radioactive waste has been inspected in accordance with the requirements of U.S. NRC License
No.16-19204-01, as amended, within 48 hours prior to shipment; and further certification is made that the
inspection revealed no items of non-compliance with all applicable laws, rules, regulations, and license
conditions."

Date:
By:
Title and Organization:
Address and Telephone:

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 81 of 141
Non-Waste DOT Shipping Paper, Rev 0

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 82 of 141
Non-Waste DOT Shipping Paper, Rev 0

8
.

S
h
i
p
p
i
n
g

P
a
p
e
r

N
u
m
b
e
r
13

.

Tr
a
n
s
p
o
r
t

In
d
e
x

(
U
s
e

t
h
i
s

n
u
m
b
e
r

o
n

a
l
l

c
o
n
t
i
n
u
a
t
i
o
n

p
a
g
e
s
)

P

a
g
e

_
_
_
_
_
_

o
f

_
_
_
_
_

P

a
g
e
(
s
)

1
1
.

U
.
S
.

D
e
p
a
r
t
m
e
n
t

o
f

T
r
a
n
s
p
o
r
t
a
t
i
o
n

D
e
s
c
r
i
p
t
i
o
n
12

.

D
O
T

L
a
b
e
l
s
14

.

P
h
y
s
i
c
a
l

a
n
d

Ch
e
m
i
c
a
l

F
o
r
m
18

.

I
d
e
n
t
i
f
i
c
a
t
i
o
n

Nu
m
b
e
r

o
f

Pa
c
k
a
g
e
17
.

T
o
t
a
l

W

e
i
g
h
t

or

V

o
l
u
m
e
15
.

I
n
d
i
v
i
d
u
a
l

R
a
d
i
o
n
u
c
l
i
d
e
s
16

.

M

a
x
i
m
u
m

P
a
c
k
a
g
e

A
c
t
i
v
i
t
y
RA
D
I
O
A
C
T
I
V
E

M
A
T
E
R
I
A
L

S
H
I
P
M
E
N
T
RE
C
O
R
D

F
O
R
M
SH
I
P
P
I
N
G

P
A
P
E
R

(C
o
n
t
i
n
u
a
t
i
o
n
)
(In
c
l
u
d
i
n
g

U
N

I
D

n
u
m
b
e
r
,

p
r
o
p
e
r

s
h
i
p
p
i
n
g

n
a
m
e
,

h
a
z
a
r
d

c
l
a
s
s
,

an
d

a
n
y

a
d
d
i
t
i
o
n
a
l

i
n
f
o
r
m
a
t
i
o
n
)
(U
s
e

a
p
p
r
o
p
r
i
a
t
e

u
n
i
t
s
)
MB
q
( m
C
i

)
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 83 of 141
Shipping Peer Review Checklist

Shipment # Waste Profile / Rev. #
(print) (print)
Manifest #
Shipper/Broker Name: Reviewer Name: (print) (print)
Reviewer – Check each block on manifest, if unsatisfactory, notify Shipper and verify corrections. Check Yes, No or
NA for each Condition listed.
Shipper Reviewer Condition
SAT NA Yes No NA
Item # Block Form 540 or equivalent
1 1 Emergency Telephone Number (highlighted) - 2 1 Organization -
3 2 Exclusive Use Shipment Indicated 4 3 Total # of Packages matches # listed
5 4 If EPA regulated – EPA manifest #
6 11 ONLY if EPA regulated, ‘Waste’ is included in the PSN
7 5 Shipper - 8 5 Contact - Phone -
9 5 User Permit Number TN - 10 5 Shipment Number -
11 5 Utah Permit Number - 12 5 Generator Type -
13 6 Carrier - 14 6 Carrier EPA I.D. Number -
15 6 Shipping Date -
16 7 # of manifest pages correct (Isotope Report and Manifest Notes count as 1 page each (2) Additional Information pages).
17 8,2 Manifest Number on all pages 540 and 541- 18 9 Consignee
19 9 Contact and Phone number 20 10 Authorized Signature & Title
21 10 Date 22 11 PSN – UN number, name, hazard class, Fissile/Fissile Excepted
23 11 Description and Container Type 24 11 RQ, additional hazard class, other technical information as necessary
25 12 DOT Label Type as appropriate 26 13 Transport Index as appropriate
27 14 Physical / Chemical Form, if not solid / oxide (hydroxide) 28 15 Individual Nuclides – at a minimum the top 95% are listed
29 16 Total package activity in SI Units - Standard units in parentheses 30 17 Total Weight or Volume (Use appropriate units)
31 18 Identification Number of Package 32 19 Terms and Conditions

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 84 of 141
Shipping Peer Review Checklist

Shipper Reviewer Condition
SAT NA Yes No NA
Item
# Block Form 541 or equivalent
33 1 Manifest Totals
34 1 Number of Packages/Disposal Containers
35 1 NET WASTE VOLUME in m3 and Ft3
36 1 NET WASTE WEIGHT in kg and lbs
37 1 SNM grams
38 1 Activity- ALL NUCLIDES in MBq and mCi
39 1 Activity- H3, C14, Tc99, I129
40 1 Source (Kg)
41 2 Manifest Number
42 3 Page of Page
43 4 Shipper Name and ID Number
44 5 Container Identification Number/Generator ID Number
45 6 Container Description
46 7 Volume – Cubic Meters (Ft3)
47 8 Waste and Container Weight – Kilograms (lbs.)
48 9 Waste Weight – Kilograms (lbs.)
10 Surface Radiation Level mSv/hr (mRem/hr)
49 11 Surface Contamination- MBq/100cm2 (dpm/100cm2) Alpha, Beta-Gamma
50 12 Waste Descriptor 51 13 Approximate Waste Volume(s) in Container
52 14 Sorbent Solidification, Stabilization, Media 53 15 Chemical Form/Chelating Agent
54 15 Weight % Chelating Agent if > 0.1%
55 16 Individual Radionuclides and Activity, Container Total – MBq
(mCi)
56 17 Waste Classification- AS – AU – B – C – BU – CU – GTCC
57 Waste Class meets WAC
EPA UHWM (compare to other shipping papers)
58 Form is approved by OMB, has pre-printed manifest tracking # with
printers 3-digit designation
59 1 Generator ID # - EPA ID #
60 2 # of UHWM manifest pages on each page
61 3 24 hr Emergency Response Phone #
62 4 Manifest Tracking Number
63 5 Generator’s name and address, contact name and phone number
64 5 Generator’s Site Address (if different than mailing address)
65 6 Transporter 1 Company Name
66 6 Transporter 1 U.S. EPA ID Number
67 7 Transporter 2 Company Name
68 7 Transporter 2 U.S. EPA ID Number
59 8 Designated Facility Name and Site Address
69 8 Designated Facility U.S. EPA ID Number
70 9a HM indicated
71 9b U.S. DOT Description (including PSN, Class, ID number including
Packing group (if any)
72 10 Number of containers
73 10 Type of containers
74 11 Total quantity

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 85 of 141
Shipping Peer Review Checklist

Shipper Reviewer Condition
SAT NA Yes No NA
Item
# Block EPA UHWM (compare to other shipping papers)
75 12 Unit Wt./Vol.
76 13 Waste Codes
77 14 Special Handling Instruction and Additional Information (Package ID numbers, Profile Number, ULLWM Number, Container Type, CHEMTREC CCN, ERG Number).
78 15 Generator’s/Offeror’s Printed/Typed Name
79 15 Signature and Date
Other Shipping Documentation
80 Disposal Site is on the current ASL
81 Carrier is on the current ASL 82 Profile is current and appropriate for waste
83 Waste Class fits profile & disposal site WAC 84 NTT is valid for profile
85 SNM Exemption is correct 86 Exclusive Use Instructions accurate for shipment
87 Transportation Security Instructions accurate for shipment 88 RAM QC notifications made as required
89 Route Plan correct (e.g., no Iowa or Missouri) – See Exclusive Use Instructions
90 ERG correct for shipment. ERG #
91 For Radioactive Shipments: For export shipment or shipment in a foreign made package, meets 49 CFR 172.203(d)(8)
92 For Radioactive Shipments the shipment of a package containing a highway route controlled quantity of Class 7 materials, meets
49 CFR 172.203(d)(10)
93 Markings meet 49 CFR Subpart D “Marking”
94 Markings meets disposal site WAC
95 Labels meet 49 CFR Subpart E “Labeling”
96 Placarding meet 49 CFR Subpart F “Placarding”

COMMENTS:

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.6 (Continued)

EnergySolutions Proprietary Page 86 of 141
Shipping Peer Review Checklist

Peer Review By: Date:
(Print/Sign)

If Corrections required (otherwise N/A) –

Corrections Completed By: Date:
(Print/Sign)

If Corrections required (otherwise N/A) –

Peer Reviewer Concurrence: Date:
(Print/Sign)

Shipping Documents submitted to EDIS on (date) by
(Print/Sign)
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.7
Calculation Worksheets, Rev 0

EnergySolutions Proprietary Page 87 of 141
Given Information CLASS 7 RADIOACTIVE MATERIAL Hazardous Substance
Step 1 Step 2 STEP 4 STEP 5 STEP 6 STEP 7 STEP 8 Step 9 Step 10

Nuclide(s)

(1)

Activity

TBq or Ci Bq

Activity
Concentration

Step 2 Bq or Ci
Step 3 g g

Concentration
Limit

173.436
Bq/g or Ci/g

Step 4
Step 5

Activity
Limit

173.436
Bq or Ci

Step 2
Step 7
RQ
LIMIT

172.101
App. A Table 2
TBq or Ci

Step 2
Step 9

Total Activity: f =
(2)
f =
(2)
f =
(3)

Step A Step B Step C Step D Step 3 Pounds Grams
Fissile Nuclides
173.403
Activity

TBq or Ci
Specific Activity
173.435
TBq/g or Ci/g
Step B
Step C
Material Weight:
(1 lb  454 g)
Pu-239
Pu-241 Notes: (1) If U-233, U-235, Pu-239 or Pu-241 are present, determine if
fissile or fissile-excepted per 173.453.
(2) If both > 1, then radioactive material (173.403) and subject to
the Hazard Material Regulations (HMR) for class 7 transport.
(3) If < 1, then not a hazardous substance (RQ). If > 1, then a
hazardous substance (RQ) and subject to the HMR.
U-233
U-235
Total fissile grams = (1)
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.7 (Continued), Rev 0

EnergySolutions Proprietary Page 88 of 141

DOT Class 7 Shipping Quantity Calculations

Given Information Type A Limit Excepted Package Type A or B? HRCQ Low Specific Activity (LSA)
Step 1 Step 2 Step 11 Step 12 Step 13 Step 14 Step 15 Step 17

Nuclide(s)

Activity

TBq or Ci

A1 or A2 d.

173.435

TBq or Ci

LQ or I & A
Limit

173.425, Table 4
(A1 or A2) x 1 E - ___

Step 2
Step 12

Step 2
Step 11

Step 14 f

3,000 St
e
p

1
7
a
For LSA-I: h.

Step 6 f

30
i.
St
e
p

1
7
b

For LSA-II & LSA-III: h.
g. “Have”
A2 fraction Step 14 f
per
gram Step 3
Step 16 LSA-II h.

[solids/gases]
Step 17b
1 E - 4
j.

Total Package Activity

1,000 TBq or 27,000 Ci LSA-II h.

[liquids]
Step 17b
1 E - 5
k.
g.

LSA-III h. Step 17b
2 E - 3
l.
Total
activity: 1 Ci = 3.7 E-2 TBq
1 TBq = 27 Ci f =_
e. f.

Notes: d. If special form, use the A1 value; or
if normal form, use the A2 value per 173.403. e. If < 1, then ship per 173.421 for LQ or 173.424 for instrument or articles; if > 1, then continue calculations.
f. If  1, then Type A Quantity; if > 1, then Type B Quantity
continue calculations for Highway Route Controlled Quantity
g. If both Steps 15 & 16 are < 1, then not HRCQ;
if either Step 15 or 16 is > 1, then HRCQ.

h. Ensure < 1 rem/hr at 3 meters from unshielded material and meets
the definition for LSA/SCO type per 173.403, 173.427 and NUREG-1608/RAMREG-003.
i. If  1, then LSA-I material; if > 1, then continue calculations.
j. If  1, then LSA-II material for solids or gases;
if > 1, then continue.
k. If  1, then LSA-II material for liquids; if > 1, then continue.
l. If  1, then LSA-III material; if > 1, then material is not LSA.
Surface Contaminated Object (SCO) h.

Non-fixed contamination on accessible surfaces: (actual surface)
 : SCO-I  24,000 dpm/100cm2 SCO-II  2,400,000 dpm/100cm2
 : SCO-I  2,400 dpm/100cm2 SCO-II  240,000 dpm/100cm2
and
Fixed contamination on accessible surfaces:
 : SCO-I  2.4 E+8 dpm/100cm2 SCO-II  4.80 E+9 dpm/100cm2
 : SCO-I  2.4 E+7 dpm/100cm2 SCO-II  4.80 E+8 dpm/100cm2
and
Non-fixed plus fixed contamination on inaccessible surfaces:
 : SCO-I  2.4 E+8 dpm/100cm2 SCO-II  4.80 E+9 dpm/100cm2
 : SCO-I  2.4 E+7 dpm/100cm2 SCO-II  4.80 E+8 dpm/100cm2
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.7 (Continued), Rev 0

EnergySolutions Proprietary Page 89 of 141

LSA II & III Worksheet
Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 Step 8 Step 9 Step 10
Nuclide(s) Activity
TBq
A2
Value
TBq
< 1000
(1)
mrem/h @
3m from
material
Convert
pounds to
grams:
454 g/lb
Calculated
Specific
Activity
Step 2
Step 5
(TBq/g)
LSA II Limit(2)
[1E-4 x A2] per
gram for solids and
gases
(TBq/g)
(3)
LSA II?
Step 6
Step 7
LSA III Limit
[2E-3 x A2] per
gram for solids
(TBq/g)
LSA III?
Step 6
Step 9

(1) Packages >1000 mrem/h at 3 meters from unshielded material must meet NRC requirements.
(2) Could the material be LSA-I? Refer to 49 CFR 173.403.
(3) If the value <1, the material is LSA-II; further calculations are not necessary. If the value is >1, then additional
calculations are needed.

 
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.7 (Continued), Rev 0

EnergySolutions Proprietary Page 90 of 141
SCO-I & II Worksheet
Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 Step 8 Step 9
Isotope Non-Fixed
Contam.
Ci/cm2
Fixed Contam.
Ci/cm2
Non-Fixed
Contam.
Limit
173.403 SCO
Definition
Non-Fixed
Contam.
Fraction
Step 2
Step 4
Fixed
Contam.
Limit
173.403 SCO
Definition
Fixed Contam.
Fraction
Step 3
Step 6
Total
Contam.
Limit
173.403 SCO
Definition
Total
Contam.
Fraction
Steps 2 + 3
Step 8

<1 Material is SCO-I;
>1 Material may be
SCO-II;


 
Evaluate SCO-II limits.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.7 (Continued), Rev 0

EnergySolutions Proprietary Page 91 of 141
DOT Reportable Quantity Worksheet
Step Step 1 Step 2
Radionuclide Activity
(Ci)
RQ Value (Ci)
49 CFR 172.101

RQ Value (Ci)
Determination

STEP 1 > 1
STEP 2

SUM of Fractions 

Note 1: For hazardous materials other than radionuclides refer to 49 CFR 172.101

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17
Attachment 5.7 (Continued), Rev 0

EnergySolutions Proprietary Page 92 of 141

DOT Fissile Exception Worksheet
Step Step 1 Step 2 Step 3
Radionuclide Activity (Ci) Specific Activity (Ci/g)

Grams
(Step 1  Step 2)
Pu-239 6.2E-2
Pu-241 1E2
U-233 9.7 E-3
U-235 2.2E-6
Sum of Grams 

Note 1: If U-233, U-235, Pu-239 or Pu-241 are present, determine if fissile or fissile-excepted per 173.453.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

Attachment 5.7 (Continued)

EnergySolutions Proprietary Page 93 of 141
Long Lived Waste Classification Worksheet
10 CFR 61.55, Table I Waste Classification for Long Lived Isotopes, Rev 0
Package Number:

Step Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7
Radionuclide
Concentration
μCi/cc or nCi/g
Note (1)
Class A
Limit Class A Fraction
Class B
Limit Class B Fraction
Class C
Limit Class C Fraction
Pu-241 (1) 350  3500
Cm-242(1) 2000 20000
Ra-226 (1) 10 100
Note 2 (1) 10 100
C-14 0.8 8
C-14 in activated metal 8 80
Ni-59 in activated metal 22 220
Nb-94 0.02 0.2
Tc-99 0.3 3
I-129 0.008 0.08
Sum of Fractions  

Notes: 1 Values for alpha emitting transuranics with half-lives greater than 5 years, Pu-241, and Cm-242 are expressed in units of nCi/g.
2 Total of all alpha emitting transuranics with half-lives greater than 5 years.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

Attachment 5.7 (Continued)

EnergySolutions Proprietary Page 94 of 141

Short Lived Waste Classification Worksheet
10 CFR 61.55, Table II Waste Classification for Short Lived Isotopes, Rev 0
Package Number:

Step Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7
Radionuclide
Concentration
μCi/cc
Class A
Limit Class A Fraction
Class B
Limit Class B Fraction
Class C
Limit Class C Fraction
Note 1 700 >700
H-3 40 >40
Co-60 700 >700
Ni-63 3.5 70 700
Ni-63 in activated metal 35 700 7000
Sr-90 0.04 150 7000
Cs-137 1 44 4600
Sum of Fractions   

Notes: (1) Total of all radionuclides with half-lives less than 5 years
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

Attachment 5.7 (Continued), Rev 0

EnergySolutions Proprietary Page 95 of 141
SNM Worksheet
Step Step 1 Step 2 Step 3
Radionuclide Activity (Ci) Specific Activity (Ci/g) Grams Step 1 / Step 2
Pu-236 5.3 E2
Pu-237 1.2 E4
Pu-238 1.7 E1
Pu-239 6.2 E-2
Pu-240 2.3 E-1
Pu-241 1.0 E2
Pu-242 3.9 E-3
Pu-244 1.8 E-5
U-233 9.7 E-3
U-235 2.2 E-6
Sum of Grams 
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 96 of 141
Attachment 5.8
Guidelines for Packaging Magnesium-Thorium
And Depleted Uranium Metal Turnings in Dry Sand

1. SCOPE

1.1 Purpose

To provide guidelines for the packaging of metal alloy turnings, chips, or
shavings consisting of Magnesium-Thorium (MgTh) or Depleted Uranium (DU).

1.2 Applicability

These guidelines apply to the packaging of pyrophoric MgTh or DU.

2. GUIDELINES

2.1 Inspect the material for burial acceptability in accordance with Reference 2.1 in
Section 2 of this procedure and the following criteria:

2.1.1 Less than 1% unintentional oil is allowable on MgTh or DU.

2.1.2 No water is acceptable.

2.1.3 If material is oxidized by incineration, then follow conditions of the
applicable site license, Reference 2.1, regarding readily dispersible
material and ash (if applicable), and contact the applicable disposal site
staff for acceptable packing methods.

2.1.4 If the material is oxidized naturally, then treat it as loose contamination.

2.2 Using the appropriate Rad Con Techniques, mix the material in a 10:1 ratio with
"dry" sand (10 parts sand and 1 part MgTh or DU) and place in a DOT 7A Type
A container. Leave a 4" void at the top of the container.

2.3 Add 3" of dry sand to top of drum.

2.4 Seal drum.

2.5 Prepare package for shipment in accordance with this procedure.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 97 of 141
Attachment 5.9
Guidelines for Packaging of Biological Waste for Disposal

1. SCOPE

1.1 Purpose

To provide guidelines for consistent packaging of biological waste.

1.2 Applicability

These guidelines apply to the packaging of radioactive biological waste for
low-level radioactive waste disposal by EnergySolutions.

2. REQUIREMENTS

2.1 Verify the biological waste to be disposed of is acceptable with the applicable
References of Section 2.0 of this procedure, e.g 2.1, 2.2, 2.5, and 2.15.

2.2 Biological waste considered pathogenic or infectious shall be previously treated to
reduce to the maximum extent practicable, the potential hazard from
non-radiological materials.

2.3 The inner containers shall be specification DOT 7A Type A package. Outer
container shall meet the design requirements of 49 CFR 173.410 or 7A Type A, as
appropriate, per Reference 2.1.

2.4 Volume of outer container shall be at least 40 percent greater than inner container
(i.e., a 30-gallon container inside a 55-gallon container).

2.5 Shipments to US Ecology sites shall comply with applicable site license for
approved absorbents, to be used in addition to the slaked lime.

For shipments to Barnwell, use slaked lime and agricultural grade 4 Vermiculite
or medium grade diatomaceous earth.

2.6 A refrigerated van shall be used to ship biological radwaste between April 1 and
October 1, if transit time will exceed 48 hours from the time the waste is first
removed from cold storage until arrival at the Barnwell Site.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 98 of 141
Attachment 5.9 (Continued)

3. GUIDELINES

Note: Plants, animals, and by-products thereof are considered biological material.
Glassware, etc., that at one time contained these materials are also
considered biological. All biological waste must be packaged in accordance
with this section.

3.1 The inner container shall have a watertight liner (i.e., polyethylene or equivalent)
of at least 4 mils thickness.

3.2 The addition of lime and absorbent to biological material should be in a ratio of
one part lime to ten parts absorbent to thirty parts biological material.

3.3 The biological material shall be placed in the inner container and thoroughly
layered with absorbent and slaked lime.

3.4 The addition of formaldehyde is strictly prohibited.

3.5 The watertight liner shall be hermetically (airtight) sealed by taping, tying, or heat
sealing.

3.6 The ring-and-bolt closure device shall be closed with an appropriate wrench.

3.7 The bottom of the outer container shall be covered with a minimum of four inches
of absorbent material.

3.8 Inner container shall be placed upright in the outer container.

3.9 After the inner container is placed in the outer container, it shall be completely
surrounded to the top of the outer container with additional absorbent material,
the lid placed on, and the ring and bolt closure device secured.

3.10 The outer container shall be equipped with a tamper-proof seal.

3.11 Prepare the package for shipment in accordance with this procedure.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 99 of 141
Attachment 5.10
RESERVED

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 100 of 141
Attachment 5.11
Guidelines for Absorption of Small Volumes
of Class A Liquid Waste for Disposal at Hanford

1. SCOPE

1.1 Purpose

To provide guidance in preparing small amounts of Class A liquid waste for
disposal at Hanford, WA.

1.2 Applicability

These guidelines apply to the processing of liquid radioactive material.

2. REQUIREMENTS

2.1 Except as allowed under the specific site's license(s), untreated liquids are not
allowed for disposal. Liquids shall be rendered non-corrosive (4 < pH < 11) prior
to treatment. Acceptable treatments are stabilization, solidification, or absorption,
depending on waste class and disposal facility.

2.2 Liquids treated by absorption shall be processed in such a manner as to leave zero
percent (0%) freestanding liquid.

2.3 Use only approved "absorbents" in accordance with applicable site's license.

3. GUIDANCE

3.1 Package liquid volume not exceeding 50 milliliters as RADIOACTIVE LSA
EXCLUSIVE USE

3.1.1 Use a container that meets US DOT 7A Type A specification package
requirements.

3.1.2 Line the container with a minimum of 4 mil plastic liner, except as
noted in the Washington State License WN-1019-2.

3.1.3 Contain the liquid in enough absorbent material to absorb at least twice
the volume of liquid (use a ratio of 4 to 1, absorbent to liquid).
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 101 of 141
Attachment 5.11 (Continued)

3.2 Package liquid volume exceeding 50 milliliters shipped as other than
EXCLUSIVE USE LSA

Packages with absorbed liquids having volume exceeding 50 milliliters shall have
a containment system composed of a primary inner and a secondary outer
containment components designed to assure retention of the liquid contents within
the secondary outer components in the event that the primary inner components
leak [49 CFR 173.412(n)].

3.2.1 Assure the liquid is sealed and contained in a primary inner container
consisting of at least 4 mil plastic.

3.2.2 Use enough approved absorbent to absorb at least twice the volume of
the liquid contained in the package (see 3.1.3).

3.2.3 Assure absorbed liquid in primary inner container is homogeneously
distributed with no detectable freestanding liquid.

3.2.4 The primary inner container will then be overpacked into a US DOT
7A Type A package.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 102 of 141
Attachment 5.12
Guidelines on the Encapsulation of Sources

1. SCOPE

This document applies to in-situ encapsulation of sources.

2. REFERENCES

EnergySolutions procedure, SD-OP-087, "Procedure for Small Scale Encapsulation of
Radioactive Waste".

3. REQUIREMENTS

3.1 Prerequisites

3.1.1 QA Approved Pre-casted Drums

3.1.1.1 The disposable container selected will be pre-poured to at
least 85% capacity and inspected by EnergySolutions
Quality Control.

3.1.1.2 The Quality Control documentation will be available at the
job site.

3.1.2 Broker Supervisor Approved Encapsulation

The Broker Supervisor or Designee may authorize the encapsulation of
sources on site without following Step 3.1.1.

3.2 Limitations and Precautions

3.2.1 All personnel utilizing this procedure will use all means available to
minimize their radiation exposure to as low as reasonably achievable.

3.2.2 Hanford

3.2.2.1 General Guidelines

3.2.2.1.1 Class A unstable - average the radionuclide
concentration over entire cement matrix - up
to 55-gallon drum and less than Class A
waste limit.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.12 (Continued)
Guidelines on the Encapsulation of Sources

EnergySolutions Proprietary Page 103 of 141
3.2.2.1.2 Class B stable - average the radionuclide
concentration over entire cement matrix up
to 55-gallon drum and less than Class B
waste limit.

3.2.2.1.3 Class C stable - average the radionuclide
concentration over entire cement matrix up
to 55-gallon drum and less than Class C
waste limit.

Note: If transuranics and radium are not
homogenous or are more than 10 nCi/g
but less than 100 nCi/g special approval is
required in either or both cases.

3.2.2.2 Radium Requirements

3.2.2.2.1 7A-Type A package is required.

3.2.2.2.2 2500 psi structural concrete necessary.

3.2.2.2.3 Assume all sources to be normal form (A2).

3.2.2.2.4 Stabilize Radium 226 source in 2R container
with structural concrete.

3.2.2.2.5 Geometrically center 2R container in 7A-
Type A package and encapsulate with
stable, structure concrete, per Reference 2 of
this Appendix.

3.2.2.2.6 Cure for 28 days.

3.2.2.2.7 Ensure 7A-Type A test documentation is
available for package based on weight and
configuration.

3.2.2.2.8 If the concentration, when averaged over
concrete matrix is > 10 but < 100 nCi/g,
special Washington State approvals must be
obtained for shipment as Class C Stable
waste.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.12 (Continued)
Guidelines on the Encapsulation of Sources

EnergySolutions Proprietary Page 104 of 141
3.2.3 Barnwell

3.2.3.1 The radionuclide concentration must be averaged over the
source volume only, for Class A, Class B, Class C sources.

3.2.3.2 All waste Class C or greater require special approval.

3.2.3.3 The smallest allowable package will be a five-gallon
container.

3.2.3.4 The South Carolina Department of Health and
Environmental Control (SCDHEC) has placed the
following container limits for source form radionuclides:

Maximum Activity
Radionuclide per Container
Ra-226 50 Ci
I-129 150 Ci
Am-241 500 Ci
Alpha > 5yrs 500 Ci
Tc-99 6 mCi
C-14 15 mCi
Pu-241 16 mCi
Cm-242 90 mCi

Note: If there are multiple radionuclides to be placed
into an individual package, unity will be
considered based upon these limits.

4. OPERATIONS

4.1 Inspect the pre-poured container for foreign materials and damage. Record
container condition and serial number (as appropriate) in the Daily Operations
Log.

4.2 Place the source in the pre-poured container cavity.

4.3 Fill the cavity to within 2" of the liner opening.

4.4 After a 6 to 24-hour cement set time, verify the billet in accordance with Section
5.0, before proceeding to Section 4.5.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.12 (Continued)
Guidelines on the Encapsulation of Sources

EnergySolutions Proprietary Page 105 of 141
Note: If it is necessary to add additional cement to the container due to
absorption or shrinkage, an additional batch may be mixed and
added.

4.5 After the Acceptance Criteria of Section 5.0 have been met, the encapsulation
liner may be closed.

5. ACCEPTANCE CRITERIA

Radioactive waste encapsulated in a disposal container shall be considered acceptable if
the following conditions are met:

Note: Hanford requires a minimum of 2500 psi concrete and a 28-day cure time for
encapsulation.

5.1 Visual inspection of the end product, normally 6 to 72 hours after process
completion, shows a uniform product with no freestanding water.

5.2 The end product, after satisfactory visual inspection, resists penetration when
probed with a rod approximately 1 inch in diameter.

6. RECORDS AND REPORTS

A copy of the Daily Operations Log and QC inspection shall be forwarded to the Broker
Supervisor Broker with the shipping papers.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Materials Revision 17

EnergySolutions Proprietary Page 106 of 141
Attachment 5.13
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility

1. TITLE

Work Instruction for Brokering of Soil and Building Debris to EnergySolutions Clive
Disposal Facility of Utah by rail.

2. SCOPE

2.1 Purpose

This work instruction describes the requirements, criteria, and methods required
for brokering of soil and building debris to EnergySolutions Clive Disposal
Facility of Utah by rail. This work instruction will provide controls in compliance
with applicable federal and state regulations, executive orders, EnergySolutions
Clive Disposal Facility's burial site license, and EnergySolutions policies.

2.2 Applicability

This work instruction is applicable to EnergySolutions personnel and trained
subcontractors who ship, or assist in shipping soil and building debris to
EnergySolutions Clive Disposal Facility of Utah by rail.

3. REFERENCES

3.1 EnergySolutions Clive Disposal Facility of Utah, Inc., Burial Site License:
UT2300249.

3.2 Utah Department of Health Rules for Control of Ionizing Radiation.

3.3 Title 49, Transportation, Parts 100 to 199 and 390 to 399.

3.4 Title 10, U.S. Nuclear Regulatory Commission (NRC), 10 CFR 20, 61 or 71.

3.5 Waste Acceptance Guidelines for EnergySolutions Clive Disposal Facility
Disposal Site

3.6 ES-BR-PR-003, Procedure for Training and Certification of Hazardous Materials
Brokers.

3.7 Title 40, "Protection of Environment", Parts 190 - 264

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 107 of 141
4. REQUIREMENTS

The following requirements shall be satisfied prior to making a radioactive material
shipment:

4.1 The Broker shall hold the appropriate current certification or qualification as a
Certified Broker or Senior Certified Broker in accordance with Reference 2.10.

4.2 The Broker shall have the appropriate instruments, markings, paperwork, and
other material prior to making a shipment.

4.3 Shipment shall not be made unless the shipper has documented evidence-showing
permission to ship to EnergySolutions Clive Disposal Facility of Utah.

4.4 The Broker shall confer with cognizant individuals as necessary such as the
Broker Supervisor, the waste generator, EnergySolutions Clive Disposal Facility
of Utah Officials, etc., concerning local, state, or compact restrictions prior to
shipping.

4.5 The Broker shall review the consignee's license for authorization to accept the
shipment prior to release of the shipment.

4.6 Shipment certification shall be made only when an inspection of the transport
conveyance confirms that the shipment is in compliance with applicable rules,
regulations, and license conditions, Reference 2.1 through 2.7 and 2.15 and 2.16.

Note: When shipping from cold to warmer weather, the shipment must
be carefully evaluated for the risk of moisture due to condensation.
When shipping from below freezing to above freezing temperature
inspect for ice that might melt in transit resulting in free standing
or leaking liquids to ensure full compliance with the Site
Acceptance Criteria.

4.7 The Broker shall obtain the following approvals to export waste:

4.7.1 Approval from the shipper's respective compact to export waste from
the compact region.

4.7.2 Approval from the Utah Bureau of Radiation Control to import waste.

5. DETAILED PROCEDURE FOR SHIPMENTS

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 108 of 141
5.1 Release Criteria

All materials and equipment (e.g. transport vehicles) to be released from the
EnergySolutions Clive Disposal Facility of Utah in accordance with this work
instruction shall be less than the release limits in Reference 3.5 of this Attachment

5.2 Contamination/Radiation Limits

Contamination/Radiation levels shall not exceed the limits specified in Reference
2.15 and 2.16.

5.3 Detailed Instruction

5.3.1 Visually inspect the transport conveyance (Gondola) using the Gondola
Inspection Report, Attachment 5.13.

Note: Items annotated, as needing attention on the Gondola
Inspection Report, Attachment 5.13, shall be corrected
prior to loading of the conveyance.

5.3.2 Remove the gondola cover.

5.3.3 A contamination and radiation survey shall be performed prior to
loading the conveyance. Enter the survey data on the Broker's Gondola
Survey Form, Attachment 5.13.

Note: If the conveyance does not meet the criteria of Reference
2.15 and 2.16, do not load until the discrepancy has been
corrected.

5.3.4 Load the conveyance to the desired capacity. Using the Broker
Administrative Information Form, Attachment 5.13, record information
about the contents loaded into the conveyance, sign and date.

Note: Only 95% of the gondola’s maximum weight capacity
shall be used.

5.3.5 Replace the gondola cover.

5.3.6 Perform a contamination and radiation survey after loading and
replacing the gondola cover. Enter the survey data on the Broker's
Gondola Survey Form, Attachment A.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 109 of 141
Note: If the conveyance does not meet the criteria of Reference
2.15 and 2.16, the shipment cannot be released until the
levels are within the limits of Reference 2.15 and 2.16.

5.3.7 Verify that the contamination and dose rate determinations were
performed prior to scheduled departure with the railroad. No
additional surveys required unless there is reason to believe radiation
or contamination levels may have increased. Exception, shipments to
the US Ecology site, Richland, WA, require that the surveys be
performed within 48 hours of shipping.

5.3.8 Record the serialized number from the Gondola on the Broker
Administrative Information Form, Attachment 5.13. Add the next
sequential shipment number (XX-XXXX) to the front of the Gondola
serial number and use this combined number as the shipment number,
record this number on the Broker Administrative Information Form.

Example: A Gondola has a serial number of 334-8897-03, and this
will be the 378th shipment from the project, the
shipment number will be XX-0378-334-8897-03.

5.3.9 Inspect the shipment for proper bracing, dunnage, and tie-downs, as
applicable.

5.3.10 Verify that the transport conveyance is properly marked, including the
emergency contact phone number.

5.3.11 Complete the appropriate shipping papers per Attachment 5.6 in the
main body of this procedure.

5.3.12 Ensure that all signature blocks have been signed.

5.3.13 Review the shipping documentation for completeness, using
Attachment A as a guideline, make and distribute the copies. Verify
approval documentation to export waste per Step 4.7.

5.3.14 Upon completion of the shipping documents, the Shipper (Broker) shall
distribute the documents to the Rail Transportation Group:

5.3.14.1 The Broker shall submit the final manifest documentation
to the rail Transportation Group within 24 hours of each
railcar being loaded/trans-loaded.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 110 of 141
5.3.14.2 Upon receipt of the manifests from the Broker, the Rail
Transportation Group will review the information
necessary to waybill the railcars to their destination. If that
information is missing or incorrect, the Rail Transportation
Group will contact the Broker for clarification. The Rail
Transportation Group will provide the waybill to the
originating railroad.

5.3.14.3 No loaded railcar shipment will be way billed without the
complete manifests being submitted by the Broker to the
Rail Transportation Group.

5.3.15 Call and inform the Broker Supervisor that a shipment is in progress.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 111 of 141
Broker Administrative Information, Rev 0
SHIPMENT NUMBER: _______________
GONDOLA NUMBER: _______________
DESCRIPTION OF MATERIAL:

TOTAL WEIGHT: ______________________________________ (Tons)
Note: Maximum Weight 95 Tons
TOTAL VOLUME: ______________________________________ (Cubic Feet)
TOTAL ACTIVITY: ______________________________________ (Millicuries)
TRANSPORTER: _______________________________________
DATE OF DEPARTURE: _______________ ESTIMATED ARRIVAL: ___________________
DATA RECORDER: _____________ DATE: ______________________________

Arrival Survey _________________ Gondola #: ______________
Departure Survey _________________ Date/Time: ______________

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 112 of 141
Broker Gondola Survey Form, Rev 0

TOP VIEW

dpm/100cm2

Mrem/hr

2 meters ___________

Contact ___________

SIDE VIEW

Contact

2 meters

SHIPMENT NUMBER:
SURVEYED BY:
INSTRUMENT/SERIAL #:

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 113 of 141

Gondola Inspection Report, Rev 0
Gondola Number:
Item Good
Needs
Attention
Cover
Sides
Top
Internals
Bottom
Stencil
Appearance/Paint
Remarks:

*Items noted under "Needs Attention" should have explanation under remarks regarding reasoning for
notation.
Inspected By: Date:
Time:

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 114 of 141
Check list Of Broker’s Work, Rev 0
Pre-Start Load Inspection Initial/Date
1. Check arrival of conveyance
a. Record gondola number.
b. Check for EnergySolutions stencil/re-stencil (if necessary).
c. Gondola Cover removed.
d. Inspection of gondola completed.
2. Conduct initial survey of conveyance:
a. Take smears, read, and record levels.
b. Record dose rates.
3. Review shipment and loading arrangements:
a. Status of paperwork/shipping documents (RSM, Surveys, etc.).
b. Crane/forklift/operators scheduled.
4. Loading Operations
a. Ensure proper safety precautions while working under crane.
b. Ensure proper weight distribution
c. Cover replaced/properly secured
5. Post-Loading Inspection
a. Outgoing gondola radiological survey completed.
b. Carrier signed Shipping papers
6. Check completion of Shipping Papers
a. Complete EnergySolutions paperwork requirements:
 Survey Forms
 Broker Checklist
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17
Attachment 5.13 (Continued)
Guidelines for Rail Shipments to EnergySolutions Clive Disposal Facility of Utah

EnergySolutions Proprietary Page 115 of 141
Check list Of Broker’s Work, Rev 0
Pre-Start Load Inspection Initial/Date
 Broker's Administration Check-list
 Gondola Inspection Report
b. Check completion of RSM information
 Verify all specific activity Calculations.
 Check totals: Weight, Activity, and Cubic Yards.
 Check wording of Certification Statement.
 Ensure Release Sign-off obtained.
c. Check Completion of Bill of Lading
 Correct description of load.
 All information completed.
 Shipper Sign-off obtained.
d. Reproduce copies of all paperwork
 Shipper Copy
 Broker Copy +(EnergySolutions Forms)
 Driver Copy (Railroad)
 Disposal Site Copy
 Broker Supervisor's copy + (EnergySolutions Forms)
 Disposal Site Copy

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 116 of 141
Attachment 5.14
Guidelines for the Use of Federal Express
as a Common Carrier for the Transport of Radioactive Material

1. SCOPE

1.1 Purpose

To provide instructions and restrictions for the use of Federal Express (FedEx) as
a common carrier for the transport of radioactive material.

1.2 Applicability

These instructions and restrictions apply to all radioactive material shipments
where FedEx is used as the carrier.

2. REQUIREMENTS/RESTRICTIONS

The following requirements/restrictions shall apply to the use of FedEx in the capacity of
transporting Radioactive Material (RAM):

2.1 FedEx shall not be used for the transport of RAM to disposal facility.

2.2 FedEx shall not be used for the transport of RAM in quantities exceeding a Type
A quantity (i.e. the packages shall contain less than the applicable A1 or A2) as
defined by 49 CFR 173.403.

2.3 FedEx shall be on EnergySolutions Approved Vendor's List as a common carrier
authorized to transport RAM for EnergySolutions.

2.4 Obtain a current copy of the IATA Dangerous Goods Regulations.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 117 of 141
Attachment 5.14 (Continued)
Guidelines for the Use of Federal Express
as a Common Carrier for the Transport of Radioactive Material

3. GUIDANCE

3.1 To begin, gather the information normally required for making the shipment (e.g.,
quantity of material, container sizes, approximate weights, DOT quantity, point of
pickup and delivery, etc.). Contact FedEx at [phone] and ask for
Dangerous Goods t (DG). Inform the FedEx DG person(s) that you are
knowledgeable in making RAM shipments, but you would like to review the
applicable requirements and scheduling with them. The FedEx DG personnel are
knowledgeable and will be of assistance in arranging pickup of your shipment by
the local FedEx office and preparing the appropriate FedEx Airbill and Shipper's
Declaration for Dangerous Goods shipping paperwork. You should also inform
the DG person that you have found from previous experience, there is sometimes
resistance from local FedEx offices when trying to arrange RAM shipments with
FedEx. The DG personnel can also advise you as to weight, dimension,
additional markings/labels, and other restrictions/ requirements associated with
your lading. A good example of these additional requirements is the CARGO
AIRCRAFT ONLY label (49 CFR 172.448) for Type A or IP packages.
Remember, for RAM in the Type A or IP packages to be allowed on a passenger
aircraft, the material must be intended for use in, or incident to, research, medical
diagnosis, or treatment. Just remember, you are making the shipment, not FedEx.
Although the DG can be of assistance to you in making your shipment properly,
FedEx is just the carrier, so don’t expect them to do your shipping work for you.

3.2 There are two basic types of FedEx air shipping documents to be considered - the
FedEx Airbill and the Shipper's Declaration for Dangerous Goods. The Airbill is
required for all RAM air shipments, and the Shipper's Declaration for Dangerous
Goods is required for all specification packages (Type A, IPs) and for certain
excepted package shipments (i.e. LQ & RQ). Contact the DG for case-by-case
instructions and requirements.

3.3 Very important - the FedEx Airbill must be completed in addition to your normal
manifesting, certification and notification requirements associated with the
transport of RAM.

Note: SC DHEC has authorized FedEx to not sign DHEC 803
Certification.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 118 of 141
Attachment 5.14 (Continued)
Guidelines for the Use of Federal Express
as a Common Carrier for the Transport of Radioactive Material

3.4 In addition to the actual shipping requirements, administrative and financial
requirements must be considered. The use and cost associated with transportation
by FedEx must be approved by the cognizant supervisor/manager prior to use.
This will include the use of the appropriate FedEx account number and project
reference number(s) for cost accounting and/or billing purposes.

Should you have questions or concerns, contact the Broker Supervisor.

3.5 Complete the appropriate Dangerous Goods Checklist from the FedEx website.
Up-to-date FedEx Express Dangerous Goods Resources can be found online using
the following keywords: FedEx Service Guide, Dangerous Goods, and/or
Resources for Shipping Dangerous Goods.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 119 of 141
Attachment 5.15
Specific Shipping Requirements
Bear Creek/Gallaher Road

Shippers must possess a Tennessee "License for Delivery" number issued by the State of
Tennessee. Refer to WM-A-501, Waste Acceptance Guidelines, Reference 2.18, to ensure waste
is acceptable at BCO or Gallaher Road, otherwise discuss Out-of-WAG approval through the
EnergySolutions Account Executive.

1. Verify that a valid contract exists between the generator and EnergySolutions.

2. Schedule shipment through an EnergySolutions Account Executive.

Note: Shipments containing SNM or PCB'S require prior approval by Bear Creek.

3. Certain waste types require prior approval before shipping. The attached Table 1
provides the prior approval requirements.

4. Form WM-A-501-F1, Shipment Summary Form shall accompany each shipment to Bear
Creek or Gallaher Road.

5. Specific waste packaging and shipping guidelines are as follows.

5.1 DAW for Direct Compaction

5.1.1 Package DAW for direct compaction in 55-gallon steel drums or
EnergySolutions-provided inner-pack boxes.

Note: EnergySolutions inner-pack boxes are not certified
containers. Therefore, inner-pack boxes must be shipped
inside another qualified outer container.

5.1.2 Do not place large metal pieces, such as piping, rods, or steel bars, in
the drum or inner-pack box vertically. Place other miscellaneous metal
pieces either horizontally or diagonally in the inner-pack box or drum.

5.1.3 Asbestos material received in packages other than 55-gallon drums or
EnergySolutions inner-pack boxes must be size reduced prior to receipt
to less than 30”Wx38”Lx44”H. Asbestos shall be double bagged in 3
mil thick bags, and marked with the required asbestos warning labels.
In addition, a Waste Shipment Record per 40 CFR 61.150(d) must
accompany any shipment of asbestos.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 120 of 141
5.2 DAW in Bulk Containers for Sorting, Compaction, and Incineration

5.2.1 Place waste to be sorted inside poly-bags and load the poly-bags into
bulk containers.

Note: Bulk containers larger than B-25-type containers shall be
capable of being off-loaded through the end.

5.2.2 Segregate materials with different radionuclide content or total activity
from the remaining materials. Identify these materials separately on the
manifest. The ID # on the segregated materials should match the
manifest.

5.2.3 Hot particle waste received in packages other than 55-gallon drums or
EnergySolutions inner-pack boxes must be size reduced prior to receipt
to less than 30”Wx38”Lx44”H. Hot particle waste shall be double
bagged, or wrapped in plastic, and marked on the outermost container
with the following statement:

CONTAINS HOT PARTICLE WASTE—DO NOT OPEN

5.2.4 Co-mingled incinerable/compactable waste for sorting shall be
positioned in the bulk container to allow off-loading first. DAW for
compaction or incineration which is packaged within the same bulk
container (e.g., B-25 boxes, cargo containers) as wastes that require
other processing methods (i.e., metals processing, GIC) shall be either
segregated by use of partitions or placed in separate containers within
the bulk package and must be clearly marked. Materials needing other
processing methods which are packaged within the same bulk container
as wastes for sorting and incineration are also subject to the specific
waste packaging guidelines for the applicable processing method.

5.2.5 Sharp metal pieces, including hypodermic needles, shall be bagged and
marked SHARPS. Hypodermic needles shall be placed in a 4-mil clear
poly-bag and securely sealed by a heat seal or tape.

5.3 DAW in Non-Bulk Containers for Direct Incineration

5.3.1 Upon request from EnergySolutions, provide certification letter
specifying that the box or fiber drum is free of all metal or glass (i.e.,
non-incinerables materials).

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 121 of 141
5.3.2 Place waste to be incinerated in clear poly-bags and place the bags in
strong tight cardboard boxes or strong tight fiberboard drums. If fiber
drums are used, do not include any non-incinerable material (e.g.,
metal, glass). Metal or poly outer containers are not required.
Note: The box or drum is limited to 21”x21”x21” and 50 lb
gross weight per package. Use of other packaging
configurations requires special approval from
EnergySolutions.

5.3.3 Clearly mark each package with the generator’s name, address, contact
name, and phone number, and number the package to correspond with
the manifest entry. Each package shall contain only one generator’s
waste.

5.4 Oil for Direct Incineration

5.4.1 Synthetic fluids, including EHC fluids and SHC lubricating fluids,
must be packaged in separate shipping containers from petroleum-
based oils.

5.4.2 Use 55-gallon non-leaking steel or polyethylene containers for oil. In
addition, ensure the containers are compatible with the oil being
transported.

5.4.3 Put the primary containers in steel or poly outer-packs to provide
double containment in the event of leakage or spillage from the primary
container. EnergySolutions can provide double-containment shipping
boxes, if requested. These containers are generally of two types:

 EnergySolutions “six-pack” LSA box loaded with six internal 79-
gallon drum over-packs. The generator’s 55-gallon drums are then
placed inside the 79-gallon drums, with absorbent added around the
outside of the 79-gallon drums. The oil-carrying capacity of a six-
pack box is approximately 330-gallons (six 55-gallon drums in each
box); and

 EnergySolutions Oil Express container, consisting of two tanks
inside a sealed, welded cargo container. The oil-carrying capacity
of this container is approximately 2,500 gallons.

5.4.4 Over-packed packages containing oil may be packaged within the same
bulk container as wastes that require other processing methods;
however, the packages need to be segregated by use of partition
partitions. Oils should be positioned in the bulk container to allow off-
loading first.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 122 of 141
5.4.5 Drums shall not be double-stacked in sea lands when shipped with
DAW.

5.5 Aqueous Liquids for Incineration

5.5.1 Put the primary containers in outer-packs to provide double
containment in the event of leakage or spillage from the primary
container. EnergySolutions BCO's license requires double containment
for outside storage.

Note: EnergySolutions can provide the “six-pack” double-
containment boxes described above, if requested.

5.5.2 Over-packed packages containing aqueous liquid may be packaged
within the same bulk container as wastes that require other processing
methods; however, the packages need to be segregated by use of
partitions. Materials for sorting and incineration should be positioned in
the bulk container to allow off-loading first.

5.5.3 Drums shall not be double stacked in sea lands when shipped with DAW.

5.6 Animal/Biological Waste for Direct Incineration

5.6.1 Inner Wrapping: Double wrap animal/biological waste that contains
liquids or could decompose to produce liquids/fluids using two 4-mil
clear poly-bags. Close each bag by heat sealing or taping. Put the bag
into a cardboard box or fiberboard drum, with a minimum of 2 inches
of incinerable absorbent in the bottom. In all instances, use
boxes/drums with no metal parts.

Wrap other animal/biological waste, including contaminated nonmetal
laboratory equipment and trash, in one 4-mil clear poly-bag. Heat seal
or tape the bag prior to placing it into the cardboard box or fiberboard
drum. Biological wastes shall not be mixed with non-incinerables in the
same container.

5.6.2 Outer Container: Only one generator’s waste shall be placed in an
individual box/drum. Use cardboard boxes or fiberboard drums with no
metal parts. Securely close each box/drum with duct tape so that all
edges or flaps are not visible. The box or drum is limited to a maximum
of 21”x21”x21” and 50 lb gross weight per package.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 123 of 141
Clearly mark each package with the generator’s name, and number the
package to correspond with the manifested entry. Mark the top of the
container, THIS END UP. Mark at least two opposite sides of the
container, BIOLOGICAL WASTE — FOR INCINERATION ONLY.
Animal carcasses/tissue shall arrive frozen at EnergySolutions.

5.6.3 Bulk Container Packaging: All packaging requirements for individual
packages apply to each package in the bulk container.

Packages containing animal/biological waste may be packaged within
the same bulk container as wastes that require other processing
methods; however, the packages need to be segregated by use of
partitions. Wastes for sorting and incineration should be positioned in
the bulk container to allow off-loading first.

5.7 Resins and Sludges for Drying/Incineration

5.7.1 Use packaging for resins and sludge to allow for efficient removal of
the waste while minimizing exposures to personnel. EnergySolutions
recognizes that generators must use containers that are compatible with
plant equipment; hence, these are recommended packaging guidelines
only.

5.7.2 Generally, resins or sludge may be packaged in steel or poly containers
that allow sufficient access to remove the waste for processing. The
larger the opening, the easier it is to remove the material. This is very
important for higher-dose-rate wastes (>100 mrem/hr) that may require
a significant amount of time to empty and may result in increased
exposure to workers.

5.7.3 Dewatering laterals that contain multiple-cartridge filters (Christmas
trees) make liners unusually difficult to empty and should be avoided if
possible.

Note: The preferred packaging for low-dose-rate sludge (<50
mrem/hr) for incineration is steel or poly drums or
boxes (preferably B-12 type).

5.8 Potentially Clean Waste (PCW) for Green is Clean

5.8.1 General PCW Packaging Guidelines

 PCW may be packaged in 55-gallon drums. EnergySolutions
prefers that large quantities of drums be banded and placed on
pallets for shipping.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 124 of 141
 PCW may be packaged in “super sacks,” on pallets, or in B-25 or
B-12 type containers. Maximum package size is 4’W 6’L 4’H
and 9,500 lb net waste weight.
 PCW may be packaged in Sealand containers. Maximum container
weight is approximately 25,000 lb gross weight.

5.8.2 “Mixed” PCW and Radioactive Waste Packaging Requirements
 Notify an Account Executive prior to a “mixed” shipment.
 Do not co-mingle packages and segregate PCW from radwaste
inside shipping container (i.e., use cargo nets or equivalent to
segregate load).
 Clearly identify PCW by using proper markings, labels, etc.
 Load PCW into shipping container so that it can be unloaded
AFTER the radioactive waste is unloaded.

Note: Radioactive waste shipped with PCW and destined
for other processing methods is also subject to
various other specific packaging criteria.

5.8.3 “Special” PCW Packaging Requirements
 Low-Density Trash PCW
 Package PCW trash in plastic bags (or equivalent) weighing less
than approximately 50 lb each.
 Asbestos PCW
o Package PCW asbestos in sealed plastic bags (or equivalent).
The asbestos must be double-bagged, with the bags free of any
tears or punctures on receipt. (For asbestos waste containing
sharp objects that might tear a bag, EnergySolutions
recommends that asbestos bags be packaged in super sacks.)
o Each bag must be properly marked for asbestos.
o No other radioactive markings/labels on or in the asbestos
waste, since this waste cannot be shredded after GIC bulk
assay.
o No yellow “rad” bags.

5.8.4 Sludges (i.e., Wastewater, Oil, and Treated Sewage) PCW
 Package PCW sludges in metal drum, boxes, or equivalent.
 An internal plastic bag or liner should be placed in drum or box
before filling.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 125 of 141
 Each “batch” of sludge waste must be sampled and analyzed (by
TCLP methods) for hazardous metals. This TCLP analysis must be
included with each waste-shipping manifest.
 Absorbent material should be placed in the container to avoid
freestanding liquid from occurring during waste shipping.

5.8.5 Paint Chips PCW
 Package PCW paint chips in metal drums, boxes (or equivalent).
 Each “batch” of paint chip waste must be sampled and analyzed
(TCLP) for hazardous metals. This TCLP analysis and a Safety
Data Sheet (SDS) must be included with each waste-shipping
manifest.

5.8.6 Water-Filtration Media (i.e., resin, charcoal) PCW
 Package PCW filtration media in metal drums, boxes, liners, or
equivalent.
 Absorbent material should be placed in the container to avoid
freestanding liquid from occurring during waste shipping.

5.8.7 High-Density (i.e., metals, soil, concrete, asphalt) PCW
 Package high-density waste in metal drums, boxes, or super sacks
or shrunk wrapped on pallets.
 Notify an Account Executive prior to any shipment of overweight
containers or very large metal components (i.e., tanks, equipment).

5.9 Sealed Sources for Encapsulation

5.9.1 Test Documentation: Type A test documentation for each Type A
package is required for acceptance of all sealed sources.

5.9.2 Sealed Sources Packaged in Drums or Inner-pack Boxes: Solid sealed
sources with concentrations below the values listed in Table 1 of the
EnergySolutions Waste Acceptance Guidelines may be placed in drums
or in EnergySolutions inner-pack boxes with other DAW material for
supercompaction.

Mark drums or inner-pack boxes containing smoke detectors, gaseous
sources, or instrument and articles containing sources: DO NOT
COMPACT — CONTAINS SMOKE DETECTORS and/or
GASESS SOURCES AND/OR INSTRUMENTS AND ARTICLES
CONTAINING SOURCES.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 126 of 141
5.9.3 Sealed Sources Packaged with Bulk DAW: Place solid sealed sources
with concentrations below the values listed in Table 1 of the
EnergySolutions Waste Acceptance Guidelines in a small container
(i.e., box or drum) and mark FOR COMPACTION ONLY —
CONTAINS SOLID SEALED SOURCES.

Place smoke detectors, gaseous sources, or instruments and articles
containing sources in small containers (i.e., boxes or drums) marked
DO NOT COMPACT — CONTAINS SMOKE DETECTORS
and/or GASEOUS SOURCES AND/OR INSTRUMENTS AND
ARTICLES CONTAINING SOURCES.

5.9.4 Radiological Limits for Sealed Sources: Sealed sources must meet the
following limits:

Radiation level per package < 200 mrem/hr contact (1 cm)
Radiation level per source < 200 mrem/hr contact (1 cm)
Removable external
contamination < 2,200 dpm beta-gamma/100 cm2
(per package or source) < 200 dpm alpha/100 cm2

Note: BCO custodian must be contacted before shipment of
PCB materials.

5.10 PCB Bulk Product Waste Metal for Best Way Metals Processing

5.10.1 Bulk Container Packaging: Use specially lined strong tight bulk
containers for PCB-contaminated metallic items. Clearly mark the liner
and package with the PCB “ML” sticker as required by 40 CFR 761.45
and the generator’s name, address, contact name, and phone number.
Number the package to correspond with the manifest entry.

Each package shall contain only one generator’s waste. Each PCB item
must be marked with PCB out-of-service date.

5.10.2 PCB concentrations in applied paint: If PCB concentration is not
identified through chemical analysis, PCB-contaminated metallic items
will be assumed to have PCB concentrations in excess of 100,000 ppm.

Note: PCB'S in excess of 50 PPM required to be manifested on
Hazardous Waste Manifest.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 127 of 141
5.11 Cask Shipments

5.11.1 All cask shipments require prior written approval from
EnergySolutions.

5.11.2 Notification shall be made if the cask model is not on list shown
below. The customer may be asked to provide the operating
instructions and special equipment if these are not available within
EnergySolutions. Failure to notify EnergySolutions of the cask type
will result in additional charges for delays in unloading.

ES 6-80-2 ES 14-170 III ES 3-60B
ES 8-120A ES 14-190H ES 8-121A
ES 8-121A ES 14-195H ES 14-210
ES 8-120B ES 14-212
ES 10-160B ES 14-215H
ES 14-170 II ES 21-300

5.11.3 Customers using an NRC-licensed cask not owned by EnergySolutions
(or CNS, Inc.) shall ensure that EnergySolutions is a “Registered User”
of the licensed cask prior to shipment to an EnergySolutions facility.
This applies to all shipments requiring licensed packages.

5.11.4 Third-party cask documents (C of C, SAR, and handling and
maintenance procedures and drawings) shall be made available to
EnergySolutions as the NRC Registered User of the cask prior to
shipment of the cask to an EnergySolutions facility.

5.11.5 All shipments shall strictly comply with the applicable Certificate of
Compliance for the cask in use (i.e., lid torque, sealing gaskets, weight
restrictions, shoring requirements, payload limitations, hydrogen gas
limitations, decay heat/watts, and neutron limitations, as applicable).

5.11.6 Liners containing “grapple bails” are to be identified on the Waste
Manifest Form.

Note: Liners containing non-EnergySolutions grapple bails
must have appropriate lifting cables attached.

5.11.7 All drums shall be palletized and pallets shall have proper lifting
devices attached. Boxes shall be equipped with appropriate lifting
devices or palletized.

Note: Drums with dose rates greater than 1 R/hr shall be
shipped in a cask on pallets.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 128 of 141

5.11.8 Disposal container and/or pallet shall have the lifting device secured at
the top of the container(s). This is to prevent the cable from becoming
caught under or between the container(s) or pallet.

Note: Lifting devices shall be of sufficient length to allow
retrieval and crane hook-up without physically entering
the cask.

5.11.9 For shipments consisting of high-integrity containers, the pallets on
which the containers are placed are considered sacrificial since the
pallets are used for proper placement in the concrete vaults.

5.11.10 When using pallets, the containers shall be positioned to remain
balanced and stable on the pallet when lifted clear of the cask.

5.11.11 When tall, slender containers (i.e., demineralizers) are loaded on a
pallet inside a cask, the containers shall be tied or secured together at
the tops to prevent containers from falling off the pallets during off-
loading.

Note: This is not required for a single tier of drums that are
placed on a pallet.

5.11.12 Palletized drums inside a cask shall be loaded to prevent movement in
such a manner that any shifted position of drums on the pallet will not
increase radiation levels measured outside the cask.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 129 of 141
TABLE 1. WASTE REQUIRING PRIOR APPROVAL AND POSSIBLY SPECIAL PRICING
WAG Section Requirement
General Non-radiological hazards to our employees shall be identified
2 Scheduling of any shipment for processing at EnergySolutions
All Any waste that does not meet the EnergySolutions WAG
5.2 Resins for incineration
5.4 Metal pieces larger than 16 ft  8 ft  8 ft per individual piece or combination of integral pieces
5.4 Metal pieces heavier than 20,000 lb per single piece
5.4 Metal melting for the following requires special evaluation:
 Metals coated with asbestos  Lead
 Alloys with melting points above 3000 degrees F  Stellite
 Galvanized metal with zinc weight percentage <1%
of the galvanized metal weight
 Tin
 Aluminum  Crushed metal items that contain entrained
nonmetallic materials
 Cadmium  Bulk metals containing >2% incinerable by weight
(e.g., wire insulation, paint, or other coatings)
 Copper/copper alloys (brass, bronze, etc.)
5.4.2 Lead with surface contamination levels greater than 1/10 the radiological values provided in Table 1-B of the
WAG.
5.4.2.5 LEMS
5.7 Compressed gases
5.8 Leaded glass (requires TCLP analysis)
5.9 Hazardous waste as identified in 40 CFR 261
5.11 Lead-acid batteries
5.13 Paint chips (requires TCLP analysis)
5.14 PCB-contaminated material
5.15 GIC processing of specialty metals (e.g. brass or bronze), circuit boards, and lead-acid batteries
5.15 GIC processing of sludges and paint chips (requires TCLP analysis)
5.17 Sealed sources
5.20 Tanks and other closed vessels
5.21 Trans-shipments for direct disposal
5.22 RCRA-empty containers
Table 1 - B When contamination levels in Table 1-B of the WAG may be exceeded
Table 1 - B TRU for processing in concentrations of 0.1 nCi/g
Table 1 - B TRU for trans-shipment in concentrations >10 nCi/g
Table 1 - C Waste containing Ra-226
Table 1 - C Waste containing Special Nuclear Material or Source Material (includes U-233, U-235, or uranium enriched in
U-233, U-235)
General Due to the non-routine nature of the types of wastes generated during decommissioning projects, EnergySolutions
reserves the right to review for approval radioactive wastes that originate from decommissioning projects
General All cask shipments (minimum of 3 days prior to arrival of shipment)
General Wooden or fiber outer containers and poly-wrapped flatbed loads
General All international shipments
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 130 of 141
Attachment 5.16
Shipping Requirements
Waste Control Specialists

1. Verify that the generator possesses a WCS-approved waste profile for the waste to be
shipped.

2. Schedule shipment at least 72 hours in advance.

3. General Criteria for Radioactive and Mixed Waste

3.1 Waste shall be packaged, loaded, and shipped in accordance with the applicable
provisions of 49 CFR Parts 170-178, 10 CFR 71, and Texas Regulations Part 11
and Part 21, Appendices D and E.

3.2 Mixed waste shall meet applicable USDOT and USEPA regulatory requirements
for the hazardous and/or toxic components in addition to meeting the regulatory
requirements for radioactive materials.

3.3 Waste containing multiple hazards shall be packaged according to the level of
hazard as defined in 49 CFR 173.2. Incompatible waste shall not be packaged
together and must be packaged in accordance with 40 CFR 264.177.

3.4 Waste containing pathogens, infectious waste, explosives, organic peroxide, or
other etiologic agents as defined in 49 CFR 173.386.

3.5 Additional packaging and waste form criteria is provided in the WCS Waste
Acceptance Criteria, CQ-100, Section 3.3.

4. WCS is authorized to dispose of certain exempt low-level radioactive material. Refer to
the WCS Waste Acceptance Criteria, CQ-100, Section 3.2 for a list of exempted
materials.

5. WCS is authorized for interim storage of low-level radioactive waste. In addition to
meeting the packaging criteria stated in 3.0 above, there are additional specific packaging
and waste form criteria. Refer to the WCS Waste Acceptance Criteria, CQ-100, Section
3.4 for the specifications.

6. WCS is authorized to accept mixed waste for interim storage and disposal. In addition to
meeting packaging criteria stated in 3.0 above, there are additional specific packaging
and waste form criteria. Refer to the WCS Waste Acceptance Criteria, CQ-100, Section
3.5 for the specifications.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 131 of 141
Attachment 5.16 (Continued)
Shipping Requirements
Waste Control Specialists

7. WCS is authorized to accept radioactive waste contaminated with PCB’s for interim
storage or disposal. Acceptance is handled on a case-by-case basis. Generally, solids
contaminated with any level of PCB’s are acceptable for disposal, but liquids must be
treated to less than 500 ppm for disposal.

8. WCS shall approve bulk waste shipments prior to shipping.

9. WCS shall approve radioactive contaminated asbestos prior to shipping.

9.1 Asbestos that is friable or capable of being friable must be wetted with a water
and surfactant mix and stored in two poly bags with a combined thickness no less
than 6 mil. The bags must be overpacked in a leak-resistant container that meets
applicable shipping requirements. Since the asbestos must be wetted during
abatement, an absorbent must be added to ensure compliance with freestanding
criteria.

9.2 All low-level radioactive waste containing asbestos shall be packaged, marked,
and labeled in accordance with 40 CFR 61.150.

9.3 Asbestos must be segregated and packaged separately.

10. Low-level radioactive and mixed waste may be exempt from certain waste form and
packaging criteria if the waste is being submitted to WCS for processing. WCS shall
approve all waste for processing on a case-by-case basis prior to shipping.

11. A Texas Hazardous Waste Manifest shall be used when transporting hazardous waste to
WCS.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 132 of 141
Attachment 5.17
Consignor Verification for Exclusive Use Radioactive Material Shipments and License
Authorization, Rev 0
To:
(Consignor)
Reference(s) EnergySolutions
Shipment Number
Scheduled Arrival Date:
Carrier:

Dear Sir / Madam:

49 CFR 173.403 – Definitions, requires shippers and carriers to verify that the consignee of an exclusive
use shipment has the resources appropriate for the safe handling of the consignment. The shipper must
also verify that only individuals having radiological training conduct receipt and unloading. For this
shipment, specific written instructions are being provided to the carrier detailing these requirements and
also the vehicle survey requirements specified in 49 CFR 173.443c, as required by 49 CFR 173.403.

Pursuant to these requirements, you are requested to provide certification that:

1. You have the necessary/appropriate resources for the safe handling of the consignment.
2. Individuals that conduct receipt and unloading have the appropriate radiological training.
3. Prior to being released for return to service use, the transport vehicle will be surveyed with the
appropriate radiation detection instruments and will not be released for return to service use until
the limits specified in 49 CFR 173.443 are met.

Prior to shipping for license transfer, 10 CFR 30.41, 40.51, and 70.42 require verification that the
consignee has a radioactive materials (RAM) license authorizing them to process the material being
shipped or transferred. Consignee must send a copy of the RAM license for verification purposes prior
to shipping.
RECEIVER’S CERTIFICATION

I certify that I have read the requirements specified above and
(Company) has the appropriate license for possession and resources for the safe handling of the
consignment listed and the individuals that conduct the receipt and unloading have the appropriate
radiological training. I further certify that the transport vehicle will not be released for return to service
use unless the radiation and contamination levels specified above are met. Please sign below in the space
provided and return it to the sender.
Signature Date
Title
Company

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 133 of 141
Attachment 5.18
Load Securement and Vehicle Safety Inspection

1. SCOPE

1.1 Purpose

To provide guidance in the securement of loads for transport and ensuring that the
vehicle meets all the safety requirements of 49 CFR 393(FMCSA).

1.2 Applicability

These guidelines apply to all loads of material for transport and all vehicles being
used to transport hazardous material.

2. REFERENCES

2.1 Federal Motor Carrier Safety Regulations Part 393 – Parts and Accessories
necessary for Safe Operation

2.2 Federal Highway Administration 23 CFR 658

3. LOAD SECURING GUIDANCE – Reference 2.1 of this attachment provides guidance
on the following topics:

3.1 The types of motor vehicles subject to the cargo securement standards, and the
general requirements for length, width and weight restrictions.

3.2 The minimum performance criteria for cargo securement devices and systems.

3.3 The standards cargo securement devices and systems must meet in order to satisfy
the requirements.

3.4 Determining the working load limits of a tie down.

3.5 Determining the minimum number of tie downs.

3.6 Requirements for front end structures used as part of a cargo securement system.

3.7 Securing intermodal containers.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 134 of 141

4. VEHICLE SAFETY GUIDANCE – Reference 2.2 of this attachment provides
guidance on the safety features of vehicles (tractors and trailers). Brokers shall
request the assistance of the driver while performing these inspections. The Broker
shall not climb into the tractor cab, turn on the tractor engine, or operate any of the
switches or knobs. While the driver activates, Broker should verify all safety features.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 135 of 141
Attachment 5.19
Category 1 and Category 2 Quantities of Radioactive Material

1. SCOPE

1.1. Purpose

Increase security requirements for higher activity shipments.

1.2 Applicability

These guidelines apply in the matter of all licenses authorized to possess
Radioactive Material Quantities of Concern per Reference 2.1 of this Attachment
and Reference 2.21 of this Procedure.

2. REFERENCE

2.1 U.S. Nuclear Regulatory Commission, 10 CFR 37 – Physical Protection of
Category 1 and Category 2 Quantities of Radioactive Material.

3. GUIDANCE

3.1 Category 1 quantity of radioactive material means a quantity of radioactive
material meeting or exceeding the Category 1 threshold in Table 1 of Appendix A
to this part. This is determined by calculating the ratio of the total activity of each
radionuclide to the Category 1 threshold for that radionuclide and adding the
ratios together. If the sum is equal to or exceeds 1, the quantity would be
considered a Category 1 quantity. Category 1 quantities of radioactive material do
not include the radioactive material contained in any fuel assembly, subassembly,
fuel rod, or fuel pellet.

3.2 Category 2 quantity of radioactive material means a quantity of radioactive
material meeting or exceeding the Category 2 threshold but less than the Category
1 threshold in Table 1 of Appendix A to this part. This is determined by
calculating the ratio of the total activity of each radionuclide to the Category 2
threshold for that radionuclide and adding the ratios together. If the sum is equal
to or exceeds 1, the quantity would be considered a Category 2 quantity. Category
2 quantities of radioactive material do not include the radioactive material
contained in any fuel assembly, subassembly, fuel rod, or fuel pellet.

3.3 Contact the Licensee (i.e. Waste Generator, Shipper) to discuss their policies and
procedures concerning Category 1 and Category 2 Quantities of Radioactive
Material.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 136 of 141
3.4 Transportation of Category 1 and Category 2 Quantities of Radioactive Material
shall be performed in accordance with 10 CFR 37 Subpart D – Physical Protection
in Transit. Contact the Licensee to discuss these requirements.

Table 1—Category 1 and Category 2 Threshold
The terabecquerel (TBq) values are the regulatory standard. The curie (Ci) values
specified are obtained by converting from the TBq value. The curie values are
provided for practical usefulness only.
Radioactive
Material
Category 1
(TBq)
Category 1
(Ci)
Category 2
(TBq)
Category 2
(Ci)
Americium-
241
60 1,620 0.6 16.2
Americium-
241/Be
60 1,620 0.6 16.2
Californium-
252
20 540 0.2 5.40
Cobalt-60 30 810 0.3 8.10
Curium-244 50 1,350 0.5 13.5
Cesium-137 100 2,700 1 27.0
Gadolinium-
153
1,000 27,000 10 270
Iridium-192 80 2,160 0.8 21.6
Plutonium-
238
60 1,620 0.6 16.2
Plutonium-
239/Be
60 1,620 0.6 16.2
Promethium-
147
40,000 1,080,000 400 10,800
Radium-226 40 1,080 0.4 10.8
Selenium-75 200 5,400 2 54.0
Strontium-90 1,000 27,000 10 270
Thulium-170 20,000 540,000 200 5,400
Ytterbium-
169
300 8,100 3 81.0
Note: Calculations Concerning Multiple Sources or Multiple Radionuclides

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 137 of 141
3.5 The “sum of fractions” methodology for evaluating combinations of multiple
sources or multiple radionuclides is to be used in determining whether a location
meets or exceeds the threshold and is thus subject to the requirements of this part.

3.5.1 If multiple sources of the same radionuclide and/or multiple radionuclides
are aggregated at a location, the sum of the ratios of the total activity of
each of the radionuclides must be determined to verify whether the activity
at the location is less than the Category 1 or Category 2 thresholds of Table
1, as appropriate. If the calculated sum of the ratios, using the equation
below, is greater than or equal to 1.0, then the applicable requirements of
this part apply.

3.5.2 First determine the total activity for each radionuclide from Table 1. This
is done by adding the activity of each individual source, material in any
device, and any loose or bulk material that contains the radionuclide. Then
use the equation below to calculate the sum of the ratios by inserting the
total activity of the applicable radionuclides from Table 1 in the numerator
of the equation and the corresponding threshold activity from Table 1 in
the denominator of the equation.

3.5.3 Calculations must be performed in metric values (i.e., TBq) and the
numerator and denominator values must be in the same units.

R1 = total activity for radionuclide 1
R2 = total activity for radionuclide 2
RN = total activity for radionuclide n
AR1 = activity threshold for radionuclide 1
AR2 = activity threshold for radionuclide 2
ARN = activity threshold for radionuclide n

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 138 of 141
Rev 0

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 139 of 141
Attachment 5.20
Shipping Exemption Value Sources

1.0 PURPOSE:

To provide instruction for the proper control, tracking, and shipping of radioactive exempt
value sources.

2.0 REFERENCES:

2.1 10CFRPart 30, Rules of General Applicability to Domestic Licensing of Byproduct
Material
2.2 49CFR173, Shippers-General Requirements for Shipments and Packagings
2.3 ES-BR-PR-002, Operating Procedure for Brokering of Hazardous Materials
2.4 ES-BR-PR-003, Training and Certification of Hazardous Material Brokers

3.0 DEFINITIONS:

3.1 Exemption Value – Means either an exempt material activity concentration or an
exempt consignment activity listed in the table in 49 CFR 173.436 or determined
according to the procedures described in 49 CFR 173.433, and used to determine
whether a given physically radioactive material is sufficiently radioactive to be
subject to the hazardous materials regulations. An exemption value is different
from an exemption, as defined in 49 CFR 171.8.

3.2 Radioactive Material – Means any radioactive material containing radionuclides
where both the activity concentration and the total activity in the consignment
exceed the values specified in the table in 49 CFR 173.436 or values derived
according to the instructions in 49 CFR 173.433. Radioactive material is also
referenced as Hazard Class 7 material. Materials meeting the above DOT definition
are subject to the transportation regulations specified in 49 CFR Subchapter C
“Hazardous Materials Regulations”.

3.3 Licensed Material – Means source material, special nuclear material, or by-
product material received, possessed used, transferred or disposed of under a
general or specific license issued by the U.S. Nuclear Regulatory Commission.

3.4 Project Manager – The Project Manager has the overall responsibility for the
performance of the project with support from other key personnel.

3.5 Authorized User – An Authorized User for the purpose of document is a person
responsible for the use of radioactive materials or supervises the activities
associated with the use of radioactive materials at a licensed facility location or
project site.

ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 140 of 141
3.6 Broker – A Broker is an individual that is certified by the Broker Committee
Chairperson by recommendation of the Broker Supervisor Broker and concurrence
of the Broker Committee.

4.0 RESPONSIBILITIES:

Brokers must comply with hazardous material regulations, radioactive material license
regulations and applicable procedures for the shipping of sources that meet the definition
of a radioactive material. Exempt Value sources shall be controlled and shipped in
accordance with the requirements below.

5.0 GENERAL REQUIREMENTS:

5.1 Source exemption determination

5.1.1 This determination must be performed by an individual that is certified in
the EnergySolutions Broker Program.

5.2 Multiple sources must be verified for unity. If sum total exceeds 1, the sources must
be shipped as a hazardous shipment by a Certified Broker

5.3 Notifications

5.4 Prior to the shipment of any Exempted Value source, notification to the receiving
facility shall be made and documented by the Project Manager or designee
responsible for the source(s). At a minimum, the notification documentation shall
contain the following information:

5.4.1 person contacted and phone number.
5.4.2 facility name and address
5.4.3 description of each source including source identification number (serial
number, etc.), type of source (solid, liquid, etc.), source isotope, and
activity
5.4.4 date of notification

6.0 SHIPPING PAPERS

Sources meeting the definition of Exemption Value quantities are not regulated by the
Department of Transportation (DOT), but a Bill of Lading will be required for source
tracking purposes.

7.0 TRANSPORTATION

7.1 Sources shall be shipped by ground only.

7.2 Sources cannot be shipped in personnel or rental vehicles.
ES-BR-PR-002
Operating Procedure for Brokering of Hazardous Material Revision 17

EnergySolutions Proprietary Page 141 of 141

7.3 Shipments in company owned vehicle’s is authorized.

7.4 No USMAIL.

7.5 For field projects where sources meeting the requirements of being Exemption Value
quantities are needed and an EnergySolutions Certified Broker is not present, the
Project Manager, under the direction of an EnergySolutions Certified Broker, or Senior
Certified Broker may ship Exemption Value sources only.

7.6 The Project Manager shall provide the EnergySolutions Certified Broker, or Senior
Certified Broker the customer notification for Bill of Lading generation. When the
Project Manager and Certified Broker, or Senior Certified Broker are in agreement with
the shipment (shipping/packaging instructions, etc.), the Certified Broker, or Senior
Certified Broker will complete and sign the Bill of Lading and forward it to the Project
Manager. The Project Manager must notify the Certified Broker or Senior Certified
Broker for approval if a change in the shipment occurs after the Certified Broker, or
Senior Certified Broker has signed the Bill of Lading.

Exhibit 4

Condition Report
Apparent Cause Analysis
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Title:Colorado Mines via RadPros Shipment to Clive Shipment Errors
Location/Project:Colorado Mines Facility
Event Date/Time:11/29/23 @ 1530 (estimate time)
Condition Report/Level:ACA CR 2023-0115/Level 2
Responsible Director/Manager:Mark Lewis
Team Leader/ACA Evaluator:Mike Cuarenta
Analysis Conducted Dates:3/18/24 -3/21/24
Team Members:
EnergySolutions Broker
VP Technical Services•David Caroll
•Jake Gardner
Reviews and Approvals:DigitallysignedbyMichaelCuarentaDN:OU=WasteManagement,CN=MichaelCuarenta,E=macuarenta@energyso!utions.comReason:IamtheauthorofthisdocumentLocation:SONGS-SDSDate:2024-03-2705:38:47FoxitPtiantomPDFVersion:9.7.5
Michael
Cuarenta /ACA Evaluator:
Mike Cuarenta
Mark Lewis
DateDigitallysignedbyMarkLewsDN:cn=MarkLewis,o=EnergySaIuiions,ou=BPF,em3il=[e-mail],c=USDate:2024.042516:11:41-041)0'/Responsible Manager:
Mark Lewis Date
Page 1 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Contents
Description of Condition
Extent of Condition
Analysis &Causes of Condition
Corrective Action(s)to Address Cause(s)
References
Personnel Interviewed
Attachments/Supporting Documents:
1.0 3
2.0 3
3.0 3
4.0 11
5.0 12
6.0 12
7.0 12
Page 2 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
1.0 Description of Condition
Problem Statement:
On 11/29/23,ES Broker made a shipment (0637-01-0001)from the Colorado Mines facility to Clive and
upon site inspection,the inspector identified multiple shipping errors (i.e.,marking stickers were not
affixed securely,LSA-II classification used instead of DOT Exempt Quantity,and evidence of waste
product on the outside of the packages).
Consequences:
The Utah Division of Waste Management and Radiation Control was required to be notified of this
discrepancy and the potential consequences of these shipping errors,which is still under review,is a
Notice of Violation (NOV)to the GSAP Permit #2914000504.|Z&7
Immediate &Subsequent Actions Taken:
The 24-hour notice was made to the state and a 7-day follow up required by Clive’s Radioactive Material
License (RML).The shipment was accepted at Clive and placed on hold inside Clive’s RCA.
2.0 Extent of Condition
This issue is bounded to this shipment performed by the particular Broker involved in this event.
To date,this particular Broker has made ~48 shipments without issue.Additionally,the other field Broker
(there is only two Brokers that work under the Broker Program)has had no severe issues with the
shipments he has responsibilities for that warranted this level of scrutiny by the Utah Regulators nor any
lower-level issues requiring disciplinary actions by the Broker Committee (this also goes for the Broker
involved in this event).Additionally,there are strict checks and balances in place for D&D Brokers to
ensure the shipments they are responsible for are in compliance with all regulations and the disposal sites’
WACs.
In 2023,there were 5,144 shipments made by EnergySolutions with two errors reported to the Broker
Committee,both errors caused by the same Broker.The need to perform a backwards review of previous
shipments is not necessarily for this EOC since the discrepancies would have presented themselves when
trying to obtain the disposal sites’acceptance.However,any lessons learned from this Event will be
shared with the other Brokers,as needed,to include any programmatic updates that are found to be
necessaiy based on the evaluation results.
3.0 Analysis &Causes of Condition
This evaluation is comprised of two methods to determine the underlying causes:
First,a sequence of events/timeline was put together to capture all essential information pertinent to the
situation.The timeline includes the Inappropriate Actions (IA)taken or not taken that impact the ability to
preclude the deficient condition.The basis allows the evaluator to review all steps/decisions made once
laid out and point out the LAs that need to be drill down.
Second,a “Why Analysis”was performed to take a more in-depth assessment of the predominant (i.e.,
most significant impact)las using record reviews,photos,and interviews.The basis for using this method
is due to it being a simple technique for occurrences and findings where the causes are somewhat evident.
Page 3 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
An actual “Why Staircase”is not recorded since the cause was short and clear;however,the IA wasfurtherelaboratedtopresenttheunderlyingcause.
NOTE:An IA is defined as an action taken,or action NOT taken,that resulted in an unintended
condition,nonconformance,or noncompliance.An LA is not intended to imply a wrongful,intentional,deliberate,or act with malice was performed.
Sequence of Events (SOE):
Below are some key dates pertinent to this event.
10/25/23 (1537hrs):RadPros provided access to the Customer Portal (CP)to create their accounts and
profile 0637-01 was started by the Director,Technical Services.
10/26/23 (0947hrs):Director,Technical Services inquiries about some data entries (EPA ID #&
Elemental Mercury)made in the new profile 0637-01 and offers to assist RadPros updating the profileoncetheanswersareprovidedforthequestionsasked.Question regarding submitting a request for a
GASP (Generator Site Access Permit)through the State of Utah was also asked.
10/26/23 (1808hrs):RadPros provides answers to questions asked and inquiries about the process for
applying for a GASP permit.
10/27/23 (0954hrs):GASP link provided.
11/3/23 (1406hrs):RadPros receives their GASP from the State of Utah.GASP #2311000504.
11/7/23 (1307hrs):RadPros notified by Director,Technical Services that the non-aqueous request has
been approved and that the waste profile to be updated,and that RadPros should begin preparing for their
shipment in the upcoming week.
11/8/23 (1355hrs):RadPros express interests in having EnergySolutions handle the paperwork/shipping
of the waste with a tentative ship date of November 30th or December 1st 2023.
11/8/23 (1424hrs):Director of Broker &Training Programs made aware of RadPros interests and asked if
there were any available shippers to meet the tentative ship dates.
11/8/23 (1437hrs):Director of Broker &Training Programs confirmed that the Broker is available to
make the shipment on November 30th,2023,but requests information about the characterization,
packaging,number of packages,and conveyance.
11/20/23 (1241hrs):Director,Technical Services provides calculations based on RadPros calculations and
emails it to the Broker.NOTE:At this time,the number of drums was only for 1 drum,but the Broker
was able to extrapolate the extra data when an additional 4 drums were added to the shipment.
Page 4of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
I was able to calculate all of the information based on the Rad Pros calculations below.
Total grams of waste:2,334;695 grams
Total lbs of waste:5,142.5 lbs (using 454 g/!b)
Total gallons of waste:605 gallons
Calculated density:
Calculated tote wt:
(two 275-gallon totes and one 55-gallon drum)
(5,142.5/605)
(8.5 *275)
(8.5 *55)
8.5 Ib/gai
2,337.5 lb
Calculated drum wt:467.5 lb
That should give you enough information for the manifests.
11/28/23 (2130hrs):Broker checks into hotel in Denver,Colorado.
11/29/23 (0500hrs):Broker tags along with RadPros employee and travel to facility (Colorado Interstate
Gas Co,LLC).
NOTE:Estimate drive from hotel to facility is ~4hrs (Denver,Colorado to Wamsutter,
Wyoming).
11/29/23 (0900hrs):Broker and RadPros employee arrive at facility.
11/29/23 (0900hrs-1300hrs):Packaging,loading,and securing work commences.Sludge spillage over on
totes identified.Drums also have snow on them.
IA-1:Package not wiped down.
11/29/23 (1400hrs):Broker calls local truck stop to see if they had adhesive spray,none in stock.
11/29/23 (1400hrs-1430hrs):Packages (2 totes &5 drums)were wiped down with brake cleaner and rags.
11/29/23:(1430hrs):Broker labeled and marked the packages as LSA-II.
IA-2:Shipment labeled and marked as Radioactive-LSA-II instead of DOT-Exempt Quantity.
Page 5 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Figure -Photo of loaded package.
IA-3:Adhesive spray not used.
11/29/23 (1500hrs-1530hrs):Tarping of the load commences;the tarp was folded over (2-layers)covering
the packages and was assumed to be tight to prevent air going through the tarp.
11/29/23 (1530hrs):Transporter (South Park Motor Lines)leaves to Clive,Utah.
IA-1 (repeat from above):Package not wiped down.
11/30/23:Shipment #0637-01-0001 arrives at Clive,Utah and issues identified.
Page 6 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Evaluation:
The SOE identified three Inappropriate Actions (IA).Using a “Why Analysis”methodology combined
with interviews and documentation reviews,each IA was further evaluated to determine the underlying
cause:
IA-1:Package not wiped down.
LA-2:Shipment labeled and marked as Radioactive-LSA-H instead of DOT-Exempt Quantity.
IA-3:Adhesive spray not used.
Inappropriate Actions (IA )Analysis
IA-1:Package not wiped down.
During the interviewing effort,the Broker did notice the sludge and snow on the drums but did
not challenge the situation and ensure the facility support POC removed it prior to labeling and
marking and eventually tarping the load.
The underlying cause for this IA is human performance related,specifically,the Broker’s
decision making was less than adequate (LTA)and did not ensure the package appearance was
satisfactory and did not consider the appearance of the sludge to be a concern at the Clive facility
upon arrival.Per ES-BR-PR-002 section 4.2.1.12.4 it states the following:“All affected packages
are wiped as dry as possible before the shipment leaves the site”.
See section 4 for actions taken and to be taken to resolve this cause.
LA-2:Shipment labeled and marked as Radioactive-LSA-II instead of DOT-Exempt Quantity.
During the interviewing effort and documentation review,the Director of Broker &Training
Programs offered the following response to this IA-2;“There is no IP-Lt compliance package with
the performance test results for the totes.Reference the DOT Subtype calculation results based on
the Characterization Report provided by RadPros (Cleanup Contractor)by Pace Analytical
(Characterization Lab).The results show that the material does not exceed the DOT exempt
quantity limits,thus could and should not have been shipped as DOT regulated LSA-II.If shipped
as non-DOT regulated the totes would not need to meet the IP-LI package requirements or be able
to withstand the IP-II performance tests.Manifesting this material as LP-II is an error.Also,an
error,in addition to the incorrect characterization as a DOT regulated LSA-II,the
Characterization Report isotopics provided by RadPros by Pace Analytical did not match the
entry in the Clive Profile.The Characterization Report and associated DOT calculations,showing
that the material could and should have been shipped DOT Exempt Quantity,used the correct
isotopic,but the isotopics identified in the profile and on the shipping papers were in error.
Following is a copy of the email to ES Broker from Director,Technical Services showing the
correct data from RadPros and Pace Analytical that,again did not match the profile or the
shipping papers.”Reference snippet above in 11/20/23 (1241hrs)time entry.
Page 7 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
0637-01Summary
Package:0637-01
Physical &Radiological Content DOTCalculations
Weight:
Volume:
2332.60 kgs 5142.50 lbs
85.00 ft3 RadioactivePackage?
ReportableQuantity?Meet LimitedQuantityforLiquid?MeetLimited Quantity forSolid?DOT QuantityMeetLowSpecificActivityl?Meet Low SpecificActivityllforSolids&Gases?Meet Low SpecificActivity ft for Liquid?Waste ClassFissileExcepted(Ref.173.453.a)
uCi/cc 0NRCQuantityofConcern<Category 2-0.000IAEAQuantity<Category3-0.000
Non RadNo-0.000
Yes -0.003Yes-0.000TypeA-0.000
Yes -0.000Yes-0.000Yes-0.000ClassA0.00%Non-Fissiie
„3m2.41
Activity
MBq mCi pCi/gmPB-210 7.0300E-05 1.9000E-06 8.1454E-04PQ-210 2.9452E-05 7.96Q0E-07 3.4125E-04
Total 9.9752E-05 2.6960E-06 1.1558E-03
Special Nuclear Material&SourceMaterial
SM(kgs)SNM (gms)
NoSNMorSMfor thisPackage
Figure -Characterization Report (RadPros/Pace Analytical).
The underlying cause for this IA is human performance related,specifically,in two ES-BR-PR-
002 requirements not being met.First,section 4.1.1 requires the use of “spreadsheets and/or
software programs (i.e.,Lowtrack,Radman,EM Waste)used to generate shipping manifest
and/or perform calculations ...”Additionally,throughout several sections in ES-BR-PR-002,it
states that “for waste shipments,determine the waste classification using the Waste Classification
Worksheet (Attachment 5.7)or equivalent with approval per step 4.1.1.Per the Broker,he stated
that he did use Lowtrack to determine the waste classification;however,when he was discussing
some items with the Broker Mentor,they came to an agreement to use the waste profile waste
classification that was created in the Customer Portal for Colorado Mines facility.However,after
this event,it was discovered that when the waste profile was setup in the Customer Portal based
on the RadPros characterization report,the Radionuclides was setup slightly higher than the lab
results to account for any potential discrepancies during the sampling efforts.Because of this
decision,in that the lab results were not used for the classification of this shipment it had adominoeffectontheotherissuesidentifiedwiththisshipment.
The other cause identified during is that since the Broker did mark and label the package LSA-II,
there was no evidence to indicate that the totes and drums met the IP-2 requirements which would
have been required for the material that meet LSA-II requirements.This is procedure compliance
issue with the requirements defined in ES-BR-PR-002 section 4.1.18.
See section 4 for actions taken and to be taken to resolve this cause.
IA-3:Adhesive spray not used.
During the interviewing effort,the Broker did inform his RadPros point of contact (POC)that
adhesive spray will be needed and if the POC could supply some;however,the POC did not
supply any.Additionally,there were several opportunities to procure adhesive spray on the way
to the facility and prior to labeling and marking the package;however,the Broker did not stop to
procure any adhesive spray.Prior to labeling and marking,the Broker did ask the facility support
POC if there was a local hardware store and was told there is one about an hour away.At that
Page 8 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
time of the evolution,it was around 1430hrs,and the Broker estimated that if he left to the
hardware store at that time,he would not be back until 1630hrs,and the shipment most likely
would not go out.
Contrary to expectations/requirements,the Broker believed that the labels and markings would
stay on the package for the ~6-hour drive to Clive,Utah.He also did not want to delay the
shipment another day and be required to drive back to his hotel in Denver,Colorado which was
~4 hours away and then come back to the facility the following morning which was another ~4-
hour drive.
The underlying cause for this IA is human performance related,specifically,the Broker did not
stop work and consider the negative impact that could occur by not using adhesive spray to secure
the labels and marking.This particular area is a common practice for all Brokers,both at D&D
sites and field/travelling Brokers.
See section 4 for actions taken and to be taken to resolve this cause.
Conclusion:
All three causes were rolled up into one apparent cause since all three causes were human performance
related,mainly,failure to use appropriate human performance tools and comply with procedure
requirements.However,each issue identified in this shipment could warrant a NOV against the GSAP
Permit #531-104)0504 on its own.
Apparent Cause:
The Broker’s decision making was less than adequate (LTA)and did not ensure the package
appearance was satisfactory and did not consider the appearance of the sludge to be a concern at
the Clive facility upon arrival.Additionally,the Broker failed to comply with ES-BR-PR-002
section 4.1.1 and 4.1.18 and ensured that the lab results were used for the waste classification;
subsequently,since LSA-H labelling and marking were used the Broker did not verify if the totes
and drums met the IP-2 requirements.Lastly,the Broker did not stop work and consider the
negative impact that could occur by not using adhesive spray to secure the labels and marking.
Training Review
A review of the Broker’s training was conducted to include past shipments prior to this event and
shipments made after this event.The involved Broker was trained and certified on the following training
items:
Broker Tech Survey Certificate-May 2022
Broker Week 2 Completion Certificate-May 2022
IATA Certificate-8 hrs-June 2022
NRC-DOT Subpart H Certificate-32 hrs-June 2022
Load Securing CBT Certificate-June 2022
Hazardous Material Driver’s Training-Aug 2022
Broker Certificate-December 2022
Broker Requal Mixed Waste Certificate-November 2023
Air Transport of RAM CBT Certificate-August 2024
Page 9 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Since being trained and certified,the Broker has been performing these duties since January 2023 and has
been working for EnergySolutions since 2022.Prior to this event,the Broker has made ~45 shipments and
most of these were for FSU during the summer of 2023.After this event,the Broker has assisted with 3
ANL shipments.
Page 10 of 12
Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
4.0 Corrective Action(s)to Address Cause(s)
Corrective Action OwnerDueDateCause
CA-1:The Director of Broker &Training Programs implemented ES-
BR-PR-002 section 4.4,Shipping Errors,guidance.Following
additional guidance defined in ES-BR-PR-001 section 4.2.1,Error
Severity Levels,this event meet the criteria to be screened as a Level 4.
Level4 definition states,“Compliance error that results in a NOV letter
from a regulatory agency.”To obtain additional in-field training,the
Broker has been assigned to work and learn under the Senior Certified
Broker at the Kewaunee D&D site until he becomes more
Apparent Cause-1:
The Broker’s decision making was less
than adequate (LTA)and did not ensure
the package appearance was satisfactory
and did not consider the appearance of the
sludge to be a concern at the Clive facility
upon arrival.Additionally,the Broker
failed to comply with ES-BR-PR-002
section 4.1.1 and 4.1.18 and ensured that
the lab results were used for the waste
classification;subsequently,since LSA-II
labelling and marking were used the
Broker did not verify if the totes and
drums met the IP-2 requirements.Lastly,
the Broker did not stop work and consider
the negative impact that could occur by
not using adhesive spray to secure the
labels and marking.
Completed Mark Lewis
knowledgeable and experienced.
CA-2:Based on the lessons learned from this event,issue a lessons
learned communication to all Brokers covering the inappropriate
actions (IA)that were identified,the underlying causes for each IA,
consequences of event,and reinforce ES-BR-PR-002 requirements that
cover these IAs that if complied with would have prevented these
issues to occur.
4/30/24 Mark Lewis
Page 11 of 12
Revision 0ApparentCauseAnalysisES-COM-CR-2022-333
Leaking Railcar #FURX322326
5.0 References
ES-BR-PR-001,EnergySolutions Broker Program Administration,Revision 7
ES-BR-PR-002,Operating Procedure for Brokering of Hazardous Materials,Revision 15
ES-AD-PR-008,Condition Reports,Revision 17
ES-AD-PR-012,Cause Analysis,Revision 6
RadPro GSAP Colorado Interstate Gas Company GSA Permit
Radpro 1st Amendment RadProslO.l 7.2023
0617-01-0001 Manifest
L1639107_Wamsutter Analytical Report,dated 8/30/2023
02c-Colorado Mines Calculation DOT Page
6.0 Personnel Interviewed
1
2
3
4
5
6
7
8
9
«David Carroll,Broker
®Jake Gardner,VP Technical Services
7.0 Attachments/Supporting Documents:
1 NA
Page 12 of 12

Exhibit 5

EnergySolutions
First Notification of Incident

Exhibit 6

Condition Report

CR-2024-0115
Colorado Mines via RadPros Shipment to Clive
Source: First Notification Report Number: FN-2023-0175
Owning Organization: D&D Project/Site: D&D General Functional Area: Regulatory Affairs/Licensing
Description:
Broker shipment from Colorado Mines resulting in multiple shipping errors. Errors that will likely result in Utah NOV and possibly fine and/or
GSAP restriction. Gap between FN and this CR is due to Q&A communication with Utah State inspector and the initial severity
determination.
Originator: Mark S Lewis Date Identified: 2/23/2024 Initiated On: 2/23/2024
Originators Questions Answer Notes
Were there any immediate actions taken?Yes Investigation into number and types of shipping errors
Is there anyone else that might be able to provide
additional information?Yes Justin Lee, Jake Gardner, and Tim Orton
Externally Identified?No Errors identified during Clive incoming inspection
Initiate Completed By: Lewis, Mark on 02/23/2024
Screening Question Answer Notes Person Notified Date Notified
Is information in CR adequate?Yes N/A N/A
Does Issue meet criteria for CR?Yes N/A N/A
Are any Interim Actions needed?No N/A N/A
10 CFR 21 Potentially Reportable?No N/A N/A
10 CFR 71 or 10 CFR 72 Potentially
Reportable?No N/A N/A
PAAA Applicable? (DOE only)No N/A N/A
Require Causal Analysis Yes N/A N/A
Require an Action Plan Yes N/A N/A
Require Extent of Condition Review Yes N/A N/A
Require CARB Review Yes N/A N/A
Completion Due Date: 7/22/2024
Significance Level: SL 2
Designation: CAQ
Causal Analysis Type: Apparent Cause Analysis (ACA)
Responsible Manager: Michael Anthony Cuarenta
Screen Completed By: Lowery, Jared on 02/29/2024
Reference Summary
WHYST-2024-0007 Identified Causes:
ANATT-2024-0016 1 Attached File(s):
- Apparent Cause Analysis CR 2024-0115 (Colorado Mines via RadPros Shipment to Clive) - Revision 1 Final.pdf
Detailed Evaluation Completed By: Cuarenta, Michael on 04/26/2024
Ops Review Task Skipped
Evaluator: Michael Anthony Cuarenta
RM Review Completed By: Cuarenta, Michael on 03/01/2024
CR-2024-0115
Causes
Cause Code: A3B1C01 – Check of work was LTA
Cause Type: Apparent
Description:
The Broker’s decision making was less than adequate (LTA) and did not ensure the package
appearance was satisfactory and did not consider the appearance of the sludge to be a concern at
the Clive facility upon arrival. Additionally, the Broker failed to comply with ES-BR-PR-002
section 4.1.1 and 4.1.18 and ensured that the lab results were used for the waste classification;
subsequently, since LSA-II labelling and marking were used the Broker did not verify if the totes
and drums met the IP-2 requirements. Lastly, the Broker did not stop work and consider the
negative impact that could occur by not using adhesive spray to secure the labels and marking.
Extent of Condition Results:
See attached file titled "Apparent Cause Analysis CR 2024-0115 (Colorado Mines via RadPros Shipment to Clive) - Final" for EOC results.
Evaluation Results Summary:
See attached file titled "Apparent Cause Analysis CR 2024-0115 (Colorado Mines via RadPros Shipment to Clive) - Final" for Evaluation
Results Summary.
Action Plan
CRA01-2024-0432 Due Date: 4/30/2024
Date Closed: 4/11/2024
Title: Corrective Action
Description:
Based on the lessons learned from this event, issue a lessons learned communication to all Brokers covering the inappropriate actions
(IA) that were identified, the underlying causes for each IA, consequences of event, and reinforce ES-BR-PR-002 requirements that
cover these IAs that if complied with would have prevented these issues to occur.
Action Type: Corrective Action
Owning Organization: D&D Project/Site: D&D General Functional Area: Brokering Program
Action Owner: Michael Anthony Cuarenta
Action Taken:
Created in error, this action to be implemented under CRA01-2024-0480.
CRA01-2024-0478 Due Date: 5/8/2024
Date Closed: 5/3/2024
Title: Corrective Action
Description:
The Director of Broker & Training Program to implement ES-BR-PR-001 section 4.3.2.1 and submit a written report to the Broker
Committee of the Broker Error and remedial actions taken for review and disposition. Take additional actions recommended by the
Broker Committee as needed.
Action Type: Corrective Action
Owning Organization: D&D Project/Site: D&D General Functional Area: Waste Management
Action Owner: Michael Anthony Cuarenta
Action Taken:
Reference attached file titled “CRA01-2024-0478 Objective Evidence” to be used as proof of completion that the Director of Broker &
Training Program implemented ES-BR-PR-001 section 4.3.2.1 and submitted a written report (a copy of the ACA) to the Broker
Committee of the Broker Error and remedial actions taken for review and disposition.
No additional actions were recommended by the Broker Committee.
CRA01-2024-0479 Due Date: 6/14/2024
Date Closed: 6/8/2024
CR-2024-0115
Title: Corrective Action
Description:
The Director of Broker & Training Program to recommend for approval from the Broker Committee if the use of the Peer Review
Checklist (similar to use by D&D Sites) should be required for use by all Brokers implementing ES-BR-PR-002.
Action Type: Corrective Action
Owning Organization: D&D Project/Site: D&D General Functional Area: Waste Management
Action Owner: Michael Anthony Cuarenta
Action Taken:
Reference attached file titled "CRA01-2024-0479 Objective Evidence" for proof of completion.
CRA01-2024-0480 Due Date: 5/8/2024
Date Closed: 4/26/2024
Title: Corrective Action
Description:
Based on the lessons learned from this event, issue a lessons learned communication to all Brokers covering the inappropriate actions
(IA) that were identified, the underlying causes for each IA, consequences of event, and reinforce ES-BR-PR-002 requirements that
cover these IAs that if complied with would have prevented these issues to occur.
Action Type: Corrective Action
Owning Organization: D&D Project/Site: D&D General Functional Area: Waste Management
Action Owner: Michael Anthony Cuarenta
Action Taken:
Reference attached file titled "CRA01-2024-0480 Objective Evidence Final" to be used as objective evidence that the action has been
implemented.
CRA01-2024-0755 Due Date: 7/11/2024
Date Closed: 7/12/2024
Title: Corrective Action
Description:
Track the disposition made by the Broker Committee regarding if the use of the Peer Review Checklist (similar to use by D&D Sites)
should be required for use by all Brokers implementing ES-BR-PR-002.
Action Type: Corrective Action
Owning Organization: D&D Project/Site: D&D General Functional Area: Brokering Program
Action Owner: Michael Anthony Cuarenta
Action Taken:
On 7/11/24, a meeting was held the Broker Director and VP Waste Services and per the Broker Director, he received feedback from
both the Broker Committee and a few Brokers in which the feedback was overall positive in that the Peer Review Checklist should be
incorporated into ES-BR-PR-002. The procedure to contain guidance that email, or tele-communication approval is acceptable if the
Broker who completed the peer review is unable to sign the checklist (which is not an issue for D&D sites).
This feedback satisfies the intent of this action and the actual revision of ES-BR-PR-002 will be tracked and implemented under CR-2024
-0251 since there is an action to revise ES-BR-PR-002 for another checklist embedded in the procedure (ref. CRA01-2024-0590).
NOTE: This action is not a corrective action and was a recommendation to improve the Broker process dependent on the feedback
received by the Broker Committee and Broker(s).
RM Concurrence Completed By: Cuarenta, Michael on 04/26/2024
QA Review Task Skipped
CARB Approval Completed By: Cuarenta, Michael on 04/26/2024
CR-2024-0115
RM Completion Review Completed By: Cuarenta, Michael on 07/12/2024
QA Completion Review Task Skipped
Final Closure Review Completed By: Cuarenta, Michael on 07/15/2024
Additional Details
Attachments
CAP Actions.pdf
2024-04-08 CARB minutes.pdf
Apparent Cause Analysis CR 2024-0115 (Colorado Mines via RadPros Shipment to Clive) - Final EDITS based on CARB Feedback.pdf
Comments
By Date Time Task Comment
Jared Brandon Lowery 4/10/2024 09:18 CARB Approval ACE review for CR 2024-0115 – CARB approved on 4/8/24. See
attached minutes and markup.
CR-2024-0115
Corrective Action Plan for CR-2024-0115

Order
Number
Action Proof of Action Completed?
1 Investigate and
identify errors
Mark Lewis, Broker Committee Chairman, discussed
errors with Broker (Dave Carroll), Jake Gardner, Tim
Orton, Justin Lee, and Broker Supervisor (Larry
Conway); looked at all pictures taken; studied the
lab results; looked at the manifest; and, verified
calculations performed. Errors include:
• Lab sample isotopic results were different than
those entered into the Waste Profile correctly.
Lab sample results is always the overriding
compliance document, not the profile
• Using lab sample results, the waste material
should have been shipped as DOT Exempt
Quantity, thus not subject to more stringent
packaging, marking, labeling, placarding, and
manifesting as the DOT LSA classification
• Marking stickers (Radioactive-LSA) were not
affixed securely. Although the areas where
markings were affixed was cleaned prior to
affixing, added prevention was not used, ie
spray adhesive and/or gorilla tape
• Although if shipped DOT Exempt where only a
General Design package would be required, the
package did not meet the IP-II package
conditions for the as shipped LSA
• Although contamination levels were below the
DOT 49 CFR 173.443 limits, the outside of the
packages had evidence of waste product that
had not been cleaned off
Yes
2 Talk and respond to
State of Utah’s
inspector and answer
his questions
Mark Lewis talked the Gage Fausto and prepared
answers to his questions. See attachments
Yes
3 Determine cause of
errors
Cause of errors has been identified as:
• an isolated incident by an individual Broker that
did not follow procedures and was not
experienced, not a programmatic problem with
procedures or oversight
• Jake Gardner was his assigned Mentor and PEER
checker per procedures. David Carroll did
discuss this shipment with Jake and Tim Orton,
prior to making the shipment. See attached
Yes
email from Tim Orton about using the isotopic
lab results
• Through review, it was determined that Broker
Operating Procedure, ES-BR-PR-002, and the
Broker Training Procedure, ES-BR-PR-003, fully
addressed all the shipping mistakes, thus would
have prevented any errors if followed
appropriately
4 Assign error level in
accordance with ES-
BR-PR-001 and
develop remedial
action plan
According to ES-BR-PR-001, this is a Level 4 error
requiring remedial training and more stringent
oversight by his Mentor and the Broker Executive
Committee
Yes
5 Carry out Remedial
Action Plan
To carry out his Remedial Action, Dave Carroll has
been assigned to work and learn under the Senior
Certified Broker at the Kewanee D&D site until he
becomes more knowledgeable and experienced
Yes

D&D CARB MEETING MINUTES

Date of Meeting: 04/08/2024 1600 EST
Attendance (Quorum is Chair plus 4 members (and QA for causal evals)):

Prior Attend

x-Pr
e
s
e
n
t

A-Ab
s
e
n
t

01
/
1
5
/
2
4

02
/
1
2
/
2
4

03
/
1
1
/
2
4

04
/
0
8
/
2
4

D&D CARB Members
Carpenter 48 1 x x x x
Bambino 23 26 x A A x
Baskett 45 4 x x A x
Eiler 39 10 x x x x
Hazelhoff (or alt Wheat) 19 6 x x A x
Spellman 9 4 A x x x
Roberts 32 17 x A A x
Zwetolitz 42 7 x x x x
Boschetti (QA) 7 4 A x x x
Others
Lowery x x x x
Mark Lewis / A. Moore / x x
Mike Cuarenta x x x
Notes:
1. Safety Message – Roberts
2. Review any outstanding extension requests
3. ACE review for CR 2024-0115 – CARB approved as noted on the attached markup
4. New CRs
Next regular meeting AGENDA (May 6, 2024, 1530 EST)
1. Safety Message –Zwetolitz
2. Review any outstanding extension requests
3. Trending discussion – based on data to be sent on May 1.
4. New CRs

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 1 of 12

Title: Colorado Mines via RadPros Shipment to Clive Shipment Errors

Location/Project: Colorado Mines Facility

Event Date/Time: 11/29/23 @ 1530 (estimate time)

Condition Report/Level: ACA CR 2023-0115/Level 2

Responsible Director/Manager: Mark Lewis

Team Leader/ACA Evaluator: Mike Cuarenta

Analysis Conducted Dates: 3/18/24 – 3/21/24

Team Members:

• David Caroll EnergySolutions Broker
• Jake Gardner VP Technical Services

Reviews and Approvals:

ACA Evaluator: /___________
Mike Cuarenta Date

Responsible Manager: ______________ __/________________
Mark Lewis Date

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 2 of 12

Contents
1.0 Description of Condition ................................................................................................................... 3
2.0 Extent of Condition ........................................................................................................................... 3
3.0 Analysis & Causes of Condition ....................................................................................................... 3
4.0 Corrective Action(s) to Address Cause(s)....................................................................................... 11
5.0 References ....................................................................................................................................... 12
6.0 Personnel Interviewed ..................................................................................................................... 12
7.0 Attachments/Supporting Documents: ............................................................................................. 12

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 3 of 12

1.0 Description of Condition
Problem Statement:
On 11/29/23, ES Broker made a shipment (0637-01-0001) from the Colorado Mines facility to Clive and
upon site inspection, the inspector identified multiple shipping errors (i.e., marking stickers were not
affixed securely, LSA-II classification used instead of DOT Exempt Quantity, and evidence of waste
product on the outside of the packages).
Consequences:
The Utah Division of Waste Management and Radiation Control was required to be notified of this
discrepancy and the potential consequences of these shipping errors, which is still under review, is a
Notice of Violation (NOV) to the GSAP Permit #2311000504.
Immediate & Subsequent Actions Taken:
The 24-hour notice was made to the state and a 7-day follow up required by Clive’s Radioactive Material
License (RML). The shipment was accepted at Clive and placed on hold inside Clive’s RCA.
2.0 Extent of Condition
This issue is bounded to this shipment performed by the particular Broker involved in this event.
To date, this particular Broker has made ~48 shipments without issue. Additionally, the other field Broker
(there is only two Brokers that work under the Broker Program) has had no severe issues with the
shipments he has responsibilities for that warranted this level of scrutiny by the Utah Regulators nor any
lower-level issues requiring disciplinary actions by the Broker Committee (this also goes for the Broker
involved in this event). Additionally, there are strict checks and balances in place for D&D Brokers to
ensure the shipments they are responsible for are in compliance with all regulations and the disposal sites’
WACs.
In 2023, there were 5,144 shipments made by EnergySolutions with two errors reported to the Broker
Committee, both errors caused by the same Broker. The need to perform a backwards review of previous
shipments is not necessarily for this EOC since the discrepancies would have presented themselves when
trying to obtain the disposal sites’ acceptance. However, any lessons learned from this Event will be
shared with the other Brokers, as needed, to include any programmatic updates that are found to be
necessary based on the evaluation results.
3.0 Analysis & Causes of Condition
This evaluation is comprised of two methods to determine the underlying causes:
First, a sequence of events/timeline was put together to capture all essential information pertinent to the
situation. The timeline includes the Inappropriate Actions (IA) taken or not taken that impact the ability to
preclude the deficient condition. The basis allows the evaluator to review all steps/decisions made once
laid out and point out the IAs that need to be drill down.
Second, a “Why Analysis” was performed to take a more in-depth assessment of the predominant (i.e.,
most significant impact) Ias using record reviews, photos, and interviews. The basis for using this method
is due to it being a simple technique for occurrences and findings where the causes are somewhat evident.

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 4 of 12

An actual “Why Staircase” is not recorded since the cause was short and clear; however, the IA was
further elaborated to present the underlying cause.
NOTE: An IA is defined as an action taken, or action NOT taken, that resulted in an unintended
condition, nonconformance, or noncompliance. An IA is not intended to imply a wrongful, intentional,
deliberate, or act with malice was performed.
Sequence of Events (SOE):
Below are some key dates pertinent to this event.
10/25/23 (1537hrs): RadPros provided access to the Customer Portal (CP) to create their accounts and
profile 0637-01 was started by the Director, Technical Services.
10/26/23 (0947hrs): Director, Technical Services inquiries about some data entries (EPA ID # &
Elemental Mercury) made in the new profile 0637-01 and offers to assist RadPros updating the profile
once the answers are provided for the questions asked. Question regarding submitting a request for a
GASP (Generator Site Access Permit) through the State of Utah was also asked.
10/26/23 (1808hrs): RadPros provides answers to questions asked and inquiries about the process for
applying for a GASP permit.
10/27/23 (0954hrs): GASP link provided.
11/3/23 (1406hrs): RadPros receives their GASP from the State of Utah. GASP #2311000504.
11/7/23 (1307hrs): RadPros notified by Director, Technical Services that the non-aqueous request has
been approved and that the waste profile to be updated, and that RadPros should begin preparing for their
shipment in the upcoming week.
11/8/23 (1355hrs): RadPros express interests in having EnergySolutions handle the paperwork/shipping
of the waste with a tentative ship date of November 30th or December 1st 2023.
11/8/23 (1424hrs): Director of Broker & Training Programs made aware of RadPros interests and asked if
there were any available shippers to meet the tentative ship dates.
11/8/23 (1437hrs): Director of Broker & Training Programs confirmed that the Broker is available to
make the shipment on November 30th, 2023, but requests information about the characterization,
packaging, number of packages, and conveyance.
11/20/23 (1241hrs): Director, Technical Services provides calculations based on RadPros calculations and
emails it to the Broker. NOTE: At this time, the number of drums was only for 1 drum, but the Broker
was able to extrapolate the extra data when an additional 4 drums were added to the shipment.

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 5 of 12

11/28/23 (2130hrs): Broker checks into hotel in Denver, Colorado.
11/29/23 (0500hrs): Broker tags along with RadPros employee and travel to facility (Colorado Interstate
Gas Co, LLC).
NOTE: Estimate drive from hotel to facility is ~4hrs (Denver, Colorado to Wamsutter,
Wyoming).
11/29/23 (0900hrs): Broker and RadPros employee arrive at facility.
11/29/23 (0900hrs-1300hrs): Packaging, loading, and securing work commences. Sludge spillage over on
totes identified. Drums also have snow on them.
IA-1: Package not wiped down.
11/29/23 (1400hrs): Broker calls local truck stop to see if they had adhesive spray, none in stock.
11/29/23 (1400hrs-1430hrs): Packages (2 totes & 5 drums) were wiped down with brake cleaner and rags.
11/29/23: (1430hrs): Broker labeled and marked the packages as LSA-II.
IA-2: Shipment labeled and marked as Radioactive-LSA-II instead of DOT-Exempt Quantity.

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 6 of 12

Figure – Photo of loaded package.
IA-3: Adhesive spray not used.
11/29/23 (1500hrs-1530hrs): Tarping of the load commences; the tarp was folded over (2-layers) covering
the packages and was assumed to be tight to prevent air going through the tarp.
11/29/23 (1530hrs): Transporter (South Park Motor Lines) leaves to Clive, Utah.
IA-1 (repeat from above): Package not wiped down.
11/30/23: Shipment # 0637-01-0001 arrives at Clive, Utah and issues identified.

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 7 of 12

Evaluation:
The SOE identified three Inappropriate Actions (IA). Using a “Why Analysis” methodology combined
with interviews and documentation reviews, each IA was further evaluated to determine the underlying
cause:
IA-1: Package not wiped down.
IA-2: Shipment labeled and marked as Radioactive-LSA-II instead of DOT-Exempt Quantity.
IA-3: Adhesive spray not used.
Inappropriate Actions (IA) Analysis
IA-1: Package not wiped down.
During the interviewing effort, the Broker did notice the sludge and snow on the drums but did
not challenge the situation and ensure the facility support POC removed it prior to labeling and
marking and eventually tarping the load.
The underlying cause for this IA is human performance related, specifically, the Broker’s
decision making was less than adequate (LTA) and did not ensure the package appearance was
satisfactory and did not consider the appearance of the sludge to be a concern at the Clive facility
upon arrival. Per ES-BR-PR-002 section 4.2.1.12.4 it states the following: “All affected packages
are wiped as dry as possible before the shipment leaves the site”.
See section 4 for actions taken and to be taken to resolve this cause.
IA-2: Shipment labeled and marked as Radioactive-LSA-II instead of DOT-Exempt Quantity.
During the interviewing effort and documentation review, the Director of Broker & Training
Programs offered the following response to this IA-2; “There is no IP-II compliance package with
the performance test results for the totes. Reference the DOT Subtype calculation results based on
the Characterization Report provided by RadPros (Cleanup Contractor) by Pace Analytical
(Characterization Lab). The results show that the material does not exceed the DOT exempt
quantity limits, thus could and should not have been shipped as DOT regulated LSA-II. If shipped
as non-DOT regulated the totes would not need to meet the IP-II package requirements or be able
to withstand the IP-II performance tests. Manifesting this material as IP-II is an error. Also, an
error, in addition to the incorrect characterization as a DOT regulated LSA-II, the
Characterization Report isotopics provided by RadPros by Pace Analytical did not match the
entry in the Clive Profile. The Characterization Report and associated DOT calculations, showing
that the material could and should have been shipped DOT Exempt Quantity, used the correct
isotopic, but the isotopics identified in the profile and on the shipping papers were in error.
Following is a copy of the email to ES Broker from Director, Technical Services showing the
correct data from RadPros and Pace Analytical that, again did not match the profile or the
shipping papers.” Reference snippet above in 11/20/23 (1241hrs) time entry.

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 8 of 12

Figure - Characterization Report (RadPros/Pace Analytical).
The underlying cause for this IA is human performance related, specifically, in two ES-BR-PR-
002 requirements not being met. First, section 4.1.1 requires the use of “spreadsheets and/or
software programs (i.e., Lowtrack, Radman, EM Waste) used to generate shipping manifest
and/or perform calculations …” Additionally, throughout several sections in ES-BR-PR-002, it
states that “for waste shipments, determine the waste classification using the Waste Classification
Worksheet (Attachment 5.7) or equivalent with approval per step 4.1.1. Per the Broker, he stated
that he did use Lowtrack to determine the waste classification; however, when he was discussing
some items with the Broker Mentor, they came to an agreement to use the waste profile waste
classification that was created in the Customer Portal for Colorado Mines facility. However, after
this event, it was discovered that when the waste profile was setup in the Customer Portal based
on the RadPros characterization report, the Radionuclides was setup slightly higher than the lab
results to account for any potential discrepancies during the sampling efforts. Because of this
decision, in that the lab results were not used for the classification of this shipment it had a
domino effect on the other issues identified with this shipment.
The other cause identified during is that since the Broker did mark and label the package LSA-II,
there was no evidence to indicate that the totes and drums met the IP-2 requirements which would
have been required for the material that meet LSA-II requirements. This is procedure compliance
issue with the requirements defined in ES-BR-PR-002 section 4.1.18.
See section 4 for actions taken and to be taken to resolve this cause.
IA-3: Adhesive spray not used.
During the interviewing effort, the Broker did inform his RadPros point of contact (POC) that
adhesive spray will be needed and if the POC could supply some; however, the POC did not
supply any. Additionally, there were several opportunities to procure adhesive spray on the way
to the facility and prior to labeling and marking the package; however, the Broker did not stop to
procure any adhesive spray. Prior to labeling and marking, the Broker did ask the facility support
POC if there was a local hardware store and was told there is one about an hour away. At that

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 9 of 12

time of the evolution, it was around 1430hrs, and the Broker estimated that if he left to the
hardware store at that time, he would not be back until 1630hrs, and the shipment most likely
would not go out.
Contrary to expectations/requirements, the Broker believed that the labels and markings would
stay on the package for the ~6-hour drive to Clive, Utah. He also did not want to delay the
shipment another day and be required to drive back to his hotel in Denver, Colorado which was
~4 hours away and then come back to the facility the following morning which was another ~4-
hour drive.
The underlying cause for this IA is human performance related, specifically, the Broker did not
stop work and consider the negative impact that could occur by not using adhesive spray to secure
the labels and marking. This particular area is a common practice for all Brokers, both at D&D
sites and field/travelling Brokers.
See section 4 for actions taken and to be taken to resolve this cause.
Conclusion:
All three causes were rolled up into one apparent cause since all three causes were human performance
related, mainly, failure to use appropriate human performance tools and comply with procedure
requirements. However, each issue identified in this shipment could warrant a NOV against the GSAP
Permit #2311000504 on its own.
Apparent Cause:
The Broker’s decision making was less than adequate (LTA) and did not ensure the package
appearance was satisfactory and did not consider the appearance of the sludge to be a concern at
the Clive facility upon arrival. Additionally, the Broker failed to comply with ES-BR-PR-002
section 4.1.1 and 4.1.18 and ensured that the lab results were used for the waste classification;
subsequently, since LSA-II labelling and marking were used the Broker did not verify if the totes
and drums met the IP-2 requirements. Lastly, the Broker did not stop work and consider the
negative impact that could occur by not using adhesive spray to secure the labels and marking.
Training Review
A review of the Broker’s training was conducted to include past shipments prior to this event and
shipments made after this event. The involved Broker was trained and certified on the following training
items:
• Broker Tech Survey Certificate-May 2022
• Broker Week 2 Completion Certificate-May 2022
• IATA Certificate-8 hrs-June 2022
• NRC-DOT Subpart H Certificate-32 hrs-June 2022
• Load Securing CBT Certificate-June 2022
• Hazardous Material Driver’s Training-Aug 2022
• Broker Certificate-December 2022
• Broker Requal Mixed Waste Certificate-November 2023
• Air Transport of RAM CBT Certificate-August 2024

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 10 of 12

Since being trained and certified, the Broker has been performing these duties since January 2023 and has
been working for EnergySolutions since 2022. Prior to this event, the Broker has made ~45 shipments and
most of these were for FSU during the summer of 2023. After this event, the Broker has assisted with 3
ANL shipments.

Apparent Cause Analysis CR 2024-0115 Revision 0
Colorado Mines via RadPros Shipment to Clive Shipment Errors
Page 11 of 12

4.0 Corrective Action(s) to Address Cause(s)
Cause Corrective Action Due Date Owner
Apparent Cause-1:

The Broker’s decision making was less
than adequate (LTA) and did not ensure
the package appearance was satisfactory
and did not consider the appearance of the
sludge to be a concern at the Clive facility
upon arrival. Additionally, the Broker
failed to comply with ES-BR-PR-002
section 4.1.1 and 4.1.18 and ensured that
the lab results were used for the waste
classification; subsequently, since LSA-II
labelling and marking were used the
Broker did not verify if the totes and
drums met the IP-2 requirements. Lastly,
the Broker did not stop work and consider
the negative impact that could occur by
not using adhesive spray to secure the
labels and marking.
CA-1: The Director of Broker & Training Programs implemented ES-
BR-PR-002 section 4.4, Shipping Errors, guidance. Following
additional guidance defined in ES-BR-PR-001 section 4.2.1, Error
Severity Levels, this event meet the criteria to be screened as a Level 4.
Level 4 definition states, “Compliance error that results in a NOV letter
from a regulatory agency.” To obtain additional in-field training, the
Broker has been assigned to work and learn under the Senior Certified
Broker at the Kewaunee D&D site until he becomes more
knowledgeable and experienced.
Completed Mark Lewis
CA-2: Based on the lessons learned from this event, issue a lessons
learned communication to all Brokers covering the inappropriate
actions (IA) that were identified, the underlying causes for each IA,
consequences of event, and reinforce ES-BR-PR-002 requirements that
cover these IAs that if complied with would have prevented these
issues to occur.
4/30/24 Mark Lewis

Apparent Cause Analysis ES-COM-CR-2022-333 Revision 0
Leaking Railcar # FURX322326
Page 12 of 12

5.0 References
1 ES-BR-PR-001, EnergySolutions Broker Program Administration, Revision 7
2 ES-BR-PR-002, Operating Procedure for Brokering of Hazardous Materials, Revision 15
3 ES-AD-PR-008, Condition Reports, Revision 17
4 ES-AD-PR-012, Cause Analysis, Revision 6
5 RadPro GSAP Colorado Interstate Gas Company GSA Permit
6 Radpro 1st Amendment RadPros10.17.2023
7 0617-01-0001 Manifest
8 L1639107_Wamsutter Analytical Report, dated 8/30/2023
9 02c-Colorado Mines Calculation DOT Page
6.0 Personnel Interviewed
• David Carroll, Broker
• Jake Gardner, VP Technical Services
7.0 Attachments/Supporting Documents:
1 NA

Exhibit 7

Condition Report
Corrective Actions
Corrective Actions CR-2024-0115

CAP
Number
Corrective Action Date
Completed
CRA01-
2024-
0478
Implement an employee performance review per ES-BR-
PR-001 with remedial actions. This includes fostering self-
critique and feedback opportunities to enhance
understanding of errors and management expectations
(Exhibit 8).
5/3/2024
CRA01-
2024-
0479
Revise ES-BR-PR-002 to incorporate a Peer Review
Checklist for manifesting paperwork. This checklist will
assist Brokers in completing required tasks and will require
peer checks prior to shipment authorization (Exhibit 2 is the
revised procedure).
6/8/2024
CRA01-
2024-
0480
Implement a Lessons Learned communication to all ES
Brokers, detailing the causes of the event and corrective
actions taken to prevent future violations (Exhibit 10).
4/26/2024

Exhibit 8

Broker Error
Remedial Actions Report
Remedial AcƟons Taken in Response to Level 4 Broker Error
In Accordance with ES-BR-PR-001

Following are the Broker ExecuƟve CommiƩee approved recommended remedial acƟons to be
taken in response to the Level 4 errors made by an EnergySoluƟons CerƟfied Broker while
making a shipment of waste from Colorado Interstate Gas for Radpros. These recommended
acƟons and approval by the Broker CommiƩee are in accordance with ES-BR-PR-001:
 Broker’s qualificaƟons are suspended from the day of Clive’s error noƟce unƟl 45 days
aŌer the remedial OJT experience starts (March 18, 2024). Suspension end date on May
3, 2024 as long as the other following remediaƟon is completed, as well.
 Broker aƩends the next Broker Requal following the error noƟce from Clive and passes
the exam.
 Broker obtains addiƟonal OJT shipping experience by assisƟng a Senior Broker with up to
at least 5 shipments
See aƩached Apparent Cause Analysis for descripƟon of errors resulƟng in the Level 4 error per
procedure ES-BR-PR-001

Exhibit 9

EnergySolutions
Email to Broker Committee
From:Mark Lewis
To:Amanda Moore; Andy Veronee; Bill Carver; Bob Brotemarkle; Clifford Bowers; Dustin T. Newton; Jason Jones;Joshua C. Grubbs; Justin Lee; Larry Conway; Nick Arden; Randall Richardson
Cc:Mike A. Cuarenta; Angie Lott
Subject:YES or NO: Broker Error Remediation Recommendation from the Broker Executive Committee to the GeneralBroker Committee
Date:Thursday, April 18, 2024 3:55:00 PM
Attachments:Apparent Cause Analysis CR 2024-0115 (Colorado Mines via RadPros Shipment to Clive) - Revision 1 Final.pdfError Recommendation.docx
Broker Committee, Attached are the remedial actions recommended by the Broker Executive
Committee and the Apparent Cause Analysis in accordance with CR 2024-0115 recently presented to
and reviewed by the CARB Committee. Please respond with a YES or NO as to your approval of the
recommended remedial actions. If NO, please provide your recommended changes.

Angie, Please keep track of this simple majority vote. When the vote reaches 7, please prepare
Broker Committee meeting minutes for the record.

Thanks, Mark

Mark S Lewis | EnergySolutions | Director of Broker and Training [e-mail] | office: 803.758-1827 | mobile: [phone] | fax: [phone] | www.energysolutions.com
CONFIDENTIALITY NOTICE: The information in this email may be confidential and/or privileged. This email is intended to be reviewedby only the individual or organization named above. If you are not the intended recipient or an authorized representative of the intendedrecipient, you are hereby notified that any review, dissemination or copying of this email and its attachments, if any, or the informationcontained herein is prohibited. If you have received this email in error, please immediately notify the sender by return email and delete
this email from your system.
P Please consider the environment before printing this e-mail

Exhibit 10

Lessons Learned Memo
to all Certified Brokers

M E M O R A N D U M Date: 4/26/2024 To: EnergySolutions Certified Brokers CC: Scott Baskett, SVP Waste Management Strategy, Amanda Moore, Director D&D LLRW Contracts From: Mark Lewis, Director of Broker and Training Programs Subject: Lessons Learned Communication Memo – Broker Errors (ref. CR-2024-0115)

Background: On 11/29/23, ES Broker made a shipment (0637-01-0001) from the Colorado Mines facility to Clive and upon site inspection, the inspector identified multiple shipping errors (i.e., marking stickers were not affixed securely, LSA-II classification used instead of DOT Exempt Quantity, and evidence of waste product on the outside of the packages).
Consequences: The Utah Division of Waste Management and Radiation Control was required to be notified of this discrepancy and the potential consequences of these shipping errors, which is still under review, is a Notice of Violation (NOV) to the GSAP Permit #2311000504.
Analysis Results: The evaluation identified three gaps that were contrary to the Broker procedures and Training, which were (1) package was not wiped down prior to shipment, shipment labeled/marked as Radioactive-LSA-II instead of DOT-Exempt Quantity, and adhesive spray was not used. Conclusion: The Broker’s decision making was less than adequate (LTA) and did not ensure the package appearance was satisfactory and did not consider the appearance of the sludge to be a concern at
the Clive facility upon arrival. Additionally, the Broker failed to comply with ES-BR-PR-002 section 4.1.1 and 4.1.18 and ensured that the lab results were used for the waste classification; subsequently, since LSA-II labelling and marking were used the Broker did not verify if the totes
and drums met the IP-2 requirements. Lastly, the Broker did not stop work and consider the negative impact that could occur by not using adhesive spray to secure the labels and marking.
Lessons Learned: When assigned Brokering duties ensure the following: - Strict compliance with ES-BR-PR-002 is maintained. - Compile all required documentation, equipment, and tools needed prior to departing to the assignment. - The shipment package meets all regulatory requirements and containers used comply
with the labeling and marking requirements. - The package is wiped down and dry as possible before the shipment leaves the site.

- When in doubt, call the Broker Supervisor for guidance, and always have a questioning attitude. - Never allow real- or perceived-time pressure to be your reasoning to get a shipment offsite, the goal is to ship waste in compliance with the regulations not to meet a schedule
deadline. This lessons learned has been added to the three (3) year running table of lessons learned that we
cover during your annual Broker Requal. Be prepared to ask questions and discuss what you would have done to prevent this when you next attend.
Lastly, use this memo to be a reminder that we, EnergySolutions, empower you, the Broker employee to utilize the Stop Work process at any time you see a unsafe condition about to occur or did occur.
Approved By
Mark Lewis, Director of Broker and Training Programs Date