DRC-2024-007563

CLIVE SITE
LETTER OF TRANSMITTAL

DATE: 11/14/2024
ATTN: LLRW
CC; Treesa Parker
Karen Kirkwood
RE: Transmittal 2024-083

Description of Documents Transmitted Qty

See attached for update to Environmental.

CL-EV-PR-012 Rev 5, Area Radiation and Radon Thoron Monitoring 1

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Please replace your current procedure revisions with the documents within this Transmittal.

You are not required to sign any documents to verify receipt of this distribution. However, you
should make every effort to ensure that your copy of the License is current.

FROM: EnergySolutions
Document Control
Clive Facility

Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-EV-PR-012

Area Radiation and
Radon/Thoron Monitoring
Revision 5

Authored By:
Jason Hill, Environmental Technician III Date
Reviewed By:
Vern C. Rogers, Director of Regulatory Affairs Date
Approved By
Thomas A. Brown, Radiation Safety Officer Date
Approved By
Vern C. Rogers, Director of Regulatory Affairs Date

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

Jason Hill Digitally signed by Jason Hill
DN: dc=com, dc=energysolutions, ou=North America, ou=Users,
ou=CLUT, cn=Jason Hill, email=[e-mail]
Date: 2024.11.12 16:15:39 -07'00'
Vern C. Rogers Digitally signed by Vern C. Rogers
DN: cn=Vern C. Rogers, o=EnergySolutions, ou=Waste Management
Division, email=[e-mail], c=US
Date: 2024.11.12 18:12:26 -07'00'
Digitally signed by Thomas BrownDN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown,
E=[e-mail]
Reason: I am approving this document
Location: Clive
Date: 2024-11-14 06:56:33Foxit PhantomPDF Version: 9.7.5
Thomas Brown
Vern C. Rogers Digitally signed by Vern C. Rogers
DN: cn=Vern C. Rogers, o=EnergySolutions, ou=Waste
Management Division, email=[e-mail], c=US
Date: 2024.11.12 18:13:03 -07'00'
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Table of Contents

1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose........................................................................................................................... 3
1.2 Scope............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 4
3.1 Definitions ...................................................................................................................... 4
3.2 Responsibilities .............................................................................................................. 5
3.3 Precautions and Limitations ........................................................................................ 7
3.4 Records........................................................................................................................... 9
4 REQUIREMENTS AND GUIDANCE .................................................................................. 9
5 ATTACHMENTS AND FORMS......................................................................................... 13

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1 PURPOSE AND SCOPE
1.1 Purpose
This procedure identifies the requirements and methods for the use of Mirion,
Landauer or equivalent (referred to hereafter as dosimeters) to determine average
radiation levels and Landauer RadTrak2®, Radonova Rapidos®, or equivalent
radon detectors (referred to hereafter as radon detectors) to monitor radon-222
(radon) and radon-220 (thoron) in an area over extended periods.
1.2 Scope
This procedure focuses on the field activities related to the use of and record
requirements for dosimeters for area radiation monitoring and radon detectors for
monitoring radon and thoron. It is written specifically for activities required by
the Environmental Monitoring Plan (as required by Radioactive Material Licenses
UT2300249 and UT2300478) but may also be used for any activity where the
dosimetry is read by the dosimetry supplier. The procedure excludes management
and tracking of dosimeters or radon detectors after they are transferred to a vendor
or the Dosimetry Specialist, as documented using a chain-of-custody.
2 REFERENCES
2.1 CL-LB-PR-003, Sample Control, As Revised.
2.2 Environmental Monitoring Plan, , As Revised.
2.3 Gollnick, D.A, Basic Radiation Protection Technology, Pacific Radiation
Corporation, Altadena, CA, Fourth Edition.
2.4 Application for 11e.(2) Radioactive Materials License, Section 17,
EnergySolutions, LLC, Salt Lake City, Utah, As Revised.
2.5 Brochure: Radtrak2® Alpha Track Radon Detector Specifications, Landauer,
Inc., Westmont, Illinois, As Revised.
2.6 Brochure: Rapidos® A High-Sensitivity Detector Specifications, Landauer, Inc.,
Westmont, Illinois, As Revised.
2.7 Pearson D. & Spangler R., Calibration of -Track Monitors for Measurement of
Thoron (220Rn), Health Physics Vol. 60, No. 5, pp 697-701, 1991.
2.8 CL-AD-PR-004, Document Preparation, Control, Distribution, Interim Storage,
and Destruction, As Revised.
2.9 CL-RS-PG-001, ALARA Program, As Revised.
2.10 CL-RS-PG-002, Radiation Protection Program, As Revised.
2.11 ES-AD-PR-008, Condition Reports, As Revised.

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3 GENERAL
3.1 Definitions
3.1.1 Background Radiation – refers to the natural radiation that constantly
exists in the environment. This includes cosmic radiation from the sun and
stars, terrestrial radiation from the Earth, and internal radiation found in all
living organisms. Background radiation represents the portion of the total
radiation dose measured from non-licensed sources, typically recorded
using a dosimeter.
3.1.2 Collected - The act of removing a dosimeter from the intended monitoring
location.
3.1.3 Control Dosimeter - A dosimeter identified by the vendor to be used for
determining the exposure from background radiation.
3.1.4 Custodian – A person who is responsible to secure by custody seal and
other means of physical security the integrity of a dosimeter.
3.1.5 Custody - A condition where a person can ensure the integrity of a
dosimeter by direct observation, by physically securing the sample using a
lock and key, or by using a custody seal.
3.1.6 Custody Seal - A custody seal is a physical barrier designed to indicate
any unauthorized access to a dosimeter. When applied correctly, custody
seals can substitute for continuous physical possession by securing sample
containers, collection bags, or shipping containers in a way that prevents
opening without breaking the seal. These seals should be made from
durable material suited to expected conditions but must visibly show
damage if accessed, ensuring the integrity of the sample.
3.1.7 Duplicate - A quality control method used to verify measurement
precision. More than one dosimeter is placed at the same location, so they
receive the same radiation exposure. The dosimeter and the duplicate
results are compared, and the difference is used to verify the reliability of
the monitoring method.
3.1.8 Exposed Dosimeters - A designation used to identify dosimeters that have
been exposed to radiation for the purpose of determining the radiation
exposure in an area over a specified period.
3.1.9 Exposed Detectors - A designation used to identify radon detectors that
have been used to measure radon/thoron exposure.
3.1.10 In Use - The condition of a dosimeter when it is being used to monitor the
radiation exposure at its intended location. The in-use period begins when
the dosimeter is placed and ends when the dosimeter is collected.
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3.1.11 Optically Stimulated Luminescence (OSL) – A technology for assessing
personal dose using aluminum oxide doped with carbon material
manufactured by Landauer.
3.1.12 Pouch - The bag used by Landauer to seal radon detection devices. Radon
detection devices received from Landauer are sealed inside a pouch. The
devices start measuring the radon/thoron concentrations in the surrounding
environment after the pouch seal is breached.
3.1.13 Placed - The act of setting a dosimeter or radon detector at its intended
monitoring location.
3.1.14 Reporting Threshold - The ratio of the measured exposure rate to the
regulatory exposure limit. In cases where multiple measured exposure
rates must be combined to calculate a ratio against the regulatory exposure
limit, the ratio shall be calculated with available measured exposures
(even if not all required exposure rates are known at the time of ratio
calculation). For example, the ratio of Deep Dose Equivalent or
Committed Effective Dose Equivalent can be used to calculate a reporting
threshold with the 100 mrem/year Total Effective Dose Equivalent limit
promulgated in Utah Administrative Code R313-15-301. When this
threshold reaches or exceeds 0.75 (i.e., 75% of the regulatory exposure
limit), a Condition Report shall be generated to assess options for reducing
the measured exposure rate, aiming to prevent any potential exceedance of
the regulatory exposure limit.
3.1.15 Sealed - A condition where air is not permitted to migrate into the radon
device.
3.2 Responsibilities
3.2.1 Radiation Safety Officer (RSO) or designee shall:
3.2.1.1 Identify approved sampling locations as specified in the
Environmental Monitoring Plan or other necessary locations.
Direct the placement of dosimeters and radon detectors to
measure exposure to external radiation or airborne radon gas
inhalation near the fence boundary surrounding waste
management areas. Document and archive this information
accordingly.
3.2.1.2 Review and report dosimeter and radon detector results related to
CL-RS-PG-001, ALARA Program, CL-RS-PG-002, Radiation
Protection Program, the Environmental Monitoring Plan, and the
Radiation Control program monitoring requirements.
3.2.1.3 Generate a Condition Report when any Reporting Threshold is
equal to or exceeds 0.75 to assess options for reducing the
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measured exposure rate, aiming to prevent any potential
exceedance of the regulatory exposure limit.
3.2.2 Environmental Monitoring Technician shall:
3.2.2.1 Report to and work under the authority of the Clive Facility
Groundwater and Environmental Monitoring Program Manager.
3.2.2.2 Communicate directly with the dosimeter or radon detector
vendor. Communication shall include ordering unused
dosimeters and radon detectors, receiving and shipping,
managing associated administrative requirements, and receiving
monitoring reports.
3.2.2.3 Ensure that Environmental Monitoring dosimetry and radon
detector orders are submitted to the vendor.
3.2.2.4 Notify the Clive Facility Groundwater and Environmental
Monitoring Program Manager when shipments containing
Environmental Monitoring dosimeters and radon detectors are
received.
3.2.2.5 Inspect dosimeters and radon detector shipments upon receipt.
3.2.2.6 Place dosimeters and radon detectors at locations identified by
the RSO.
3.2.2.7 Package and ship exposed dosimeters and radon detectors to
vendor.
3.2.2.8 Timely provide Environmental Monitoring related reports to the
Clive Facility Groundwater and Environmental Monitoring
Program Manager.
3.2.2.9 Request raw data reports from dosimeter and radon detector
vendors, as required.
3.2.2.10 Record the placement location and unique dosimeter or radon
detector identification numbers into the vendors electronic form,
prior to placement.
3.2.2.11 Identify duplicate sample locations.
3.2.2.12 Place dosimeters and radon detectors.
3.2.2.13 Ship unexposed dosimeters for Gamma Spike test.
3.2.2.14 Ship unexposed radon detectors for Radon Spike test.
3.2.2.15 Verify the logs are complete and accurate, then sign and date.
3.2.2.16 Transmit completed logs to the Clive Facility Groundwater and
Environmental Monitoring Program Manager.
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3.2.3 Clive Facility Groundwater and Environmental Monitoring Program
Manager shall:
3.2.3.1 Provide order information to the Environmental Monitoring
Technician.
3.2.3.2 Review and sign the dosimeter and radon detector field
placement logs after verifying they are complete and accurate.
3.2.3.3 Review and report dosimeter and radon detector results,
assemble Reporting Threshold ratios for measured dosimeter
results, promptly reporting Report Threshold ratios and
dosimeter results to the RSO, including highlight of any findings
that indicate potential upward trends, Reporting Threshold
exceeding or equal to 0.75, or non-compliance with dose limits
established in the Environmental Monitoring Plan, ALARA
Program, or Radiation Protection Program.
3.2.3.4 Direct special sampling, as needed.
3.2.3.5 Maintain an adequate radon detector inventory to meet
Environmental Monitoring Plan requirements.
3.3 Precautions and Limitations
3.3.1 Specifically required radiation and radon and thoron monitoring locations
and quality assurance requirements are established in the Environmental
Monitoring Plan. Radiation and radon and thoron monitoring may be
required at additional locations as directed by the Clive Facility
Groundwater and Environmental Monitoring Program Manager or the
RSO. Additional location will be documented per CL-AD-PR-004.
3.3.2 Dosimeters and radon detectors shall be shipped and stored in a manner
that prevents premature exposure, (such as by sealed plastic pouch – as
conducted by Landauer).
3.3.3 After a dosimeter has been placed and exposed to external radiation, the
results include radiation from the area being monitored and background
radiation. Unexposed dosimeters are used as controls to identify exposure
received when the dosimeter is not in use. For this reason, dosimeters
awaiting exposure shall be stored with control dosimeters prior to and
after use.
3.3.4 Radon detectors begin measuring radon and thoron when the seal on the
pouch is breached. Detectors shall be placed for monitoring within one
hour after the seal is breached. Failure to place radon detectors within one
hour after seal is broken shall be documented in the comment section of
the log. Document the date, time and reason the pouch was breached
greater than one hour before being put in place.
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3.3.5 The dosimeter or radon detector number shall be confirmed at time of
placement and again when it is collected, to ensure the log is correct.
Confirmation is done by either the use of the lab’s online tracking system
or a lab provided checklist.
3.3.6 When collected, radon detectors shall be placed in a common zip top bag
to inhibit further migration of radon and thoron into the device. Detectors
collected following exposure shall be returned within 4 days after the
device is collected.
3.3.7 Radon detectors shall be protected from unnecessary exposure to moisture.
Radon detectors with visible water or other damage shall be removed from
service and the measured exposure from these devices excluded from
subsequent analysis and reporting.
3.3.8 Only radon detectors specifically authorized by the Environmental
Monitoring Plan shall be employed.
3.3.9 Radonova Rapidos® detector shall only be used for monitoring required
by the Environmental Monitoring Plan.
3.3.10 Radonova Rapidos® and Landauer RadTrak2® detectors may be used for
supplemental occupational monitoring in the Restricted Area (under the
RSO’s direction).
3.3.11 Abnormal conditions that may affect the radon detector readings shall be
noted in the radon detector log.
3.3.12 All dosimeters used during a given monitoring period shall be returned
together in the same shipment to supplier.
3.3.13 Dosimeter shipments should be received, inspected, and inventoried early
enough to provide time to correct errors before the dosimeters need to be
placed.
3.3.14 Radon detectors shall not be placed after the expiration date.
3.3.15 Exposed radon detectors shall be controlled using Form EC-0101E
(Chain-of-Custody). A chain-of-custody shall be filled out prior to
relinquishing custody to someone other than the person collecting the
sample or to another lab. Associated Chain-of-Custody requirements are
listed in Section 4.4.
3.3.16 The number of dosimeters ordered each quarter should consider the
number of locations specified in the Environmental Monitoring Plan, the
number of dosimeters needed for spike and duplicate testing, and
dosimeters for any additional location required by the RSO.

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3.4 Records
3.4.1 RSO directives shall be documented in a memo having an assigned
correspondence number. The last directive will supersede previous
directives, so only one document needs to be referenced to determine the
RSO-directed radon detection monitoring locations for any given quarter.
The correspondence number for the active RSO directive shall be recorded
on the last sheet of the radon detector log each quarter. Additional location
will be documented per CL-AD-PR-004.
3.4.2 Radon Detector/OSL Log, Form # CL-EV-PR-012-F1 shall be used to
record detector and dosimeter monitoring information.
3.4.3 The gamma spike test shall be documented using Form # CL-EV-PR-012-
F2.
3.4.4 A new log shall be started each Quarter. The Quarter/Year and the page
number shall be written on each page before use.
3.4.5 Radon detector logs and chain-of-custody documents shall be submitted to
Document Control for archiving within 30 days after the final signature.
3.4.6 Duplicate samples shall be recorded in sequential order as D-1, D-2, D-
3…. The actual location shall be recorded in the comment section of the
log. The actual location of the duplicate sample shall not be disclosed to
Landauer until after the radon detector results have been reported.
4 REQUIREMENTS AND GUIDANCE
4.1 Shipment Receipt
4.1.1 Verify there is no visual damage to dosimeters and detectors.
4.1.2 Compare the packing list, purchase requisition, and content to ensure the
correct number of dosimeters or radon detectors, were sent. Confirmation
is done by either the use of the lab’s online tracking system or a lab
provided checklist.
4.1.3 Upon receipt of radon detectors, assign them to their locations and mark
them on the outside of the pouch. Use the Contract number and password
provided in the shipping paperwork to log onto the vendor website. Fill
in the form with the location and dosimeter ID’s. Leave the time and date
blank for now. Mark the shipping paperwork with the Quarter/Year and
keep in a safe place. Keep this paperwork with the log after the detectors
have been collected. Fill out the new CL-EV-PR-012 F1 with the
dosimeter ID’s.
4.2 Dosimeter Placement
Note: Dosimeter and detector placement and collection may be done
concurrently.
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4.2.1 Open monitoring enclosure, if required.
4.2.2 Record or confirm the location is correctly identified on the log.
4.2.3 Verify the dosimeter or detector number are next to the appropriate
location on the log.
4.2.4 Open the seal on the pouch, if necessary.
4.2.5 Withdraw the radon detector from pouch and record the start date and time
next to the appropriate location on the log.
4.2.6 Write the location on the detector using a visible marker.
Note: Radon detectors should be placed within one hour of breaking
the seal on the pouch.
4.2.7 Place the dosimeter or detector.
4.2.8 Close and lock monitoring enclosure, if required.
4.3 Dosimeter and Detector Collection
4.3.1 Open monitoring enclosure, if required.
4.3.2 Collect dosimeter or radon detector from enclosure or location.
4.3.3 Confirm the identification number on the side of the dosimeter or as
inscribed on the radon detector with the number recorded in the log.
4.3.4 Record the collection date, time, and initial in the log.
4.3.5 Close and lock monitoring enclosure, if required.
4.4 Chain of Custody Requirements
4.4.1 Exposed dosimeters and detectors must remain in the custody of the
individual collecting the sample until they are relinquished. Alternatively,
the dosimeters or detectors should be secured with a custody seal or stored
in a secure location until shipment.
Note: Only one person at any time may have custody of a dosimeter
or detector.
4.4.2 Form EC-0101E documentation instruction:
4.4.2.1 Custody Holder: The person collecting the dosimeter or
detector. If the dosimeter or detector is being transferred from
another chain-of-custody it is the person receiving the dosimeter
or detector.
4.4.2.2 Sampling Team: Person(s) collecting the dosimeters or
detectors.
4.4.2.3 Field Logbook Page No.(s): Record “Radon Detector/OSL Log”
with the applicable Quarterly sampling period and year.
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4.4.2.4 Sample ID: List the identification listed on the dosimeter or
detector.
4.4.2.5 Description: If the monitoring location is different from the
dosimeter or detector identification, record the sample location.
If the dosimeter or detector was used as a duplicate, record the
duplicate number (i.e., D-1, D-2, D-3…). This blank may also
be used to record details related to a single dosimeter.
Note: To prevent disclosing the monitoring location of
duplicate quality control measurements do not record the
location of duplicate samples on the chain-of-custody form.
4.4.2.6 Date and Time: Identify the date and time a dosimeter or
detector is collected or transferred from another chain-of-
custody. A single related date and time (e.g., the date and time
the chain-of-custody document was written, the sampling event
start, or sampling event stop date and time) may be used for all
rows.
4.4.2.7 Relinquished To COC: List the chain-of-custody number where
the dosimeter or detector is being transferred.
4.4.2.8 Received from COC: List the chain-of-custody where the
dosimeter or detector is being transferred from.
4.4.2.9 Transfer Initial Date/Time: The date and time when a sample
was transferred to a different chain-of-custody and the initial of
the person removing or accepting responsibility for the dosimeter
or detector.
4.4.2.10 To transfer the chain of custody to another individual:
4.4.2.10.1 Sign the “Relinquished By” blank.
4.4.2.10.2 The person accepting the chain-of-custody; verifies
the dosimeters or detector with the chain-of-
custody, signs in the corresponding “Received By”
blank, and enters the transfer date and time in the
“Date/Time” blank.
4.4.3 Seal the radon detectors and a copy of the chain of custody and a copy of
the detector log in a bag using a tamper proof seal for shipment.
4.4.4 Place the sealed radon detectors in the box for shipment. Ship box
containing the detectors to the address of record for the supplier.
4.4.5 A supplier employee shall sign the “Received by” section and return a
copy of the chain-of-custody to document that they have custody of the
listed radon detectors.
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4.4.6 The corresponding incomplete chain-of custody shall be replaced with the
chain-of-custody returned by the supplier.
4.5 Gamma Radiation Spike Test
4.5.1 Collect dosimeters for spike test and one control dosimeter. The control
dosimeter is used to verify the gamma exposure to the spike test
dosimeters from sources other than the spike test.
4.5.2 Record the dosimeter numbers in Radon Detector/OSL Log (CL-EV-PR-
012-F1), and Gamma Spike Test (CL-EV-PR-012-F2).
4.5.3 Ensure that the dosimeter used as the control dosimeter is adequately
labeled.
4.5.4 Record the dosimeter information (Id#, Spike/Control, and Device type)
on Form CL-EV-PR-012-F1.
4.5.5 Record the requested exposure on Forms CL-EV-PR-012-F2.
4.5.6 Deliver or ship dosimeters with Form CL-EV-PR-012-F2 for gamma
exposure.
Note: The distance from the source to the detector's effective center
during exposure must be at least seven times the larger of the source’s
or detector’s maximum dimension. The OSL should be secured to
prevent movement, with its face directed toward the radioactive
source during the gamma spike exposure. After exposure, ensure that
the "Source," "Exposure," "Exposure Calculation," "Performed by,"
"Organization," and "Date" sections of Form CL-EV-PR-012-F2 are
completed.
4.5.7 Return dosimeter to have them read by the applicable organization.
4.6 Radon Detector Spike Test
4.6.1 Select four sealed radon detectors and verify pouch is sealed.
4.6.2 Record the detector number on log with spike information.
4.6.3 Seal and address package
4.6.4 Ship the package to the radon spike test facility.
4.7 Compliance with Regulatory Exposure Limits
4.7.1 The Reporting Threshold shall be calculated each time new measured
exposure rates become available. When not all measured exposure rates
are available for comparison with regulatory exposure limits, a partial
Reporting Threshold shall be calculated as a ratio of the incomplete
measured exposure rates against the regulatory exposure limit. For
example, the ratio of Deep Dose Equivalent or Committed Effective Dose
Equivalent can be used to calculate a reporting threshold with the 100
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mrem/year Total Effective Dose Equivalent limit promulgated in Utah
Administrative Code R313-15-301.
4.7.2 When this threshold reaches or exceeds 0.75 (i.e., 75% of the regulatory
exposure limit), a Condition Report shall be generated to assess options
for reducing the measured exposure rate, aiming to prevent any potential
exceedance of the regulatory exposure limit.
5 ATTACHMENTS AND FORMS
5.1 CL-EV-PR-012-F1 Radon /Gamma Log (Example)
5.2 CL-EV-PR-012-F2 Gamma Spike Test (Example)

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Attachment 5.1 – Radon /Gamma Log, CL-EV-PR-012-F1

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Attachment 5.1 – Radon /Gamma Log, CL-EV-PR-012-F1 cont.

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Attachment 5.2 - Gamma Spike Test, CL-EV-PR-012-F2

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