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Home My WebLink AboutDRC-2024-007465 299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 (801) 649-2000 ▪ Fax: (801) 880-2879 ▪ www.energysolutions.com November 5, 2024 CD-2024-228 Mr. Doug Hansen, Director Division of Waste Management and Radiation Control P.O. Box 144880 Salt Lake City, UT 84114-4880 Subject: Radioactive Materials License UT 2300249: Clive Site Radiological Security Plan – Amendment Request Dear Mr. Hansen: EnergySolutions herein requests Revision 5 of its Clive Site Radiological Security Plan be amended as proposed in the attached to correct a minor typographical error in the definition of “Authorized Personnel” that was discovered during routine Quality Assurance Surveillance 2410-009. The redline / strikeout of the amended Clive Site Radiological Security Plan proposes updates to personnel titles revisions and typographical corrections, including the following change in Section 3.0, DEFINITIONS: Authorized Personnel – Personnel with Unescorted/Unrestricted access who have completed training as required by operating procedure CL-TN-PR-100, Clive Facility Training CL-TN-PR-010, General Training Procedure. Please contact me at (801) 649-2000 if you have questions regarding this amendment request. Sincerely, Vern C. Rogers Director of Regulatory Affairs enclosure EnergySolutions Clive Site Radiological Security Plan Revision 65 November 5, 2024May 13, 2016 Table of Contents 1.0 PURPOSE 1 2.0 SCOPE 1 3.0 DEFINITIONS 1 4.0 RESPONSIBILITIES 2 5.0 GENERAL 3 6.0 SECURITY PLAN REQUIREMENTS 3 6.1 SITE ACCESS BOUNDARY CONTROLS 3 6.2 RESTRICTED AREA ACCESS CONTROLS 4 6.3 WASTE ACCESS AREAS CONTROL 5 6.4 RADIOACTIVE MATERIALS QUANTITIES OF CONCERN (RAMQC)5 7.0 REFERENCES 6 8.0 ATTACHMENTS 6 EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 2 of 6 May 13, 2016November 5, 2024 1.0 PURPOSE This plan outlines the required security measures to be implemented at the EnergySolutions Clive facility to prevent radioactive waste material(s) and contaminated equipment from being used within or exiting the facility without authorization. 2.0 SCOPE This plan outlines the security measures in place for the EnergySolutions Clive facilities; with additional measures identified for specific waste access areas within the Bulk Waste Facility (BWF). It requires a multi-layer security model containing specific security controls for site access, Rrestricted Aarea boundary, and overall waste access. This Pplan applies to all personnel who access EnergySolutions Clive facility located within Section 32. 3.0 DEFINITIONS Waste Access Areas Areas where personnel can come in direct contact with un-containerized waste. These areas include the following: 11e.(2), Class A West, and Mixed Waste disposal cells Intermodal Unloading Facility Mixed Waste Treatment Facilities when they contain waste Rail Digging Facility Rotary Dump Facility Rotary Dump FacilityEast Side Rotary Facility  Shredder Access Control Stations The only points (designated areas) established for normal personnel and personal item entrance and egress to and from the Restricted Area. Restricted Area Boundary The perimeter of the Restricted Area that requires access and occupancy control for radiation protection purposes. The Restricted Area boundary is posted “Caution, Radioactive Material” and is bordered by a 6-foot high6-foot-high fence. Controlled Area The area within EnergySolutions’ property that is controlled for purposes other than radiation protection (i.e., security). Un-Containerized Waste Bulk waste that has been unloaded from a transportation container. Debris EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 3 of 6 May 13, 2016November 5, 2024 Debris is material for disposal other than soil. Unloading For the purposes of this Plan, unloading is the removal of unpackaged waste from the container. Authorized Personnel – Personnel with Unescorted/Unrestricted access who have completed training as required by operating procedure CL-TN-PR-100, Clive Facility TrainingCL-TN-PR-010, General Training Procedure. 4.0 RESPONSIBILITIES 1.1 The General Manager of Clive has the ultimate responsibility and accountability for establishing and implementing this Pplan. The General Manager of Clive delegates authority to implement this Plan to the Plant Administration Manager. 1.2 The Manager, Waste Disposal Operations; Manager, Container Management; and Manager, Shipping and Receiving are responsible for the management of all waste handling operations and coordinating resources to implement and ensure compliance with this Plan. 1.3 The Quality Assurance Manager Director or designee is responsible for performing surveillance and/or audit activities to verify implementation and compliance with the requirements of this plan. The Quality Assurance Manager Director is also responsible for administering ES-AD-PR-008, Condition Reports, used to document deficiencies and correctiveCorrective Aactions relating to this Plan. 1.4 The Radiation Safety Officer (RSO) is responsible for providing radiation safety support to the Manager, Waste Disposal Operations; Manager, Container Management; and Manager, Shipping and Receiving in implementing this Plan. The RSO is also responsible for the performance and documentation of radiological inspections and surveys, andsurveys and controlling and monitoring Access Control Points. 4.6 The Plant Administration Manager oversees site security. Security personnel are is responsible for monitoring waste access areas, Restricted Area boundaries and site access areas, and performing random security checks on personnel and vehicles accessing these facilities. 4.7 EnergySolutions Employees and Contractor Personnel are responsible for understanding and enforcing portions of this Plan as applied to their job assignment/work area, andarea and reporting ANY suspicious activity to their supervisor. 4.8 All personnel are responsible for the safe operation of the facility and compliance with this plan. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 4 of 6 May 13, 2016November 5, 2024 5.0 GENERAL While transferring or unloading waste, facility vehicles and equipment shall not be left unattended. Prior to removal from the Restricted Area, all hand and small power tools within the Bulk Waste Facility Rrestricted Aareas shall be uniquely identified and distinguishable from waste material tools delivered to the site for disposal. NOTE:Tools owned by subcontractors or rental equipment used inside the Rrestricted Aareas for special projects, shall be controlled by markings, security seals, security escorts or physical inventories. Individuals assigned as security escorts shall have no other responsibility while performing the assigned task. Facility (Site) security patrols shall be performed seven days a week and twenty-four hours a day. A minimum of three patrols is required within a 24-hour period. Facility (Site) Security patrols will include the following: Random searches Detection of breaches in fencing Detection of any other discrepancy in fencing such as height Detection of unattended vehicles Detection of suspicious items, persons, or activities Detection of unauthorized access by individuals Restricted Area interior security patrols shall be performed when personnel are present within the Restricted Area and will include the following: Random searches Detection of breaches in fencing Detection of any other discrepancy in fencing such as height Detection of unattended vehicles Detection of suspicious items, persons, or activities Detection of unauthorized access by individuals During periods of limited operations such as nights, weekends, holidays, or non-regular working days, Restricted Area interior security patrols shall be performed in those areas only where personnel are present (i.e., Truck Unloading Dock). 6.0 SECURITY PLAN REQUIREMENTS 6.1 Site Access Boundary Controls Visitors to the EnergySolutions Clive site will be directed to the Administration Building via road signs. Prior to being allowed unescorted access beyond the Administration Building, visitors will be briefed on security measures and general risks found at the facility. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 5 of 6 May 13, 2016November 5, 2024 All individuals who access the site will be subject to camera surveillance and random inspections by security personnel. 6.2 Restricted Area Access Controls Activities within the Restricted Area shall be monitored by Security, either by presence or by the use ofusing security cameras. Within 7 calendar days of discovery, Restricted Area fence lines shall be freed from vegetation, equipment, and debris to help security personnel identify unauthorized material or equipment as outlined in CL-SE=-PR-001, Security Operations Protocol. The Restricted Area 6’ chain-link fence shall be considered compromised and require repair if the height from the ground surface to the top of the fence or gate is less than 5’9” as defined in CL-RS-PG-002, Radiological Protection Program. Fencing greater than 6’ tall is acceptable. Any fencing breach or area of inadequate height shall be identified in accordance with CL-SE-PR-001, Security Operations Protocol and repairs tracked on a Condition Report in accordance with operating procedure ES-AD-PR-008, Condition Reports. In addition, any unplanned breach of the restricted area fencing shall require 24-hour verbal notification to the Division of Waste Management and Radiation Control (DWMRC), followed within 7 calendar days by a written report. All material and equipment shall exit the Restricted Area through designated Aaccess Ccontrol Ppoints unless an exception is granted by the RSO. Unless otherwise approved by the RSO, periods of limited operations in accordance with the following paragraph, Radiation Safety personnel shall be present at personnel Access Control Point areas during periods of operation. They shall monitor personnel and other items entering and exiting the Restricted Area. During periods of limited operations such as nights, weekends, holidays, or non- regular working days, Radiation Safety personnel assigned to the Access Control Points may perform monitoring duties within the operational area in addition to duties at the Access Control Point. The Access Control Point shall be locked to prevent outside access if Radiation Safety personnel are not present. Personnel Exiting Restricted Area All personnel must exit the Restricted Area through designated Access Control Points except during a designated emergency or unless an exception is granted by the RSO. Upon request, items inside clothing shall be removed and presented to the Radiation Safety personnel located at the Access Control Point. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 6 of 6 May 13, 2016November 5, 2024 Random security checks shall be performed on personnel exiting the area by Security personnel. Designated and approved Transfer Areas established for relocation of cell construction material, fill material, and Controlled Low-Strength Material (CLSM) into the Rrestricted Aarea shall be monitored by Ssecurity Oofficers and/or security cameras. Transport Containers Exiting the Restricted Area shall be subject to the following: 1.A satisfactory radiological survey shall be completed; and 2.Security seals shall be installed on empty containers exiting the facility. Note: The point of compliance for security seals being present on containers is at the time of transfer out of the Restricted Area. Security seals may fall off or be removed for follow-up inspection from containers that are held in storage outside of Restricted Areas at the Clive facility. The General Manager of Clive, Container Management or applicable Site Manager shall be immediately notified if security seals are found to be breached or of any other suspicious items found during inspections. 6.3 Waste Access Areas Control Security Ppersonnel shall perform documented daily random security searches on personnel and vehicles accessing these areas. Access to the East Side Rotary Facility, West Rotary Facility, Rotary Dump and Intermodal Unloading Facility shall be monitored either by security personnel or security cameras. Only authorized personnel shall be permitted to enter designated waste access areas. Security Oofficers shall conduct physical inspections of designated waste access areas when work is being performed. Any unauthorized individuals or equipment found in these areas without the proper clearance shall be immediately reported to the General Manager of Clive and RSO. 6.4 Radioactive Materials Quantities of Concern (RAMQC) Any aggregated category 1 or category 2 quantity of radioactive material as defined in Utah Administrative Code (UAC) R313-37 (equivalent to 10 CFR 37) will be managed in accordance with this Plan and CL-SE-PR-030, Clive Facility Protection of Radioactive Materials Quantities of Concern (RAMQC). Protection and management of RAMQC includes: Protection of associated information;information. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 7 of 6 May 13, 2016November 5, 2024 Plan and procedure record retention requirements;requirements. Training/refresher training requirements for the Plan and applicable procedures;procedures. Access authorization for Plan review requirements; and Coordination with Local Law Enforcement Agency (LLEA) for response to threats to the facility. 7.0 REFERENCES CL-TN-PR-100, Clive Facility Training ES-AD-PR-008, Condition Reports CL-RS-PG-002, Radiation Protection Program CL-SE-PR-001, Security Operations Protocol CL-SE-PR-030, Clive Facility Protection of Radioactive Materials Quantities of Concern (RAMQC) 10 CFR 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material. 8.0 ATTACHMENTS None 299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 (801) 649-2000 ▪ Fax: (801) 880-2879 ▪ www.energysolutions.com EXHIBIT A Clive Site Radiological Security Plan Proposed revision 6 in Redline / Strikeout (November 5, 2024) EnergySolutions Clive Site Radiological Security Plan Revision 65 November 5, 2024May 13, 2016 Table of Contents 1.0 PURPOSE ..................................................................................................................................................... 1 2.0 SCOPE .......................................................................................................................................................... 1 3.0 DEFINITIONS ............................................................................................................................................. 1 4.0 RESPONSIBILITIES .................................................................................................................................. 2 5.0 GENERAL ................................................................................................................................................. 43 6.0 SECURITY PLAN REQUIREMENTS ................................................................................................... 43 6.1 SITE ACCESS BOUNDARY CONTROLS ......................................................................................................... 43 6.2 RESTRICTED AREA ACCESS CONTROLS .................................................................................................... 54 6.3 WASTE ACCESS AREAS CONTROL ............................................................................................................. 65 6.4 RADIOACTIVE MATERIALS QUANTITIES OF CONCERN (RAMQC) .......................................................... 65 7.0 REFERENCES .......................................................................................................................................... 76 8.0 ATTACHMENTS ...................................................................................................................................... 76 EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 1 of 6 May 13, 2016November 5, 2024 1.0 PURPOSE This plan outlines the required security measures to be implemented at the EnergySolutions Clive facility to prevent radioactive waste material(s) and contaminated equipment from being used within or exiting the facility without authorization. 2.0 SCOPE This plan outlines the security measures in place for the EnergySolutions Clive facilities; with additional measures identified for specific waste access areas within the Bulk Waste Facility (BWF). It requires a multi-layer security model containing specific security controls for site access, Rrestricted Aarea boundary, and overall waste access. This Pplan applies to all personnel who access EnergySolutions Clive facility located within Section 32. 3.0 DEFINITIONS Waste Access Areas Areas where personnel can come in direct contact with un-containerized waste. These areas include the following:  11e.(2), Class A West, and Mixed Waste disposal cells  Intermodal Unloading Facility  Mixed Waste Treatment Facilities when they contain waste  Rail Digging Facility  Rotary Dump Facility  Rotary Dump FacilityEast Side Rotary Facility   Shredder Access Control Stations The only points (designated areas) established for normal personnel and personal item entrance and egress to and from the Restricted Area. Restricted Area Boundary The perimeter of the Restricted Area that requires access and occupancy control for radiation protection purposes. The Restricted Area boundary is posted “Caution, Radioactive Material” and is bordered by a 6-foot high6-foot-high fence. Controlled Area The area within EnergySolutions’ property that is controlled for purposes other than radiation protection (i.e., security). Un-Containerized Waste Bulk waste that has been unloaded from a transportation container. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 2 of 6 May 13, 2016November 5, 2024 Debris Debris is material for disposal other than soil. Unloading For the purposes of this Plan, unloading is the removal of unpackaged waste from the container. Authorized Personnel – Personnel with Unescorted/Unrestricted access who have completed training as required by operating procedure CL-TN-PR-100, Clive Facility TrainingCL-TN-PR-010, General Training Procedure. 4.0 RESPONSIBILITIES 4.1 The General Manager of Clive has the ultimate responsibility and accountability for establishing and implementing this Pplan. The General Manager of Clive delegates authority to implement this Plan to the Plant Administration Manager. 4.2 The Manager, Waste Disposal Operations; Manager, Container Management; and Manager, Shipping and Receiving are responsible for the management of all waste handling operations and coordinating resources to implement and ensure compliance with this Plan. 4.3 The Quality Assurance Manager Director or designee is responsible for performing surveillance and/or audit activities to verify implementation and compliance with the requirements of this plan. The Quality Assurance Manager Director is also responsible for administering ES-AD-PR-008, Condition Reports, used to document deficiencies and correctiveCorrective Aactions relating to this Plan. 4.4 The Radiation Safety Officer (RSO) is responsible for providing radiation safety support to the Manager, Waste Disposal Operations; Manager, Container Management; and Manager, Shipping and Receiving in implementing this Plan. The RSO is also responsible for the performance and documentation of radiological inspections and surveys, andsurveys and controlling and monitoring Access Control Points. 4.6 The Plant Administration Manager oversees site security. Security personnel are is responsible for monitoring waste access areas, Restricted Area boundaries and site access areas, and performing random security checks on personnel and vehicles accessing these facilities. 4.7 EnergySolutions Employees and Contractor Personnel are responsible for understanding and enforcing portions of this Plan as applied to their job assignment/work area, andarea and reporting ANY suspicious activity to their supervisor. Formatted: Font: Italic EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 3 of 6 May 13, 2016November 5, 2024 4.8 All personnel are responsible for the safe operation of the facility and compliance with this plan. Formatted: Font: Not Bold EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 4 of 6 May 13, 2016November 5, 2024 5.0 GENERAL While transferring or unloading waste, facility vehicles and equipment shall not be left unattended. Prior to removal from the Restricted Area, all hand and small power tools within the Bulk Waste Facility Rrestricted Aareas shall be uniquely identified and distinguishable from waste material tools delivered to the site for disposal. NOTE: Tools owned by subcontractors or rental equipment used inside the Rrestricted Aareas for special projects, shall be controlled by markings, security seals, security escorts or physical inventories. Individuals assigned as security escorts shall have no other responsibility while performing the assigned task. Facility (Site) security patrols shall be performed seven days a week and twenty-four hours a day. A minimum of three patrols is required within a 24-hour period. Facility (Site) Security patrols will include the following:  Random searches  Detection of breaches in fencing  Detection of any other discrepancy in fencing such as height  Detection of unattended vehicles  Detection of suspicious items, persons, or activities  Detection of unauthorized access by individuals Restricted Area interior security patrols shall be performed when personnel are present within the Restricted Area and will include the following:  Random searches  Detection of breaches in fencing  Detection of any other discrepancy in fencing such as height  Detection of unattended vehicles  Detection of suspicious items, persons, or activities  Detection of unauthorized access by individuals During periods of limited operations such as nights, weekends, holidays, or non-regular working days, Restricted Area interior security patrols shall be performed in those areas only where personnel are present (i.e., Truck Unloading Dock). 6.0 SECURITY PLAN REQUIREMENTS 6.1 Site Access Boundary Controls Visitors to the EnergySolutions Clive site will be directed to the Administration Building via road signs. Prior to being allowed unescorted access beyond the Administration Building, visitors will be briefed on security measures and general risks found at the facility. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 5 of 6 May 13, 2016November 5, 2024 All individuals who access the site will be subject to camera surveillance and random inspections by security personnel. 6.2 Restricted Area Access Controls Activities within the Restricted Area shall be monitored by Security, either by presence or by the use ofusing security cameras. Within 7 calendar days of discovery, Restricted Area fence lines shall be freed from vegetation, equipment, and debris to help security personnel identify unauthorized material or equipment as outlined in CL-SE=-PR-001, Security Operations Protocol. The Restricted Area 6’ chain-link fence shall be considered compromised and require repair if the height from the ground surface to the top of the fence or gate is less than 5’9” as defined in CL-RS-PG-002, Radiological Protection Program. Fencing greater than 6’ tall is acceptable. Any fencing breach or area of inadequate height shall be identified in accordance with CL-SE-PR-001, Security Operations Protocol and repairs tracked on a Condition Report in accordance with operating procedure ES-AD-PR-008, Condition Reports. In addition, any unplanned breach of the restricted area fencing shall require 24-hour verbal notification to the Division of Waste Management and Radiation Control (DWMRC), followed within 7 calendar days by a written report. All material and equipment shall exit the Restricted Area through designated Aaccess Ccontrol Ppoints unless an exception is granted by the RSO. Unless otherwise approved by the RSO, periods of limited operations in accordance with the following paragraph, Radiation Safety personnel shall be present at personnel Access Control Point areas during periods of operation. They shall monitor personnel and other items entering and exiting the Restricted Area. During periods of limited operations such as nights, weekends, holidays, or non- regular working days, Radiation Safety personnel assigned to the Access Control Points may perform monitoring duties within the operational area in addition to duties at the Access Control Point. The Access Control Point shall be locked to prevent outside access if Radiation Safety personnel are not present. Personnel Exiting Restricted Area All personnel must exit the Restricted Area through designated Access Control Points except during a designated emergency or unless an exception is granted by the RSO. Upon request, items inside clothing shall be removed and presented to the Radiation Safety personnel located at the Access Control Point. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 6 of 6 May 13, 2016November 5, 2024 Random security checks shall be performed on personnel exiting the area by Security personnel. Designated and approved Transfer Areas established for relocation of cell construction material, fill material, and Controlled Low-Strength Material (CLSM) into the Rrestricted Aarea shall be monitored by Ssecurity Oofficers and/or security cameras. Transport Containers Exiting the Restricted Area shall be subject to the following: 1. A satisfactory radiological survey shall be completed; and 2. Security seals shall be installed on empty containers exiting the facility. Note: The point of compliance for security seals being present on containers is at the time of transfer out of the Restricted Area. Security seals may fall off or be removed for follow-up inspection from containers that are held in storage outside of Restricted Areas at the Clive facility. The General Manager of Clive, Container Management or applicable Site Manager shall be immediately notified if security seals are found to be breached or of any other suspicious items found during inspections. 6.3 Waste Access Areas Control Security Ppersonnel shall perform documented daily random security searches on personnel and vehicles accessing these areas. Access to the East Side Rotary Facility, West Rotary Facility, Rotary Dump and Intermodal Unloading Facility shall be monitored either by security personnel or security cameras. Only authorized personnel shall be permitted to enter designated waste access areas. Security Oofficers shall conduct physical inspections of designated waste access areas when work is being performed. Any unauthorized individuals or equipment found in these areas without the proper clearance shall be immediately reported to the General Manager of Clive and RSO. 6.4 Radioactive Materials Quantities of Concern (RAMQC) Any aggregated category 1 or category 2 quantity of radioactive material as defined in Utah Administrative Code (UAC) R313-37 (equivalent to 10 CFR 37) will be managed in accordance with this Plan and CL-SE-PR-030, Clive Facility Protection of Radioactive Materials Quantities of Concern (RAMQC). Protection and management of RAMQC includes:  Protection of associated information;information. EnergySolutions, LLC Clive Site Radiological Security Plan Revision 65 Page 7 of 6 May 13, 2016November 5, 2024  Plan and procedure record retention requirements;requirements.  Training/refresher training requirements for the Plan and applicable procedures;procedures.  Access authorization for Plan review requirements; and  Coordination with Local Law Enforcement Agency (LLEA) for response to threats to the facility. 7.0 REFERENCES CL-TN-PR-100, Clive Facility Training ES-AD-PR-008, Condition Reports CL-RS-PG-002, Radiation Protection Program CL-SE-PR-001, Security Operations Protocol CL-SE-PR-030, Clive Facility Protection of Radioactive Materials Quantities of Concern (RAMQC) 10 CFR 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material. 8.0 ATTACHMENTS None