DRC-2025-000019

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 12/31/2024 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2024-089
Description of Documents Transmitted Qty
See attached for update to Radiation Safety. CL-RS-PG-001, ALARA Program Rev. 18 1 ------------------------------------------------------------------------------------------------------------ Please replace your current procedure revisions with the documents within this Transmittal. You are not required to sign any documents to verify receipt of this distribution. However, you should make every effort to ensure that your copy of the License is current. FROM: EnergySolutions Document Control
Clive Facility
Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-RS-PG-001
EnergySolutions
Clive ALARA Program
Submitted By:
Thomas A. Brown, Radiation Safety Officer (RSO)
Concurrence
By RSC:
Brennon Dick, Operations Manager
Approved By
David F. Booth, General Manager
Date:
Revision: 18
12/30/2024
Digitally signed by Thomas Brown
DN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown, E=[e-mail]
Reason: I am approving this documentLocation: Clive
Date: 2024-12-30 10:44:20Foxit PhantomPDF Version: 9.7.5
Thomas Brown
Brennon Dick Digitally signed by Brennon Dick
Date: 2024.12.31 07:59:17 -07'00'
Adobe Acrobat version: 2024.005.20320
Digitally signed by David F Booth
DN: C=US, O=EnergySolutions, CN=David F Booth, E=[e-mail]
Reason: I am approving this document.
Location: NA
Date: 2024-12-31 09:23:32
Foxit PhantomPDF Version: 9.7.5
David F Booth
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 2 of 18

Table of Contents

1 Objective ................................................................................................................................. 3
2 Definitions............................................................................................................................... 3
3 References ............................................................................................................................... 3
4 Responsibilities ....................................................................................................................... 4
4.1 General Manager of Clive ............................................................................................ 4
4.2 Site Managers ................................................................................................................ 4
4.3 Radiation Safety Officer ............................................................................................... 4
4.4 Radiation Safety Technicians ...................................................................................... 5
4.5 Individual Workers ....................................................................................................... 5
4.6 Radiation Safety Committee ........................................................................................ 6
5 ALARA Program Description ................................................................................................ 7
5.1 ALARA Policy Statement............................................................................................. 7
5.2 ALARA Goals................................................................................................................ 8
5.3 Investigation Levels ...................................................................................................... 9
5.4 ALARA Program Elements ......................................................................................... 9
6 Radiation Protection Program ............................................................................................... 11
6.1 ALARA Technical Reviews ........................................................................................ 11
7 Attachments .......................................................................................................................... 13
7.1 Occupancy Factor Criteria and Justification ........................................................... 13
7.2 CL-RS-PG-001 F1, Dose Extension Authorization Form ....................................... 13

EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 17

PAGE 3 OF 18
1 Objective
The objective of the ALARA Program is to ensure that all reasonable actions are taken to
reduce radiation exposures and effluent concentrations to levels that are considered as
low as is reasonably achievable (ALARA).
EnergySolutions is committed to applying the ALARA philosophy, and thus this ALARA
Program, and all aspects of its operations, including the initial planning for waste
disposal services, engineering, waste disposal and processing operations, and site
decommissioning. This ALARA Program applies to all operations involving exposure to
ionizing radiation.
2 Definitions
2.1 ALARA (as low as is reasonably achievable)- Making every reasonable effort to
maintain exposures to radiation as far below the dose limits as is practical
consistent with the purpose for which the licensed activity is undertaken, taking
into account the state of technology, the economics of improvements in relation to
state of technology, the economics of improvements in relation to benefits to the
public health and safety, and other societal and socioeconomic considerations, and
in relation to utilization of nuclear energy and licensed materials in the public
interest.
2.2 Investigative Level- that level of radiation dose or release to the environment that
requires a formal investigation and report.
3 References
3.1 Code of Federal Regulations, Title 10, Part 20 (as adopted in Utah Administrative
Code R313-15).
3.2 Bernard Shleien, et. al., Handbook of Health Physics and Radiological Health,
Williams and Wilkins, 1998, pages 11-42 to 11.53.
3.3 Federal Register: (Volume 47, Number 248), “Licensing Requirements for Land
Disposal of Radioactive Waste,” December 27, 1982, Pages 57446-57463.
3.4 NUREG-1530, Reassessment of NRC’s Dollar Per Person-Rem Conversion
Factor Policy, August 2015
3.5 U. S. Nuclear Regulatory Commission Regulatory Guide 4.20 Constraint on
Releases of Airborne Radioactive Materials to the Environment for Licensees
Other Than Power Reactors, April 2012
3.6 U. S. Nuclear Regulatory Commission Regulatory Guide 8.10, "Operating
Philosophy for Maintaining Occupational Radiation Exposures As Low As
Reasonably Achievable." (5-77)
3.7 U. S. Nuclear Regulatory Commission Regulatory Guide 8.31, "Information
Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills
will be As Low As Reasonably Achievable." (5-02)
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 4 of 18
3.8 U. S. Nuclear Regulatory Commission Regulatory Guide 8.37, "ALARA Levels
for Effluent from Materials Facilities." (7-93)
3.9 U. S. Nuclear Regulatory Commission: Health Physics Question and Answers.
Question 26(a): “There has been some confusion about the revised part 20
requirements with respect to controlled areas and when individuals are receiving a
public or occupational dose.,” November 24, 2017, https://www.nrc.gov/about-
nrc/radiation/protects-you/hppos/qa26.html
4 Responsibilities
4.1 General Manager of Clive
The General Manager of Clive is ultimately responsible for establishing and
maintaining the ALARA program. Some of the elements of this responsibility are:
4.1.1 Ensuring that the Clive management ALARA philosophy is consistent
with the current regulatory requirements and that the ALARA Program is
updated as required.
4.1.2 Ensuring that the Clive ALARA philosophy and Program requirements are
considered in all radiation work planning activities.
4.1.3 Ensuring that the authority and responsibilities for developing and
implementing the ALARA procedures are delegated to the appropriate
management staff.
4.1.4 Ensuring that adequate resources are available to implement the ALARA
Program. This includes staff, training programs, equipment, and facilities.
4.1.5 Ensuring that adequate resources are available for performance
measurement systems to demonstrate compliance with the goals and
objectives of the ALARA program.
4.2 Site Managers
The Site Managers responsibilities include:
4.2.1 Ensuring that the ALARA Program is actively supported at the site. This
is accomplished by demonstrating a commitment through written policy
statements and activities to enhance the employee's awareness of the Clive
ALARA philosophy and goals.
4.2.2 Assisting in the preparation of ALARA goals and objectives. This is
normally accomplished by providing input to the Radiation Safety
Committee who develops the goals and objectives.
4.2.3 Supporting the Radiation Safety Officer in his/her efforts to implement the
ALARA Program at the site.
4.3 Radiation Safety Officer
The Radiation Safety Officer has the responsibility for implementing the ALARA
Program at the disposal site. These duties include:
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 5 of 18
4.3.1 As the Chair of the Radiation Safety Committee (RSC), assisting in the
preparation of ALARA goals for the site.
4.3.2 Conducting formal reviews of the site radiation protection program to
assess the effectiveness of the ALARA procedures in meeting the ALARA
goals and objectives. This will be done annually.
4.3.3 Reviewing and approving plans for new equipment, process changes, or
changes in operating procedures to ensure that they are consistent with the
ALARA program.
4.3.4 Conducting RSC meetings, quarterly and as necessary.
4.3.5 Developing plans, procedures, and methods for maintaining personnel
radiation exposures and effluent concentrations ALARA. This is
accomplished in part as a team effort with the Site Managers and the site
engineering staff.
4.3.6 Conducting employee-training programs in which the Clive ALARA
philosophy is presented and understood by all employees.
4.3.7 Establishing and maintaining personnel and environmental monitoring
programs appropriate for assessing compliance with regulatory
requirements and for determining whether ALARA goals and objectives
were met.
4.3.8 Performing an analysis of site operations, environmental, work area, and
personnel monitoring data to determine whether ALARA goals were met
and to identify areas of further improvement.
4.3.9 Overseeing the documentation of radiation surveys and work area
inspections at least once per week while work is being performed.
4.4 Radiation Safety Technicians
Radiation Safety Technicians (RSTs) assist the Radiation Safety Officer in
implementing the ALARA Program. A very important responsibility of the RST
is to evaluate work practices in the field as to whether they are consistent with
regulatory requirements and the Clive ALARA Program. Recommendations for
work stoppages or changes in work practices are typically the responsibility of the
RST.
4.5 Individual Workers
Every radiation worker assumes some responsibility for maintaining his radiation
exposure ALARA. He/she has been trained in the ALARA philosophy and job-
related safety practices. Worker responsibilities include:
4.5.1 Understanding the Clive ALARA philosophy and how it applies to the
particular job.
4.5.2 Complying with all standard operating procedures, warning signs, and
barriers.
4.5.3 Understanding the radiation hazards associated with his/her particular job.
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 6 of 18
4.5.4 Providing suggestions to the Radiation Safety Officer or other
management on how exposures or releases might be further reduced.
4.5.5 Applying existing radiation exposure reduction methods, such as time-
distance-shielding, to the job site.
4.5.6 Applying contamination control measures designed to prevent Personnel
Contamination Events (PCEs). Such measures include but are not limited
to:
• Disposing of outer layer of gloves after handling radioactive waste
or verifying the absence of radioactive contamination by having
the gloves checked by a qualified individual with an instrument
capable of detecting such contamination.
• Disposing of outer layer of gloves or having the absence of
radioactive contamination verified prior to performing tasks that
could transfer contamination to the skin such as donning or doffing
respirators, using phones, etc.
4.5.7 Promptly reporting to line management or the Radiation Safety Officer
conditions or practices at the site that may not be consistent with the Clive
ALARA program.
4.5.8 Tracking and monitoring personnel annual dose to ensure compliance with
EnergySolutions ALARA goals.
4.6 Radiation Safety Committee
The Radiation Safety Committee (RSC) considers the ALARA Program an
integral part of the Radiation Protection Program. The RSC shall consist of the
following members:
• Radiation Safety Officer
• General Manager
• Operations Manager
• CWF Operations Supervisor
• Container Management Supervisor
• Environmental Compliance Manager
• Site Engineer
The RSO and three members (or designees) must be present for a quorum. As
such, the committee responsibilities are:
• Developing the ALARA Goals and Objectives for each year (or Project).
• Ensuring that ALARA Goals and Objectives are effectively integrated into
management plans and operating procedures.
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 7 of 18
• Reviewing all ALARA audit reports and reporting information to the
General Manager of Clive.
• Review Occupancy Factors (OF) on an annual basis.
• Radiation Safety Committee Agenda
The RSC agenda shall include the following at a minimum:
• Attendees.
• Approval of the previous quarter RSC minutes.
• ALARA – Occupational dose will be reviewed that includes
Collective dose for the Clive site, the maximum individual exposed
and the average measurable dose for occupational workers
(TEDE). These occupational exposures will be reviewed every
quarter and trended over a 2 year period. 4th quarter agendas will
include an item to establish annual occupational exposure ALARA
goals for the upcoming year.
• Semiannual Environmental results as applicable.
• Radiation Safety concerns.
5 ALARA Program Description
5.1 ALARA Policy Statement
EnergySolutions believes that it is prudent to maintain radiation exposures to
workers and the environment as low as reasonably achievable (ALARA). In
order to implement this policy, EnergySolutions management endorses this
ALARA Program and agrees to provide the necessary resources to implement it.
The NRC per person-rem dollar amount from NUREG-1530 may be used for cost
benefit analysis. This amount is for stochastic effects only and is not to be
applied to deterministic effects.
The General Manager of Clive is ultimately responsible for establishing and
implementing this ALARA Program. Under his direction, EnergySolutions
personnel will develop and implement various facets of the ALARA program.
On-site workers will conduct their work in such a manner that considerations for
reducing radiation exposure will be of paramount importance. Failure to do so
may result in disciplinary action.
The RSO has the primary responsibility for monitoring the ALARA Program and
reporting to the General Manager of Clive. He/she will ensure that:
• Facility designs are reviewed and that changes necessary to minimize
worker exposure or releases to the environment are incorporated.
• Training programs incorporate the ALARA concept and that all personnel
understand their responsibilities.
• ALARA goals are established for each calendar year.
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 8 of 18
• Evaluations are done at least annually to assess whether the ALARA goals
and objectives have been achieved.
The Radiation Safety Officer has the organizational freedom to stop work and
raise any ALARA concern to upper levels of management, including the President
of EnergySolutions, should a satisfactory resolution not be possible at lower levels
of management.
While the ultimate responsibility lies with the General Manger of Clive, all
EnergySolutions personnel are expected to carry out their responsibility in the full
implementation of this ALARA Program.
5.2 ALARA Goals
ALARA goals will be developed by the Radiation Safety Committee and will be
concurred by the Site Managers having the day-to-day responsibility for
operations. Guidance provided in Regulatory Guide 8.37 will form the basis for
establishing goals. Several types of goals may be established as discussed below.
Annual occupational and environmental goals will be established based on
historical operational records, release models, and regulatory limits. Goals will be
set close to what has been achieved in the past or near predictions based on
models. It is recognized that if goals are inadequately established, they frequently
will not be met and may have to be adjusted upward.
The Clive Facility will use the following goals until revised by the Radiation
Safety Committee.
5.2.1 Occupational Radiation Exposure- As approved and documented on RSC
minutes.
5.2.2 The ALARA goal for individual members of the general public is 20
percent of the total effective dose equivalent limit in UAC, R313-15-301.
The ALARA goal also includes compliance with the mandatory ALARA
limits from UAC, R313-15-101(4) which states “the individual member of
the public likely to receive the highest dose will not be expected to receive
a total effective dose equivalent in excess of 0.1 mSv (0.01 rem) per year”
and the dose limits from UAC, R313-25-19 which are “0.25 mSv (0.025
rem) to the whole body, 0.75 mSv (0.075 rem) to the thyroid, and 0.25
mSv (0.025 rem) to any other organ of any member of the public”.
5.2.3 For release of equipment, vehicles, and conveyances from the Restricted
Area, the ALARA goals are specific to the type of release and the isotopes
of concern. The release limits are specified in the applicable Clive
procedure(s). The Radiation Safety Officer must approve all release limits.
5.2.4 For releases of personnel from the restricted area the ALARA goals for
both skin and clothing contamination are:
5.2.4.1 Gross alpha 100 dpm/100 cm2
5.2.4.2 Gross beta 1,000 dpm/100 cm2
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 9 of 18
5.2.5 For releases of personnel from the restricted area the ALARA goals for
soles of shoes contamination are:
5.2.5.1 Gross alpha 300 dpm/100 cm2
5.2.5.2 Gross beta 1,000 dpm/100 cm2
5.2.6 For large projects where dosimetry records are expected to reflect the
associated exposures, project ALARA goals may be developed when
practical.
5.2.7 For a declared pregnant woman (assuming a ten month gestation period)
5.2.7.1 50 mrem TEDE
5.3 Investigation Levels
Until revised and approved by the Radiation Safety Committee, the Clive Facility
will use the following investigative levels:
5.3.1 Investigate all semiannual personnel radiation exposures that exceed a
TEDE of 100 mrem.
5.3.2 Investigate site conditions where measured airborne radionuclide
concentrations in the work area exceed 30 percent of the respective
derived air concentration (DAC) for the measurement period.
5.4 ALARA Program Elements
The ALARA philosophy is an integral part of many of the Clive Faculties’
operating and administrative procedures as discussed below.
5.4.1 Standard Operating Procedures and Radiation Work Permits
EnergySolutions uses standard operating procedures (SOPs) and Radiation
Work Permits (RWPs) for work within a RCA, including radiation safety,
work area and environmental monitoring, waste testing, waste handling,
and waste disposal. These SOPs and RWPs specify methods to be used to
ensure safe operations, including personnel protective equipment, general
area radiological conditions, and other special safety instructions.
5.4.2 Facility and Equipment Design
All facility designs and specifications for new equipment will be reviewed
prior to construction or purchase to ensure that they are consistent with
EnergySolutions ALARA Program.
5.4.3 Engineering and Administrative Controls
5.4.3.1 Pre-operational Reviews
Pre-operational reviews are performed prior to receiving a
new waste stream to determine whether EnergySolutions
SOPs are appropriate for maintaining radiation exposures
ALARA. Any waste stream with a significant potential for
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 10 of 18
exposure will require a RWP that addresses ALARA
concerns.
Pre-operational reviews are also conducted prior to using
new waste-handling equipment on site as well as prior to
using new facilities, where radiation exposure is a
consideration.
5.4.3.2 Modification of designs and SOPs
Whenever pre-operational reviews indicate that ALARA
considerations are inadequate, EnergySolutions will make
the necessary changes or modifications to ensure that
radiation exposures are ALARA. All new modifications or
designs will be subjected to a pre-operational review until all
unresolved issues are adequately addressed.
5.4.4 Radiation Worker Safety Training
All personnel visiting or working at the site will be trained in
EnergySolutions ALARA philosophy and given the basic information on
how to minimize radiation exposure and releases to the environment. The
requirements for training, including specific initial and refresher training
for ALARA are contained in the Clive Facility Training procedure. The
Radiation Safety Officer is responsible for ensuring that individual
workers are trained on task specific methods for minimizing radiation
exposure and releases.
5.4.5 Control of Airborne Radioactivity
EnergySolutions considers the control of airborne radioactivity essential to
the ALARA program. Operational procedures and license conditions
establish specific measures for controlling dust and airborne releases of
radionuclides including the application of water and chemical surfactant to
dusty areas, prompt covering of wastes having greater potential for
creating airborne radioactivity, suspension of work under adverse
meteorological conditions and establishing vehicle speed limits.
Vigilant enforcement of these rules and procedures is a duty of the Site
Managers and all site personnel. While respirators will be worn for
certain work tasks, EnergySolutions primary controls are considered to be
engineering and operational controls, such as containment or ventilation.
5.4.6 Control of Liquid Effluent
The current design of the waste disposal site is to prevent surface water
from entering and leaving the site. All process liquids are used in other
processes are disposed of in evaporation ponds or evaporation tanks, and
thus no liquid effluent exists. As part of the ALARA audit, the site will be
inspected to ensure that the design objectives are being met.
5.4.7 ALARA Audits and Inspections
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 11 of 18
The RSO has the responsibility for monitoring the implementation of this
ALARA Program and assessing its effectiveness. Audits will be done at
least annually.
The ALARA audit may be done in conjunction with a Radiation Safety
program audit. However the ALARA audit will be broader in scope in
that fulfilling the commitments and responsibilities of line management
including operations will be evaluated.
ALARA audit and inspection tasks include:
5.4.7.1 Determining whether ALARA goals are being met
5.4.7.2 Evaluating radiation exposure and release trends to identify
potential problems
5.4.7.3 Reviewing records of ALARA-related activities to ensure
that design and operational reviews are being conducted
5.4.7.4 Assessing the understanding by site employees of the
EnergySolutions ALARA policy
5.4.7.5 Reviewing the Radiation Protection Program content
5.4.7.6 Reviewing emergency plans and procedures including fire
protection to ensure that they are consistent with ALARA
5.4.8 Dose extensions
Dose extensions to exceed EnergySolutions ALARA goals, as stipulated
in Section 5.2, shall be authorized by the General Manager of Clive with
concurrence from the RSO. Dose extensions shall not exceed corporate
limits. In accordance with EnergySolutions ALARA philosophy, it is the
individual radiation worker’s responsibility to monitor their annual dose
and ensure compliance with EnergySolutions ALARA goals and timely
intervention should an extension be needed. Complete Attachment 7.2 for
a dose extension.
6 Radiation Protection Program
6.1 ALARA Technical Reviews
6.1.1 Work Area and Environmental Radiation Monitoring
The Radiation Safety Officer will periodically evaluate existing radiation
safety and environmental monitoring methods and procedures to
determine if they are providing the performance data on which
achievement of ALARA goals can be evaluated.
Changes in methods and procedures may be required to provide a better
understanding on such subjects as the principal sources of airborne
releases, the effect of wind speed and other meteorological conditions on
airborne concentrations and releases to the environment, and sources of
external radiation exposure.
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 12 of 18
6.1.1.1 Semiannual Evaluation
At a minimum, on a semiannual basis, the Environmental
Manager will provide the Radiation Safety Officer the
calculated environmental doses derived from air sample and
dosimetry data.
This evaluation shall include dose calculations to “members
of the public used to demonstrate compliance with Utah
Administrative Codes (UAC), R313-15-301, R313-15-
101(4), and UAC, R313-25-19. The dose limits in UAC,
R313-15-301 apply to the dose received to individual
members of the public in unrestricted or controlled areas. A
member of the public is defined as any individual except
when that individual is receiving an occupational dose.
The ALARA constraint limit in UAC, R313-15-101(4), and
the “Protection of the General Population” limits in UAC,
R313-25-19 require more restrictive controls and limits for
members of the public and general requirement.
Compliance with these regulations will be consistent with
the current NRC guidance for these requirements as
contained in 10CFR20.1101(d), and 10CFR61.41
respectively. The NRC has stated that both of these
conditions apply to members of the public located outside
the Site boundary. Regarding acceptable methods used to
demonstrate compliance with 10CFRR20.1101(d) the NRC
regulatory position states: “In determining the member of the
public likely to receive the highest dose from airborne
radioactive material released from licensed operations to the
environment, licensees need not consider nonresidents
within the facility boundary.” The NRC includes a similar
intent when discussing the addition of 10CFR61.41 in the
final rule to 10CFR61 where they state: “It is the
Commission’s intent that the provisions of Part 20 will apply
to all aspects of radiation protection during operations except
for releases of radioactivity from the site which will be
governed by the more stringent requirement of 10CFR
61.41.”
Compliance with UAC, R313-15-101(4) and UAC, R313-
25-19 will be determined by dividing the appropriate dose
measured at the air monitoring located along the site
boundary by 50. This would essentially estimate the dose to
a member of the public located at the Restricted Area
boundary for one complete week during year which is
expected to be conservative. This method was determined
to be more conservative than the potential airborne dose to
an off-site resident.
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 13 of 18
The rail siding located about 1800 meters north of Section
32 was selected to model the potential dose to an off-site
resident. The rail siding was selected because it was the
closest installation outside the Site boundary. The
atmospheric dispersion was calculated using a Gaussian
Plume model to determine the expected difference in the
concentration of airborne radioactive particulate resulting
from Site operations measured at the Section 32 North
boundary and at the rail siding. The result of the Plume
model calculated that airborne particulate concentrations
from Site emission would be 10,000 times less at the rail
siding than at the Section 32 north boundary. The estimate
assumed the receptor was continuously located in the center
of a stability class D plume. It was also assumed that the
emission source and receptor were both at ground level.
6.1.2 Emergency Response and Contingency Plans
The Radiation Safety Officer and Site Safety Lead will periodically
evaluate the site Emergency Response and Contingency Plans to ensure
that the prescribed actions are consistent with EnergySolutions ALARA
policy.
6.1.3 Fire Control
Fire control at the disposal site is not considered to be a major problem.
However, the Radiation Safety Officer and Site Safety Lead will evaluate
the fire control procedures, practices, and engineered features for existing
and planned structures to ensure that they are consistent with
EnergySolutions ALARA policy.
7 Attachments
7.1 Occupancy Factor Criteria and Justification
7.2 CL-RS-PG-001 F1, Dose Extension Authorization Form

EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 14 of 18

Attachment 7.1- Occupancy Factor Criteria and Justification
References:
1 Response letter Mr. Dwight Chamberlain, NRC Region IV, dated April 7, 1999
2 NUREG/CR-6204, Questions and Answers Based on Revised 10 CFR Part 20
3 NCRP Report No. 49, Structural Shielding Design and Evaluation for Medical Use of X
Ray and Gamma Rays of Energies Up to 10 MEV
4 10 CFR 20, Standards for Protection Against Radiation
5 R313-15, Standards for Protection Against Radiation
The definition of an Occupancy Factor (OF) per Reference 3 is “The factor by which the
workload should be multiplied to correct for the degree of occupancy of the area in question
while the source is ‘On’.” This definition is for use at an X ray facility but can be related to
EnergySolutions operation.
EnergySolutions will use the OF as an unitless number by which the annual restricted area (RA)
boundary dose limits will be modified by to correct for the degree or type of occupancy at the
point-of-compliance, the restricted area boundary.
To support the various OF’s, the following justifications are submitted:
1 Remote location of the EnergySolutions site
The closest resident is a Rest Stop Attendant located approximately eight miles northeast of the
site on Interstate I-80.
EnergySolutions Security Guards make routine tours around the site perimeter. The Security
Guards or Radiation Safety staff would be aware of any personnel who would be near the RA
boundary on a routine basis.
2 Zoned in a Hazardous Industrial Area
The EnergySolutions site is located inside a Hazardous Industrial District in accordance with the
Uniform Zoning Ordinance of Tooele County, Utah. The Hazardous Industrial District
“provides areas in appropriate remote locations where hazardous processes necessary to aiding in
protecting the environment by providing an area that hazardous wastes may be disposed in a safe
manner.”
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 15 of 18
Attachment 7.1- Occupancy Factor Criteria and Justification Continued
3 U.S. Nuclear Regulatory Guide 8.37, ALARA Levels for Effluents From Material
Facilities
This Regulatory Guide was written to provide guidance for compliance with 10 CFR 20.1301.
In the body of the guide, it states, “Licensees may choose to focus their evaluation of public dose
to members of a critical group as suggested by the International Commission on Radiological
Protection (ICRP) as a means of identifying and controlling the exposure to the individual
member of the public likely to receive the highest exposure.” EnergySolutions bases its
calculations on the dose received by the Maximally Exposed Individual (MEI).
Regulatory Guide 8.37 also states, “Licensees need not assume worst case models when
calculating dose but rather make assumptions that will result in realistic estimates of actual dose
received by the member of the public likely to receive the highest dose.” Since it is unrealistic to
assume that the MEI is at the restricted area boundary for 24 hours per day, 365 days per year
(OF=1).
This assumption is further supported in Reference 2, pages 29 and 31.
As a guide, EnergySolutions is using a table as portrayed in Reference 3, Table 4. This table
designates areas with respect to full, partial or occasional occupancy and stipulates their
respective OF’s of 1, 1/4, 1/16, and 1/32. These OF’s are indicative of certain area segments
which are related to its location and the number of hours a person would be located at that area,
on an annual basis.
Occupancy Factor Designations
Full Occupancy (OF=1)
Hours per days at RA boundary = 24 hours
Total annual hours at RA boundary = 8760 hours
This would be applicable to an occupational exposed individual or a resident.
Occupational exposed individuals are monitored in accordance with 10 CFR 20. 1201
and Utah Radiation Control Rules R313-15-201. There are no residents at the RA
boundary.
Partial Occupancy (OF=1/4)
Hours per days at RA boundary = 6 hours
Total annual hours at RA boundary = 2250 hours
This is most applicable to unmonitored personnel who work at the site on a full time
basis, i.e., forty hours per week, 50 weeks per year.
year
hours
day
hoursxyear
days 876024365=
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 16 of 18
Attachment 7.1- Occupancy Factor Criteria and Justification Continued
Include five hours of overtime per week and two weeks vacation:

Intermittent Occupancy (OF=1/16)
Hours per days at RA boundary = 1.5 hours
Total annual hours at RA boundary = 548 hours
This is applicable to sections of the restricted area boundary where unmonitored
personnel would be located for short periods of time, i.e., vehicular traffic, truck drivers.

Occasional Occupancy (OF= 1/32)
Hours per days at RA boundary = 0.75 hours
Total annual hours at RA boundary = 274 hours
This is applicable to sections of the restricted area boundary where unmonitored
personnel would be located infrequently.

Occupancy Factor Evaluation/Determination
All of EnergySolutions various regulatory limits will use these OF’s:
10 CFR 20.1301 or Utah R313-15-302, Compliance with Dose Limits for Individual Members of
the Public- 100 mrem TEDE
10 CFR 20.1101 (d), Annual ALARA Constraint Limit- 10 mrem
10 CFR 61.41 or Utah R313-25-19, Protection of the General Population from Releases of
Radioactivity- 25/75/25 mrem
10 CFR 40, Appendix A, Criterion 8, Airborne Effluents- 25/75/25 mrem
year
hours
week
daysxyear
weeks 2250550=
OFhours
hours 25.0257.08760
2250 ==
day
hours
days
yearxyear
hours 6
365
2250 =
year
hoursxyear
hours 5480625.08760 =
day
hours
days
yearxyear
hours 5.1
365
548 =
year
hoursxyear
hours 2740313.08760 =
day
hours
days
yearxyear
hours 75.0
365
274 =
EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 17 of 18
Attachment 7.2- CL-RS-PG-001 F1, Dose Extension Authorization Form

EnergySolutions Clive ALARA
Program
CL-RS-PG-001
Revision 18

Page 18 of 18